ML16253A209

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Proposed Final Revision to Appendix J to 10 CFR Part 50 and Related Final Regulatory Guide
ML16253A209
Person / Time
Issue date: 05/17/1991
From: Ward D
Advisory Committee on Reactor Safeguards
To: Carr K
Advisory Committee on Reactor Safeguards
References
D910517
Download: ML16253A209 (2)


Text

D910517 The Honorable Kenneth M. Carr Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Chairman Carr:

SUBJECT:

PROPOSED FINAL REVISION TO APPENDIX J TO 10 CFR PART 50 AND RELATED FINAL REGULATORY GUIDE During the 373rd meeting of the Advisory Committee on Reactor Safeguards, May 8-11, 1991, we considered the proposed revision to Appendix J to 10 CFR Part 50, "Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants," and a related Regulatory Guide (Task No. MS 021-5), "Containment System Leakage Testing." These proposals were discussed during a joint Regulatory Activities and Containment Systems Subcommittee meeting on May 8, 1991. During these meetings, we had the benefit of discussions with representatives of the NRC staff and of the nuclear industry.

We also had the benefit of the document referenced.

We offer the following findings:

Revision of Appendix J to 10 CFR Part 50 is desirable.

The staff's proposal to make the revised version of Appendix J less prescriptive and to provide detailed guidance in a regulatory guide is appropriate.

The implementation of the proposed revision to Appendix J clearly is a backfit.

The staff has been unable to conclude that the proposed revision will provide a substantial increase in safety.

The staff believes that the proposed revision will not increase costs to licensees; some licensees believe otherwise.

There has been continuing constructive dialogue between the staff and industry representatives, chiefly relating to a Licensing Topical Report being prepared by the BWR Owners' Group. There are still some technical issues that would benefit from further dialogue between the staff and industry.

We understand from the staff that this dialogue will take place prior to issuance of this proposed revision.

The proposed revision does not reflect new insights and knowledge about the role of containment, and containment leakage, in mitigating the consequences of severe accidents.

In view of these findings, we have no objection to the proposed revision to Appendix J to 10 CFR Part 50 or to the accompanying Regulatory Guide.

Sincerely, David A. Ward Chairman

Reference:

Note dated April 9, 1991 to S. Duraiswamy, ACRS, from G. Arndt, RES,

Subject:

10 CFR 50, Appendix J and Regulatory Guide MS 021-5, with enclosures:

(a) Draft Federal Register Notice -- Statement of Consideration and Final Appendix J Rule (b) Draft Federal Register Notice - Statement of Availability and Final Regulatory Guide MS 021-5