Information Notice 1985-71, Containment Integrated Leak Rate Tests

Containment Integrated Leak Rate Tests

ML031180640
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	08/22/1985
From:	Jordan E NRC/IE
To:
References
IN-85-071, NUDOCS 8508200623
Download: ML031180640 (7)

SSINS No.: 6835 IN 85-71 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, D.C. 20555 August 22, 1985 IE INFORMATION NOTICE NO. 85-71: CONTAINMENT INTEGRATED LEAK RATE TESTS

Addressees

All nuclear power reactor facilities holding an operating license (OL) or a

construction permit (CP).

Purpose

This information notice is provided as a notification of a potentially signifi- cant problem pertaining to containment integrated leak rate tests (CILRTs). It

is expected that recipients will review the information for applicability to

their facilities and consider actions, if appropriate, to preclude a similar

problem occurring at their facilities. However, the suggestion contained in

this information notice (namely, that licensees review their programs with

respect to the guidelines provided), does not constitute an NRC requirement.

Therefore, no specific action or written response is required.

Description of Circumstances

Recent staff reviews of the CILRTs performed at San Onofre, Kewaunee, and

Monticello nuclear power plants have indicated that many utilities are misin- terpreting the relationship between local leak rate testing and CILRTs. 10 CFR

50, Appendix J, discusses containment leakage testing in terms of Type A, B,

and C tests. The Type A test is a measurement of the overall integrated

leakage rate of the primary containment; whereas Type B and C tests are local

leak rate tests designed to detect and measure local leakage across each

pressure-containing or leakage-limiting boundary for primary containment.

As a result of Type B and C tests, some utilities are performing repairs and

adjustments before conducting Type A tests without properly adjusting the Type

A test results for the Type B and C leakage rates. Without this adjustment, the "as found" condition of the primary containment cannot be properly determined.

In some cases, when this adjustment is made properly, a Type A test may fail to

meet the acceptance criteria of Apprndix J with regards to the "as found"

condition. When two successive Type A test failures occur, Appendix J requires

more frequent CILRTs. However, if Type B and C leakage rates constitute an

identified contributor to this failure of the "as found" condition for the

CILRT, the general purpose of maintaining a high degree of containment integrity

might be better served through an improved maintenance and testing program for

8508200623

IN 85-71 August 22, 1985 containment penetration boundaries and isolation valves. In this situation, the licensee may submit a Corrective Action Plan with an alternative leakage

test program proposal as an exemption request for NRC staff review. If this

submittal is approved by the NRC staff, the licensee may implement the corrective

action and alternative leakage test program in lieu of the required increase in

Type A test frequency incurred after the failure of two successive Type A

tests.

Discussion:

Sections III.D.1.a, 2.a and 3.a of Appendix J require that a set of three

periodic Type A tests be performed at approximately equal intervals during each

10-year service period, and that Type B and C tests be performed during reactor

shutdown for refueling but in no case at intervals greater than 2 years. Under

these test requirements, there are many occasions when Type A, B, and C tests

must be performed during the same reactor shutdown period. Questions are

frequently raised concerning the correct sequence of conducting the Type A, B,

and C tests and the potential impact of the results of the Type B and C tests

on the success or failure of a periodic Type A test.

The NRC staff has previously provided partial guidance to utilities on these

questions on an individual case basis with respect to inspection and enforce- ment activities (see Attachment 1). The staff position on these questions, as

previously employed in inspection and enforcement, may be summarized as

-fo-llows.:- -

1. Section III.A.3 of Appendix J requires that all CILRTs be conducted in

accordance with the provisions of ANSI N45.4-1972. Paragraph 4.2 of ANSI

N45.4-1972 states that for periodic CILRTs no repairs or adjustments are

to be made to the containment structure prior to conducting the test in

order to disclose the normal state of repair of the containment structure.

2. Type B and C tests may be performed either before the start of or after

completion of the periodic Type A test provided that the pretest require- ments of Paragraph 4.2 of ANSI N45.4-1972 and Section III.A.1.a of Appen- dix J are met; i.e., no repairs or adjustments to the primary containment

boundary are made so that the containment can be tested in as close to the

"as is" condition as practical. As such, the leakage information obtained

from the "as is" (sometimes called "as found") Type A-test results can be

used to assess the containment condition and its integrity following a

period of plant operation.

