ML19318G243

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Submits Licensee Schedule of Best Estimates for Operator Licensing Exams & Requalification Exams for FY89-92 Per Generic Ltr 88-13
ML19318G243
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 09/09/1988
From: Rothert W
IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To: Hannon J
NRC
References
GL-88-13, NG-88-3015, NUDOCS 8809150022
Download: ML19318G243 (3)


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go na cg M UNITED STATES f3 [k{

NUCLEAR REGULATORY COMMISSION g '

C W ASHINGTON. D. C. 20555

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\ ,,,,, / SEP 15 fpog HEh0hANDUM FOR: Edwaro L. Jordan, Chairman Committee to Review Ger,eric Requirements FROM: Eric S. Beckjord, Director )

Office of Nuclear Regulatory Research

SUBJECT:

AMENDMENT OF APPENDIX J TO PERMIT MASS POINT ANALYSIS Enclosed for review and approval by the CRGR is a limited revision to 10 CFR l; Part 50, Appendix J, which the NRC staff is recommending that the EDO issue as '

a final rule.

The CRGR recommended that this revision be published as a final rule, )

effective on the date of publicatior. without the. customary 30-day waiting period. This revision will modify the currev regulation and permit the use of the Mass Point data analysis method for containment leakage testing. A' regulatory analysis was previously prepared and reviered on the effects of the change on s6fety. :ost, and other matters as normally required for CRGR review.  ;

The final, rule ls identical. to the proposed rule issued for public cocant on February 29, 1988, (53 FR 5985). The following language is added to

Section III.A.3 of 10 CFR Part 50, Appendix J:

"In addition to the Total Time and Point-to-Point methods'described in that standard, the Mass Point method, when used with a test duration of  ;

at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, is an acceptable method to use' to caiculate leakage rates. A typical description of the Mass Point method can be found in the American Nationel Standard ANSI/ANS 56.8-1987, 'Containment System Leakage Testing Requirements,' January 20, 1987."

Also, es in the proposed rule,'the following sentence is deleted from Sectian III.A.3 of the existing rule in order to allow a change in the methods now permitted:

"The method ciusen for t! M test shall normally be used for the periodic tests."

As'noted in more detail in u. < 1 ed Public Coment Resolution Memo, j twenty-one comment letters wer, ,b.eived. Three principal comments were pre- 1 sented. l l

First, all commenters supported the addition of the Mass Point analysis to the list of acceptable analysis methods. i i

Second, all but two commentors objected to requiring a 24-hour test duration if using the Mass Point method.

Third, one objection was raised to the degree of flexibility permitted by the proposed wording in defining the Mass Point method.

8809210022 880915 fg4, g RES SIJBJ *** ,

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o Edward L. Jordch 2 l

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Thi NRC staff believes that the wording of the revision as published for camment accurately represents the NRC staff's position. All comments have been.  ;

reviewed. In'spite of the objections raised.in the comments to the wording or content of the rule revision, the wording submitted for the final revision to

. this rule is identical to that published for public comment. The Public Comment Resolution Memo addresses in detail the NRC staff's thinking in retain- i ing toe wording of t;ie proposed rule.

The P.egulatory Analysis, Backfit Antlysis, and other administrative reviews, i

such as reporting requirements review, were all taken care of in the development,.

review, and approval of the proposed rule revision. <

~ The Office of the General Counsel has revier this amendment and Las no legal objection. The Office of Nuclear Reactor P+ tion and Regional Offices 1-V >

concur with this amendment. The Office 'e 'stration and Resources Manage- i ment has reviewed this action and considers o be in a form acceptable for  ;

publication. The Office of Governmental and 6 ablic Affairs has concurred in  !

the draft Congressional letter and has determined that no public announcement .

is needed for this amendment. The ACRS, by copy of this memorandum, is being  ;

informed of this amendment's status, and will place it on its agenda for formal ,

review if it feels additional clarification.snd discussion are necessary. ,

For further information contact Gunter Arndt, Task Leader, Structural and ,

. Seismic Engineering Branch (492-3945).  :

Eric S. Beckjo , Director Office of Nuclear Regulatory Research  ;

Enclosures:

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RES memo to EDO w/encls.

cc: See attached list  !

CRGR (15)

ACRS (15) ,

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I DISTRIBUTION: (W/ENCLOSURE)  ;

i ESEec k,iord ,1 RES-  !

DFRoss, RES i TSpeis, RES  !

. GAArlotto, RES RBosnak, RES AMurphy, RES.

GArndt, RES ,

ATse, RES  !

TM0rley, MRR  ;

LCShao, NRR JRichardson,.NRR JKudrick, NRP.  ;

JPulsipher, NRR ,i DLurie, ARM/DBA l JTaylor, EDO  ;

EJordan, AEOD  :

DKirpatrick, NRR i SMCNeil. NRR -

WRussell, RI  !

PKEapen, RI l JGrace, RII-FJape, RII ,

HWhitener, RII l BDavis, RIII  !

GWright, RIII l FMaura, RIII i SHare, RIII  :

RMartin, RIV l JMilboan, RIV l

'JTapia, RIV JMartin, RV  ;

DKirsch, RY-  !

CClark, RV i' DGrimsley, RM/DRR DMeyer, RPB  ;

BSheldon, RMB '

HParcover, RMB ,

EJakel, OGC i SDuraiswamy, ACRS  ;

EIgne, ACRS  :

MTaylor, CRGR l SFeld, RES/RDM JBradburne, CA i JFouchard, PA SGagner, PA l JConran, AEOD l 40CS;;(AC-541) "I' i 0FX3,

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. g o UNITED STATES i 3 a,

NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20S$5 b ..s / *  !

MEh0RANDUM FOR: Victor Stello, Jr.  !

Executive. Director fcr Operations  !

FROM: Eric S. Beckjord, Director  ;

Office of Nuclear Regulatory Research j

SUBJECT:

EFFECTIVE AMENDMENT OF 10 CFR PART 50, APPENDIX J TO PERMIT MASS POINT ANALYSIS Attached for your signature is' a Federal Register notice amending 10 CFR Part  !

50, Appendix J "Primary Reactor Containment Leakage Testing for Water-Cooled  :

-Power Reactors", to permit the use of the Mass Point analvsis method for calcu- t

lating containment leakage rates.

