Information Notice 1998-13, Post-Refueling Outage Reactor Pressure Vessel Leak Testing Before Core Criticality
05-9
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
April 20, 1998
NRC INFORMATION NOTICE 98-13: POST-REFUELING OUTAGE REACTOR PRESSURE
VESSEL LEAK TESTING BEFORE CORE CRITICALITY
Addressees
All holders of operating licenses for nuclear power reactors except those that have permanently
ceased operations and have certified that fuel has been permanently removed from the reactor
vessel.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert
addressees of the requirement to complete pressure tests and leak tests of the reactor
pressure vessel (RPV) before core criticality. It is expected that recipients will review the
information for applicability to their facilities and consider actions, as appropriate, to avoid
similar problems. However, suggestions contained in this information notice are not NRC
requirements; therefore, no specific action or written response is required.
Background
Under the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME
Code) , Section Xl, Class 1 and 2 leakage tests provide a level of defense-in-depth for detecting
pressure boundary leakage. From a safety perspective, performing this test using nuclear heat
defeats the intended purpose of ensuring the integrity of the RPV as a fission product barrier.
A December 1995 rule change to Part 50 of Title 10 of the Code of Federal Regulations
(10 CFFtlParts50), Appendix G,Section IV.A.2.d, clarified the staff position as follows:
"Pressure tests and leak tests of the reactor vessel that are required by Section Xi of the ASME
Code must be completed before the core is critical' The final rule was published in the Federal
Register on December 19, 1995. In addition, the Federal Register notice referenced a letter to
Messrs. Reynolds and Stenger of the Nuclear Utility Backfitting and Reform Group (NUBARG)
from James M. Taylor, NRC Executive Director for Operations, dated February 2, 1990, in
which Mr. Taylor discussed the explicit prohibition of using nuclear heat to perform pressure
and leak tests (Accession Number 9002120362).
6
~
?D
Aft
E £ODT[69-0131 Rso0
IN 98-13 April 20, 1998
Description of Circumstances
On June 22, 1997, the licensee for Quad Cities Station performed the required ASME Code, Section Xl leak test of the RPV following Unit 2 criticality and startup from a refueling outage.
The reactor was at approximately 12-percent power. On October 1, 1997, while reading
Appendix G for guidance on a separate issue, the licensee discovered that it had violated the
requirement to complete pressure and leak testing before the core is taken critical.
In December 1997, a Region IlIl inspector reviewed (1) ASME Code Class I system pressure
tests for the Quad Cities Units 1 and 2 refueling outage 14 and (2) problem identification
forms (Inspection Report 50-254/97-27, Accession Number 9803170418). The licensee had
previously documented the violation that took place on June 22, 1997, of Appendix G
requirements in one of the problem identification reports. The Inspector found that the visual
VT-2 examinations of the Unit 2 drywell area required by the ASME Code were conducted in a
very short time. In an effort to keep exposure time to a minimum, licensee personnel covered
very large examination areas in a very short time (e.g., 50 examination areas in 12 minutes).
The short examination time called into question the adequacy of the visual VT-2 examinations.
The NRC and the licensee discussed apparent violations during an open, predecisional
enforcement conference that took place on January 9, 1998. On March 12, 1998, the NRC
issued a Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $330,000
for violations of Appendix G to 10 CFR Part 50, 10 CFR 50.59, and Technical Specification
surveillance requirements.
Discussion
This issue is of significant concern because licensees should recognize that the intent of
performing the ASME Code pressure and leak tests before the reactor is taken critical is to
ensure the integrity of the RPV without using nuclear heat. The staffs position has been, and
continues to be, that performing pressure and leak tests after the core is critical is
unacceptable. This point was clarified in the December 1995 rule change.
4
K>
IN 98-13 April 20, 1998 This information notice requires no specific action or written response. However, recipients are
reminded that they are required to consider industry-wide operating experience (including NRC
information notices) when practical and when setting goals and performing periodic evaluations
under 10 CFR Section 50.65, "Requirement for Monitoring the Effectiveness of Maintenance at
Nuclear Power Plants," If you have any questions about the information in this notice, please
contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor
Regulation (NRR) project manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Andrea D. Lee, NRR
301-415-2735 E-mail: adwl
nrc.gov
Melvin Holmberg, Rill
630-829-9748 E-mail: mshenrc.gov
Attachment: List of Recently Issued NRC Information Notices
Tech Editor had concurred on 3118198
1 J
(
DOCUMENT NAME: G:NVERN\\CRITLEAK.IN
- See Previous Concurrence
INDICATE IN BOX: "C"=COPY W/O ATTACHMENTIENCLOSURE, "E"COPY WIATI
"N"NO COPY
I
Attachment
April 20, 1998
Page 1 of I
LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
98-12 Licensees' Responsibilities
4/3198
All U.S. Nuclear Regulatory
Regarding Reporting and Follow-up
Requirements for Nuclear-Powered
Pacemakers
Commission nuclear pacemaker
licensees
98-11
Cracking of Reactor Vessel
Internal Baffle Former Bolts
in Foreign Plants
3/25/98
All holders of operating licensing
for pressurized-water reactors
(PWRs) except those who have
ceased operation and have
certified that fuel has been
permanently removed from the
reactor vessel.
