ML20244E095

Responds to 860708 Request for Interpretation of 10CFR50, App J,Section III.A.3(a),requiring Containment Integrated Leak Rate Tests to Be Conducted Per ANSI N45.4-1972.Mass Point Method May Be Used Only When Exemption Granted

ML20244E095
Person / Time
Issue date:	07/16/1986
From:	Olmstead W NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Arlotto G NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20244D710	List: DD-87-02, Informs That Secy Received Ltr from Professor Z Reytblatt Requesting Review by Commission of Directors Decision DD-87-02.On Advice of Ofc of General Counsel,There Is No Adjudicatory Prohibition in Circulating Professor Ltr ML20244D708 ML20244D778 ML20244E095 ML20244E482 ML20244E507 ML20244E518 ML20244E520 ML20244E526 ML20244E529 ML20244E533 ML20245A325 ML20245A347 ML20245A352 ML20245A357 ML20245A360 ML20245A364 ML20245A369 ML20245A371 ML20245A381 ML20245B280 ML20246M232
References
TAC-52665, NUDOCS 8607240387
Download: ML20244E095 (1)

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G. A. Arlotto Director MEMORANDUM FOR:

Division of Engineering, RES William J. Olmstead FROM:

Assistant General Counsel Rulemaking and Fuel Cycle G

CONTAINMENT INTEGRATED LEAK RAT

SUBJECT:

ted an interpretation of all In your memorandum to me dated July 8, you requesSection 1 which states that

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50,. Appendix J.

Standard (ANSI) N45.4-7972...'.

containment integrated leak rate tests "...sha CFR' Part 10

' mass point" method of test erith the provisions of the American National d section of the regulations.

The speciSc issue presented is whether th to 10 CFR 50.12.

.Our position is that the mass po n to the utility pursuant which allows only ' two grantedspect$cally refers to N45.4-1972i t and total time method is exemption S 56.8 (1981), accepts the Section !!I. A.3(a) methods of test computation, viz., the point-to-p The fact that a revised national standard, ANSI /AN -

cine reference.

mass paint method is of no4elp in the face of this spesent to th f updated national standards The proposed revision to Appendix J, which has been revision of Appendix J is is less prescriptive and would allow the use osuch ble regulatory requirement. Th h

is the applica complete, however, N45.4-1972 tl memorandum from Darrell Eisenhut to James Par ow I

faulty assumption and should not be followed.

III. A.3(a), the staff will i

mo appears to suggest In attempting to justify an exemption from Sect The Partlow memo of February 26 vides more accurate results

(...*the mass point method has merit...').

Econsees" are maing this method.

states that the mass point method " generally pro ea has faDen seriously that the ' total time' method,' and that 'mostIf this i

behind the technology.

William J. Olmstead Assistant Genere. Counsel Rulemaking and Fuel Cycle

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