]

Background:

i The CRGR recommended that this revision be published as an imediately effec- ,

tive rule to modify the current regulation and to permit the use of the Mass.  !

Point data analysis method for containment leakage testing. A regulatory

~

analysis was previously prepared and reviewed cn the effects of the change on  !

safety, cost, and other matters as normally required for CRGR review. }

The final rule is identical to the proposed rule issued for public coment  :

j on February 29,1988,(53FR5985). The following language is added to  ;

~

Section III.A.3 of 10 CFR Part 50, Appendix J:  ;

"In addition to the Total Time and Point-to-Point methods described in i that standard, the Mass Point method, when used with a test duration of i

l at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, is an acceptable method to use to calculate leakage  ;

e rates. A typical description of the Mass Point method can be found in  !

the American National Standard ANSI/ANS 56.8-1987, 'Containment System Leakage Testing Requirements,' January 20, 1987."

Also, as in the proposed rule, the following sentence will be deleted from

! Section III.A.3 of the existing rule in order to allow a change in the methods  ;

now permitted: ,

y i "The method chosen for the initial test shall nomaliy be used for the  !

periodic tests." j The proposed rule was published for public coment on February 29,1938 under  ;

the signature of the EDO. The comment period expired March 30, 1988. j t

Coments.

I As nated in more detail in the enclosed Public Coment Resolution Memo, 21

.coment letters were received. Three principal coments were presented.

i i

First, all comentors supported the addition of the Mass Point analysis to the

. list of acceptable analysis methods. -

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Second, all but two commentors objected to requiring a 24-hour test duration  !

if using the Mass Point method. l Third, one objection was raised to the degree of flexib4'lity permitted by the proposed wording in defining the Mass Point method. j .

The NRC staff believes that the.wording of the revision as published for. com- l ment accurately represents the.NRC staff's position. All comments have been '

, reviewed. In spite of the objections raised in the comments to the wording or content of the proposed rule, the wording submitted for the final revision to '

this rule is identical to that of the proposed rule. The Public Comment Resolution Memo addresses in detail the NRC staff's thinking in ,

adopting the rule as proposed. .

Notices:

A notice to the Comission that the ED0 has signed this rule is enclosed for  ;

inclusion in the next Daily Staff Notes (Enclosure 5). The appropriate Con-4 gressional committees will be notified (Enclosure 3). A copy of the Public Comment Resolution Memo (Enclosure 2) will be sent to all commentors and placed l in the Public Document Room.

'I Coordination:

The Office of the General Counsel has reviewed this amendment and has no legal ,

< objection. The Office of Nuclear Reacter Regulation and Regional Offices I-V  !

concur in this amendment. The CRGR has reviewed this amendment and approved  ;

it for publication as a final rule. The Office of Administration and  ;

i Resources Management has reviewed this amendment and considers it to be in a form acceptable for publication. The Office of Governmental and Public Affairs ,

has concurred in the draft Congression,s1 letter and has determined that no -

public announcement is needed for thi.; amendment. The ACRS has been informed ,

of this amendment's status, and raised no objections to its issue. j 2

e Eric S. Beckjord, Director Office of Nuclear Regulatory Research

Enclosures:

:1. Federal Register Notice of Final Rulemaking
2. Public Comment Resolution Memo
3. Draft Congressional Letter '
4. Federal Register publication of Proposed Rulemaking (53 FR 5985)
5. Draft Daily Staff Notes Item l

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Approved For Publication The Commission delegated to the EDO (10 CFR 31(a)(3)) the authority to detelop and promulgate rules as defined in the APA (5 U.S.C. 551(4)) subject to the limitations in NRC Manual chapter 0103, Oroanization and Functions, Office of the Executive Director for Operations, pa. graphs 0213, 038, 039 and 0310.

The amend enclosed Part 50 rule, entitled by adding "Alternative to 10 Method CFR Part 50, for Leakage Appendix J SectionRate Testing),"

III.A.3(a , will statisticci data analysis techniques (Mass Point) that the NRC staff considers ,

to be an acceptable method of calculating containment leakage rates.

This final rule does not constitute a significant question of policy, nor does it amend regulations contair.ed in 10 CFR Parts 7, 8, or 9 Subpart C. I there-fore find that this rule is within the scope of my rulemaking authority and am proceeding to issue it.

, Date Victor Stello, Jr.

Executive Director for Opr.rations f

i ENCLOSURE 1 i

Federal Register Notice of Final Rulemaking s

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[7590-01]

NUCLEAR REGULATORY COMMISSION  ;

10 CFR Part 50 t Alternative Method for Leakage. Rate Testing

.AGENCY: Nuclear Regulatory Comission.

ACTION: Final rule.

SUMMARY

The Nuclear Regulatory Comission (NRC) is ame..ding its regulations i to modify the requirements applicable to the leakage testing of containments of .

light-water-cooled nuclear power plants. The rule explicitly pennits the use of a statistical data analysis technique that the NRC considers to be an accept-able method of calculating containment leakage rates.  ;

EFFECTIVE DATE: (The 'e of publication). t i

.FOR FURTHER INFORMATION CONTACT:

Mr. E. Gunter Arndt, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Comission, Washingtcn, DC 20555, telephone 301-492-3814 (after '

October 1, 19ES).

SUPPLEMENTARY INFORMATION:

Background

The Nuclear Regulatory Comission is amending 10 CFR Part 50, Appendix J,  !

"Primary Containment Leakage Testing for Water-Cooled Power Reactors," to

  • explicitly permit the use of the Mass Point statistical data analysis method for calculating containment leakage rates. The Mass Point method involves calculation of the air mass at a series of points in time and the plotting of '

mass against time. A linear regression line is plotted through the mass-time '

points using e least squares fit. The slope of this line is divided by the intercept of this line, and the result is multiplied by an appropriate constant to obtain the calculated leakage rate.

