ML20215D978
| ML20215D978 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/1985 |
| From: | Sniezek J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Committee To Review Generic Requirements |
| Shared Package | |
| ML20215D926 | List: |
| References | |
| FOIA-86-483 NUDOCS 8610140380 | |
| Download: ML20215D978 (4) | |
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UNITED STATES
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WASHINGTON, D. C. 20555 JUN 201985 NOTE TO:
CRGR Members APPENDIX J Enclosed is a memo from Frank Gillespie regarding reexamination of the Appendix J regulations. You may want to consider this in your CRGR 1,
deliberations regarding Appendix J.
M Jr iSniezeP.
Enclosure:
As stated cc: Frank Gillespie Guy Arlotto i
l g oi g o e60926 REYTBLA86-483 PDR
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JUN 201985 NOTE T0: CRGR Members APPENDIX J Enclosed is a memo from Frank Gillespie regarding reexamination of the Appendix J regulations. You may want to consider this in your CRGR deliberations regarding Appendix J.
Origina1 signed by
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James H. Sniezek Jim Sniezek
Enclosure:
As stated cc: Frank Gillespie Guy Arlotto Distribution:
VStello JHSniezek MTaylor WSchwink DELROGR ci 0FC :ROGR/D NAME :JHSniezek RATE 86/19L85 3 -.
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Notes on App.J.
7/5/85 From Scinto
- 1) Principal problem is inclusion of testing of secondary containments.
See Intro and IVB.
This is at odds with 50.54(o).
But that could be readily fixed by amending 50.54(o).
However, issue is whether NRC wishes to in fact increase the scope of App.
J.
App. J does Det now cover (impose testing requirements on) secondary conpainment.
RES indicated that it believes that IVB now imposes testing requirements on "other structures.."
The provision now in App. J.
simply states that "other structures...shall be subject to individual tests in accordance with the procedures specified in the technical specifications..."
This is simply a reference indicating that
'4 secondary containments etc should be tested as required by the.
tech spec.
-It is not a requirement of App.
J.
that there be any such tech specs or any such tests if the tech specs are silent.
3e New App.
J.
specifically covers secondary containments, specifically requiring that tech specs must have secondary containment testing requirements and requiring by regulation that the tests be done.
This is an increase in scope of App.J.
It may be justified, but thus far I have seen no assessment justifying the imposition of this requirement at this time.
Do we have a lot of reactors out there whose tech specs now do not contain adequate testing requirement for the individual plants ? Basis ?
If they now do contain adequate testing requirements in the tech specs why are we now imposing the same or a different requirement by regulation?
There are also some inadvertent wording problems caused by the inclusion of secondary containments.
While type A tests are limited to " containment systems" a defined term limited to primary containment, and type C tests are limited to
" containment isolation valves" a defined term limited to GDC valves, type B tests apply to containment penetrations" an undefined term now broadened by the inclusion of secondary containments into the rule so that it now, probably inadvertently, covers penetrations of secondary containments.
- 2) For the preop test, the term " general inspection" in the present rule (VA) is changed to" visual inspection" here.
I understand that RES does not mean a visual (surface) examination of the type of close visual exam required for piping when the term visual exam is used for piping. On the other hand RES appears to want something more specific than the present term " general inspection".
Problem of using undefined terms.
- 3) Ippo111to pointed out the poor wording of IIA (1)(c) and IIIA(5) and in IIIB (3) (b).
Arndt said he would fix.
- 4) I have problems with any regulation written to call for an
-U undefined standard requiring the issue to be" acceptable to
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the staff".
IIIA(7).
I don't accept that definition in a to-be-written (and rewritten) reg guide is an adequately definitive regulation.
Similarly, I have a problem with VII A which permits changes in requirements if " acceptable to the NRC staff on some other defined basis".
- 5) wording of III A (B) (a).
It is written to require the staf f to approve the test schedule submitted by the licensee.
Should be changed to "shall be submitted to the staff for review and approval".
's 4