ML20154H457
| ML20154H457 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/30/1988 |
| From: | Snow B ROCHESTER GAS & ELECTRIC CORP. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR5985, RULE-PR-50 53FR5985-00014, 53FR5985-14, NUDOCS 8805250339 | |
| Download: ML20154H457 (1) | |
Text
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ROCHESTER GAS AND ELECTRIC CORPORATION e 89 EAST AVENUE. F.OChESTER. N Y. 14649 0001 18 APR -4 P6 30 March 30, 1988
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1 SRANCW Secretary, U.S. Nuclear Regulatory Commission i
Washington, DC 20555 Attention: Docketing and Service Branch
Subject:
Alternative Method for Leakage Rate Testing Federal Register Vol. 53 No. 39 Monday, February 29, 1988 Proposed Rules Page 5985
Dear Mr. Secretary:
The following is presented in response to your request for comments in the subject article of the Federal Register.
It is the view of the technical staff in our utility that the mass point method of evaluating test data provides an important and improved tool for use in conducting leakage rate testing of the Ginna containment.
It is also our view, however, that linking the mass point method with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test duration requirement is inappropriate.
In our
- view, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> requirement is unnecessarily restrictive in that. leakage rate can generally be established with proper confidence in a shorter period of time.
In lieu of the length of test requirement we suggest that the rulemaking should simply establish the acceptability of the mass point method and allow the analysis of data to determine the length of testing.
Very truly yours, ARM-Bruce A. Snow gg525033988033o 50 53FR5985 PDR 05/0
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