This Mass Point method was incorporated in a newer ANSI standard, ANSI/ANS-

< 56.8-1981, "Containment System Leakage Testing Requirements" (revised 1987) and i in fact has been accepted by the NRC staff as an imprcved alternative method of calculating containment leakage rates. However, it was recently recognized by the NRC staff that a strict interpretation of the specific wording of Appendix J, III.A.3, by referencing only the older ANSI standard, would preclude use of L the newer, improved method. To alleviate this restriction on the use of an >

improved alternative methodology, it is necessary to clarify the language in j Section III.A.3 to explicitly permit the use of the newer Mgss Pcint method in ,

addition to the earlier methods covered by ANSI N45.4-1972 I ANSI N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear ,

Reactors" (dated March 16,1972). Incorporation of ANSI N45.4-1972 by refer- ,

ence was approved by the Director of the Federal Register on October 30, 1972. l Copies of this standard, as well as ANSI/ANS-56.8-1987, "Containment System .

Leakage Testing Requirements" (dated January 20,1967) may be obtained frott the American Nuclear Society, 555 North Kensington Avenue, La Grange Park, IL 60525. A copy of each of these standards is available for inspection at the Comission's Public Document Room at 2120 L Street NW., Washington, DC.

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[7590-01]

A proposed rule concerning the addition of the Mass Point method was published for comment on February 29, 1988 (53 FR 5985). The complete history i and background for the proposed action were discussed in detail in the Supple-mentary Information section which accompanied the proposed rule. The effect of this amendment will be to permit licensees to use tr.2 Mass Point analysis as en alternative to the Total Time and Point-to-Point analyses incorpo.'ated by ,

reference into Appendix J by ANSI N45.4-1972.

The final rule is identical to the proposed rule publis'ted for comment, and '

adds the following words to Section III.A.3:

"b addition to the Total Time and Point-to-Point methods described in that standard, the Mass Point method, when used with a test duration of .

at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, is an acceptable method to use to calculate leakage  ;

rates. A typical description of the Mass Point method can be found in the American National standard, ANSI/ANS 56.8-1987, "Containment System Leakage Testing Requirements", January 20, 1987."

Also, es in the proposed rule, in order to allow a change in the methods now i permitted, the final rule deletes the following sentence from Section III.A.3 of Appendix J:

"The method chosen for the init:al test shall normally be used for the .

periodic tests."

The NRC believes the wording of the revision as published for comment, and as finally amended, clearly and accurately represents the NRC's position.

  • All comments have been reviewed. In spite of the objections raised in the l comments to the wording or content of the proposed rule, the wording in the ,

4 final rule is identical to that published for public coment. A Public Comment

  • Resolution Memo has been prepared and sent to all who comented. 11 is avail-l able for inspection and copying at the NRC's Public Document Room at 2120 L Street,. Washington, DC. The memo addresses in more detail the NRC's decision 4

to Lecp the wording the same as in the proposed revision. A brief sumary of the comments received is set out in the followino paragraphs.

1 Summary of Public Comments i Twenty-one comment letters were received. In general, three principal j comments were presented.

I First, all commentors supported the addition of the Mass Point analysis to the list of acceptable analysis methods.

Second, all but two commentors objected to requiring a 24-hour test duration ,

in ccmbination with the Mass Point method.  ;

^

As noted in the amchoatory proposed rule of February 29, 1988, the position stated in the text is consistent with the po',ition that has been taken by the NRC staff when granting exemption requests on this matter. In particuler, the -

description of the Mass Point metis 4 and its coupling with a test duration of .

at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reflect prior exemption approvals and maintain necessary consistency.

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[7590-01]

The intent of this limited arrendment is not to endorse ANS 56.8, nor to propose any of the changes and updating represented by the October 29, 1986 proposed general revision to Appendix J (51 FR 39538). Instead, this action does no more than eliminate the need for exemptions to the existing rule by permitting the use of a statistical method that has been generally accepted Tor several years. This revision simply codifies prior exemptions that permitted the use of the Mass Point method for 24-hour tests.

Inclusion of the 24-hour duration is considered necessary because a consider-eble difference tf opinicn exists as to what is a sufficient test duration.

Until an acceptable set of alternate technical criteria is developed to re-place the 24-hour duration criterit7, i.he NRC staff intends to continue the 24-hour criterion. Some alternative technical criteria were presented for public review and comment in propose egulatory guide MS 021-5, "Containment System Leakage Testing,"2 on October z8, 1986. These crite i and others pro-posed are still being evai vated in crder to determine what h an appropriate set of test termination criteria to ir.clude in the final regulatory guide.

Third, one objection was raised to the degree of flexibility permitted by the proposed woroing in defining the Mass Point method.

If this comment were to be followed, the effect would be to incorporate by reference into 10 CFR Part 50 the exact Mass Point analysis as defined in ANSI/ANS 56.8-1987, along with the portions of that standard that are relevant to setting the conditions of use of this analysis. The existence of proposed regulatory guide MS 021-5 demonstrates that this degree of compatibility between ANS 56.8 and a position acceptable to the NRC staff does not exist.

Therefore, in order to define in detail a Mass Point analysis that would be acceptable to the NRC staff, such an incorporation by reference would also have to conta k the portions of proposed Regulatory Guide MS 021-5 that modify the ANS 56.8 definition and use of the Mass Point analysis. Thi': approach would be unoesirably cumbersome, inflexible, and restrictive in tne ability to keep the legally acceptable Mass Point analysis current with any future improvements, simplifications, or changes in the state-of-the-art of statistical reduction of test data to a leakage rate.

An alternative perhaps could be to simply state that the Mass Point method be defined ir a manner acceptable to the NRC staff, and leave that definition to the finalization of proposed regulatory guide MS 021-5. However, this would probably be a less acceptable alternative because it would be more flexible than the current wording and would depend heavily on the as yet unissued regulatory guide.

2A free single copy of draft regulatory guide MS 021-5, to the ev.tent of sup-ply, may be obtained by writing to the Distribution Section, Pocument Control Branch, Division of Information Support Services, U.S. Nuclear Regulatory Com-missien, Washington, DC 20555. A copy is also available for inspection, or copying for a fee, in the NRC Public Document Room, 21E9 L Street, NW, Washington, D.C.

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[7590-01]

l Finally, as noted in the proposed rule of February 29, 1980, the wording was j intentionally made instructive but flexible in the event that the proposed general revision to Appendix J and its proposed associated regulatory guide are not issued as final documents. Should that happen, then a clear need would l exist for some flexibility in the ability of Appendix J to keep up with changes to ANS 56.8 and potential future modificatiens to the Mass Point analysis Effective Date Since the amendment sct forth below is intended to provide relief from, rather than to impose, restrictions currently in effect, the Commission is, pursuant to 5 U.S.C. 553(d)(1), making the final rule effective on (the date of publi-caticn) without the customary 30-day waiting period.  !

