ML23151A464

PR-050 - 53FR05985 - Alternative Method for Leakage Rate Testing

ML23151A464
Person / Time
Issue date:	02/29/1988
From:	NRC/SECY
To:
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PR-050, 53FR05985
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ADAMS Template: SECY-067 02/29/1988 PR-050 - 53FR05985 - ALTERNATIVE METHOD FOR LEAKAGE RATE TESTING PR-050 53FR05985 RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

PAGE 1 OF 2 STATUS OF RULEMAKING RECORD 1 OF PROPOSED RULE:

PR-050 RULE NAME:

ALTERNATIVE METHOD FOR LEAKAGE RATE TESTING PROPOSED RULE FED REG CITE:

53FR05985 PROPOSED RULE PUBLICATION DATE:

02/29/88 ORIGINAL DATE FOR COMMENTS: 03/30/88 NUMBER OF COMMENTS:

EXTENSION DATE:

I I

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FINAL RULE FED. REG. CITE: 53FR45890 FINAL RULE PUBLICATION DATE: 11/15/88 NOTES ON: EDO SIGNED FINAL RULE ON 11/1/88. FINAL RULE PUBLISHED AT 53 FR 45 TATUS 890. EFFECTIVE 11/15/88.

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DOCKET NO. PR-050 (53FR05985}

DATE DOCKETED 03/14 88 03/21/88 DATE OF DOCUMENT 03/10/88 03/15/88 In the Matter of ALTERNATIVE METHOD FOR LEAKAGE RATE TESTING TITLE OR DESCRIPTION OF DOCUMENT COMMENT OF STONE & WEBSTER (R. B. BRADBURY} (

COMMENT OF OCRE, INC. (SUSAN L. HIATT} (

2}

03/22/88 02/17/88 FEDERAL REGISTER NOTICE - PROPOSED RULE 03/25/88 03/23/88 COMMENT OF PUBLIC SERVICE OF NEW HAMPSHIRE (J. W. CONNELLY} (

3}

03/28/88 03/25/88 COMMENT OF FLORIDA POWER & LIGHT COMPANY (W. F. CONWAY} (

4}

03/29/88 03/23/88 COMMENT OF YANKEE ATOMIC ELECTRIC COMPANY 03/29/88 03/30/88 03/31/88 03/31/88 04/01/88 03/18/88 03/22/88 03/29/88 03/29/88 03/31/88 (DONALD W. EDWARDS} (

5)

COMMENT OF WISCONSIN ELECTRIC POWER COMPANY (C. W. FAY} (

6}

COMMENT OF DUKE POWER COMPANY (HAL B. TUCKER} (

COMMENT OF PUBLIC SERVICE OF NEW HAMPSHIRE (GEORGES. THOMAS, V.P.} (

8}

COMMENT OF WISCONSIN PUBLIC SERVICE CORP.

(D. C. HINTZ, V.P. - NUCLEAR POWER} (

10}

COMMENT OF NORTHEAST UTILITIES (CYAPCO & NNECO}

(E. J. MROCZKA} (

9}

l}

7}

04/01/88 04/04/88 04/04/88 03/29/88 COMMENT OF COMMONWEALTH EDISON (W. E. MORGAN} (

11}

03/30/88 COMMENT OF FOUR UTILITIES (NICHOLAS S. REYNOLDS} (

12}

03/29/88 COMMENT OF WASHINGTON PUBLIC POWER SYSTEM SYSTEM (G. C. SORENSEN} (

13}

04/04/88 03/30/88 COMMENT OF ROCHESTER GAS & ELECTRIC CORPORATION (BRUCE A. SNOW} (

14}

DOCKET NO. PR-050 (53FR05985)

DATE DOCKETED 04/04/88 04/04/88 04/06/88 04/11/88 04/15/88 05/06/88 05/26/88 DATE OF TITLE OR DOCUMENT DESCRIPTION OF DOCUMENT 03/31/88 COMMENT OF ALABAMA POWER COMPANY (R. P. MCDONALD) (

03/30/88 COMMENT OF GEORGIA POWER COMPANY ( L. T. GUCWA) (

16) 04/01/88 COMMENT OF NEW YORK POWER AUTHORITY (JOHN C. BRONS) (

04/05/88 COMMENT OF NIAGARA MOHAWK POWER CORPORATION (C. V. MANGAN, SR. V.P.) (

19) 04/07/88 COMMENT OF NORTHERN STATES POWER COMPANY (DAVID MUSOLF) (

20) 05/02/88 COMMENT OF PHILDELPHIA ELECTRIC COMPANY (S. J. KOWALSKI, V.P.) (

21) 04/04/88 COMMENT OF TENNESSEE VALLEY AUTHORITY (R. GRIDLEY) (

15)

17)

18)

11/15/88 11/15/88 FEDERAL REGISTER NOTICE - FINAL RULE

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l.5'-:J F-(l.,S'i PHILADELPHIA ELECTRIC COMPANY ENGINEERING AND RESEARCH DEPARTMENT 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA. 19101 (215) 841 -4000 Mr. Sarruel J. Chilk Secretary of the Comnission MAY 2 1988 U.S. Nuclear Regulatory Cannlssion Washington, D.C.

20555 Attention:

Docketing and Service Branch

REFERENCE:

FILE:

Dear Mr. Chilk:

Proposed Rule:

Alternative Method for Leakage Rate Testing Letter, N. S. Reynolds to S. J. Chilk, dated 3/30/88 Same Subject Equip 3-1-6 (Leak Testing)

Notice of a proposed rule allowing use of the Mass Point method of leakage rate testing appeared in the Federal Register on February 29, 1988.

Philadelphia Electric Company endorses the cannents on this proposed rule made by NUBARG in the referenced letter (attached).

A verification of Type A test results using Mass Point methodology over an 8-hour test duration has been included in the Limerick Unit 1 Technical Specifications since its licensing in 1984. This methodology, in conjunction with an 8-hour test, has been employed at Peach Bottom since ANS/ANSI 56.8 was promulgated in 1981.

By requiring a 24-hour test, the NRC would be imposing a backfit that would extend the critical path outage time consUT1ed by this test by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.

Since the proposed rule imposes a new requirement and would have an adverse financial impact upon the utilities, the 24-hour Type A test duration should be subjected to a complete backfit analysis in accordance with 10CFR50.109 prior to promulgation.

In place of this, we agree with NUBARG in urging that the lesser test duration specified in ANSI/ANS-56.8-1981 be adopted into 10CFR50 Appendix J.

Attachment ACC/vvg/04078803 Yours v A

Vice President Nuclear Engineering Acknowledg!O t,y efJftl MAY 2 6 1988

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• U. 5. NUCLE.A.R REGULA lORY COMMISSION DOCKETING t.. SERVICE SECTION OFFICE OF THE SECRE-T ARY OF THE COMMISSION l:locumQnl StotiJI ict s_/3/_'f+/-',_

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BISHOP, COOK. PURCELL & REYNOLDS 1400 L STREET. N.W.

WASHINGTO N. O.C. 20005-3502 (202) 371-5700 March JO, 1988 Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Docketing and Service Branch Re:

Proposed Rule: Alternative Method For Leakage Rate Testing (5 3 Fed. Reg.

5985 (February 29, 1988))

Dear Mr. Chilk:

-:"ELD<, 4A0!'7* INTI.AW UI TE:L£C0P1£R, (2021 371*!!9!!0 The following comments on the above-referenced proposed rule are submitted on behalf of Arkansas Power & Light Company, consolidated Edison Company of New York, Inc., Southern California Edison Company, and TU Electric.

The proposed rule would amend 10 C.F.R. P~rt 50, Appendix J by expressly allowing the use of the Mass-Point technique for analyzing integr&ted leak rate test data.

We support the proposed rule insofar as it endorses the Mass-Point anal ysis technique, but believe additional f lexibility, consistent with current standards, should be provided for the apprcpriate test duration.

The NRC currently interprets the integrated leak rate testing requirements of Appendix J as author:z ing the use of onl y the t wo data analysis technique s reflected in ANSI-N45.4-1972, " Leakage Rate Testing of Containment Structures for Nuclear Reactors."

That 1972 standard reflects the two techniques in use at that time, namely, the Point-to-Point and Total Time techniques.

As the proposed rule recognizes, the Mass -Point analysis technique is o f comparatively recent development 3nd has been accepted by ind~3try and t he NRC as the pr~ferred data analysis technique in use at this time.

53 Fed.

Reg. at ~985.

In fact, beginning in 1981, the more recent versions of the ANSI standard expressly adopt the Mass-Point

~echnique.

See ANS I/~~S-56.8-1987.

Many licensees have been

~ermi tted to us~ t j i s techniqu~ f or analyz ing int egrated leak ra~e testing data.

. / '

I

/

Samuel J.

March 30, Page 2 Chilk 1988 Therefore, the proposed rule is a needed and appropriate update in the Appendix J provisions for acceptable data analysis techniques.

We support this endorsement of the Mass-Point method.

The proposed rule, however, would mandate a 24-hour test duration for the Mass-Point technique.

We do not believe that there is an adequate technical basis for the 24-hour test duration period.

