IA-85-136, Forwards marked-up Draft Containment Sys Branch Response to Items in Affidavit Attached to Citizens Against Nuclear Power 840605 Petition Re Integrated Leak Rate Testing at Facility.Containment Integrity Confirmed.Matter Closed

Forwards marked-up Draft Containment Sys Branch Response to Items in Affidavit Attached to Citizens Against Nuclear Power 840605 Petition Re Integrated Leak Rate Testing at Facility.Containment Integrity Confirmed.Matter Closed

ML20140G009
Person / Time
Site:	Zion File:ZionSolutions icon.png
Issue date:	12/03/1984
From:	Houston R Office of Nuclear Reactor Regulation
To:	Lainas G Office of Nuclear Reactor Regulation
Shared Package
ML20140C940	List: IA-85-136, Forwards marked-up Draft Containment Sys Branch Response to Items in Affidavit Attached to Citizens Against Nuclear Power 840605 Petition Re Integrated Leak Rate Testing at Facility.Containment Integrity Confirmed.Matter Closed ML20140C933 ML20140C981 ML20140E041 ML20140F491 ML20140F558 ML20140F607 ML20140F916 ML20140F989 ML20140G009 ML20140G034
References
FOIA-85-136 TAC-55267, NUDOCS 8507120273
Download: ML20140G009 (11)

Text

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MEMOR DUM FOR:

. G. C. Lainas, Assistant Director for Operating Rea . ors, b -

FROK:F R. W. Houston, Assistant Director for Reactor Safety, DSI

SUBJECT:

PETITION FOR EMERGENCY RELIEF: RE ILRT AT ZION, UNIT 1 (TACS 55267)

Reference:

1. Petition for Emergency Relief to the U.S. Nuclear Regulatory Commission, Re: Commonwealth Edison Company, Zion, Unit 1, dated June 5, 1984, Submitted by Citizens Against Nuclear Power

2. Memorandum for D. G. Eisenhut (NRR), from R. L. Spessard (IE),

dated September 7, 1984 In response to Technical Assistance TACS No. 55267, the Containment Systems Branch (CSB) has completed its review of the Petition (Reference 1) and at-tached affidavit by Dr. 2. V. Reytblatt. In essence, the Petition questioned the validity of the containment integrated leak rate test performed on Zion, Unit I during March, 1981. As a result, NRC Region III conducted an independ-

,..JMrs ent investigation of the 1981jtests at Zion, Unit 1. The results of this investigation are documented in Reference 2. The CSB has reviewed the Region III report and concurs in its findings.

T' he Affidavit attached to the Petition is represented by the Petitioner as the technical support to the allegations contained in the Petition. Therefore, in responding to the Petition, the CSB has responded to the pertinent items (12 through 18) of the Affidavit. These responses are contained in the enclosure.

In summary', we have found that most of the Reytblatt comments do not address the nost important aspects of the test. Nevertheless, we concur with the general comment that the containmqnt leak rate as stated in the test report

. nl MP3 could not be verified by the 19814 test res,,ylts.

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licepe of our concern, and indicated that a demonstration of cont'ainment leak tightnessfesymbe necessary for continued operation of Zion, Unit 1.

shut 7 On July 18, 1984, CommonwealthEdisonCompany,[ftheirown-volit ,

down Zion, Unit 1, and performed an integrated leak rate test during the period from July 27 to August 1,1984, under close supervision of the NRC inspectors.

i This ILRT was found successful and we conclude that containment integrity has been confirmed and verified. We, therefore, consider the subject matter closed.

R. Wayne Houston, Assistant Director for Reactor Safety Division of Systems Integration

Enclosure:

As stated cc: R. M. Bernero D. G. Eisenhut R. L. Spessard, RIII F. Maura, RIII J. Norris G. Arndt M g

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CSB RESPONSES TO ITEMS 12 THROUGH 18 0F THE REYTBLATT AFFIDAVIT ON THE 1981 ZION, UNIT 1 CONTAINMENT INTEGRATED LEAK RATE TEST d

12. ent logs of the 1981' Test, a sdmmary of which is contained in the CECO

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_ st Report, describe the following events on March 12, 1981:

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1. From page 10:

"0300 Completed normal ILRT at data set #326."

"0429 Began induced leakrate test."

"1200 HUT recirc. pump stopped."