Environmental Impact: Categorical Exclusion The Commission has determined that this rule is the type of action described )

in the categorical exclusion in 10 CFR 51.22(c)(2). Therefore, neither an environmental impact statement nor an environmental assessment have been prepared for this rule.

Paperwork Reduction Act Statement This final rule does not contain a new or amended information collection requirement subject to the Paperwork Reduction Act of 1980(44 U.S.C. 3501 et seq.). Existing requirements were approved under the Office of Management and ,

Budget approval number 3150-0011.

f Regulatory Analysis The Commission has prepared a regulatory analysis on this regulation. fhe analysis examines the costs and benefits of the alternatives considered by the

, Commission. Interested persons uay exar.ine a copy of the regulatory analysis

- at the NRC Public Document Room, 2120 L Street NW., Washington, DC.

i l Regulatory Flexibility Certification j As required by the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b), the ,

i Commission certifies that this rule does not have a significant economic  ;

impact on a substantial number of small entities. This rule affects only the .

4 licensing and operation of nuclear power plants. The companies that own these plants do not fall within the scope of the definition of "small entities" st.t forth in the Regulatory Flexibility Act or the Small Business Size Standarde set out in the regulati m s issued by the Small Business Administration at I?

[ CFR Part 121.

l Backfit Analysis

- The NRC has determined that a backfit analysis is not required for this rule

'oecause, although the rule is applicable to all current or future operating nuclear power plants, the provisions of the rule codify and permit the i continuation of a previously accepted practice. This action will not encumber l those using this accepted practice with the added burden of seeking exemptions

j. to the existing rule, e

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[7590-01] ,

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< List of Subjects t

Ar.titrust, Classified information, Fire prevention, Incorporation by reference, Intergovernmental relations, Nuclear power plants and reactors, Penalty, Radiation protection, Reactor siting criteria, Reporting and recordkeeping requirements.

For the reasons set out in the preamble and under the authority of the.

Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 552 and 553, the NRC is adopting the following amend-ment to 10 CFR Part 50 PART 50--DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES

1. The authority citation-for Part 50.continues to read as follows:

Authority: Sec. 161,.68 Stat. 948, as amended (42 U.S.C. 2201); sec 201, i 88 Stat. 1242, as amended (42 U.S.C. 5841).

2. In Appendir. J,Section III.A.3.(a) is revised to read as follows: -

6 Appendix J--Frimary Reactor Containment Leakage Testing for Water-Cooled Power a

Nactors

  • * * *
  • i III. Leakage Testing Requirements

' A. Type A Test- + *

  • i I 3. Test Methods. (a) All lype A tests shall be conducted in accordance with l
the provisions of the American National Standard N45.4-1912, "Leakage Rate i Testing of Containment Structures for Nuclear Reactors", Farch 16, 1972. In  :

addition to the Total time and Point-to-Point methods described in that standard, i the Mass Point method, when used with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, is l an acceptable method to use to calculate leakage rates. A typical description i af the Mass Point roethod can be found in the American National Standard ANSI/ANS ,

56.5 j987, "Containment System Lcakage Testing Requirements", January 20, l

1987.

1 I

I ANSI N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear l l Reactors" (dated March 16,1972). Incorporation of ANSI N45.4-1972 by refer- i 4

ence was approved by the Director of the Federal Register en October 30, 1972. i Copies of this standaro, as well as ANSI/ANS-56.8-1987, "Containment System i

) Leakage Testing Requirements" (dated January 20,1987) may be obtained frem l the American Nuclear Society, 555 North Kensington Avenue, La Grange Park, It i 60525. A copy of each of these standards is available for inspection at the l

Commission's Public Document Room at 2120 L Street NW., Washington, DC.

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[7590-01]

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  • Dated at Rockville, MD, this day of 1988.

For the Nuclear Regulatory Commission.

Victor Stello, Jr.,

Executive Director for Operations.

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i ENCLOSURE 2 l Public Comment Resolution Memo .

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I PUBLIC COMMENT RESOLUTION MEMO d

Twenty-one comment letters were received, and three principal comments were presented.

First, all commentors supported the expansion of 10 CFR Part 50, Appendix J, to permit the use, if desired, of the Mass Point method of analysis in addition to the Total Time and Pcint-to-Point methods.

Secced, all but two commentors objected to requiring a 24-hour test duration in combination with the Mass Point method.

Third, one objection was raised to the degree of flexibility permitted by the proposed wording in defining the Mass Point method. ,

More specific comments can be characterized as .thirteen, recognizing differ-ences in how the above three principal comments were presented. These com-ments are shown in Tables 1 6 F.

These more specific comments have been addressed as follows:

1. Comment: Proposed rule acceptable without comments. .

Response: None needed.

P

2. Comment: Mass Point method is acceptable.

Response: None needed.

1

3. Comment: Do not require a 24-hour test duration.

Response: As noted in the proposed rule of February 29, 1988, the position stated in the words being added is consistent with the position that has been taken by the NRC staff when granting exemption requests on this matter. In particular, the description of the Mass Point method and its coupling with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> both reflect those prior exemption approvals and maintain that consistency.

Inclusion of the 24-hour duration is considered necessary because there is a considerable difference of opinion as to what is a sufficient test duration.

Until an acceptable set of alternative technical criteria is developed to replace the 24-hour duration criterion, the NRC staff intends to continue the 24-hour criterion. Some alternative technical criteria were presented for public review and comment in proposed regulatory guide MS 021-5 on October 28, 1986. These criteria and others proposed are still being evaluated in order to determine what is an appropriate set of test termination criteria to include in l the final regulatory guide, l

l

4. Comment: The proposed rule is contrary to ANS 56.8-1987 and to the l 1

proposed general revision of Appendix J that was published for comment on October 29, 1986.

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Response: The intent of this limited amendm2nt is not to endorse ANS 56.8, nor to propose any of the chances and updating represented by the October 29, 1986 proposed general rev'sion to Appendix J. Instead, it does no more  !

than eliminate the need for exemptions to the existing rule by permitting the use of a statistical method that has been generally accepted for several years.

