ML20151A888
| ML20151A888 | |
| 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 53FR5985-00009, 53FR5985-9, B12870, NUDOCS 8804070291 | |
| Download: ML20151A888 (3) | |
Text
0 ll 00CETNUMBER g,_g h PROPOSED RULE NORTHEAST UTILITIES
( 53 F4 6 N b. m. sig em IEntYEconect osm.oato L
a 50%000%~
m **oco.38 APR -) A9 :10 March 31, 1988
[0ckNGIildvYCE BRAHCW Dockat Nos.
C-7 0-d :
,1 f, W Re:
S. J. Chilk Secretary of the Comission U.S. Nuclear Regulatory Comission 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 Appendi-J to 10CFR50, Paragraph
!!!.A.3, dated October 15, 19b..
(3)
M. L. Boyle letter to E. J. Mroczka, Exemption From the Requirements of Ap>endix J to 10CFR50, Paragraph III.A.3, dated October 15 ;,987.
(4)
D. H. Jaffe letter to E. J. Mroczka, Exemption From the Requirements of Ap>endix J to 10CFR50, Paragraph !!!.A.3, dated February 3. :,988.
(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 Contain-J ments,' December 1983.
1,..
ee
- 5., 7 M
Centlemen:
Haddam Neck Plant
'{
Millstone Nuclear Power Station, Unit Nos."1. 2 and 3 J
Coments on Proposed Rule
&l.tgrnative Method for leakaos Rate Testina On February 29,1988 (Reference 1), the NucleaF Regul'atory Commission :(NRC) published a proposed rule amending its regulations applicable to the leakage i
testing of containments to permit the use of the mass point method As.,aD alternative method for calculating containment leakage rates.
Connecticut Yankee Atomic Power Company (CYAPC0) and Northeast Nuclear Energy Company (NNECO) respectfully submit the following coments in. support of the proposed rule.
y, y
weed by CS3 APR.1.,1388,
~
Ma
/h
^
i W"""""'
g40g291 880331 50 5 3FRt995 PDR..
4 U.S. Nuclear Regulatory Commission 812870/Page !
March 31, 1988 The intent of the >ro>osed 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 can affect the validity of the initial data or outgassing or instrument error, lations.
The mass point method calculates point and downstream leakage calcu 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 ANS), Electric Power Research Institute (EPRI) and the NRC Nuclear Society (Staff has shown its sup> ort of the use of the mass point Staff.
The NRC l
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, t, and 3, CYAPC0 and NNECO hereby submit specific consents in l
response to the proposed rule:
CYAPC0 and NNECO agree with the proposed change to Appendix J o
allowing for use of the mass point method during periodic Type A tests, per the provisions of ANS56.8 1987, CYAPC0 and NNECO have concluded that mass point tests of durations o
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. 1 and 2.
In addition, EPRI has advocated the use of reduced duration testing l
(References (5) and (6)).
i l
o CYAPC0 and NNECO recommend adopting ANS56.81987 using mass point l
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-cent.
In sunnary, CYAPCO and NNEC0 support the proposed rule. Use of the mass point method is a more accurate method for calculating containment leakage rates and has gained the support of the professional connunity.
The use of the mass point method represents the best available and proven containment leakage rate calculational and measurement technology.
l I
llt l
I O
t i
U.S. Nuclear Regulatory Consission 812870/Page 3 March 31, 1988 l
We trust that these consents will be useful in the finalization of the proposed rule.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY f1 E.' V MrottKa /J Senior Vice Pfeeldent cc:
W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 D. 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. I and 3 Senior Resident Inspector, Haddam Neck Plant J.T.ShedioskylDesk Document Contro p
6 i
l I
I I I