95-52, Supp.1
Fire Endurance Test Results
for Electrical Raceway Fire
Barrier Systems Constructed
From 3M Company Interam
Fire Barrier Materials
3/17/98
All holders of operating
licenses for nuclear power
reactors except those who
have permanently ceased
operation and have certified that
fuel has been permanently
removed from the reactor vessel.
98-10
98-09
98-08
Probable Misadministrations
Occurring During Intravascular
Brachytherapy With The
Novoste Beta-Cath System
Collapse Of An Isocam II
Dual-Headed Nuclear
Medicne Gamma Camera
Information Likely To Be
Requested If An
Emergency Is Declared
Offsite Power Reliability
Challenges from Industry
Deregulation
3/9198
315/98
3/2/98
2/27/98
All Medical Licensees
All Medical Licensees
All Parts 30,40, 70, 72, and
76 licensees and certificate
holders required to have a
Nuclear Regulatory Commission- approved Emergency Plan.
All holders of operating licensees
for nuclear power reactors
98-07 OL = Operating License
CP = Construction Permit
I
IN 98-13 April 20, 1998 This information notice requires no specific action or written response. However, recipients are
reminded that they are required to consider industry-wide operating experience (including NRC
information notices) when practical and when setting goals and performing periodic evaluations
under 10 CFR Section 50.65, "Requirement for Monitoring the Effectiveness of Maintenance at
Nuclear Power Plants," If you have any questions about the information in this notice, please
contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor
Regulation (NRR) project manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Andrea D. Lee, NRR
301-415-2735 E-mail: adwl@nrc.gov
Melvin Holmberg, Rill
630-829-9748 E-mail: msh@nrc.gov
Attachment: Ust of Recently Issued NRC Information Notices
Tech Editor had concurred on 3/18/98 DOCUMENT NAME: G:\\VERN\\CRITLEAK.IN
- See Previous Concurrence
N DICATE IN BOX: "C"=COPY WIO ATTACHMENTIENCLOSURE, "E"=COPY WIATTIENCL, "N"=N0 COPY
OFFICE
EMCB:
E EMCB:DE
(A)D:DE
E
C:PECB
l
(A)D:DRP il
NAME
ADLee
l klidhman
n
I GLainas*
SRichards
JLieberman*
JRoe*
ill
I,
DATE
IN 98-XX
Marchxx, 199
Page 3 of
This information notice requires no specific action or written response. Ho
er, recipients are
reminded that they are required to consider industry-wide operating ex
ence (including NRC
information notices) when practical and when setting goals and perfo
ing periodic evaluations
under 10 CFR Section 50.65, "Requirement for Monitoring the Effe iveness of Maintenance at
Nuclear Power Plants," If you have any questions about the inf
ation in this notice, please
contact one of the technical contacts listed below or the appr
riate Office of Nuclear Reactor
Regulation (NRR) project manager.