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This revision would simply codify prior exemptions that permitted the use of the Mass Point method for 24-hour tests.

That does not mean, however, that the Mass Point method is considered to be perfect in its current form by all who use it. Nor is it likely to remain static in any form as time r an. For this reason, the NRC staff has chosen not to incorporate by reference into the proposed general revision to Appendix J any national standard or other guidelines that describe the details of how to perforn the leakage rate testing program. These are the technical details that will change as the state of the art of leakage testing changes. Instead, a proposed regulatory guide was published for comment at the same time as the proposed Appendix J general revision. The proposed regulatory guide would en-dorse ANS 56.8 and stay current with it. The current Appendix J endorses ANS N45.4-1972, not ANS 56.8.

5. Comment: Use ANS 56.8 8-hour minimum test duration and criteria in place of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Response: This limited revision is neither a full nor partial endorsement of ANS 56.8., nor is it a replacement of the incorporated referenced standard, ANS N45.4-1972, with the more current ANS 56.8. Endorsement of AN5 56.8 will I

be done through the proposed general revision to Appendix J and its related regulatory guide. As noted in the response to Coment #3, the proposed rego-latory guide MS 021-5 as issued for public comment took exception to the ANS 56.8 8-hour minimum test duration, and suggested criteria for measuring when a test had been run long enough. These criteria, and alternatives to them that have been propostd, ere still being reviewed for reliability and effectiveness.

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4 Therefore, the NRC staff feels that it is premature to revise the test duration criteria on which it has being relying for so long. At this time, the NPC staff will not replace the general criterion for a 24-hour test duration with the ANS 56.8 8-hour test duration.

6. Comment: Endorse ANS 56.8-1981 in place of ANS N45.4-1972.

Response: See responses to Comments #4 and 5.

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7. Comment: Base test length on time necessary to obtain 95% confidence level.

Response: Exectly how the test length is to be determined is the reason that the proposed regulatory guide MS 021-5 suggested criteria supplementary to ANS 56.8. As stated above, these and other suggestions are still being evaluated.

8. Conment: Allor the analysis of the data to determine the length of testing.

Response: This is essentially saying the.same as Comment #7, although stated slightly differently. The response, therefore, is the same as for Comment #7.

9. Comment: Licensees should be authorized to adopt test durations which they determine are accurate.

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Response: Until a consensus is reached on an acceptable set of technical criteria which will determine test duration, the NRC staff does not intend that such a crucial parameter as test duration be determined on a non-standard basis and without NRC involvement. Therefore, this comment was not adopted.

10. Comment: Modify Anpendix J to allow a test duration minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when utilizing the Mass Point method.

Response: Same response as for Comment f5.

11. Conment: Delete "when used with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> "

and add "With any test method, test duration shall be at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless a shorter duration has been approved by the Commission..."

Response: Where an exception has already been granted by the Commission from the requirement to perform a 24-hour Type A containment iategrated leakage rate test, such an exception will continue to be valid, so long as the; basis for the exception remains unchanged. The bases for performing Type A tests of less than 24-hour duration have already been established and currently are limited in number (BN-TOP-1; ANSI N45.4-1972, para. 7.6). The general revision to 10 CFR Part 50, Appendix J, and its related regulatory guide, when final-ized, will provide the generic flexibility sought by this comment.

Providing the recommended wording would result in attempts to tai or test criteria to plant-specific bases for determining test duration. This would further complicate a complex testing program that is already in need of 5

standardization and simplification. Although the need for certain plant-specific variations in test details is clear, the purpose of the test program is best served when the data, information, and experience can be compared and evaluated on a broader btsis. In addition, the regulatory and inspection bur-dens are increased as individual plant test programs deviate from a standard test criteria or use uniq;e bases for determining when a test can be con-sidered as acceptable.

IE. Comment: The 24-hour Mass Point test imposes a backfit on plants currently using Mass Point in conjunction with an 8-hour test duration. A complete 10 CFR 50.109 backfit analysis should be done.

Response: As noted before, those licensees that already have been granted exceptions from the 24-hour test duration may continte to operate under that exception so long as they also continue to operate under the conditions under which it was granted. Therefore, no backfit is being imposed on these licensees.

Any licensees currently performing a Mass Point analysis, whether 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, may only do so if legally exempted from the requirements of 10 CFR Part 50, Appendix J, which has been interpreted as permitting only Total Time or Point-to-Point 3nalyses. Any licensee using Mass Point analysis, whether for N hours or 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, must therefore demonstrate a legal basis for doing so.

For those using Macs Point analysis without a sufficient legal basis, the Backfit Rule states that a backfit analysis is not required when a modification 6

.9 is necessary to bring a facility into compliance with rules of the Commission.

For those not using Mass Point anelysis, this revision provides a legal option to do so if desired, under conditions that are intended to exist until a consensus is achieved on standard criteria for determining a Type A test duration and those criteria are promulgated and made effective in a general revision to Appendix J and its associated regulatory guide.

13. Comment: The Mass Point definition is too flexible, replace "typical" with "completely acceptable."

Response: If this comment were to be followed, the effect would be to incorporate by reference into 10 CFR Part 50 the exact Mass Point analysis as defined in ANSI/ANS 56.8-1987, along with the portions of that standard that are relevant to setting the conditions of use of this analysis.

The existence of proposed regulatory guide MS 021-5 demonstrates that this degree of compatibility between ANS 56.8 and a position acceptable to the NRC staff does not exist. Therefore, in order to define in detail the Vass Point analysis that would be acceptable to the NRC staff, such an incorporation by reference would also have to contain the portions of pt oposed Regulatory Guide MS 021-5 that modify the ANS 56.8 definition and use of the Mass Point analysis.

This approach would be undesirably cumbersome, inflexible, and restrictive in the ability to keep the legally acceptable Mass Point analysis current with any future improvements, simplifications, or changes in the state-of-the-art of statistical reduction of test data to a leakage rate.

An alternative perhaps could be to simply state that the Mass Point method be defined in a manner acceptable to the NRC staff, and leave that definition to 7

7 the finalization of proposed regulatory guide MS 021-5. However, this would probably be considered as less acceptable since it would be more flexible than ,

the current wording, and would depend heavily on the yet unissued regulatory guide.