ANSI/ANS-56.8-1987 (at 15.4), which endorses the Mass-Point technique, specifies a minimum test duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, demonstrating that the Mass-Point technique is considered to provide accurate and reliable results for test durations of considerably less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

As the EPRI report entitl~d "Containment Integrated Leak-Rate Testing Improvements," dated November 1982 (at 3-32), found, "[t]here is no engineering or sci£.ntific reason for a minimum leak test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Unless the NRC provides an adequate technical justification for the 24-hour test duration provision,1/

we believe it would be arbitrary for the NRC to ignore the explicit co clus:on5 of the technical organizations that have addressed this issue.

In addition, because the NRC has previously accepted the use of the Mass-Point technique for tests of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for some licensees, the proposed 24-hour test duration would represent a backfit for these licensees.

10 C.F.R. §50.109.

in conclusion, while we support the NRC's recognition of the Mass-Point technique, we urge the NRC to adopt the added flexibility of ANSI/ANS-56.8 in the acceptable test duration.

As indicated by ANSI/ANS-56.8, a lesser test duration is technically acceptable, and can result in the reduction of necessary outage time for integrated leak rate tests.

1/

Respec,fu I

The Staff does not attempt to provide a =echnical ba sis for the 24-hour test duration provision, but simply notes that this requirement would reflect prior exemptions for certain licensees.

f)OCKET NUMBER PR - 5 0 bff PRO~~~R~~~:;s-J@

Northern States Power, 'Cbmpany 414 Nicollet Mall pl.. 25 Minneapolis, Minn1J8ta !f\Pft1 15 Telephone (612) 3.30-5500 April 7, 1988 Secretary Attn:

Docketing and Service Section US Nuclear Regulatory Commission Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263 LICENSE NO. DPR-22 PRAIRIE ISLAND NUCLEAR GENERATING PLANT DOCKET NOS. 50-282 LICENSE NOS. DPR-42 50-306 DPR-60 Comments on Proposed Change to 10 CFR Part 50, Appendix J Alternative Method for Leakage Rate Testing The purpose of this letter is to provide comments related to a proposed change to 10 CFR Part 50, Appendix J, "Alternative Method for Leakage Rate Testing," published in the Federal Register on February 29, 1988.

Northern States Power Company generally agrees with the proposed change and believes it will be beneficial.

We have one comment to offer related to the specification of a 24-hour test duration when using the Mass Point Method.

Suggested Change Change the wording proposed for Section III.A.3 to read, 11

' *** the Mass Point method is an acceptable method to use to calculate leakage rates.

With any test method, test duration shall be at l east 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless a shorter duration has been approved by the Commission.... "

Reason for Change Specifying a 24-hour minimum test period in the Regulations removes the flexibility for a licensee to perform shorter dura-tion tests in those cases where it can be demonstrated to the satisfaction of the NRG Staff that shorter tests are valid.

MAY 2 6 1988 Acknowledged by card ********.-...............

,. *. MJ,.1.:.,. r. KrGUIA:ORY COMMI SSIQt-,

OOCKETiNG & SERVICE SCCTION OHiC!: OF THE SECRET ARY Of iHE COMMISSION Ct<v.,MI Statisli:s

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Secretary of the Commission April 7, 1988 Page 2 Northern States Power Company Type A containment leakage tests are usually on the critical path of a refueling outage.

If a valid test can be performed in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the savings in outage time to a licensee can be equivalent to several hundred thousand dollars.

In the past, short duration tests have been approved by the NRG Staff on a case-by-case basis for plants using the methodology of Bechtel Corporation Topical Report BN-TOP-1.

In particular, containment designs which are insulated from possible diurnal effects can often be tested in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a high degree of statistical confidence that the measured leakage is well below the Technical Specification limit.

The Mass Point method of computing leakage is, in many ways, superior to methods described in ANSI N45.4-1972.

The 1972 standard permits short duration tests upon approval by the Commission of the test procedure.

Limiting use of the Mass Point method to tests of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more would have the effect of imposing an unnecessary and costly restriction on a licensee wishing to use a superior method of calculating leakage.

Thank you for the opportunity to comment on the proposed change to the Commission's Regulation.

0~~~-~

David Musolf

\

Manager Nuclear Support Services c:

Regional Administrator, Region III, NRG NRG SR Resident Inspectors NRG Project Managers G Charnoff

N T NIAGARA UMOHAWK DOCKET NUMBER PR-r (l'I)

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NIAGARA MOHAWK POWER CORPORATION/ 301 PLAINFIELD ROAD, SYRACUSE, N y:J1:1J'¥Et TELEPHONE (315) 474-1511 April 5, 1988 NMPlL 0242 Secretary, U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:

Docketing and Service Branch Gentlemen:

Re:

Nine Mile Point Unit Docket No. 50-220 DPR-63

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BRANCi.;

Niagara Mohawk offers the following comment on the proposed rule published in the February 29, 1988 Federal Register (53FEDREG 5985).

The proposed rule concerns containment testing.

Niagara Mohawk concurs with the proposed wording to permit the use of the Mass Point method to calculate leakage rates.

However, we do not think it is necessary to couple the use of the Mass Point method with a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test duration.

After the containment test conditions have stabilized, sufficient data can be recorded in approximately six hours to provide a calculation of containment leakage within the upper 95% confidence limit.

This is similar to the Duration Criteria in Section 2.3 of the Bechtel Topical Report BN-TOP-1, Revision 1, November 1, 1972.

We believe the test duration should be based on statistical analysis and not solely on elapsed time.

Very truly yours, NIAGARA MOHAWK POWER CORPORATION c~

Senior Vice President CVM: svm 4726G cc:

Regional Administrator, Region I Mr. R. A. Capra, Director Mr. R. A. Benedict, Project Manager Mr. W. A. Cook, Resident Inspector MAY 2 6 i988 Acknowledged by card............... __

.J. ~. N\}CH:AR R(GUL~IC~'t COMMISSION OOCKHING I. SU~VICf SKT¥00 flCf OF THE SKlH Alt rnE COMM!SStON O:,cu-r,.Cffl S,t..,iti.t ia

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TENNESSEE VALLEY Alh-{l~'+ oqgs-J CHATTANOOGA, TENNESSEE 37401 SN 157B Lookout Pl ace APR 04 1988

• aa HAY 26 P 2 :38 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

NUCLEAR REGULATORY COMMISSION {NRC) - PROPOSED RULE - 10 CFR 50, APPENDIX J, ALTERNATIVE METHOD FOR LEAKAGE RATE TESTING The Tennessee Valley Authority {TVA) has reviewed and is pleased to provide comments on the proposed rule noticed in the February 29, 1988 Federal Register

{53FR 5985-5986) regarding the addition of the Mass Point method as an acceptable method of calculating containment leakage rates.

We support this proposed amendment to 10 CFR 50, Appendix J, Section III A.3.

TVA has successfully used this method in addition to the required methods since June 1978.

An analysis of our test data clearly indicates that accurate results can be obtained using the Mass Point method for test durations significantly less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Our data, which i s available for review, supports a test duration of eight hours.

Therefore, we recommend that Appendix J be modified to allow a test duration minimum of eight hours when utilizing the Mass Point method.

This could have substantial benefits to critical path outage time without any loss in accuracy of predicting containment leak rate.

We apprec iate the opportunity to comment.

cc:

See page 2 Very truly yours, TENNESSEE VALLEY AUTHORITY R'!~~tor+

Nuclear Licensing and Regulatory Affairs 8804070070 880404 PDR TOPRP EUTTVA An Equal Opportunity Employer

, U.S. Nuclear Regulatory Commission cc:

Mr. E. Gunter Arndt Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NH. Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Di vision U.S. Nuclear Regulatory Commission One White Flint, North 11 555 Rockville Pike Rockville, Maryland 20852 Bellefonte Resident Inspector Bellefonte Nuclear Plant P.O. Box 2000 Hollywood, Alabama 35752 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens. Alabama 35611 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 Watts Bar Resident Inspector Watts Bar Nuclear Plant P.O. Box 700 Spring City, Tennessee 37381 APR 041988

11. S. NUCLEAR REGULATORY COMMISS I DOCKETING & SERVICE SECTION OFFICE OF THE SECRET ARY OF THE COMMISSION Document Stetistics

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8 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:

Docketing and Services Branch

Subject:

James A. FitzPatri ck Nuclea r Power Plant Docket No. 50-333 Indian Point 3 Nuclear Power Plant Docket No. 50-286 Alternative Method for Leakage Rate Testing

Reference:

NRC Noti ce of Proposed Rule, 53 FR 5985, dated February 29, 1988.

Dear Sir:

Nuclear Generation The New York Power Authority has reviewed and evaluated the proposed amendment to 10 CFR 50, Appendix J concerning an alternative method for leakage rate testing of primary containment structures (Reference 1).

The Authority endorses the Mass Point method and its inclusion into the acceptance criteria for the Type "A" Primary Containment Integrated Leakage Rate Test (PCILRT).

This method accurately calculates the containment leakage rate with less statistical uncertainty than does the Total Time method with the generally used uncertainty analysis.

The Technical Specifications for the Authority's FitzPatrick plant require a Mass Point analysis, while Appendix J requires t h e Total Time method.

Theref ore, the Authority performed both Mass Point and Total Time analyses for the 1987 FitzPatrick PCILRT.

This allows a comparison of the two techniques using identical containment conditions.

Measured leakage rates using the two methods were consistant and differed by only 5%.

However, the reported leak rates (based on the Bechtel BN-TOP-1 method for calculating the 95% upper confidence level) show the Total Time results to be 40% greater than the Mass Point result. This comparison demonstrates that both methods produce consistent containment leakage measurements and that the Total Time statistical analysis is inherently overconservative.