3. If repairs or adjustments performed as a result of the Type B and C

testing programs or for any other reasons are made to the primary contain- ment boundary before the Type A test sequence, local leak tests must be

performed on the affected portion of the containment boundary to determine

the minimum pathway leakage rates before and after the repairs or adjust- ments are made. The minimum pathway leakage would be the smaller leakage

rate of in-series valves tested individually, one-half the leakage rate

IN 85-71 August 22, 1985 for in-series valves tested simultaneously by pressurizing between the

valves, and the combined leakage rate for valves tested in parallel. The

"as found" Type A test results can then be obtained by adding the differ- ences between the affected minimum path leakage before and after repairs

or adjustments to the overall measured Type A test result. A periodic

Type A test would be called a "failure" if the "as found" Type A test

result (with appropriate correction from local leak tests) exceeds the

acceptance crtieria of Appendix J.

4. -The question has been raised by various utilities as to how far in advance

of the Type A test the Type B and C tests may be conducted without having

to add the leakage differences to the Type A test results. The staff

position on this question has been that after Type B and C tests, the

penetrations and valves should experience some period-of normal service

conditions before the Type A test. If the Type B and C tests are con- ducted before the Type A test during the same refueling outage, the

service condition criterion would not be met. If, however, some operating

service time is achieved, the Type A test can be conducted essentially

independent of the time duration of exposure to the normal service condi- tions. Thereafter, a Type A test could be conducted without having to

consider the local leak rate results in determining the "as found"

condition.

The continuance of containment leak-tight integrity is the primary importance

in performing Type A, B, and C tests. Therefore, it may be beneficial for li- censees to implement improved maintenance and testing programs for containment

penetrations to ensure that known or likely leaking penetrations will not result

in the overall loss of containment leak-tight integrity and in the ensuing

penalties for Type A test failure.

It should also be noted that containment leak-tight integrity is monitored

between CILRTs through the Type B and C test programs. Failure to meet the

acceptance criteria of Appendix J for those tests generally constitutes a loss

of containment integrity as defined in the Technical Specifications and may be

reportable by the licensee under the provisions of 10 CFR 50.73., Sections

(a)(2)(ii) and (a)(2)(v)(C).

It is suggested that licensees review their CILRT program with respect to the

above guidelines.

IN 85-71 August 22, 1985 No specific action or written response is required by this information notice;

however, if you have any questions regarding this notice, please contact the

Regional Administrator of the appropriate NRC regional office or the technical

contacts listed below.

ar. /ardan, rec or

Division 10 Emergency Preparedness

and Enineering Response

Office of Inspection and Enforcement

Technical Contacts: Y. S. Huang, NRR

(301) 492-9493

0. C. Kirkpatrick, IE

(301) 492-4510

S. A. McNeil, IE

(301) 492-9602 Attachments:

1. Documentation from NRC to Utilities, Related to Repairs and

Adjustments Done Prior to Type A Tests

2. -List of-Recently Issued IE Information Notices

Attachment 1 IN 85-71 August 22, 1985 Documentation from NRC to Utilities, Related to

Repairs and Adjustments Done

Prior to Type A Tests

1. Letter to Consumers Power Company from R. L. Spessard, "Big Rock Point

CILRT Schedule," February 3, 1983 This letter informed the licensee of the necessity to increase the CILRT

frequency because of the failure of two consecutive Type A tests conducted

in 1977 and 1982. During the 1982 refueling outage, Type B and C tests

were conducted and several valves were found to leak excessively and were

repaired. Subsequently the Type A test was conducted and the licensee

reported a successful test, but it did not include the initial Types B and

C leakage in the Type A test results. The NRC staff reviewed the tests

and determined that the Type B and C leakage should be added to the Type

A test results, because the plant had not been in service between the time

of the Type B and C tests and the Type A test. With the addition of the

Type B and C leakage to the Type A test result, the leakage was excessive

and the containment was deemed to have failed the "as found" test

condition.

2. Letter to Commonwealth Edison Company from R. L. Spessard, "Quad Cities

Unit 1 Containment Integrated Leak Rate Test Frequency," October 7, 1983.

