ML20245A347
| ML20245A347 | |
| Person / Time | |
|---|---|
| Issue date: | 08/22/1986 |
| From: | Ross D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Vollmer R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20244D710 | List:
|
| References | |
| TAC-52665, NUDOCS 8703200148 | |
| Download: ML20245A347 (12) | |
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AUG 2 21985 MEMORANDUM FOP:
R. Vollmer, Deputy Director Office of Nuclear Reactor Regulation FROM:
Denwood F. Ross, Jr., Acting Director Office-of Nuclear Regulatory Research
SUBJECT:
APPENDIX J AND CILRT I believe it useful to summarize the status of Appendix J and CILRT, as of August 86, and to provide some suggestions.
Backcround 1.
The current Appendix J (111.A.3, Test Methods) states that all Type A tests shall be conducted in accordance with ANSI N45.4 (1972).
2._
The ANSI N45.4 standard (para. 7.9) notes that leakage rate calculations can be by either the point-to-point method or total-time method.
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i, The mass point method is not mentioned. However the standard says "the calculations can be either"; it does not say must or shall.
It does say, however:
Leakage rates shall therefore be calculated on at least an hourly basis for 24 consecutive hours (or other agreed-upon period). The leakage determined from these hourly calculations shall be plotted against time, and a statistically averaged hourly leakage rate shall be obtained by e linear least-squares fit to the resulting graph. The 24-h leakage rate shall be equal to 24 times this averaged hourly rate.
It is suggested that the hourly leakage rates be calculated and plotted continuously during the test to disclose any gross variations.
A fair reading of the standard is that the mass point method is not excluded.
3.
The mass point method is widely used; in 1983 (NUREG/CR-3549) about half the utilities used it.
4.
Comparisons of the three methods (see attached Fig. 3.5 from NUREG/CR-3549) shows the technical superiority of mass point.
5.
Appendix J revision started in 1978 per request from NRR. As of Aug.1986, the proposed rule is awaiting Comission decision.
Chairman Zech has approved with comments, and Commissioner Roberts
..has disapproved, although his comments indicate some basis for a
' conditional approval.
(Both vote sheets are enclosed.)
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.6.
The new Appendix J contains general guidance; the specifics are in a regulatory guide, which in turn embraces the new ANSI 56.8 (1981). The
. mass point method.is embrnced (15.7). The new standard is a replacement for N45.4.
7.
The existing Apppendix J definition of leakage rate is:
"D.
' Leakage rate'.for test purposes is that leakage which occurs in a unit of time, stcted as a percentage of weight.of the original content of-containment air at the leakage rate test pressure that escapes,to the outside atmosphere during a 24-hour test period."
This seems as consistent with the mass point method as with the point-to-point or total-time methods.
8.
Impact of containment building leakage on LWR accident risk has been estimated in NUREG/CR-3539 (April 1984) on Fig. 4.1 (enclosed herein).
is a weighted impact consequence factor. Recently Theordinate,hlP,asdoneinadifferent. fashion,anddocumentedin (June 1986) thi w NUREG/CR-4330; see Fig. 2.1 (enclosed).
9.
OGC recently (July 16,1986) stated, in response to a request from G. Arlotto, that the mass point method may be used only when an exemption-l is granted. The OGC memo, the Arlotto memo, and the related Eisenhut and I
Partlow memos are all enclosed. Note from these that NRR believes the mass point method may be used and IE believes most licensees use it.
- 10. Recent regional concern has been expressed as follows:
I Region V (Aug. 5, 1986) a.
Trojan used mass point method, and passed. They also used total time i
and passed, but total-time and UCL did not pass. However R:V does not consider that a problem. They suggest an IN to clarify l
acceptable methods and recognize mass point.
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b.
Region II (July 11,1986)
Region 11 had questions on a recent Oconee CILRT. Their concern had to do with 17.6 of ANSI 45.4, with respect to test period less than i
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. According to the inspection report (p. 3, tb) the mass Plot is used.
(See also p. 7, ((3), where ANSI /ANS 56.8 is cited).
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Reg' ion V (June 12,1986)'
Region V questioned whether it was a successful CILRT if on mass point, leakage including UCL met tech specs, but on using total time (with UCL) it did not.' RES response was the the ILRT was acceptable.
'CopNs of.these regional expressions of concern are enclosed.