This conservatism may necessitate a long duration (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) test to allow the Total Time upper confidence level (UCL) to meet the leakage rate acceptance criteria.

MAY 2 6 19 Acknowledged by card..*********** ~!.__

.....), NUUtA ;_

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The rapid convergence of the Mass Point 95% UCL to the measured leakage rate results in a more accurate reported leakage rate.

It also allows a shorter duration test without a significant change in the reported results.

This is especially true when test data is collected more frequently than once/hour.

The FitzPatrick Mass Point results met the leakage rate acceptance criteria (including UCL) in approximately 2 1/2 hours and fully stabilized within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> using data collected every 20 minutes.

The Commission should allow a minimum test duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when using a Mass Point analysis in accordance with the provisions of ANSI/ANS 56.8-1987.

Should you or your staff have any questions regarding this matter, please contact Mr. J. A. Gray, Jr. of my staff.

cc:

Very truly yours,

~

ohn C. Brans Executive Vice president Nuclear Generation U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Office of the Resident Inspector u.s. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Resident Inspector's Office Indian Point Unit 3 U. s. Nuclear Regulatory Commission P. o. Box 337 Buchanan, NY 10511 Mr. Harvey Abelson Project Directorate I-1 Division of Reactor Projects - I/II U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Joseph D. Neighbors, Sr. Project Manager Project Directorate I-1 Division of Reactor Projects I/II U. s. Nuclear Regulatory Commission Mail Stop 14B2 Washington, D. C.

20555

Georgia Power Company 333 Piedmont Avenue Atlanta, Georgia 30308 Telephone 404 526-6526 DOCKET NUMBER n

PROPOSED RULE PR -!J7J -. l/.!fY (53 ~/2. 5CJJl'S) ooc*K*~--~

Mailing Address:

Post Office Box 4545 Atlanta, Georgia 30302 L. T. Gucwa Manager Nuclear Safety and Licensing March 30, 1988 Secretary U. S. Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, D. C.

20555 l Il l.'

USNRC

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SL-4430 0917U X7GJ17-C220 COMMENTS ON PROPOSED REVISION TO 10 CFR 50 APPENDIX J Gentlemen :

Georgi a Power Company (GPC) appreciates the opportunity to comment on the proposed rule for containment leakage testing, "Alternative Method for Leakage Rate Testing" (53FR7534).

GPC holds NRC operating licenses for Plant Hatch Units l and 2, located in Appling County, Georgia, and for Plant Vogtle Unit 1, located in Burke County, Georgia.

In addition, GPC holds a construction permit for Plant Vogtle Unit 2.

GPC applauds the NRC' s efforts to permit state-of-the-art testing methodologies for continued demons tra ti on of containment integrity.

GPC urges the NRC to continue efforts to clarify and incorporate industry practices into the requirements of Appendix J to 10 CFR 50.

GPC would like to see application of the same type of regulatory initiative where the accepted codified methodologies have fallen behind state-of-the-art capabilities.

Our only technical comment is on the proposed test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> associated with the use of ANSI/ANS 56.8 test methodology.

Whereas the proposed revision to Appendix J

presents a 24-hour test period, our experience with running parallel calculations with Mass Point and Total Time methodologies indicates that conservative, reliable Integrated Leak Rate Test (ILRT) results can be obtained in a test of approximately eight (8) hours duration.

As permitted by ANSI, the reported ILRT leakage rate is that at the 95% upper confidence level (UCL), not the leakage value that is actually calculated.

In other words, the calculated leakage rate is the base value to which a statistical uncertainty factor is added.

The s ta tis ti cal uncertainty factor is a function of the number of data points and the amount of data scatter. Assuming a constant degree of scatter, the longer an ILRT is run, the lower the reported leakage rate at the 95% UCL would tend to be.

Thus, a reduced duration test (eight hours) would tend to yield acceptable, conservative results.

The minimum eight hour test duration specified by ANSI/ANS 56.8 should be adopted in the final rule, rather than the apparently arbitrary 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> required by the proposed revision to Appendix J.

MAY 2 6 1988 Acknowledged by ca rd.~ ***........,.... ___.

V S. NUCLcAR R:GULAfOR'/ COMMIS-S!Ot-1 DOCn7 1:--;G a 5qv1(t SEC:flON 9,r.,-_:;,,jf F1E St'J','.iAP.Y 1)' f!f"' f..t ',',',\~!~,I*)~~

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700775 U. S. Nuclear Regulatory Commission March 30, 1988 Page Two If you have any questions with regard to these comments, please contact this office at any time.

Sincerely, w~~~r~

L. T. Gucwa MJB/ju c:

Georgia Power Company Mr. J. T. Beckham, Jr., Vice President - Plant Hatch Mr. P. D. Rice, Vice President and Vogtle Project Director Mr. G. Bockhold, Jr., General Manager - Plant Vogtle GO-NORMS 0917U

Alabama Power Company 600 North 18th Street Post Office Box 2641 DOCl{ET NUMBER PR ~!;7J

,sJ PtWPOSED RULE Birmingham, Alabama 35291-0400 Telephone 205 250-1835 L 5 3 FIG !>q f b:}oocr.E,Er U:,NHC R. P. McDonald Senior Vice President Docket Nos. 50- 348 50- 364 Mr. Samuel J. Chilk Secretary March 31, 1988 U. S. Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Docketing and Service Branch

Dear Mr. Ch ilk:

Re:

Proposed Rule: Alternative Method For Leakage Rate Testing (53 Fed. Reg. 5985 (February 29, 1988))

ftPR -4 P7:54 <<\

Alabama Power OFF I Cf _l1f, ~':.L}~1f/tJithern electric system OOCKE 1,N., ~... :a.t<

l ~ARCP The proposed rule would amend 10 C.F.R. Part 50, Appendix J by expressly allowing the use of the Mass-Point technique for analyzing integrated leak rate test data.

We support the proposed rule insofar as it endorses the Mass-Point analysis technique, but believe additional flexibility, consistent with current s tanrlar ds, ~hould be provided for the appropriate test duration.

The NRC currently interprets the integrated leak rate testing requirements of Appendix J as authorizing the use of only the two data analysis techniques reflected in ANSI-N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear Reactors."

That 1972 standard reflects the two techniques in use at that time, namely, the Point-to-Point and Total Time techniques.

As the proposed rule recognizes, the Mass-Point analysis technique is of comparatively recent development and has been accepted by industry and the NRC as the preferred data analysis technique in use at this time.

53 Fed. Reg. 5985.

In fact, beginning in 1981, the more recent versions of the ANSI standard expressly adopt the Mass-Point technique.

See ANSI/ANS-56.8-1987.

Many licensees have been permitted to use this technique for analyzing integrated leak rate testing data.

ACJ<nowteaged by card MAY 2 6 fg9g

\J *.5, NV':LF.A~ R~GIJLATORY COMMISSI ~

0OCKF.TING & srn*1CE SECTION OFrlG,'.)F THF. SECRETARY O? T' :r ((;,\; 11S510N

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Mr. Samuel J. Chilk March 31, 1988 Page 2 Therefore, the proposed rule is a needed and appropriate update in the Appendix J provisions for acceptable data analysis techniques.

Ye support this endorsement of the Mass-Point method.

The proposed rule, however, would mandate a 24-hour test duration for the Mass-Point technique. Ye do not believe that there is an adequate technical basis for the 24-hour test duration period.

ANSI/ANS-56.8-1987 (at ~5.4), which endorses the Mass-Point technique, specifies a minimum test duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, demonstrating that the Mass-Point technique is considered to provide accurate and reliable results for test durations of considerably less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

As the EPRI report entitled "Containment Integrated Leak-Rate Testing Improvements," dated November 1982 (at 3-32), found, "[t]here is no engineering or scientific reason for a minimum leak test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Unless the NRC provides an adequate technical justification for the 24-hour test duration provision, 1 we believe it would be arbitrary for the NRC to ignore the explicit conclusions of the technical organizations that have addressed this issue.

In addition, because the NRC has previously accepted the use of the Mass-Point technique for tests of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for some licensees, the proposed 24-hour test duration would represent a backfit for these licensees.

In conclusion, while we support the NRC's recognition of the Mass-Point technique, we urge the NRC to adopt the added flexibility of ANSI/ANS-56.8 in the acceptable test duration.

As indicated by ANSI/ANS-56.8, a lesser test duration is technically acceptable, and can result in the reduction of necessary outage time for integrated leak rate tests.

Respectfully ALABAMA POYE

<J(N R. P. McDonald RPM/JAR:dst-T.S.1 cc:

1 Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. Y. H. Bradford The Staff does not attempt to provide a technical basis for the 24-hour test duration provision, but simply notes that this requirement would reflect prior exemptions for certain licensees.

YORK STAT£ D ~i:r.)

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ROCHESTER GAS AND ELECTRIC CORPORATION

• 89 EAST A VENUE, ROCHESTER, N. Y. 14649-0001

• ae APR -4 P 6 :30 T E LEPHON E March 30, 1988 A R EA C ODE 7 16 546 -2700 Secretary, U.S. Nuclear Regulatory Commission Washington: DC 20555 Attention: Docketing and Service Branch OFF!C'- OF SE..:1{t 14r. *t BOCKEi ING 6c ~UiVICf' f!RAN C11

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 2 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-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,

g/U{,U_~

Bruce A. Snow MAY 2 6 198

~cknowledged by card................,!...,

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, I lJ. s. NUCLEAR REGULA TORY cMMISSrOH DOCKHING & SfRVICE SECTION

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WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968

• 3000 George Washington Way

• Richland, Washingto March 29, 1988 Secretary U.S. Nuclear Regulatory Commission Washington, D. C.

