ML18053A566
| ML18053A566 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/09/1988 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8809160170 | |
| Download: ML18053A566 (3) | |
Text
consumers Power POWERING MICHlliAN'S PIUlliRES5 General Offices: 1946 West Pernell Road *. J~ckson, Ml 49201 * (617) 788-1636 September 9, 1988 Nuclear Regulatory Commission Document Control Desk Washington~ DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
REQUEST FOR EXEMPTION FROM 10 CFR 50 APPENDIX J III.A.3 -
CONTAINMENT LEAKAGE RATE DATA ANALYSIS Kenneth W Berry Director Nuclear Licensing 10 CFR 50 Appendix J III.A. 3 requires; "All Type A tests shall be* conducted in accordance with the provisions of the American National Standard N45.4-1972, Leakage Rate Testing of Containment Structures for Nuclear Reactors, March 16, 1972." These methods are generally described as the "Total Time" or "Point to Point" methods.
A third method, the "Mass Point" method for determining containment leakage rates is described in ANSI/ANS-56.8-1987 (Containment System Leakage Testing Requirements) and is an improved methodology for data analysis over the Point to Point and Total Time methods.
Because the Mass
~Point method presents an improved methodology for the analysis of containment leakage test data, we have decided to use this methodology to determine the total containment leakage rate at our Palisades Plant.
However, since the "Mass Point" method is not specifically approved by the requirements of Appendix J, an exemption to the requirements of 10 CFR 50 Appendix J III.A.3 is required.
Therefore, a request for exemption, in accordance with the requirements of 10 CFR 50.12, is provided in Attachment 1.
Our current plans indicate that we will begin the ILRT starting approximately 11/1/88.
In order to maintain this schedule we request that this exemption be approved, or*that that we receive an indication that approval will be forthcoming as early as possible.
A check in the amount of $150.00 (approval fee) is enclosed in accordance with 10 CFR 50 170.12(c).
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, ~RC NRC Resident Inspector - Palisades Attachment OC0888-0016S-NLO1
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ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 REQUEST FOR EXEMPTION FROM 10CFR50 APPENDIX J III.A.3 CONTAINMENT LEAKAGE RATE DATA ANALYSIS September 9, 1988 1 Page OC0888-0016S-NL01
- ~*
PALISADES PLANT EXEMPTION REQUEST CONTAINMENT LEAKAGE RATE DATA ANALYSIS Section III.A. 3 of Appendix J to 10 CFR 50 requires that; "All Type A tests
.shall be conducted in accordance with the provisions of the American National Standard N45.4-1972, Leakage Rate Testing of Containment Structures for Nuclear Reactors." These methods are generally know as the "Total Time" and the "Point to Point" methods.
However, for the following reasons, Consumers Power Company has determined that the use of a third method, the "Mass Point" method is equivalent or superior, and therefore is an acceptable alternative, to the methods approved by 10 CFR 50 Appendix J for determining the total containment leakage rate.
- 1.
The Mass Point method has been incorporated into the latest revision of ANSI/ANS-56.8-1987 ("Containment System Leakage Testing Requirements") and is an improved methodology for data analysis over the Point to Point and Total Time methods of data analysis.
- 2.
A proposed rule issued February 29, 1988 (53 FR 5985) includes the Mass Point method as an acceptable alternative to the Total Time and Point-to-Point methods for Type A containment tests.
As noted in the background statements for the proposed rule, the Mass Point method has in fact been accepted by the NRC staff as an improved alternative to the Total Time and* Point to Point methods for calculating containment leakage rates.
- 3.
The acceptance criteria for the ILRT as described in 10 CFR 50 Appendix J and the Palisades Technical Specification 4.5.1.b.3 are not affected by the use of the Mass Point technique.
Based on the information presented.above, Consumers Power Company requests an exemption from the requirements of 10 CFR 50 Appendix J. III.A.3.
This exemption requests satisfies the provision of 10 CFR 50.12(a)(ii) in that we have shown that the Mass Point method of data analysis is equivalent or superior to the currently approved methods of data analysis for containment leakage rate testing and fulfills the underlying purpose and intent of 10 CFR 50 Appendix J III.A.3.
OC0888-0016S-NL01