Reytblatt's Comment:

This quotation means that approximately ninety minutes after the completion of the Basic Test, a Verification Test (the " induced leakrate test") was performed, but it did not yield the expected results. The Verification Test did not validate the satisfactory performance and reliability of the Basic Test.

CSB Response:

A review of the 1981 Test indicates the calculated leak rate from the Basic Test is 0.0158 w/o/ day, which is only a small fraction of the 511owable leak rate for the Zion containment. ~

A small leak rate is

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• g difficult to verify, especially when the small imposed leak rate for the verification test is also small. This is what happened durin the 1981

' Zion test. . From .y' the available t'est data, the difference between the Basic

. s 1. 0Y est and th erification Test was as high as 0 ,rather'tkanwithin the 0.25 L, limit. - AltW'T'Tiva Veri s icacionst did .ist-vei ; .y i.iie calculated %k rate-from the _b.asic__tae+ wi+ hin-t-ha equired accuracy, it is not appropriai.e, unen,-to-furthcr- uvriclude-that thc Basic f b

.Tes,tm; c e e (u)_, } crg{at>lggr p.g'< geremence I was-unsatisfactory

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W ii. From the same page:

, "3400 Re-initialized imposed leak calculations from 369."

Reytblatt's Comment:

This quotation shows that eleven hours after the completion of the Bzsic Test, a second Verification Test was performed, and again failed to prove the validity of the Basic Test.

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I,"_rdlL14{ /g s w ir,. ,a1 Reytblatt misinterpret ~ed the . test scendio; Ziop 'did not, perform .a "secondifs A /n

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Ve'rifica). ion Test," but ra her a sec/ond calcu'lation wa/s perfor ed us/ingal l af+ %

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. different set of data.Trom the'same continuous Vfificatpfi Te3.] The- - -

second calculaticTr gave a result within 0.34 L ,Bwhich again exceeded the k t' required accuracy of 0.25 La. . W 5 ,ph..cy3 es% .b.

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iii. From the same page:

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. "1700 Re-initialized from 367. . ,.

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? 1745 Terminated imposed leak test at set 405."

Reyblatt's Comment:

This means that fourteen hours after the completion of the Basic Test, a third Verification ~ Test was started. This Verification Test was completed in forty-five minutes, and waf' deemed to be a proof of validity of the Basic Test.

CSB Response:

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%pipp Reytblatt misinterpreted the _the scenario.// nly one Verification Test i

f a l..c was performed, and lasted for about-Rhteen hoursy.d Tieaan d='es. How-ever, three calculations were performed using three different sets of data from the sane Verification Test. The third calculation showed that the result l fell within the required accuracy of 0.25 L,.

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l It is acceptable to conduct several verification tests, if valid reasons are given for the unacceptability of previous verification tests. In the case of l

Zica, however, the Verification Test violated certain principles of statistics.

l In order to obtain the required accuracy of 0.25 L*, the licensee selected,

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-pest-tWthe /' esired d data set. Therefore, from a statistical standpoint, the I

1981 Basic Test result is not acceptable. The Verification Test data was not l

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obtained in an appropriate manner for use in demonstrating the acceptability of the 1981 Basic Test leak rate.

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rom page 15 of the Ceco Test Report:

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"IW Tank Volume Change 4

Date Level Volume Added inches inches gallons" "3-11-81 20.5 9.5 47.0 3-12 21.0" Reytblatt's Comment:

This quotation pro've's that on March 12, 1981 - during the same time period that these Verification Tests were carried out - a procedure known as IW (" Irrigation Water Injection") had been applied to the containment environment. A total of approximately 44 gallons of water was injected, which might have substantially changed the containment environment.

CSB Response:

Reytblatt has drawn conclusions af ter quoting the CECO Tes t out ]

context. Our review of the 1981 test indicates hatwat[fwas on ~L ' to be leakibg into the containment during the spond day of data taking, and that

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5 this continued until the end of the verification test. Although we do not condone the water leakage problem during the test, we disagree thal.i the con- '

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was substantially changed during the verificat@n test.

Sineb wa:ter leakage had occurred for seven days prior to the start of the Verification Test, . containment conditions should have been comparable during both the Basic Test and the Verification Test.