20555 ATTN:

Docketing and Service Branch

Subject:

PROPOSED RULE ALTERNATIVE METHOD FOR LEAKAGE RATE TESTING DO(,'L,.* * -

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SN" v.

l1C The subject proposed Rule would allow usage of State-of-the-art leakage rate testing methods.

Specifically, the proposed Rule would modify 10CFR 50, Appendix J, Section III.A.3 to explicitly permit use of the mass point method.

This mass point method is incorporated in ANSI Standard ANSI/ANS 56.8(1981)

"Containment System Leakage Testing Requirements".

The Supply System commends the NRC for its willingness to embrace new technologies and methods as they are developed and proven.

The development of new technologies and their inclusion into a logical and rational regulatory framework is an essential element towards a viable future for the nuclear power industry. These are goals which should be shared by both the industry and the NRC.

We are concerned however that in this particular instance, the NRC staff may have departed somewhat from those goals.

The position stated in the proposed Rule has been developed so as to remain consistent with prior approvals of exemption requests.

In particular, the mass point method and its coupling with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reflect those prior exemption approvals and maintains that consistency.

While the desire on the part of the regulator to maintain consistency may be understandable, there is no technical basis for requiring a minimum test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The method incorporated in ANSI/ANS 56.8 (1981) allows a minimum test duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following stabilization, provided at least 20 data sets have been obtained for use in leak rate calculations.

Our experience in comparing the results of the mass point method with those of the currently approved total time method, using data collected at our WNP-2 plant, show that the ANSI/ANS 56.8 mass point method is indeed the more accurate.

MAY 2 6 1988 Acknowledged by card............... _...,...

d. S. NUCL~A.R ~(CU( A fd~V COMMIS5f0ti DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMIS510N Pcs Im ~r1; D -~,.

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US NRC Proposed Rule - Leakage Rate Testing Page 2 The Supply System supports the NRC in regulatory framework based on sound principles, and one which is consistent.

opting for consistency with past approvals step in the development of new methods and the overall process.

its efforts to produce a scientific and technical It appears though, that may prevent an evolutionary technologies, thus, slowing Thank you for this opportunity to participate in the NRC' s rul emaki ng process.

Should you have any questions or desire further clarification on this matter, please feel free to contact me.

Very truly yours, lil/~~d

./vi_ G. C. Sorensen, Manager

/ -

Regulatory Programs cc:

DL Williams/BPA 399

DOCKET NUMBER PR rROPOSED RULE

-5 6 L AW O FFICE/_ 5 3 FR. 6-</?':;J 00CK[iEt' U.'NRC B I S H O P, COOK, PU RC E L L & RE Y NO LD S 14 0 0 L STREET, N.W.

WASHINGTON, D.C. 200 05-3502 (202) 371 -570 0

• 88 APR -4 P 4 :01 March 30, 1988 WRITER'S DIRECT DIAL OFF!C~. 'r } t. l,, '. IA --'{

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.!£)(\.-440574 INTLAW UI TEL ECOPIER, (2 0 2) 371*5950 Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Docketing and Service Branch Re:

Proposed Rule: Alternati ve Method For Leakage Rate Testing (53 Fed. Reg. 5985 (February 29. 1988))

Dear Mr. Chilk:

The following comments on the above-referenced proposed rule are submitted on behalf of Arkansas Power & Light Company, Consolidated Edison Company of New York, Inc., Southern California Edison Company, and TU Electric.

The proposed rule would amend 10 C.F.R. Part 50, Appendix J by expressly allowing the use of the Mass-Point technique for analyzing integrated leak rate test data.

We support the proposed rule insofar as it endorses the Mass-Point analysis technique, but believe additional flexibility, consistent with current standards, should be provided for the appropriate test duration.

The NRC currently interprets the integrated leak rate testing requirements of Appendix J as authorizing the use of only the two data analysis techniques reflected in ANSI-N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear Reactors."

That 1972 standard reflects the two techniques in use at that time, namely, the Point-to-Point and Total Time techniques.

As the proposed rule recognizes, the Mass-Point analysis technique is of comparatively recent development and has been accepted by industry and the NRC as the preferred data analysis technique in use at this time.

53 Fed.

Reg. at 5985.

In fact, beginning in 1981, the more recent versions of the ANSI standard expressly adopt the Mass-Point technique.

See ANSI/ANS-56.8-1987.

Many licensees have been permitted to use this technique for analyzing integrated leak rate testing data.

~cknowledged by card MAY 2 6 198,8

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Samuel J. Chilk March 30, 1988 Page 2 Therefore, the proposed rule is a needed and appropriate update in the Appendix J provisions for acceptable data analysis techniques.

We support this endorsement of the Mass-Point method.

The proposed rule, however, would mandate a 24-hour test duration for the Mass-Point technique.

We do not believe that there is an adequate technical basis for the 24-hour test duration period.

ANSI/ANS-56.8-1987 (at 15.4), which endorses the Mass-Point technique, specifies a minimum test duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, demonstrating that the Mass-Point technique is considered to provide accurate and reliable results for test durations of considerably less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

As the EPRI report entitled "Containment Integrated Leak-Rate Testing Improvements," dated November 1982 (at 3-32), found, "[t]here is no engineering or scientific reason for a minimum leak test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Unless the NRC provides an adequate technical justification for the 24-hour test duration provision,_JJ we believe it would be arbitrary for the NRC to ignore the explicit conclusions of the technical organizations that have addressed this issue.

In addition, because the NRC has previously accepted the use of the Mass-Point technique for tests of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for some licensees, the proposed 24-hour test duration would represent a backfit for these licensees.

10 C.F.R. §50.109.

In conclusion, while we support the NRC's recognition of the Mass-Point technique, we urge the NRC to adopt the added flexibility of ANSI/ANS-56.8 in the acceptable test duration.

As indicated by ANSI/ANS-56.8, a lesser test duration is technically acceptable, and can result in the reduction of necessary outage time for integrated leak rate tests.

_JJ The Staff does not attempt to provide a technical basis for the 24-hour test duration provision, but simply notes that this requirement would reflect prior exemptions for certain licensees.

Commonwealth Edison e

One First National Plaza, Chicago, Illinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 - 0767 Mr. Samuel J. Chilk, secretary U.S. Nuclear Regulatory Commission Attn:

Docketing and service Branch Washington, D.C.

20555 March 29, 1988

Subject:

Proposed Rule on Alternative Method for Leakage Rate Testing (53 Fed Reg 5985, February 29, 1988)

Dear Mr. Ch ilk:

OOC:K[TEQ USNHC

• aa APR -1 P4 :01 Commonwealth Edison has reviewed the above mentioned Proposed Rule as outlined in the Federal Register Notice of February 29, 1988 and would like to submit the attached comments.

Thank you for giving us this opportunity to comment on this issue.

Respectfully, W.E. Morgan Nuclear Licensing Administrator sj/4426K MAY 2 6 1988 4cknowledged by card..........,.. __ __._

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0. S. NUCLEAR REGULATORY COMMISSIO.tl DOCKETING ?, SERVICE SECTION OFFICi' *> T'-:F. SECRETARY OF *r c ':UM.'

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ATT.hCHMENT 1 Commonwealth Edison ' s Company Coinments On:

Proposed Rule on Alternative Method for Leakage Rate Testing (53 Fi d Reg 5985, February 29, 1988)

This prov1des Commonwealth Edison Company's ("Edison") comments on the Nuclear Regulatory Commission's (NRC) proposal to amend 10CFR Part 50, Appendix J, Section III.A.3, Leakage Testing Requirement, Test Methods for Type A Tests.

Edison supports the proposed amendment to the extent that it authorizes licensees to use the Mass Plot Method for calculating leakrates during an ILRT.

Such a change has long been overdue in view of the general perception that the Mass Plot Method is technically superior to the alterna-tive methods which the NRG currently approves for 1 icensees' use.

Edison also considers technically acceptable the calculational methodology 1n ANSI/ANS 56.8.

However, for the reasons discussed below, Edison believes that a test durations of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1s unnecessarily long for test using the Mass Point Method and that the intended fl exi bi 1 ity to perm1 t subsequent NRC modifications to this rule without further rulemaking 1s contrary to both the requirements of the Administrative Procedure Actt 5 U.S.C. 553, and the NRC's backfit rule, 10CFR50.109.

Accordingly. Edison believes that the requirement for a test period of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> should be deleted and that the rule be made definitive as required by law by deleting the word 11typical."

24~Hour Test Per1Q,d A test durati on of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is unnecessarily long for the Mass Point Method for leak rate testing.

Experience with the Mass Point method shows that shorter periods are adequate to demonstrate adequate protection of the public health and safety. Moreover, there 1s no realistic possibility t hat 1 icensee will use inadequately short testing durations because any attempt to perform a test 1n. an interval too short to demonstrate ade.qu.ate protection raises to unacceptability high levels the probability of failing the local rate criteria. Thus, leak rate testing inherently contains limits on the length of the test duration, limits which ensure that licensees will test for a period long enough to de~onstrate adequate protection of public health and safety, In view of these c1rcumstances, there is no safety just1fication for requiring a testing period of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This lack of safety justification is especially troublesome because the minimum 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> testing period results 1n the waste of cr1tica1 path time, thus causing 1 icensees to incur economic penalties with no compensating increase in safety.

