ML20215D930
| ML20215D930 | |
| Person / Time | |
|---|---|
| Issue date: | 07/08/1985 |
| From: | Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Roe J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20215D926 | List: |
| References | |
| FOIA-86-483 NUDOCS 8610140363 | |
| Download: ML20215D930 (3) | |
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UNITED STATES j
[/* *% j NUCLEAR nEGULATOnY COMMissl0N WASHINGTON, D. C. 20t55 _
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MEMORANDUM FOR: J. V. Roe Deputy Director for Operations FROM: R. B. Minogue, Director Office of Nuclear Regulatory Research
SUBJECT:
RES REVIEW OF APPENDIX J In your note dated June 3, 1985, you requested that RES provide you with tht.
. basis for proceeding with revisions to Appendix J while at the same time examining the risk effectiveness of containment leakage / leak rate testing.
Dett.iled responses to your request are presented in the Enclosure.
The existing Appendix J is not clearly written; thus, differing interpretations between NRC staff and licensees are causing difficulty in its implementation;
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it further references an obsolete industry standard. The DRA0/RES program is'
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examining the risk and cost effectiveness of all of the containment leaktightness requirements to detennine their value with respect to plant safety and possible alternative requiremerits.
I believe that the proposed Appendix J should be published for public coments, as recomended by ACRS. The public comments on the proposed rule, in conjunc-tion with recomendations from the DRA0 progran to be submitted to the ED0 in November 1985, will provide additional bases for detennining the value of the interim revision to the regulation.
Please let me know if you have any further questions.
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Robert B. Minogue, D rector Office of Nuclear Regulatory Research
Enclosure:
Response to Mr. Roe's Note cc: V. Stello, ED0 H. Denton, NRR i
8610140363 860926 PDR FOIA REYTBLA86-483 PDR e
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k RESPONSE TO MR. R0E'S NOTE DATED Jt't r 2,19P5 J. ,T_he Basis For The Tvc forcrcts. RES Initiatives The ret.scris for the two separate RES prograr:s tre:
(e) Pifft. rent timing--Appendix J revisior. prccrcrs was initiated in 19PO.
On the other hand, the prcgram or, review of regulatory requircretts was initiated in late 1964. At the tirre of the initiation of the seccrd precrar, the proposed rule for Appendix J revision was already fully devtlcped.
(b) Different purposes--Appendix J revision was initiated fer the purpose of 1972 up)datire r.r.d clarifying the existing Apper; dix J (promulgated inw On the ethrir hand, the DRA0 program on review of containment leakage was initiated as part of a larger program to implement a 19M art .
1985 Couaission PPG item to eliminate existing regulatory require-nents that have marginal impcrtar.ce to safety. Therefore, the ORAC program will engage a broad review of the requirements related to .
containecr+ leakape (including regulaticr.s in Part 50 Appendix J.
Technical Specifications, regulatory guides) in terrrs of safety sig-nificance t.rd erst to the industry and the NRC.
- 2. The Need For The Separate RES Initiatives Under the prescrt situation, two separate prograrr.s are needed based or. the fc11rwir.g reasons:
(a) There are practical difficulties in continuing to apply the eFisting Appert'ix J. Problems have developed in applicatien and interpreta-tion of the existing rule which cause different interpretatiers between licensees and NRC inspectors; also between NRC Regions erd Meer'ceerters Offices. Furthemere, the current version of Appendi). .7 contains a reference on an obsolete industry standard. Revisirr of Appr:rdix J should be published without delay to avoid continuing those difficulties.
(b) The product nf the DRAC program is a recommendation to the E00.
devr-1reped together with other NPC Offices, on whether and how the cristing reouirements on containtert ieakage should be modified. An3 recourendations for change woult! irclude a conceptual model cf r sr.t cf rr;r,tiretrents that the staff feels wculd maintain containment leet.
tightness needed to adequatcly protect public health and safety. The pr,sMt411ty of additional chances resultirig trom oagoing source terr.,
severe accident, and tech spec improverrent studies will also br: i addressed. Peressary chances in regulatory requirements would be l accomplished thrcugh subsenuent rulerrakire actier, following ED0's ENCLOStml
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epproval of the recorno.endation. The time it may take for crr..r,'r.tf er of this rulen.aking acticr. would be about two years.
- 3. The Means Of Cccrdiretion Between The Staf' E" orts .
The DRA0 program lookirp at the r'sk effectiveness of containment leakage rate at:d leak testing requiren.ents obtains c.rreral cuidance from a Progran Adviscry Group consisting of manapart frco several Headquarters Offices inclucing NRR, RES and IE. In additier, there is close coordiwtion betveen DRAO, DET and NRR or this prr.,'cct on both the management and st6ff
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Gunter Arndt (RES), John Hut.rg erd James Shapaker (NRR) are advisors tc DRAC on this pro.iect. All three are actively involved in the developtrer.t of the Appendix J revision. Vr. Arrdt is the task leader for the raision of Appendix J.
- 4. Whether P.ES A.rticipates Additional Revision To The Requirements As A Result Of The DRA0 Program RES anticipates thet, as a result of the DRA0 program, the staff will probably make reconcendatinns to the EDO to modify the existing regulatory
- requiren.ents cr. certainment leakage rates and leakage testing.
ENCLOSURE
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