Reytblatt's Comment:

13. Failure of the first Verification Test proves that the Basic Test had been deficient.

CSB Eesponse:

We acknowledge that the Verification Test result, based on the first data sct, did not verify the leak rate of the Basic Test within the required accuracy (10.25 L,). However, h6 do not agree that this " proves," a .

priori, the Basic Test was deficient.l.'d'd' hj"" g ht;"" JG tua 6ihn/ fish

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14. Failure of the second Verification Test provides further confirming evidence that the Basic Test had been deficient.

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pmr CSB Response:

d Again the licensee did not perform a second Verification Test; rather, a

- . . A secon ciculation a was done using a different data set from the sam'e' Verifica-tion Test. id not verif the Basic Test result. Taken This calculation dod+amalso p% r ausswp . s. /bf & cussM alone, it does not confirm that thef B::ic Test was eficient.

Reytblatt's Comment:

15. The Verification Test should be conducted immediately upon conclusion of the Basic Test, so that there will be little risk of changes occurring in the containment environment. However, during the 1981 Test, in fourteen hours since the completion of the Basic Test, two Verification Tests failed, and also, due to the IW application, significant alteration in the containment environment may have occurred. The third Verification Tcst therefore cannot be considered valid.

CSD Response:

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Reytblatt failed to understand that there was only one continuous Verification J ~T hs. [g.,

Test conducted, which lasted thi+ teen hours.end iiiiec -%ut^0. He also f ailed to understand that the IW application actually started very early in the test, and was not an event that suddenly occurred during the Verification I

, Test. Therefore, it is not a question of whether the Verification Test should L

i be considered valid, or the Basic Test deficient, but rather a question of j whether the Verification Test had verified the\bepe. Ld ' :t 7;te vf G.0158

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16. By not analyzing the reasons why'the Verification Tests failed.,and by

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jhoGepeating the Basic Test, which was certainly necessary under these circumstances, the testing organizatinn violated the Standard.

CSB Response: ,,

Appendix J to 10 CFR 50 requires that if the supplemental test result is not within 0.25 L,, the reason shall be determined, corrective action taken, and a successft1 supplemental test performed. Our review of the 1981 test indicues that the licensee did not establish a valid reason for the inability to verify the Basic Test result after using two data sets from the supplemental test (Verification Test), and failed to perform a subsequent, successful supplemen-

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tal test. nstead, the licensee inade a t4 ate) -pest-testTe' ctTon~5f~~

Giata from the same Verificatio'n Test to establish the required accuracy of the t '.L.,.4 -J.,d "

Basic Test result. The Trstdext selection of data is unacceptable from a j ^

statistical standpoint. Therefore, we conclude that the 1981 Test did not comply with the requirements of Appendix J in that a successful supplemental test had not been performed.

Reytblatt's Comment:

'17. In my opinion, it is inconceivable that the testing organization had no knowledge of the unacceptability of repeated Verification Tests. More-over, out of three Verification Test results, two of which showed the Basic Test to be deficient, the test ng organization selected the third q - -- r k.

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Verification Test results, although these results were obtained after the containment environment may have significantly changed. In my opinion,

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oo CSB Response' as presented, egnend tr.-1de based on a misunder-Reytblatt's df qomment stWA- is, M g standing of(the Verification Test. Nevertheless, our review of the 1981 test indicates that the testing organization misused the Verification Test data.

Consequently, the 1981 Test was judged to be incomplete and inconclusive.

Reytblatt's Comment:

18. In summary, the 1981 test is invalid and provides no assurance whatever that the Zion, Unit I reactor containment leak rate is as stated in the

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Test Report.

CSB Resconse: [

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' The finality expressed in the Reytblatt summary concerning the overall merits [

of the 1981 Test is an overstatement and somewhat inappropriate. We have judged the 1981 Test to be incomplete and inconclusive, in that the Basic Testi c.c '

result was not appropriately verified, as required by Appendix J.,~Y,,_.thsee-foce1 informed the licensee of our finding and indicated that a demonstration toca of containment integrity sn=he necessary for continued operation of Zion, Unit

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$&- , 1984 and a satisfactory Type A test was performed.

A--_ NRC .inspecto.s were present as observers throughout the course of the test. A detailed review of the Zion, Unit 1 Type A tests performed in 1981,1983, and 1984 is:I phsented in

}; A the: staff report from R. L. Spessard, Division of Reactor Safety, Region III, to'D. G. Eisenhut, Division of Licensing, NRR, dated September 7,1984.

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