To avoid these unjustif1-abl e pen a 1t 1 es, licensees should be authorized to adapt test durations which they cietermine are adequate.

Safety will not be compromised by such a procedure because, as discussed above, the probability of failing the tests 1s raised to unacceptably high levels if licensees choose test durations which are not long enough to demonstrate adequate protection of the public health and safety.

Flexible Rule The proposal to word the rule flexibly enough to accommodate subsequent modifications without further rulemaking flies in the face of the fundareental purpose of rul emaki ng.

Rul ema k1 ng 1 s intended to g1 ve the affected public an opportunity to comment on an agency's proposal to exercise its authority to promulgate binding law.

That opportunity to comment 1s denied when an agency purposefully words a proposed rule vaguely enough to permit subsequent changes without subsequent opportun it 1 es for comment.

Th 1 s 1 ssuance of a blank check is just the kind of agency action the rulemaking provis1ons of the Admi n i strati ve Procedures Act (

11 APA) were intended to prec 1 ude.

Therefore, to conform to the notice and comment requirements of the APA, the proposed rule should be mod ifi ed to replace the word 11typical" by the words "completely acceptable." This change would provide the statutorily required definiteness for this rule.

A flexibly worded rule is also in-consistent with the requirements for a regulatory analysis and backfit analysis. A regulatory analysis requires the NRC to compare the costs and benefits of the proposal with the costs and benefits of alternatives.

Such a comparison cannot be made meaningfully if the costs and benefits of the proposal are uncertain because the proposal is subject to unspecified change.

That is the case here.

Thus, to comply with the requirements for a meaningful regulatory analysis, the proposed rule must be stated without the possibility of future unspecified changes.

As for t he need for a backfit analysis, the reason given (or not performing one *is inconsistent wH.:tr-a *flex*ib1e *Tule.

The *NRC-tietsrrnined that a backfit ana 1 ys is 1 s not re qui red because 11 the proposed rule wou1 d cod 1fy and permit the continuation of a previously accepted practice." While this may be true as long as the NRC accepts the Mass Plot method in ANSI/ANS-56.8-1987, it may no longer be true if the acceptable calculati onal method is subsequently changed.

Thus, to comply with the NRC 1 s backfit rule, the proposed amendment to Appendix J must be stated more definitely as suggested.

Even if the rule as proposed is just within the boundaries of acceptability, there is no justification for promulgating a rule with such a high potential for controversy over interpretation.

Certainly, nothing in the history of Appendix J suggests that the minimum time for notice and comment required by law would be too long if this rule were to require subsequent modification.

And should a situation arise in which such prompt action is required, the NRC can exercise its discretion to grant exemptions until an expedited rulemaking is concluded.

Thus, the NRC should exercise its discretion to provide clear and unambiguous guidance to licensees by promulgating a definitive final rule as described above.

Finally, by supporting the NRC's *proposal to adopt the calculational methcdol-ogy in ANSI/ANS 56.8, Edison does not intend to imply that it endorses any other parts of that document nor its adoption as previously proposed by the NRC. (51 Fed. Reg. 39538, October 29, 1988).

WPSCC414I433-1598 TELECOPIER (4141 433-1297 UUI.JI\LI l't !..!l'IIL>L.I\ l'K So

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WISCONSIN PUBLIC SERVICE CORPORATION USIWC 600 North Adams* P.O. Box 19002

• Green Bay, WI 54307-9002 l 1

• sa t1J\R 31 P 4 :

March 29, 1988 Secretary of the Commission Attention Docketing and Service Branch U. S. Nuclear Regulatory Commission Washington, D.C.

20555 Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Comments on Proposed Rule Allowing the Use of ANSI/ANS-56.8-1987 (Mass Point Technology) to Calculate Containment Leakage Rates Federal Register 5985, Monday, February 29, 1988, Vol. 53 No. 29

References:

1) D. C. Hintz to NRC Office of Administration, Comments on Duke Power Company's Amendments to Facility Operating Licenses, September 11, 1986

2) D. C. Hintz to NRC, Comments on Proposed 10 CFR 50, Appendix J, April 24, 1987 Wisconsin Public Service Corporation (WPSC) concurs with the NRC on its position to allow the use of mass point methodology in the calculation of containment leakage rates.

The above references document WPSC 1 s support for this tech-nically superior method of calculating containment leakage.

The use of this method should yield a more accurate indication of actual leakage rates.

For these reasons WPSC supports the proposed rule to allow the use of mass point methodology with one exception.

The proposed rule requires a 24-hour test dura-tion.

This time limit appears arbitrary and is in conflict with ANSI/ANS 56.8-1987 11Containment System Leakage Testing Requirements.

11 Section 5.4 of this ANSI/ANS standard states the following with regard to test duration:

11 The duration of the test period must be sufficient to enable adequate data to be accumulated and statistically analyzed 11 and, 11A type A test shall last a minimum of eight hours after stabilization.

11 WPSC therefore encourages the NRC to eli-minate the 24-hour test duration in favor of criteria consistent with the ANSI/ANS standard.

rMY 2 6 1988 Acknowledged by ca rd. *** ; *, * ; *** ~: *...,

I u..S.

'UCLEAR !EGULATO~Y COMMISSIOri DOCKETING & SERVICE SECTION oi:;:1cr 0: THE SECRETARY OF THE CvMMISSION

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Secretary of the Commission March 29, 1988 Page 2 It is hoped that this proposed rule reflects an NRC trend toward incorporating more modern and accurate testing methods which will eliminate unnecessary con-servatisms while maintaining plant safety.

Sincerely, J /!Jf D. C. Hintz Vice President - Nuclear Power ALH/jms cc - Mr. Robert Nelson, US NRC US NRC, Region III US NRC Document Control Desk

IJU~t\tl NUMHtt( PR c-o ROPOSED RULE

• i7 **.

NORTHEAST UTILITIES

( S-3 F rL ~9'0 General Offices

• Selden Street, Berl in, Connecticut

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THE CONNECTICUT LIGHT AND POWER COMPANY WESTERN MASSACHUSETTS ELECTRIC COMPANY HOLYOKE WATER POWER C0'4PANY NORTHEAST UTILITIES SERVICE COMPANY NORTHEAST NUCLEAR ENERGY COMPANY P.o. Box 270 oqc:KFTED HARTFORD, CONNECTYaws6,f1~Cj??

(203) 665-5000

'i,r S. J. Chil k March 31, 1988 "al APR J. P2 :43 OFFIC E: Or ::,, LI r. lAl'I

• OOCKET ING " c,d'

• IC:f.

Docket Nos. 50-213 BRANC~

50-245 50-336 50-423 B12870 Re:

10CFR50, Appendix J Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D. C.

20555

References:

Gentlemen:

(1)

Federal Register, Volume 53, Number 39.

(2)

F. M. Akstulewicz letter to E. J. Mroczka, Exemption From the Requirements of Appendix J to 10CFR50, Paragraph III.A.3, dated October 15, 1987.

(3)

M. L. Boyle letter to E. J. Mroczka, Exemption From the Requirements of Appendix J to 10CFR50, Paragraph III.A.3,

dated October 15, 1987.

(4)

D. H. Jaffe letter to E. J. Mroczka, Exemption From the Requirements of Appendix J to 10CFR50, Paragraph III.A.3,

dated February 3, 1988.

(5)

EPRI Report NP-2726, "Containment Integrated Leak Rate Testing Improvements," November 1982.

(6)

EPRI Report NP-3400, "Criteria for Determining the Dura-tion of Integrated Leakage Rate Tests of Reactor Contain-ments," December 1983.

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1, 2 and 3 Comments on Proposed Rule Alternative Method for Leakage Rate Testing On February 29, 1988 (Reference 1), the Nuclear Regulatory Commission (NRC) published a proposed rule amending its regulations applicable to the leakage testing of containments to permit the use of the mass point method as an alternative method for cal cul at i ng containment leakage rates.

Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) respectfully submit the following comments in support of the proposed rule.

MAY 2 6 198~

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U.S. Nuclear Regulatory Commission B12870/Page 2 March 31, 1988 The intent of the proposed rev1s1on to Appendix J is to allow use of the mass point method to calculate containment leakage rates.

The mass point method is a more accurate means of determining containment 1 eakage rates.

The tot a 1 -

time method calculates a series of time weighted leakage rates, based upon differences between an initial data point and points occurring later in time.

The adequacy of this method is sensitive to the initial data point.

Any perturbations, such as fluctuations in containment air temperature, ingassing or outgassing or instrument error, can affect the validity of the initial data point and downstream 1 eakage ca lcul at ions.

The mass point method ca 1 cul ates leakage rates based upon contained air mass.

This technique accurately calculates the mass of air inside containment and plots it as a function of ti me.

The slope of the 1 i near least squares fit of the data is the leakage rate.

The use of this method is we 11 known and endorsed by the American Nuclear Society (ANS), Electric Power Research Institute (EPRI) and the NRC Staff.

The NRC Staff has shown its support of the use of the mass point method as an alternative method of ca lcul at i ng containment 1 eakage rates by granting exemptions to the Haddam Neck Plant, Millstone Unit No.

