ML20213A442

Forwards Request for Exemption from 10CFR50,App J,Paragraph III.A.3, Test Methods, Requiring Type a Tests (Containment Integrated Leak Rate Test) Be Conducted Per ANSI 45.4-1972. Mass Point Method for Leakage Calculation Utilized.Fee Paid

ML20213A442
Person / Time
Site:	Yankee Rowe
Issue date:	04/17/1987
From:	Papanic G YANKEE ATOMIC ELECTRIC CO.
To:	Mckenna E NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
References
FYR-87-41, NUDOCS 8704280013
Download: ML20213A442 (3)

Text

Telephone (617) 872-8100

= TWX 710 380L7619 YANKEE ATOMIC ELECTRIC COMPANY 1671 Worcester Road, Framingham, Massachusetts 01701

. YANKEE

• April 17, 1987 FYR 87-41 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Attention: Eileen M. McKenna, Project Manager Project Directorate #1 Division of PWR Licensing - A

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) Yankee Letter of USNRC, dated December 29, 1965 (c) Yankee Letter to USNRC, dated June 4, 1975

Subject:

Request For Exemption to 10CFR50 Appendix J

Dear Ms. McKenna:

Pursuant to 10CFR50.12, Yankee Atomic Electric Com,m.y hereby requests an exemption from the requirement of 10CFR50 Appendix J Paragraph III.

A. 3, Test Methods, which requires that Type A Tests (Containment Integrated Leak Rate Test) be conducted in accordance with ANSI 45.4-1972. ANSI N45 4-1972 requires that leakage calculations be performed using either Point-to-Point or Total Time Method.

Yankee has utilized the Mass Point Method for leakage calculations since its initial operational test in 1965, Reference (b). Subsequent to the issuance of 10CFR50 Appendix J, Yankee identified in Reference (c), that it had been assured (by the NRC Staff) that its test methods are in accordance with the intent of ANSI-N45 4-1972 and that no exemption would be required.

This understanding was reinforced by the 1976 USNRC staff position which endorsed the use of the Mass Point Method, the modification of ANSI-N45.4 in 1931 which specifies the use of the Mass Pvint Lethod and the most recent draft revision to Appendix J which incorporates the revised version of ANSI-N45 4.

Notwithstanding the above, Yankee was notified by the USNRC in April 1987, that the use of the Mass Point Method for containment leakage calcuations is not consistent with the requirements of 10CFR50 Appendix J, Paragaraph III.A.3 Attached is Yankee's request for an exemption from this restlatory requirement. We request a timely review of this application as our next Type A test is scheduled for May 1987 Additionally, Yankee will be submitting a proposed change to Yankee Nuclear Power Station's Technical Specification to make it consistent with this exemption request.

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a US Nuclear Regulatory Commission April 17, 1987 888 FYR 87-41 Fee An application fee of $150.00 is enclosed in accordance with 10CFR170.21.

Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY G. Pap ic, Jr.

Senior Project Engineer Licensing

. ATTACHMENT BACKCROUND Yankee Atomic Electric Company performed its first containment leak rate test in August, 1965, using what is now known as the Mass Point Method of analysis.

This method was discussed and compared with the methods presented in the then draft ANS 7.6 " Proposed Standard for Leakage Rate Testing of Containment Structures for Nuclear Reactors", June 15, 1964, in the test report YAEC-1009, submitted to the Commission on December 29, 1965 All subsequent containment integrated leakage tests have been analyzed and reported using the Mass-Point Method.

On August 27, 1971, the AEC published a proposed version of Appendix J to 10CFR50 which specified the minimum containment leakage test requirements for water-cooled power reactors and referenced the proposed standard, ANS 7.6. On February 14, 1973, the Final Rule was published that referenced ANSI N45.4-1972 " Leakage Rate Testing of Containment Structures for Nuclear Reactors", dated March 16, 1972. Section 7.9 of that standard allogad cither the Point-to-Point er Total Time Method of data analysis and made no reference to the Mass Point Method of data analysis.

Our concern over compliance with Appendix J is documented beginning with the submittal of Proposed Change 112, dated January 3,1974, requesting certain exemptions from Appendix J. At that time, it was not clear to us that our method of data analysis was in agreement with all the provisions of ANSI N45.4-1972, and hence, Appendix J. As was pointed out in our subsequent letter of June 4,1975, we were assured by the Commission that our test methods were in accordance with the intent of ANSI N45.4-1972, and no exemption from the provisions of Appendix J were required.

A revision to the testing standard, now designated as ANSI /ANS 56.8-1981, "Contain-ment System Leakage Testing" was published in the Spring of 1981, which incorporated the Mass-Point Method of data analysis to the exclusion of the two previous methods.

This standard is about to be revised and published as ANSI /ANS 56.8-1987, still incorporating the Mass-Point Method of data analysis.

In April, 1987, Yankee Atomic Electric Company was notified by the USNRC that the previous staff position that allowed (and encouraged) the Mass-Point Method of data analysis was not consistent with the regulatory requirements of 10CFR50 Appendix J, Paragraph III.A.3 Pending revision to the regulation, licensees who wish to continue the use of the Mass-Point Method of analysis must request an exemption from the Appendix J requirement to conform to ANSI N45.4-1972.

JUSTir'ICATION:

Yankee Atomic Electric Company believes that this exemption should be granced pursuant to 10CFR50.12(a) (2) (ii) in that application of the regulation in the particular instance is not necessary to achieve the underlying purpose of the rule, which is to provide an accurate and conservative measurement of the containment integrated leakage rate. The need for this exemption is predicated on the determination that, although the technical adequacy of the Mass-Point Method of analysis, as used by Yankee Atomic Electric Company, is not in question, its use is not consistant with the requirements of 10CFR50, Appendix J and its reference to ANSI N45.4-1972.

This exemption will enable Yankee Atomic Electric Company to continue to report its test results for Integrated Containment Leakage Tests (ILRT) in the same manner as it has for the last 22 years.

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