ML20150E387

Comment Supporting Proposed Rule 10CFR50,App J Re Alternative Method for Leakage Rate Testing.Change Would Remove Util of Burden of Seeking Exemption to App J in Order to Employ More state-of-the-art Statistical Analyses

ML20150E387
Person / Time
Site:	Yankee Rowe
Issue date:	03/23/1988
From:	Denise Edwards YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR5985, RULE-PR-50 53FR5985-00005, 53FR5985-5, FYC-88-004, FYC-88-4, GLA-88-041, GLA-88-41, NUDOCS 8803310201
Download: ML20150E387 (1)

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BP4hCH Secretary United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Docl.eting and Service Branch

Subject:

Comments pertaining to Proposed Rule (10 CFR 50, Appendix J),

"Alternative Method for Leakage Rate Testing" (53 FR 5985)

Dear Sir:

Yankee Atomic Electric Company (YAEC) appreciates this opportunity to comment on the proposed rule regarding 10CFR50, Appendix J. YAEC owns and operates the Yankee Nuclear Power Plant in Rowe, Massachusetts. Our Nuclear Services Division also provides engineering and licensing services for other nuclear power plants in the Northeast, including Voro.ont Yankee, Maine Yankee and New Hampshire Yankee (Seabrook).

Incorporation of the mass point method into Appendix J as an acceptable method of calculating containment leakage rates is definitely an improvement. We have used this method and believe it is better than others. The proposed change relieves us and other utilities of the burden of seeking an exemption to Appendix J in order to employ this more state-of-the-art statistical data analysis technique. We fully endorse and support this change.

A compliment to this proposed change to Appendix J, which would greatly im-prove its consistency, is replacement of the outdated reference to ANSI-N45.4-1972 "Leakago Rate Testing of Contain=ent Structures for Nuclear Reactors", with a reference to MSI-N56. 8- 1981 "Containment System Leakage Testing Requiremen*,s" (revised 1987). The current standard incorporates the mass point method, ahereas the obsolete standard refers to earlier techniques.

Since NRC was a major participant in the consensus committee that developed and more recently revised this standard it would seem reasonable that NRC regulations should accurately reflect the appropriate current standard.

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Very truly yours,

' Donald W. Edwards i

Director, Industry Affairs

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