1 and Millstone Unit No. 2 (References (2), (3), (4)).

As 1 i censees of the Haddam Neck Pl ant and Mi 11 stone Nuclear Power Station, Unit Nos. 1, 2, and 3, CYAPCO and NNECO hereby submit specific comments in response to the proposed rule:

o CYAPCO and NNECO agree with the proposed change to Appendix J allowing for use of the mass point method during periodic Type A tests, per the provisions of ANS56.8-1987.

o CYAPCO and NNECO have concluded that mass point tests of durations less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are feasible and justifiable as was demonstrated at recent reduced duration tests at Millstone Unit Nos. 1 and 2.

In addition, EPRI has advocated the use of reduced duration testing (References (5) and (6)).

o CYAPCO and NNECO recommend adopting ANS56.8-1987 using mass point test durations of at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in lieu of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> require-ment.

In summary, CYAPCO and NNECO support the proposed rule.

Use of the mass point method is a more accurate method for calculating containment leakage rates and has gained the support of the professional community.

The use of the mass point method represents the best available and proven containment leakage rate calculational and measurement technology.

U.S. Nuclear Regulatory Commission 81287O/Page 3 March 31, 1988 We trust that these comments will be useful in the finalization of the proposed rule.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY Senior Vice President cc:

W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 R. L. Ferguson, NRC Project Manager, Millstone Unit No. 3 A. B. Wang, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2 and 3 J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant Document Control Desk

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NYN-88036 George S. Thomas Vice Presld~Elfle[ Production U'.':>NhC le Service of New Hampshire New Hampshire Yankee Division March 29, 1988 MA~-3(

'88.... P7:01 Secretary United States Nuclear Regulatory Commission Washington, DC 20555 Attention:

Docketing and Service Branch

Subject:

Proposed Rule; Alternative Method for Leakage Rate Testing

Dear Sir:

The New Hampshire Yankee (NHY) Division of Public Service Company of New Hampshire (PSNH) appreciates this opportunity to comment on the proposed rule regarding 10 CFR 50 Appendix J published in the Federal Register, Vol. 53, No.

39, on Monday, February 29, 1988.

PSNH is the agent and representative of the Joint Owners of Seabrook Station.

The proposed rule, as specified, appears to be contrary to ANSI/ANS 56.8-1987 and a proposed general revision of Appendix J published in the Federal Register, Vol. 51, No. 209, on Wednesday, October 29, 1986 in the area of ILRT test duration when using the Mass Point Analysis technique.

Neither ANSI 56.8-1987 nor the proposed general revision of Appendix J specify a minimum test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Furthermore, requiring a minimum test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when using the Mass Point Analysis technique appears to be without basis since ANSI/ANS 56.8-1987 requires (in Section 5.4) that "the duration of the test period must be sufficient to enable adequate data to be accumulated and statistically analyzed so that a leakage rate and upper confidence limit can be accurately determined".

The proposed rule change which would codify the acceptability of the Mass Point Analysis technique is a worthwhile and timely improvement to the rule.

However, past testing experience throughout the industry has shown that adequate data can be accumulated and statistically analyzed in test periods less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Therefore, it is felt that the minimum testing period as stated in ANSI/ANS 56.8-1987 would be a more appropriate duration for the conduct of a leakage test.

Very truly yours, George S. Thomas

.. J\PR 1 1988 A'ck'10'Nlf!dged by ca ref..* -:*;:-;:;: **

P.O. Box 300. Seabrook, NH 03874. Telephone (603) 474-9574

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Du1rn PowEa GoMPANY oot KElf.e P.O. BOX 33189 IJ 'HRC HAL B. TUCKER VIOE PR.ESIDBNT NUCLEAR P RODUCTION March 22, 1988 The Secretary of the Commission CHARLOTTE, N.C. 28242 U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention:

Docketing and Service Branch

Subject:

NRC Proposed Rule

Dear Sir:

Alternative Method for Leakage Rate Testing Duke Power Company Comments In the Federal Register (53FR5985) dated February 29, 1988, the Nuclear Regulatory Commission published for comment a proposed rule change to 10 CFR 50, Appendix J allowing for the use of the Mass Point method when coupled with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This rule change is proposed as an interim measure until the general revision to Appendix J and its related Regulatory Guide MS-021 are approved.

Duke Power generally supports the addition of the Mass Point method for leakage rate testing.

Specific comments to the proposed rule are as follows:

(1)

This Proposed Rule incorrectly makes the statement that it is similar to a previous Appendix J revision proposed in Federal Register Notice (FRN) 51FR39538 issued October 29, 1986.

While this proposed rule specifically requires the performance of a Mass Point Test over a duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the October 29, 1986 FRN specifically excludes the test duration from the rule.

The October, 1986 FRN stated that the test duration is "considered as part of the testing procedures, and is a function of the state of the testing technology and the level of confidence in it".

The Staff should return to the previous wording or explain the apparent decrease in the "level of confidence" which has resulted in the perceived need to now specify an excessive minimum test duration.

(2)

The proposed revision states that "a typical description of the Mass Point Method can be found in the American National Standard ANSI/ANS 56.8-1987, "Containment System Leakage Testing Requirements".

"A typical description" is not definitive guidance with respect to the test method.

For instance, the Standard requires a minimum test duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and a total of at least 20 data points.

The proposed rule triples the minimum duration of the test, but does not address the number of data points required.

(3)

The FRN states that "the intent of the proposed wording is to allow sufficient flexibility for such adjustments to be made to the method... "

This intent is not accomplished.

The requirement for a minimum test APR 1 1988

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The Secretary of the Commission March 22, 1988 Page Two duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is inconsistent with the referenced standard.

Additionally, to obtain NRC Staff approval for a deviation from the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> an exemption would also need to be processed.

This is an increased burden, not "flexibility".

(4)

On September 18, 1987, Duke Power Company submitted to the NRC for review a set of termination criteria that must be satisfied in order to conduct a Mass Point CILRT in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The termination criteria were developed to satisfy paragraph 7. 6 of ANSI-N45. 4, i.e., demonstrate "to the satisfaction of those responsible... that the leakage rate can be accurately determined during a shorter test period".

We are still waiting for a response from the NRC to this proposal.

I n summary, it is entirely appropriate for the Staff to include Mass Point as an acceptable tool for leakrate testing. It is not appropriate to specify, without recourse or alternative, a test duration significantly in excess of that recommended in the referenced standard.

Duke Power recommends that this proposed rule endorse the test time duration and number of data points required as specified in the referenced standard.

Very truly yours, Hal B. Tucker DM/11011/ sbn xc:

Mr. Darl Hood Office of Nuclear Reactor Regulations U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Ms. Helen Pastis Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555

, **0 Wisconsin Electnc Powrn coMPANY 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 VPNPD-88-164 March 18, 1988 Mr. Samuel Chilk, Secretary DOCKET NUMBER PR r * ~

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(414) 277-2345 U. S. NUCLEAR REGULATORY COMMI SSION Washington, D.C. 20555 Attention:

Docketing and Service Branch

Dear Mr. Chilk:

COMMENTS ON PROPOSED REVISION TO 10 CFR 50, APPENDIX J This letter is to transmit our comments on the proposed revision to 10 CFR 50, Appendix J as published in the Federal Register on February 29, 1988.

We support the proposed change to Section III.A.3.a that allows the use of the Mass Point method of data analysis.

We also endorse your proposal to remove the last sentence from this same section.

We recommend, however, the test duration criteria in ANSI/ANS-56.8-1987, "Containment System Leakage Testing Require-ments," Section 5.4 be accepted in the revised regulations.

The background information that was published with the proposed change acknowledges that advances in leakage rate technology have occurred since Appendix J was published in 1973.

These advances, in both hardware and methodology, have not only resulted in improved methods of evaluating data, but have also made it possible to accurately measure a leakage rate in much less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

We believe that using a results-based test termination criteria such as that described in Section 5.4 of ANSI/ANS-56.8-1987 will avoid needlessly prolonging tests without degrading the test's ability to detect unacceptable leakage.

EPRI Report NP-3400, "Criteria for Determining the Duration of Integrated Leakage Rate Tests of Reactor Containments", December 1983, analyzed another results-based test termination criteria.

This report concluded that the duration of an acceptably accurate containment integrated leakage rate test is primarily a function of test method and instrumentation system and that predefining a minimum duration had neglig i ble effect on test accuracy.

MAR 2 9 1988'*

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I Mr. Samuel Chilk March 18, 1988 Page 2 We trust these comments will be useful to you in facilitating implementation of these proposed changes.

We request that you also consider the additional revision discussed in this letter.

We believe these regulations are important not only to assure the continued safety of plant operation, but also because of their direct impact on plant availability and costs.

Very truly yours, c~£ Vice President Nuclear Power

YANKEE ATOMIC

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U',NHC Telephone (6 17) 8 72-81 00 TWX 710-380-7619 GLA 88-041 FYC 88-004 1671 Worcester Road, Framingham, MaY38chlfARtt2911~ 9 :2a March 23, 1988 OFFl(,f u St tl'\ t fA;,

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United States Nuclear Regulatory Commission Washington, DC 20555 Attention:

Docketing and Service Branch

Subject:

Comments pertaining to Proposed Rule (10 CFR 50, Appendix J),

"Alternative Method for Leakage Rate Testing" (53 FR 5985)

Dear Sir:

Yankee Atomic Electric Company (YAEC) appreciates this opportunity to comment on the proposed rule regarding 1 0CFR50, Appendix J.