Finally, as noted in the proposed rule of February 29, 1988, the wording was ,

intentionally made instructive but flexible in the event that the proposed general revision to Appendix J and its proposed associated regulatory guide do not get issued as final documents. Should that happen, then a clear need would ,

exist for some flexibility in the ability of Appendix J to keep up with changes to ANS 56.8 and potential future modifications to the Mass Point analysis.

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l Table 1 PUBLIC COMMENT LETTERS

  1. Originator Date Comments
1. S&W 3/10/88 1 3/15 1
2. OCRE
3. PSNH (Connolly, Test Eng'r) 3/23 2,3
4. FPL 3/25 2,3,7 3/23 2,6
5. YANKEE
6. WE 3/18 2,5
7. DUKE 3/22 2,3,5 ,
8. PSNH (Thomas, V.P.) 3/29 2,4
9. NU 3/31 2,5 3/29 2,5
10. WPSC
11. CEC0 3/29 2,3,9,13 ,
12. B,C,P&R 3/30 2,5,12
13. WPPS 3/29 2,5
14. RG&E 3/30 2,8
15. AP 3/31 same as ltr #12 3/30 2,5
16. GPC ,
17. NYPA 4/1 2,5
18. TVA 5/4 2,10 l 4/5 2,8
19. NM I 2,11  !
20. NSP 4/7
21. PE 5/3 2,5,12 I

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Table 2 KEY

1. Proposed rule acceptable without further comment.
2. Mass Point acceptable.
3. Do not require 24-hour test duration.
4. Proposed rule is contrary to ANS 56.8-1987 and proposed general revision of i?pendiy. J.
5. Use ANS 56.8 8-br minimum test duration and criteria in place of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
6. Endorse ANS 56 8-1981 in place of ANS N45.4-1972.
7. Base test length on time necessary to obtain 95% confidence level.
8. Allow the analysis of the data to determine the length of testing.
9. Licensees should be authorized to adopt test durations which they determine are accurate.
10. Modify Appendix J to allow a test duration minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when utilizing the Mass Point method.
11. Delete "when used with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" and add "

With any test method, test duration shall be at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless a shorter duration has been approved by the Commission..." ,

12. 24-hr Mass Point test imposes a backfit on plants currently using Mass Point in conjunction with an 8-br test duration. A complete 10CFR50.19 .

backfit analysis should be done.

13. Mass Point definition is too flexible, replace "typical" with "completely acceptabl e .

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EhCLOSURE 3 ,

Draft Congressional Letter i

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'.* 8 n NUCLEAR REGULATORY COMMISSION g WASHINGTON, D. C. 20555 9g-.....s'e i i

DRAFT .

The Honorable John B. Breaux, Chairman i Subcommittee on Nuclear Regulation Committee on Environment and Public Works '

United States Senate Washington, DC 20510

Dear Mr. Chairman:

The NRC has sent to the Office of the Federal Register for publication the i enclosed amendment to the Commission's rules in 10 CFR Part 50. l The amendment is a limited revision of Appendix J "Primary Reactor Containment Leakage Testing for Water Cooled Power Reactors," of 10 CFR Part 50. It will clarify the existing regulation to explicitly permit the continued use of a  ;

statistical analysis technique (Mass Point method) that has been considered acceptable for years in calculating containment leakage rates. i Sincerely, l

Eric S. Beckjord, Director Office of Nuclear Regulatory Research i

Enclosure:

Federal Register Notice .

i cc: Sen. Alan K. Simpson i

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i The Honorable Morris K. Udall, Chairman

  • Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, DC 20515 cc: Rep. Manuel Lujan, Jr.

i The Honorable Philip R. Sharp, Chairman i Subcommittee on Energy and Power Committee on Energy and Commerce United States House of Representatives Washington, DC 20515 cc: Rep. Carlos J. Moorhead 1

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.5 ENCLOSURE 4 i 1

Federal Register Publication of Proposed Rulenaking I

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., Federal Register / Vol. 53 No. 39 / Monday. February 29. 1983 / Proposed Rules 5985 4

period(s) of service during whieh he/she the NRC considers to be an acceptable this line, and the result is multiplico Sy was entitled to be insured. method of calculating containment an appropriate constant to obtain the leakage rate s. calculated leakagt rate.

DATt s: Comment period expires March This Mass Point rnethod was PART 690-FEDERAL EMPLOYEES 30.1968. Comments received after this incorperated in a newer ANSI standard HEALTH BENEFITS PROGRAM date wdl be considered if it is practical AaSI/ANS-50.&-1981. "Containment t do so, but ast..arance of censideration System Irakage Testing Requirements"

, 3. The authority cation for Part MO T continues to read as follows: (rev;sed 1987) and in fact has been

" secewed on or before th(is date.cannotaccepted be ghenbyexcept or comments the NRC staff as an Authority: 5 U.S C. e913. I 890102 also 7

y bsued ur.der 5 U.S C.1104. ADDREssEs:Mail written comments to: improved alternative method of j Secetary U.S. Nuclear Regulatory calculating cc ntainment leakage rates.

4. In Subpart C of I art 890, paragraph Commission, Washington, DC 20555. I!awever it ms recently recognized by

,3 H90.303(al is revised to read as follows: Attention: Docketing and Service the NRC stal. that a strict interpretatien i 890.303 Coi.Unuation of enroftment Branch. Deliver comments to: Room of the specific wording of Appendix j.

i (a) On transfer or retirement. (1) 1121.1717 H Street NW., Washington.

DC. between 7:30 a.m. and 4.15 p.m.

III.A.3. by referencing only the older

( Except as otherwise provided by this ANSI stardard, would pret!ude ese of I part, the registration r)f an employee or weekdays. Cocies of comments received the newer,improved methon To 5 annuitant eligible to continue rerollment may be examined at the NRC Public alleviate this restriction on thi. nse of an

continues without change when he or D cument Room.1717 H Street NW., improved alternative methodolog,. it is she moves from one employing office to Washington DC. necessary to clarify the language in another. without a break in service of FOR WRTHER tr *>RMATION CONTACT
Section ll.A.3 to explicitly permit the use more than 3 days. whether the personnel Mr. E. Cunter e adt. Office of Nuclear of the newer Mass I-oint method in i.. action is designated as a ransfer or not. Regulatory Research. U.S. Nuclear addition to the earlier methods covered

[2] In order for an employee to Regulatory Commission. Washington, by ANSI-N45.4-1972. A similar revisiota continue en enrollment as an annuitant. DC. 20555, telephone (301) 492-3945, is in fact proposed as part of the he or she must meet the participation SUPPLEMENT ARY INFORM AT10tc. currently pending ScDeral revision to

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j requirements sei forih a18905;bl of iitie

"'tE a Avrendix .' (s ee 51 rR 39538. ociober 29.