Discussion What conclusions can be' drawn from the background? Some are:
The ANSI 45.4 standard does not reference mass point; the N56.8 does; a case could be made that 45.4 does not-prohibit it.
Many plants use mass point; NRR has given guidence to IE that it is acceptable.
Updated technical information and expert opinion indicate that the mass
. point method is technically acceptable.
Confusion exists in the regions.
There is no sa'ety problem. The question is on what legal basis to accept a mass point analysis.
The ongoing Appendix J rulemaking will not provide a short tern remedy.
What recommendations should be made?
'(1) Develop a broader interpretation of existing Appendix J and ANS N45.4-1972.
(2) Since concerns are related to interpretation of ANSI N45.4-1972, submit a request for interpretation from ANS (the originator of the standard) on the acceptability of mass point method.
(3).If (1) or (2) are deemed impractical, draft a minor rulemaking for EDO to
" clarify" existing Appendix J.
(4) Prepare guidance memo for Sniezek (?) to send to regional administrators to use as agency policy, until Appendix J is revised allowing the use of the mass point method.
%4 Denwood F. Ross, Jr., Acting Director cc: J. Sniezek Office of Nuclear Regulatory Research J. Taylor R. Starostecki E. Jordan
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s cc: Stello J.. Burns Roe Cy:- - Kel ber '
. Arndt SH'ec.
J.: Richardson E. Hill M
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SAMUEL J. CHILK, SECRETARY OF THE COMMIS$10N T0:
FROM:
. chairman zech sEcy-se-167 - Issuance or PROPOSED Revision To 10 crR 50, APPENDIX J PLUs RELATED DRAFT REGULATORY GUID
SUBJECT:
MS 021-5 ABSTAlft APPROVED _ " b'/c"St5) DISAPPROVED _
NOT PARTICIPATING REQUEST DISCUSSION See attached ccrvnents.
C0!7;ENTS:
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PLEASE ALSO RESPOND TO PER.
MEMORANDUM IF ONE HAS BE SECRETARIAT NOTE:
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.a Chairman Zech's coraents on SEcY-86-167 i
I believe that any reasonable effort that i
d, cdds assurance that the containment system will function as des In the Backfit Analysis:
l rall plant is capable of providing a substantial increase in the ove l
h advisability of safety.
I would like to specifically solicit coraents on t referenc d of in the text of Appendix J.
llecting data I also would like to request coraents on the value of d for acceptance criteria for.this condition.
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RESPONSE SHEET hrMt,Ms HDenton, ::RP.
JTaylor. IE TRehm SAMUEL J'. CHI.LK, SECRETARY OF THE COMMISSION T0:
FROM:
COMMISSIONER ROBERTS' l
SUBJECT:
.sEcY-ss-167 - sssUAnet or raoPosED nEvzszoN T6 to era 50, APPENDIX J PLUS RELATED DFArT REGULATORY GUIDE MS 021-5
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ABSTAIN' APPROVED DISAPPROVED x
REQUEST DISCUSSION-NOT PARTICIPATING-COMENTS:
See attached conenents.'
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PLEASE ALSO RESPOND TO AND/OR.
MEMORANDUM IF ONE HAS BEEN ISSUED O SECRETARIAT NOTE:
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COMMISSIO.NERROBERTSCOMMENTSONSECY.
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I agree with the staff assessment that this proposed rule cannot be justified on the basis of an increase in the protection of public health and safety, let alone meeting the backfit rule's threshold of a " substantial increase".
In view of the long term efforts underway which may result in major changes to Append.ix J a,d in spite of the benefits n
to be achieved from these proposed changes, I do not believe this rule rises to a level of significance that would warrant exempting it from the requirements of 10 CFR 50.109.
Accordingly, I cannot approve publishing this proposed rule based either on it meeting the backfit rule's requirements or exempting it from the backfit rule.
If this rule does indeed aid the NRC's licensing and enforcement s.taff while at the same time providing greater flexibility and potential cost savings to licensees, then I do believe that there is merit to publishing it for public I also believe that it would be helpful to receive comments on the questions posed in this rulemaking package.
comment.
Therefore, I would agree to publication of this proposed it is noted that it is not rule for comment provided that the {ommission's intent to impose this rule either under the In backfit rule or by exempting it f rom the backfit rule.
this regard, comments should be solicited on whether itn. lieu of the curr i
would be adooted voluntarily
'Fr~ whet'her there are parts of the rule which don't constitute licensees or corn.
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