ML19291A520

Comments on Proposed Revision 1 to Reg Guide 1.50:revision Does Not Appear Consistent W/Technical Facts.Paper Is Confusing

ML19291A520
Person / Time
Issue date:	11/03/1977
From:	Hanauer S NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Kebnemuyi M NRC OFFICE OF STANDARDS DEVELOPMENT
References
FOIA-79-109 NUDOCS 7905160426
Download: ML19291A520 (2)

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I MEMORANDUM FOR:

M. Kehnemuyi, AD/GES, DES, SD

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FROM:

S. H. Hanauer, TA ED0

SUBJECT:

REGULATORY GUIDE 1.50, REVISION 1 I

It's not clear at all to me how the proposed guide revision squares with the technical facts.

I find the Value Impact Statement almost impossible to get through.

It is confusing and apparently inconsistent, although I wouldn't want to certify that this is true because it's so difficult to read.

The proposed Action I is apparently contrary to technical infomation available in Babcock and Wilcox and Westinghouse topical reports based The discussion not in this section, out on experimental infonnation.

buried in Section 2IA. on page 6, lines 4 to 6, suggests that this fI technical information is, in fact, unsatisfactory, but I can't tell, and I can't find out by a reasonable amount of reading in the Value Impact Statement.

If the alternatives are equally satisfactory, why r.,,

are we tightening up on the guide? If the alternatives are not satisfactory, why doesn't the guide say so.

The second sentence of paragraph I.C.1 in the Value Impact Statement is incomprehensible to me.

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Paragraph I.C.2 in the Value Impact Statement is not clear at all to Is this additional inspection required because the guide is to rr.s.

' e adopted? The implication is that adopting the guide increases the possibility of cracking. Is there some other point thBt I have missed?

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Daragraph I.C.3 in the Value Impact Statement is stated in such a way that I can't tell whether it is favorable to or unfavorable to adoption 4' ',

of the proposed guide.

If Paragraph I.C.4 of the Value Impact Statement is true, then we ought 3-Li.;

to throw this paper away. Furthermore, as I read the guide, adopting it U,(.j will not produce the gas savings not adequately discussed in the preceding M. -A nateH a1.

p The discussion of technical alternatives (Section 11 in the Value Impact G-

Statement) leaves me in the dark whether these things are good or bad.

F and how they affect the decision to adopt the proposed regulatory guide or not.

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i M. Kehnemuyi 2

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Paragraph IIIB of the Value Impact Statement deals with the procedural alternatives only as nearly as I can tell.

If this isn't true, it f

should be stated more clearly.

Conclusion I feel that this paper as now written is highly confusing, and this i

I feeling is confimed by the value Impact Statement which leaves me completely in the dark how I should feel about this paper as a reader and potential user.

0:ist:a1515 W St.crp.m H. c.retar Stephen H. Hanauer Technical Advisor to Executive Director for Operations f' e e

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