1906k H ""er, tb pmposed rule

5. United States Code, for cortinuing cn

( enrollment as an annuitant as of the In 197 - en the Commission initially change in /olves a number of complex pmmulgated its requir-ments matters and a final rule concerning the lg commencing date of his or her annuity

c. monthly compensation. concerning con*ainmem : stegrated revision to Appendix ] may not be j (3) for the purpose of this part. an leakage rate testing (10 CFR Part 50 completed for some time. In order to minimize any further delay in codifying U cmployee is considered to have enroiled Appendix. the Commission required 1

at his or her first opr)rtunity if the licensees to use state-of-the-art Itakage the accepted use of the Mass Point {6 emplovec registere to be enro!!cd test methodology and specifically called methad, the Commission proposes to during'the first of the periods st' ~orth in for Type A test methods described in modify Section 1II.A.3 to explicitly 5 i 890.301 in which he r she was eligible American National Standard ANSI-- permit the use of the Mass Point method, ' to register or was covered at that time N45.4-1972. "14akar.e Rate Testing of subject to certain conditions that have by the enrollment of another employee Containment Structures for Nuclear been accepted by the NRC staff since

  .h            or annuitant or registered to be enro!!cd Reactors ( Appendix j Sec. Ill.A.3).                       approximately 1976, as well as to perrait jy          effective not later than December 31 3994, That standerd accepted two techniques for evnluating test results: the Total the use of the prior methods referenced in ANSI-N45.4-1972.The position stated c            .        .    .             .    .                  Time rnethod and the Point to-Point              in the words being added is consistent method. In the Total Time method, a              with the position that has boer taken by p            li'R Duc~ r&4201 Filed 2-2tMa. B 45 mm)               series ofleakage rates are calculated on         the NRC staff when granting exemption mmc, cm sars.es.u E                                                                  the basis of containment air mass               requests on this matter. In particular the g ifferences between an iritial data po:nt description of the Mass Point method n

e.nd each individual data point and its coup'.ing with a test duration of NUCLEAR REGULATORY thereafter, and an average of these at 1:ast 24 hours both rtilect those prior CCMMISStON leakage rates is then determined. In the exemption approvals and maintain that

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b to CFR Part 50 P int-to.Point method. .he leakagt rates consistency.1mprovements to the d are based on the air mass difference wording in the existing Appendix J of10 I, bet.;een each pair of consecutive data CFR Part 50 are contemplated in a Alternative Method fcr t.eakage Rate

    !           Testing                                               points, and these leakage rates are then        proposed general revisior. to Appendix J 9                                                                 averaged to yield a single leakage rate         and in a related regulatory guide (MS k             Act NCY:Nuc!cat Regulatcry                            estimate.                                       021-5. "Containment System Leakey j,            Commissiou                                                 Subsequently, fur ther advances in         Testing") that would endorse ANS!/
  $             AcTsoec Propcsed rule.                                leakege rate testirg technology have            ANS-56.8. If the more general revision
provided improved test methods. of Appendix J is adopted before this
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SUMMARY

The Nuclear Regulatory Cornmir.sion (NRC)is i oposing a including a newer method sf evaluating test data ca!!ed the Mass Point method.

Im.ited revision b< t mes final, this action wi.' become s mecessary and will i hmited amendment to clarify the The Mass Point rnethod intches be withdra,rn. However. this is not

regtJrements of its regulations calculation of the air mass at a series of hkely. Thervfore, until such a general
  '             apphcable to the leakage testmg of                    pohts in time and the plotting of mass          revision is adopted, the description of containments of hght.water coo!cd                     against time. A Imcar regression ime is         the Mass Point method in ANSI/ANS-4             r uclear power Wras. The tuoposed rue plotted throgh the mass.time points                             5G r,is considered useful for explaining g             % Id esplicitly pernut the use of a                   using a least squares fit. The slope of         the method and its application in statistir.d d..to an.dyss tectn.que that              this hnt is dmded by the mtercept of            general to the containment leakage rate h
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Federal Register / ol. 53. No. 39 / .\londay. February 29. 1988 / Proposed Rules J 5936 -

                                                                                                                                                                                       .,              r to,t program. Adjustments to the ANS!/         in the NRC Pubhc Document Room.1717 Appendix pPrimary licactor ANS46 8 at%cription of the h!ass Pomt          11 Street NW.. Washington DC.The                   Containment Leakage Testing for Water-                                                -

rnethod n.ay 1+e oe<.irable as this method Commission requests pubbe comment Cooled Power Reactors l crolve. and is apphed to this on the draft argulatory analy',is. . . . . . f , specializeit and complex test program. Comments on the draf t analysis may be  ? The intml of the propowd wordmg is to submitted to the NRC as inicated under III. trakage Testing Requirements f allow suffnient fiexilnhty for such the AcontssEs head:ng. * * * *

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adjuvments to be made to the method A. Type A test * *

  • Regulatory f.lexibility Certificat.ion 3.Test Methods.(al AllType A tests shalt k  !

should a general revision to Appendix ) an i on espbcit endorsement of ANS!/ be conducted in accordance with the f In accordance with the Regulatory ' ANS-56 is thraugh a regulatory guide not Flexibility Act of 1980 (5 U.S.C. 605[b))* d dE]5 Ii " t i Testig , j promptly replace this hmited revision. the Commission certifies that this rule,if of Containment Structures for Nuclear The proposed action to be taken is the prorpulgated will not have a significant b Reactors? March 16.1972 In addition to the addition of the following wards to economic impact on a substantial Total Time and Point to-Pc .nt methods I ' Section lil.A.3 of the existir g rule: number of small entities.This proposed described in that standard, the Mass Point t r: le affects only the lic<:nsing and methe * <hen used with a test duration of at > in addition to the Total Time and Point to. feast 24 hours. is an acceptable methoo to use Pout methods desenbed in that standard, the operation of nuclear power plants.The Mass Point method, when used with a test companies that own these plants do not to calculate leal te rates. A typical , , durat._.. of at least a hours. is an a" sabk d**i tion P of the Mass Point method can be a fall within the scope of the definition of un n the American National Standard j method to use to calculate leakage t . A a "small entities".ses forth in the ANSI/ANS-56 6-1967."Cr.ntainment System  ; typical descnption of the Mass Point method m8]g can be found in the American National u8 Y CXS Y T teakage Testing Requir .ments? january T.O. j Business Size Etandards set out in 39g7.i , , Standard ANS!/ANS-5&s-19c7 1

  • Containment System 1.cakarc Teving regulations issued by the Small Business . . . . .

