NRC Use of Consensus Codes and Standards
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1 NRC Use of Consensus Codes and Standards July 7-10, 2014 Kenneth J. Karwoski, Senior Level Advisor Division of Engineering NRC Office of Nuclear Reactor Regulation 1
2 Who are We? The Energy Reorganization Act of 1974 established the the U.S. Nuclear Regulatory Commission (NRC) to regulate commercial uses of nuclear material. The NRC employs about 4,000 people in its Maryland headquarters and 4 regional offices in Pennsylvania, Georgia, Illinois and Texas. Mission: to license and regulate the nation s civilian use of byproduct, source and special nuclear materials to ensure adequate protection of public health and safety, promote the common defense and security, and protect the environment. 2
3 The NRC Regulates: Nuclear reactors commercial power reactors, research and test reactors, new reactor designs; Nuclear materials nuclear reactor fuel, radioactive materials for medical, industrial and academic use; Nuclear waste transportation, storage and disposal of nuclear material and waste, decommissioning of nuclear facilities; and Nuclear security physical security of nuclear facilities and materials from sabotage or attacks. 3
4 Our Primary Functions Establish rules and regulations Issue licenses Provide oversight through inspection, enforcement, and evaluation of operational experience Conduct research to provide support for regulatory decisions Respond to emergencies 4
5 NRC s Policies on Consensus Codes and Standards Consensus codes and standards have been integral to the regulatory process since Codes and standards promote safe operation of nuclear facilities and improve the effectiveness and efficiency of regulatory oversight Federal law requires agencies to use technical standards developed by voluntary consensus standards bodies and participate in their development, where possible - National Technology Transfer and Advancement Act of OMB Circular A-119, annual reporting through NIST 5
6 NRC Staff Participation NRC staff participates on codes and standards development committees along with other stakeholders Codes and standards are developed based on a rigorous consensus process with input from all stakeholders NRC reviews codes and standards for possible endorsement in regulatory documents 6
7 NRC Formal Endorsement Process Rules and regulations: Title 10 to the Code of Federal Regulations (10 CFR) Regulatory Guides (RGs) Standard Review Plans (SRPs) Generic communications (e.g., Regulatory Issue Summary) 7
8 Other NRC Endorsement Processes Safety evaluation reports Licenses Inspection procedures Memoranda Reports (NUREGs) 8
9 Shortcomings of Informal Processes Incomplete or inconsistent treatment of the standard Bypasses key agency checks and balances Difficult to find in the regulatory record 9
10 NRC Endorsement Process: Rulemaking Most formal of NRC endorsement processes Standards incorporated by reference in rulemaking process become regulatory requirements Includes public comment and rigorous reviews Takes several years to complete a typical rulemaking 10
11 Codes and Standards Rule: 10 CFR 50.55a Incorporates by reference ASME Codes: - ASME BPV Code, Section III for design - ASME BPV Code, Section XI for in-service inspection - ASME OM Code for in-service testing Approves, conditions or disapproves use of ASME Code cases in 3 RGs - RG 1.84 (Section III Code cases) - RG (Section XI Code cases) - RG (OM Code cases) - RG (Disapproved ASME Code cases) Incorporates by reference two IEEE Standards: - IEEE Standard 279 Criteria for Protection Systems - IEEE Standard 603 Criteria for Safety Systems 11
12 NRC Endorsement Process: Regulatory Guides Describe methods that the NRC considers acceptable for use in implementing specific parts of the NRC s regulations Not substitutes for regulations; compliance with RGs is not required Includes review by various review bodies and public Typically takes 1-2 years to complete 12
13 Other NRC Endorsed ASME Standards ASME NQA-1, Quality Assurance (QA) Program Requirements for Nuclear Facilities, (Referenced in RG 1.28, QA Program Requirements ) ASME QME-1, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants (Referenced in RG 1.100, Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants ) 13
14 ANS/ASME Standards ASME RA-S-2002, Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications (Referenced in RG 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities ) ANS/ASME joint program on risk (Developing updated and more comprehensive PRA standards for referencing in NRC RG 1.200) 14
15 International Standards Developers International Atomic Energy Agency (IAEA) Safety Standards, Codes of Conduct International Standards Organization (ISO) Standards International Committee on Radiation Protection (ICRP) recommendations NRC participates in these international organizations, but does not directly endorse their standards 15
16 Conclusions NRC makes extensive and effective use of codes and standards as part of its regulatory process NRC endorsement of codes and standards include regulations, regulatory guides, standard review plans NRC actively participates in many domestic and international standards bodies NRC endorsement of codes and standards creates practical regulatory requirements and guidance that is key to consistent safety performance of nuclear facilities 16
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