ML20154H457

Comment Supporting Proposed Rule 10CFR50 Re Alternative Method for Leakage Rate Testing.Suggests That Rulemaking Should Simply Establish Acceptability of Mass Point Method & Allow Analysis of Data to Determine Length of Testing

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)

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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 hour test duration requirement is inappropriate. In our view, the 24 hour 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 l