Requirements." lanuary20.1967. Administration at 13 CFR Part 121. Dated at 11ethesda. MD. this 17th day of k ' l'eb.*uary 1968. [ In order to eliminate a contradictioc llackfit Analysis For the Nuclear Reget atory Commission. y t with the intent of this proposed action to ahe NRC has determm.ed that a y;cio,3,,g,, y,,, , permit a change in the snethods now backfit analysis is not required fer this permitted. the following : atence will be Lecutke Din ctorforoperations. t proposed rule because, although the 3 deleted from Section ll!.A.3 of the proposed rule would be applicable to all [rR Doc. 88428 Filed 2-26-88 8 45 nm] p

               * * * "E
  • g'. current or future operating nuclear 8'" C E 75" 4 The method chown for the initial test suall nrrmally be used for the periodic tests.

power plants the provisions of the f. proposed rule would codify and permit invitation to Comment the continuation of a previously FEDERALTRADE COMMISSION j Comments imm all interested persons accepted practice.This proposed action { wo nM encumber Sose eng As = = [ , on a!! aspects of this limited revissort are a;cepted practice with the added Reporting and Recordkeeping (' requested by the comment expiration burde of seeking exemptions to the di te in order that the final revision will Requirements for Wool Products, Fur reflect consideration of all points of *""U"8 " Pioducts, and Textile Fiber Products 5 , view. List of Subjects in 10 CFR Part 50 Acmcy:Federal Trade Commission. , Ewironmental impact: Categorical Antitrust Classified information. Fire ggyio,c Notice of proposed rulemaking.  ; Eaclusion prevention incorporation by reference. -- , The Commission has determined that Intergovernmental relations. Nuclear summ:The Federal Trade . pmr plants end reactors. Penalty. Commission issues proposecfregulations this proposed rule is the type of action , to reduce the borden of corrplying with described in the categorical exclusion in R8i 'tion protection. Reactor siting ' critena. Reporting and recordkeepmg the labeling requirements of the Rules 10 CFR 51.22[r)(2). Therefore. neither an and Regulations Under the Wool environment impact statemcot nor an reouirements. Pr ducts Labeling Act of1939.the Rules ensironmental assessment has been Fm the reasons set out in the and Regulations Under the Fur Products prepared for this proposed rule-preamble and under the authority of,the Labeling Act and the Rules and Paperwork Reduction Act Statement Atomic EnerEy Act o'1954 as amenu. ed. Regulations Under the Textile Fiber 1 th e i" k This proposed rule doet nu contain a gj, en 5 S C 5 3. t e Products identification Act. Under the new or amended information co!!cction P'#P * ****O#

             , requirement snb,ect  i    to the Paperwork is proposing to adopt the following                Recordkeeping provisions m.each of the                                     ~,

amendment 1o 10 CFR Part 50. three regulations wo21d be simplified r Reductr aim 980 (44 U.S.C. 3501 et seg).1 , ,uirements were PART 50---DOf!ESTIC LICENSING OF [ appron ander the Office of FRODUCTION LND UTILIZATION ' ANSI N4s *-in ~isakare Raie Teshns of 7 Manegement and Budget approval FACILITIES C"" '"**"'S""'"'N"C"'""""5" # tdaied Wrch 16."157). Incorporanon of ANSI l number 3150-0011. N4s 4-15.F2 by reference was ag.proved by the 1 The ata..ority citation for i3att50 threctiir of the f ederal Register on Orieber 3a 8W2-Re.;u!atory Analysis continues to read as follows: cop es of this siendard, as =cli es ANst/ANS-sr n- -. The Commission has prepared a drail g g sur. -coni .n enn system trakurTesimg Requiremena s d a may be regulatory an.dvsis on this pmposed amended (42 U S C. 2'011. sec. 201. Im Stat- ons,mca en m,ei,aau Ameno ianuarr 2a Sum n Nude.r .cienv. Lss rule.The analysis esamines thL costs 1N2. as amer.ded (42 U S C. SM11 wnh A.%maton Aven c. e, crog, a .at it. was and benehts of the alterr.atnes . A uin of ea< h of these stand.ai's a avait ble for cusidered by the Commission. Ihe 2. In Appenda J. Section lit A.3 tot is ,,,,pn t on oiis,commssmn s ponnt oorume n.

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urait analye k mai!able for inspection revised to read as follows: um as i71718 sin et Nw w nhmeion Dc iNo i _ --, . . - _ ~ - - , . , . ., 4

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ENCLOSURE 5 Draft Daily Staff Notes Item t e d l l l 1 I I 4

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4I i 1 DAILY STAFF NOTES j OFFICE OF NUCLEAR REGULATORY RESEARCH i Final Rule to'be Signed by EDO -!

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I, On , 1988, The Executive Director for Operations approved i a final rule that amends 10 CTR Part 50, Appendix J, "Primary Reactor.Contain- 'l ment Leakage.Testing for Water-Cooled Power Reactors " to permit the use of a  : statistical data analysis technique (Mass Point) that'the NRC staff considers i to be en ecceptable method of calculating containment leakage rates. This constitutes notice to the Commission that, in accordance with the rule-' I

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meking authority delegated to the EDO.-the EDO has signed this final rule 3

                           'and proposes to forward it on'                          to the Office of the Secretary '

for FR publication, unless otherwise directed by the Commission.  ; i i l

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