Jack
AV/koe, Acting Director
fn of Reactor Program Management
of Nuclear Reactor Regulation
Technical contacts:
Andrea D. Lee,
301-415-2735 E-mail: adw@i
Melvin
Attachment: List of
Issued NRC Information Notices
DOCUMENT
INDICATE IN BOX: "C"
OFFCE
MCB
Previous Concurrence
COPY
OFFICE
I EMCB:
IN 98-XX
March xx, 1998 This information notice requires no specific action or written response. However, recipients are
reminded that they are required to consider industry-wide operating experience (including NRC
information notices) when practical and when setting goals and performing periodic evaluations
under 10 CFR Section 50.65, "Requirement for Monitoring the Effectiveness of Maintenance at
Nuclear Power plants," If you have any questions about the information In this notice, please
contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor
Regulation (NRR) project manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Andrea D. Lee, NRR
301-415-2735 E-mail: adwl@nrc.gov
Melvin Holmberg, Rill
630-829-9748 E-mail: msh@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: G:%VERN\\CRITLEAK.IN
- See Previous Concurrence
INDICATE IN BOX: "C"=COPY W/O ATTACHMENTIENCLOSURE, "E"=COPY WIATTIENCL, "N"N=
COPY
IOFFICE
EMCB:DE
l
DDET E
C
J
(A)D:DRPM
NAE
ADLee*
KWichman
v
GLainas*
SRichards
JUeberman- JRoe
DATE
3 /3 /98
3/38
3/12/98
__8
3116/98
3/
/98
OFFICIAL RECORD COPY
IN 98-XX
March xx, 1998 This information notice requires no specific action or written response. However, recipients are
reminded that they are required to consider industry-wide operating experience (including NRC
information notices) when practical and when setting goals and performing periodic evaluations
under 10 CFR Section 50.65, "Requirement for Monitoring the Effectiveness of Maintenance at
Nuclear Power plants," If you have any questions about the information in this notice, please
contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor
Regulation (NRR) project manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts:
Andrea D. Lee, NRR
301-415-2735 E-mail: adwl@nrc.gov
Melvin Holmberg, Rill
630-829-9748 E-mail: msh@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DOCUMENT NAME: G:\\VERN\\CRITLEAK.IN
See Previous Concurrence
INDICATE IN BOX: CCOPY W/O ATTACHMENTIENCLOSURE, 'ELECOPY WIATTIENCL, 'NNO COPY
OFFICE
EMCB:DE I E EMCB:DE
(A)D:DE I E
C:PECB
D:OE
(A)D:DRPM
NAME
ADLee*
KWIchman *
GLainas*
SRichards
JUeberman
JRoe
DATE
3 /3 /98
13//98
3112 /98
31 /98
13/16198
31 _98
OFFICIAL RECORD COPY
IN 9X-XX
Month XX, 199X
Page X of X
power plants," to Part 50 of Title 10 of the Code of Federal Regulations.) If you have any
questions about the Information in this notice, please contact the technical contact listed below
or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Jack W. Roe, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact(s): Andrea D. Lee, NRR
(301) 415-2735 E-mail: adwl@nrc.gov
Melvin Holmberg, Rill
(630) 829-9748 E-mail: msh@nrc.gov
Attachment: List of Recently Issued NRC Information Notices
DISTRIBUTION
PUBLIC
EMCB RFIPF
File Center
MHolmberg, Rill
MMayfield (RES)
DOCUMENT NAME: G:\\LEE\\QUAD IN2.WPD
See Previous Congurrence
IaIfmclms
W Nfy.
ROX
dlVPY Win ATTACHMUElTENCLOSURE. SE-COPY WIATThENCL
NN".NO COPW
OFFICE
EICB:DEV E EMCB:DE
(A
D:
D:PECB
NAME
ADLee
KWchiman
as
Jeberman
JRoe
DATE
3 /3 /98
3 /3/8418<t
/98
/98 OFFICIAL RECORD COPY
-
IN 9X-XX
Month XX, 199X
Page X of X
In addition, there was a lack of knowledge of the change in the applicable regulation.Which
suggests a weakness in the method for disseminating rule changes to the onsite
if. This
raises a larger concern with regard to how licensees with multiple sites ensureiat their sites
receive information each time a rule is changed. It should also be noted that
o formal onsite
staff review occurred prior to the decision to perform the pressure test afte criticality.
This informatiqn notice requires no specific action or written response
owever, recipients are
reminded that t1ey are required to consider industry-wide operating
perience (including NRC
information notices) where practical, when setting goals and perfo
ing periodic evaluations
under Section 50.65, "Requirement for monitoring the effectivenss of maintenance at nuclear
power plants," to Part 50 of Title 10 of the Code of Fed
.
..) If you have any
questions about the inkormation in this notice, please conta
e technical contact listed below
or the appropriate Offi&,of Nuclear Reactor Regulation (N
) project manager.
Jack
.Roe, Acting Director
Diviin of Reactor Program Management
ce of Nuclear Reactor Regulation
Technical contact(s): Andrea D. Lee,
(301) 415-2735 E-mail: adwi
r
Melvin Hol6 b
(630) 8
9748 E-ma mshenr
Attachment: List of ecentlv Issued NIRC Information
MMayfield (RES)
File Center
DOCUMENT NAME: G:\\LEE\\QUAD N2.WPD
/*
INDICATE IN BOX:L 'CCOPY W10 ArTACHMENTIE
LOSURE. -E".COPY WiATTAENcL -NuNo COPY
OFFICE
EMCB:DE
E:t B
_J
l (A)D:DE
I
D:OE ZZ
D:PECB
I
NAME
l ADLeKS
7i
GLainas
JUeberman
JRoe
DATE
13 /3/98 J5t
/98
1 198l
I
/98
OFFICIAL RECORD COPY
f V