This letter also informed the licensee of the necessity to increase the

CILRT frequency because of the failure of two consecutive Type A tests.

These tests were conducted in 1979 and 1982. Type B and C tests conduct- ed during the 1982 refueling outage, prior to the Type A test, showed that

the combined leakage from several valves exceeded the allowable Technical

Specification. In addition, the seal between the drywell head and the

drywell vessel flange was found to be leaking to such an extent that the

leakage could not be measured. The licensee repaired these leaks and then

conducted a Type A test that showed the leakage to be within the allowable

limits. The NRC staff, however, determined that the containment had

failed the CILRT with respect to the "as found" condition. This determi- nation was based on the position that the Type B and C test results could

be excluded from the "as found condition" only if some period of normal

station service existed between Type B and C tests and the Type A test.

3. Inspection Report No. 50-305/84-19 (DRS), Kewaunee, November 27, 1984 and

Notice of Violation to Wisconsin Public Service Corporation - Docket No.

50-305, November 28, 1984.

Attachment 1 IN 85-71 August 22, 1985 The inspection report discusses an exemption to Appendix J issued to

Wisconsin Public Service Corporation by the NRC. The exemption permitted

Type B and C tests and repair work on penetrations to be performed at

Kewaunee before Type A tests were conducted. The exemption required that

leakage reduction caused by the repairs be added to the Type A test result

for the purpose of evaluating the "as found" condition. The licensee then

wrote to the NRC stating that it did not believe that an exemption was

required to perform Types B and C tests before performing a Type A test.

The licensee based this on the belief that Type A testing and Type B and

C testing were two separate events performed on two separate schedules.

In 1984, the licensee performed Type B and C tests before performing the

Type A test and failed to add the pre- and post-repair differential

leakage to the "as found" Type A test results in its CILRT report. As

stated in the inspection report, the NRC staff did not agree with the

licensee's position because Type B and C testing (with repair) would

invalidate part of the purpose of the Type A test (that is, to establish

the "as found" condition). As a result, the notice of violation covering

this failure was issued on November 28, 1984.

4. Inspection Report No. 50-206/85-12 San Onofre Unit 1, April 5, 1985.

Paragraph 6 of this report discusses the results of the CILRT performed at

-San -Onofre-during 1985. Type C testing and repair work was performed on

six sets of valves just before the Type A test was conducted. However, differential leakage resulting from the repair was not added to the Type A

test results reported. As a result a notice of violation covering this

failure is under consideration.

Attachment 2 IN 85-71 August 22, 1985 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

Information Date of

Notice No. Subject Issue Issued to

85-70 Teletherapy Unit Full 8/15/85 All material

Calibration And Qualified licensees

Expert Requirements (10 CFR

35.23 And 10 CFR 35.24)

85-69 Recent Felony Conviction For 8/15/85 All power reactor

Cheating On Reactor Operator facilities holding

Requalification Tests -an OL or CP

85-68 Diesel Generator Failure At 8/14/85 All power reactor

Calvert Cliffs Nuclear facilities holding

Station Unit 1 an OL or CP

85-42 Loose Phosphor In Panasonic 8/12/85 Materials and fuel

Rev. 1 800 Series Badge Thermo- cycle licensees

luminescent Dosimeter (TLD)

Elements

85-67 Valve-Shaft-To-Actuator Key 8/8/85 All power reactor

May Fall Out Of Place When facilities holding

Mounted Below Horizontal Axis an OL or CP

85-66 Discrepancies Between 8/7/85 All power reactor

As-Built Construction facilities holding

Drawings And Equipment an OL or CP

Installations

85-65 Crack Growth In Steam 7/31/85 All PWR facilities

Generator Girth Welds holding an OL or CP

85-64 BBC Brown Boveri Low-Voltage 7/26/85 All power reactor

K-Line Circuit Breakers, With facilities holding

Deficient Overcurrefit Trip an OL or CP

Devices Models OD-4 and 5

85-63 Potential for Common-Mode 7/25/85 All power reactor

Failure of Standby Gas Treat- facilities holding

ment System on Loss of Off- an OL or CP

Site Power

OL = Operating License

CP = Construction Permit