YAEC owns and operates the Yankee Nuclear Power Plant in Rowe, Massachusetts.

Our Nuclear Services Division also provides engineering and licensing services for other nuclear power plants in the Northeast, including Vermont Yankee, Maine Yankee and New Hampshire Yankee (Seabrook).

Incorporation of the mass point method into Appendix J as an acceptable method of calculating containment leakage rates is definitely an improvement.

We have used this method and believe it is better than others.

The proposed change relieves us and other utilities of the burden of seeking an exemption to Appendix Jin order to employ this more state-of-the-art statistical data analysis technique.

We fully endorse and support this change.

A compliment to this proposed change to Appendix J, which would greatly im-prove its consistency, is replacement of the outdated reference to ANSI-N45. 4-1972 "Leakage Rate Testing of Containment Structures for Nuclear Reactors ;,, with a reference to ANSI-N56. 8-1981 "Containment System Leakage Testing Requirements" ( revised 1987).

The current standard incorporates the mass point method, whereas the obsolete standard refers to earlier techniques.

Since NRC was a major participant in the consensus committee that developed and more recently revised this standard it would seem reasonable that NRC regulations should accurately reflect the appropriate current standard.

very truly y~

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Donald W. Edwards Director, Industry Affairs

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'88 MAR 28 P 4 :45 Secretary OFF!CE._Ci1 ~E..,.:A-, (

u. s. Nuclear Regulat!l9f¥ 1db~_i;!:i~lefn Attn:

Docketing and Serv1~e 'i3ranch 1717 H Street, N.W., Room 1121 Washington, D. C. 20555 Mr. Secretary:

Re:

Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 P. 0. BOX 14000, JUNO BEACH, FL 33408-0420 MARCl:l 2 5 1988 L-88-131 Proposed Rule Change -

10 CFR 50 Appendix J Florida Power

& Light Company (FPL) provides the following comments concerning the proposed rule change to 10 CFR 50 Appendix J -

Primary Reactor Containment Leakage Testing for Water-Cooled Power

Reactors, published in the Federal Register, February 29, 1988.

(1)

FPL endorses the addition of the Mass Point methodology to acceptable leakage rate calculational methods already incorporated into Appendix J.

(2)

FPL disagrees with the coupling of the Mass Point methodology with a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test period.

Bases:

Test period length should be based on the time necessary to gather enough data with a degree of accuracy to obtain a 95% confidence level that the measured leakage rate is accurate.

This is a statistical requirement independent of methodology.

Coupling this methodology with a minimum 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test period will severely limit its use.

FPL appreciates this opportunity to comment on this rule change.

Very truly yours, w~

Acting Group Vice President Nuclear Energy WFC/RG/gp cc:

Dr. J. Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant RG.PRC an FPL Group company

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James W. Connolly Seabrook Station P. O. Box 300 Seabrook, NH 03874 March 23, 1988 United States Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION:

DOCKETING AND SERVICE BRANCH

Dear Sir:

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I ING & S[i< V/('f BRANCl-i New Hampshire Yankee (NHY), a division of Public Service of New Hampshire (PSNH), appreciates this opportunity to comment on the proposed rule regarding 10 CFR 50 Appendix J published in the Federal Register, Vol. 53, No. 39, on Monday February 29, 1988.

PSNH is the agent and representative of joint owners of Seabrook Station in Seabrook, New Hampshire.

The proposed rule, as specified, appears to be contrary with ANSI/ANS 56.8-1987 and a proposed general revision of Appendix J published in the Federal Register, Vol. 51, No. 209, on Wednesday October 29, 1986 in the area of ILRT test duration when using the Mass Point Analysis technique.

Neither ANSI 56.8-1987 nor the proposed general revision of Appendix J spe-cify a minimum test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Furthermore, requiring a minimum test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when using the Mass Point Analysis technique appears to be without basis since ANSI/ANS 56.8-1987 requires (in Section 5.4) that "the duration of the test period must be sufficient to enable adequate data to be accumulated and statistically analyzed so that a leakage rate and upper confidence limit can be accurately determined".

The intent of the proposed rule change to codify the acceptability of the Mass Point Analysis Technique appears to be well intended and will relieve the industry of large amounts of regulatory uncertainty.

Past testing experience throughout the industry has shown that adequate data can be accumulated and sta-tistically analyzed in test periods less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and has been recognized in the revised standard ANSI/ANS 56.8-1987.

Requiring a minimum test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when using the Mass Point Analysis technique may also produce many needless requests for exemption from this requirement.

JWC/jw Respectfully,

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~__ckn_owledged by card.** :;;..""-,,;- ;;-;;;;:;.;liiil;a P.O. Box 300. Seabrook, NH 03874. Telephone (603) 474-9574

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• as MAR 22 P 3 :25 Federal Register / Vol. 53, No. 39 / Monday, February 29, 1988 / Proposed Rules 5985 period(s) of service during which he/she was entitled to be insured.

PART 890-FEDERAL EMPLOYEES HEAL TH BENEFITS PROGRAM

3. The authority citation for Part 890 continues to read as follows:

Authority: 5 U.S.C. 8913; § 890.102 also issued under 5 U.S.C. 1104.

4. In Subpart C of Part 890, paragraph 890.303(a) is revised to read as follows:

§ 890.303 Continuation of enrollment.

(a) On transfer or retirement. (1)

Except as otherwise provided by this part, the registration of an employee or annuitant eligible to continue rerollment continues without change when he or she moves from one employing office to another, without a break in service of more than 3 days, whether the personnel action is designated as a transfer or not.

(2) In order for an employee to continue an enrellment as an annuitant, he or she must meet the participation requirements set forth at 8905(b) of title 5, United States Code, for continuing an enrollment as an annuitant as of the commencing date of his or her annuity or monthly compensation.

(3) For the purpose of this part, an employee is.considered to have enrolled at his or her first opportunity if the employee registered to be enrolled during the first of the periods set forth in

§ 890.301 in:-which he or she was eligible-to register or was covered at that time by the enrollment of another employee or annuitant, or registered to be enrolled effective not later than December 31, 1964.

(FR Doc. 88-4281 Filed 2-26-88: 8:45 am)

BILLING CODE 6325-01-lol NUCLEAR REGULATORY COMMISSION 10 CFR Part50 Alternative Method for Leakage Rate Testing AGENCY: Nuclear Regulatory Commission.

ACTION: Proposed rule.

SUMMARY

The Nuclear Regulatory Commission (NRC) is proposing a limited amendment to clariTy the requirements of its regulaiions applicable to the leakage testing of containments of light-wa !er-cooled nuclear power plants. The proposed rule would explicitly permit the use of a statistical data analysis technique that*

the NRG.considers to be an acceptable method of calculating containment leakage rates.

DATES: Comment period expires March 30, 1988. Comments received after this date will be-considered if it is practical to do so, but assurance of consideration cannot be given except for comments received on or before this date.

ADDRESSES: Mail written comments to:

Secretary, U.S. Nuclear Regulator.y Commission, Washington, DC 20555, Attention: Docketing and Service Branch. Deliver comments to: Room 1121, 171-7 H Street NW., Washington, DC, between 7:30 a.m. and 4:15 p.m.

weekdays. Copies of comments received may be examined at the NRC Public Document Room, 1717 H Street NW.,

Washington, DC.

FOR FURTHER INFORMATION CONTACT:

Mr. E. Gunter Arndt. Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC, 20555, telephone (301) 492-3945.

SUPPLEMENTARY INFORMATION:

Background

In 1973, when the Commission initially promulgated its requirements concerning containment integrated leakage rate testing (10 CFR Part 50, Appendix J), the Commission required licensees to use state-of-the-art leakage test methodology and specifically called for Type A test methods described in American, National-Standard ANSI-N45.4-1972, "Leakage Rate Testing of Containment Structures for Nuclear Reactors" (Appendix J,.Sec. III.A.3).

That standard accepted two techniques for evaluating test results: the. Total Time method and*the Point-to-Point method. In the Total Time method, a series of leakage rates are. calculated on the basis of containment air mass..

differences between an initial data point and each individual data point thereafter, and an average of these leakage rates is then determined. In the Point-to-Point method, the leakage rates are based. on the air mass difference between each pair of consecutive data points, and these leakage. rates are then averaged to yield asingle leakage rate estimate.

Subsequently, further advances in leakage rate testing technology have provided improved test methods,.

including a newer method of evaluating test data called the Mass Point method.

The Mass Point method involves calculation of the air mass at a series of points in time and the plotting of mass against time. A linear regression line is plotted through the mass-time points using a least squares fit. The slope of this line is divided by the intercept of 00 n1w*--* *,r-,** *-r this line, an t e 'ff.u \'1i * *m'i:ih1blmd by an appropriate coris anrtb obtain the calculated leakage rate.

This Mass Point method was incorporated-in a newer ANSI standard, ANSI/ ANS-56.8-1981, "Containment System Leakage Testing Requirements" (revised 1987) and in fact has been accepted by the NRC staff as an improved alternative method of calculating containment.leakage rates.

