B12870, Comment Supporting Proposed Rule 10CFR50 Re Leakage Testing of Containments to Permit Use of Mass Point Method as Alternative Method for Calculating Containment Leakage Rates

Comment Supporting Proposed Rule 10CFR50 Re Leakage Testing of Containments to Permit Use of Mass Point Method as Alternative Method for Calculating Containment Leakage Rates

ML20154G681
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	03/31/1988
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR5985, RULE-PR-50 53FR5985-00050, 53FR5985-50, B12870, NUDOCS 8805250035
Download: ML20154G681 (3)

Text

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'M APR -7 P2 :43 March 31, 1988 0FFICE Cr ~u .;an 00CMEliNG A 'vitti.

Eqcket Nos. 50-213 BRANCH 50-245 50-336 50-423 B12870 Re: 10CFR50, Appendix J S. J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555

References:

(1) Federal Register, Volume 53, Number 39.

(2) F. M. Akstulewicz letter to E. J. Mroczka, Exemption From the Requirements of Appendix J to 10CFR50, Paragraph III.A.3, dated October 15, 1987.

(3) M. L. Boyle letter to E. J. Mroczka, Exemption From the Requirements of Appendix J to 10CFR50, Paragraph I!!.A.3, dated October 15, 1987.

(4) D. H. Jaffe letter to E. J. Mroczka, Exemption From the Requirements of Appendix J to 10CFR50, Paragraph III.A.3, dated February 3, 1988.

(5) EPRI Report NP-2726, "Containment Integrated leak Rate Testing Improvements," November 1982.

(6) EPRI Report NP-3400, "Criteria for Determining the Dura-tion of Integrated Leakage Rate Tests of Reactor'Co'ntain-ments," December 1983. .

Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.1, 2 and 3

• Comments on Proposed Rule Alternative Method for leakaae Rate Testina . . .

On February 29,1988 (Reference 1), the Nuclear Regulatory CondissioN '(NRC) published a proposed rule amending its regulations applicable to the leakage testing of containments to cermit the use of the mass point method as an alternative method for calsulating containment leakage rates. Connecticut Yankee Atomic Power Company (CYAPC0) and Northeast Nuclear Energy Company (NNECO) respectfully submit the following comments in support of the proposed rule.

8805250035 880331 PDR PR 50 53FR5985 PDR h

U.S. Nucleer Regulatory Comission B12870/Pagu 2 March 31, 1988 ,

The intent of the proposed revision to Appendix J is to allow use of the mass point method to calculate containment leakage rates. The mass point method is a more accurate means of determining containment leakage rates. The total-time method calculates a series of time weighted leakage rates, based upon differences between an initial' data point and points occurring later in time.

The adequacy of this method is sensitive to the initial data point. Any perturbations, such as fluctuations in containment air temperature, ingassing or outgassing or instrument error, can affect the validity of the initial data point and downstream leakage calculations. The mass point method calculates leakage rates based upon contained air mass. This technique accurately calculates the mass of air inside containment and plots it as a function of time. The slope of the linear least squares fit of the data is the leakage rate. The use of this method is well known and endorsed by the American Nuclear Society (ANS), Electric Power Research Institute (EPRI) and the NRC Staff. The NRC Staff has shown its support of the use of the mass point method as an alternative method of calculating containment leakage rates by granting exemptions to the Haddam Neck Plant, Millstone Unit No. I and Millstone Unit No. 2 (References (2), (3), (4)).

As licensees of the Haddam Neck Plant and Millstone Nuclear Power Station, Unit Nos.1, 2, and 3, CYAPC0 and NNEC0 hereby submit specific coments in response to the proposed rule:

o CYAPC0 and NNECO agree with the proposed change to Appendix J allowing for use of the mass point method during periodic Type A tests, per the provisions of ANS56.8-1987.

l o CYAPC0 and NNEC0 have concluded that mass point tests of durations less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are feasible and justifiable as was demonstrated

at recent reduced duration tests at Millstone Unit Nos. I and 2. In addition, EPRI has advocatea the use of reduced duration testing (References (5) and (6)).

l o CYAPC0 and NNEC0 recomend adopting ANS56.8-1987 using mass point test durations of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in lieu of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> require-ment.

( In sumary, CYAPC0 and NNEC0 support the proposed rule. Use of the mass point method is a more accurate method for calculating containment leakage rates and l has gained the support of the professional comunity. The use of the mass point method represents the best available and proven containment leakage rate calculational and measurement technology.

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U.S. Nuclear Regulatory Comission 812870/Page 3 March 31, 1988 We trust that these coments will be useful in the finalization of the proposed rule.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENEP.GY COMPANY E.' Mroczka g Se or Vice President cc: W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1

0. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 R. L. Ferguson, NRC Project Manager, Millstone Unit No. 3 A. B. Wang, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2 and 3 J. T. Shediosky, Senior Resident Inspector, Haddam Neck Plant Document Control Desk l

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