For those few still working in Nuclear Power, does anyone have a procedure that addresses the long term use of scaffolding and need for a 50.59? Please advise.
You would be best advised to follow NEI 96-07 guidance in order to develop a plant-specific approach for this.
NEI 96-07 Section 4.1.2 states that temporary alterations in support of maintenance activities are themselves treated as maintenance activities that are governed under the maintenance rule 10CFR50.65(a)4. At our plant, scaffolding is treated as a temporary change in configuration in support of a maintenance activity. Since 50.65(a)4 applies more specific criteria than 50.59, the requirements of 50.59 are not applied unless the scaffold is left in place for more than 90 days, or never completely removed. Even then, your normal scaffold procedure could cover it as long as it gets a 50.59 screening or evaluation. Otherwise it would follow the modification process which would invoke 50.59.
Hope this helps. 50.59 applicability to temporary installations always sparks interesting debate, so I'm interested to hear everyone else's take on this.
50.59 (c)(40 says "The provisions in this section [50.59] do not apply to changes to the facility or procedures when the applicable regulations establish more specific criteria for accomplishing such changes."
50.65(a)(4) says "Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety."
NRC SECY-00-0203 "recommends that the Commission approve publication of RG 1.1.187, which endorses the industry guidance document developed by the Nuclear Energy Institute (NEI), NEI 96-07, 'Guidelines for 10 CFR 50.59 Implementation,' Revision 1, dated September 2000."
Like it or not, temporary changes are those that last 90 days or less. See the discussion in
Buut the key for this thread seems to be "The evaluation does not disappear, the evaluation, however, is done under the aegis of the (a)(4) safety assessment and management of the risk as opposed to through the process of 50.59. That is really the change. The assessment we expect, the NRC's expectation is the evaluation of whatever they evaluate when they put up
scaffolding, that evaluation will nonetheless take place, an engineering evaluation of hanging lead shielding on a pipe or whatever they do with that sort of stuff. Those kinds of things will still have to be done, but they won't have to go through the formal 50.59 process, they will be handled through the maintenance risk assessment and risk management process."