However, it was recently recognized by the NRC staff that a strict interpretation of the specific wording of Appendix J, III.A.3, by referencing only the older ANSI standard, would preclude use of the newer. improved method. To alleviate this restriction on the use of an improved alternative methodology, it is necessary to clarify the language in Section II.A.a to explicitly permit the use of the newer Mass Point method in addition to the earlier methods covered by ANSI-N45.4-1972. A similar revision is in fact proposed as part of the currently pending.general revision to Appendix J (see 51 FR 39538, October 29, 1986). However, that proposed rule change involves a number of complex matters, and a final rule concerning the revision to Appendix J may not be completed for some time. In order to minimize any further delay in codifying the accepted use of the.Mass Point method, the Commission proposes to modify Section III.A.3 to explicitly permit the. use. of the. Mass Point method, subject to certain conditions that have been accepted by the NRC staff since approximately 1976, as well as to permit the use of the prior methods referenced in ANSI-N45.4-1972. The position stated in the words being added is consistent with the position that has been taken by the NRC staff when granting exemption requests on this matter. In particular, the description of the Mass Point method and its coupling with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> both.reflect those prior exemption approvals and maintain that consistency. Improvements to the wording in the existing Appendix J ofl0 CFR Part 50 are contemplated in a proposed general revision to Appendix-J and in a related regulatory guide (MS 021-5, "Containment System Leakage Testing") that would endorse ANSI/

ANS-56.8. If the more general revision of Appendix J is adopted before this limited revision be"comes final, this action will become unnecessary and will be withdrawn. However, this is not likely. Therefore, until such a general revision is adopted, the description of the Mass Point method in ANSI/ ANS-56.8 is considered useful for explaining the method and its application in general to the containment leakage rate

5986 Federal Register / Vol. 53, No. 39 / Monday, February 29, 1988 / Proposed Rules tr.st progrn m. A<ljustments to the ANSI/

ANS-56.8 description of the Mass Point method may be desirable as this method evolves and is applied to this specialized an<l complex test progra m.

The inten t of the proposed wording is to allow sufficien t flexibility for such atljustments to be made to the method shoultl a general revision to Appendix J and an explicit endorsement of ANSI/

ANS-56.8 through a regulatory guide not promptly replace this limited revision.

The proposed action to be taken is the add ition of the following words to Section III.A.3 of the existing rule:

In addition to the Total Time and Point-to-Puint methods described in that standard. the Mass Point method, when used with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, is an acceptable method to use to calcula te leakage ra tes. A typical description of the Mass Point method can be found in the American National Standard ANSI/ ANS--56.8-1987.

• • containment System Leakage Testing Requirements." January 20, 1987.

In order to eliminate a contradiction with the intent of this proposed action to permit a change in the methods now permitted, the following sentence will be deleted from Section III.A.3 of the existing rule:

The method chosen fur the initial test shall normally be used for the periodic tests.

Invitation to Comment Comments from all interested persons on all aspects of this limited revision are requested by the comment expiration date in order tha t the final revision will refl ect consideration of all points of view.

Environmental Impact: Categorical Exclusion The Commission has determined that this proposed rule is the type of action described in the categorical exclusion in 10 CFR 51.22(r:)(2). Therefore, neither an environment impact statement nor an environmental assessment has been prepared for this proposed rule.

Paperwork Reduction Act Statement This proposed rule does not contain a new or amended information collection requirement subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.). Existing requirements were approved under the Office of

• Management and Budget approval number 3150-0011.

Regulatory Analysis The Commission has prepared a draft regulatory amilysis on this proposed rule. The analysis examines the costs and benefits of the alternatives considered by the Commission. The dra ft analysis is available for inspection in the NRC Public Document Room. 1717 H Street NW., Washington, DC. The Commission re<]uests public comment on the draft regula tory analysis.

Comments on the draft analysis may be submitted to the NRC as indicated under the ADDRESSES heading.

Regulatory Flexibility Certification In accord,mce with the Regulatory Flexibility Act of 1980 (5 U.S.C. 605[b)),

the Commission certifies that this rule, if promulgated, will not have a significant economic impact on a substantial number of small entities. This proposed rule affects only the licensing and operation of nuclear power plants. The companies that own these plants do not fall within the scope of the definition of "small entities" set forth in the Regulatory Flexibility Act or the Small Business Size Standards set out in regula tions issued by the Small *Business Administration at 13 CFR Part 121.

Backfit Analysis The NRC has determined that a backfit analysis is not required for this proposed rule because, although the proposed rule would be applicable to all current or future operating n_uclear power plants. the provisioris of the.

proposed rule would codity and permit the continuation of a previously accepted practice. This proposed action would not encumber those using this accepted practice with the added

• burden of seeking exemptions to the existing rule.

List of Subjects in 10 CFR Part 50 Antitrust, Classified information, Fire prevention, Incorporation by reference, Intergovernmental relations. Nuclear power plants and reactors, Penalty, Radiation protection, Reactor siting criteria, Reporting and recordkeeping requirements.

For the reasons set out in the pre,imble and under the authority of the Atomic Energy Act of 1954, as. amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendment to 10 CFR Part 50.

PART SO-DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES.

1. The authority citation for Part 50 continues to read as follows:

Authority: Sec. 161. 68 Stat. 948, as amended (42 U.S.C. 2201 ); sec. 201. 88 Stat.

1242. as amended (42 U.S.C. 5841)._

2. In Appendix J.Section III, A.3.[a) is revised to read as follows:

Appendix }-Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors III. Leakage Testing Requirements A. Type A test-* * *

3. Test Methods. (a) All Type A tests shall be conducted in accordance with the provisions of the American National Standard N45.4-1972, "Leakage Ra te Testing of Containment Structures for Nuclear Reactors," March 16, 1972. In addition to the Total Time and Point-to-Point methods

• described in that standard, the Mass Point method, when used with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, is an acceptable method to use to calculate leakage rates. A typical description of the Mass Point method can be found in the American National Standard..

ANSI/ANS--56.8-1987, "Containment System Leakage Testing Requirements," January 20, 1987. 1 Dated at Bethesda, MD, this 17th day of February 1988./

For the Nuclear Regulatory Commission.

Victor Stelle, Jr.,

Executive Director for Operations.

[FR Doc. 88-4228 Filed Z-21HJ8; 8:45 am]

BILLING CODE 7590-01-M FEDERAL TRADE COMMISSION 16 CFR Part 300,301, and 303 Reporting and Recordkeeping Requirements for Wool Products, Fur Products, and Textile Fiber Products AGENCY: Federal Trade Commission.

ACTION: Not_ice of propose~ rulemaking.

SUMMARY

The Federal Trade Commission issues proposel regulations to reduce the burden of complying with the labeling requirements of the Rules and Regulations Under the Woot Products Labeling Act of 1939, the Rules and Regulations Under the Fur Products Labeling Act and the Rules and.

Regulations Under the Textile Fiber Products Identification Act. Under the proposed amendments, the Recordkeeping provisions in each of the three regulations would be simplified 1 ANSI N45.4-1972, "Leakage Rale Tesling of Containment Structures for Nuclear Reaclors*

(da ted March 16. 1972). lncorpora lion o'f ANSI N45.4-1972 by reference was approved by lhe Di rector of the Federal Register on October 30. 1972.

Copies of this standard. as well as ANSI/ ANS-56.6-1987. "Con tainment System Leakage Testing Requirements* (dated Ja nuary 20. 1987) may be obtained from the American Nuclear Society. 555 North Kensington Avenue. La Grange Park. II. 60525.

A copy of each of these standards is ava ilable for inspection at the Commission*s Public Document Room at 1717 H Street NW.. Washington. DC 20555.

M1~rch 15, 1988 OOlKULf U',HkC

'88 HAR 21 P 3 :55 Of F!C::. (r ::::vlt.iAl'I t OOCKEi 1N" A. SERVICf.

BRANCli COMMENTS OF OHIO CIT I ZENS FOR RESPONSIBLE ENERGY, I NC.

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• OCRE * )

ON PROPOSED RULE, 10 CFR 50, "ALTERNATIVE METHOD FOR LEAKAGE RATE TESTING" (53 FED. REG. 5985, FEBRUARY 29, 1988)

OCRE supports this proposed rule.

Amendins Appendix J to allow the us e of the mass point method is overdue.

The amen d ment should be promptly approved in the interest of public safety.

Respectf ully submitted, susc,n L. Hic,tt OCRE Representati v e 8275 Munson Rocid Mentor, OH 44060

( 216 ) 25.5-3158 MAR 2 9 1988.....,.

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D ENVER H O U STON NEW YORK DALL AS PORTLAND, O R RICHLAND. W A WASHINGTON, O.C.

Secretary of the Commiss i on U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn:

Docke ting and Serv ice Branch ALTERNATE METHOD FOR LEAKAGE RATE TESTING (53FR5985)

W. U. TELEX : 94-0001 94-0977 Of FI C

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March 10, 1988 This letter i s in response to t he NRC request f or comment on the proposed amendment of 10CFR50, Appendix J set forth in the Federal Register, 53FR5985 dated February 17, 1988.

We support the proposed rule change to allow the use of the Mass Point Method (as described in ANSI/ANS 56.8-1987) to determine the containment leakage rate when performing a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test.

This method provides a proven way of evaluating contai nment leakage test data.

We appreciate the opportunity to comment on the proposed rule and we hope that it is approved.

R. B.

Chief Engineer, Nuclear Technology and Li cens i ng Divi s i on RBB:fpf

~cknowf"d30d by card MAR 2 1 1988

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