ML15244A653
| ML15244A653 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Fermi, Catawba, McGuire  |
| Issue date: | 06/20/1991 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Zwolinski J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15244A654 | List: |
| References | |
| NUDOCS 9106270276 | |
| Download: ML15244A653 (5) | |
Text
MEMORANDUM FOR:
John A. Zwolinski, Assistant Director for Region III Reactors, Division of Reactor Projects for Regions III, IV, V and Special Projects, Office of Nuclear Reactor Regulation FROM:
Hubert J. Miller, Director, Division of Reactor Safety, Region III
SUBJECT:
REQUEST FOR ASSISTANCE -
INTERPRETATION OF REQUIREMENT FOR CONTAINMENT PENETRATION LOCAL LEAK RATE AS-FOUND TESTING (AITS 91-0310)
In the past the Region III staff has taken the position that as-found testing of containment penetrations was required whenever a Type B or C surveillance test was scheduled (e.g.,
during each refueling outage).
We have also informed licensees that the as-found local leak rate test can be waived for those penetrations which the licensee knows are leaking, as long as the licensee is willing to record them as failed with indeterminant leakage. We have taken this position based on our interpretation of 10 CFR Part 50, Appendix J, Paragraph III.C.1, and 10 CFR Part 50, Appendix B, Criteria XI and XVI. The latter requirements are normally implemented by the licensee's Quality Assurance program through reference to ANSI N18.7-1976, Sections 5.2.7.1, 5.2.8, 5.2.11, 5.2.19, and 5.3.10. These sections require that surveillance tests be conducted to determine the condition of components and that these surveillances be sufficient to determine that repairs or replacements will be effective in correcting deficient conditions.
In addition, we-feel that the letter from T. E. Murley to Duke Power Company dated July 27, 1989, with regards to the Type A testing backfit appeal, agrees with our position on as-found testing of containment penetrations. These specific requirements are discussed in the Attachment to this request.
Recently, the Detroit Edison Company (DECo) took the position that for outages for which a Type A test is not scheduled, as-found testing of containment penetrations is not required prior to the performance of maintenance which would affect the leak tightness of the penetration and that they do not have to declare the penetration to have failed. The licensee does recognize that as-found testing is required during an outage when a Type A test is conducted. The Region III staff disagrees with DECo's position.
106:270~276 910620 PDRc
John A. Zwolinski 2
J 0 IM We request that NRR establish the official NRC position on this issue. Messrs. J. Kudrick and J. Pulsipher of the Plant Systems Branch have been briefed on this issue.
2!-GNAL SGNED B HUJ
- J. iLLE Hubert J. Miller, Director Division of Reactor Safety Region III
Attachment:
As stated cc w/attachment:
J. Kudrick, PSB/NRR J..Pulsipher, PSB/NRR G. Arndt, RES P. K. Eapen, RI H. Whitener, RII W. Seidle, RIV B. Faulkenberry, RV RIII I
RIII RIII RIII Maura/cg Phillips right Hasse Martin Miller 06//9/91 06//? /91 06/V/91 06/ 4 /91 06/Cj /91 06/10/91
Attachment Requlatory Basis for As-found Type B and C Testing
Background
The issue is whether or not as-found Type B and C local leak rate testing of containment penetrations is required during non-Type A test refueling outages. The Region III staff position has.been that as-found local leak rate tests are required. However, a licensee may declare a penetration to have failed in lieu of performing the as-found test. Region III has stated this position to licensees since the issuance of Appendix J. This position is based on two separate regulatory specifications, 10 CFR Part 50, Appendix J, Section III.C.1, and 10 CFR Part 50, Appendix B, Criteria XI and XVI.
The first regulation states that each valve to be tested be closed by normal operation and without exercising or adjustments.
While it could be argued that preliminary exercising could be referring to as-left testing as well as to as-found testing, the use of the term "adjustment" could only indicate that an as-found test is required. The American College Dictionary defines the term adjust as "to put in working order, to bring to a proper state or position...."
Therefore, our position is that Appendix J,Section III.C.1 requires a test of the penetration prior to any maintenance which would put the valve in working order, i.e., in the as-found condition.
The second regulation deals with the requirements of 10 CFR Part 50, Appendix B. Criterion XI, requires that a test program be established to assure that all testing required to demonstrate that structures and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Criterion XVI, requires that significant conditions adverse to quality be promptly identified, that the cause be determined, and that corrective action be taken to preclude repetition. If as-found testing were not required, there would be no,way to identify if the component had performed satisfactorily in service, nor would there be a means to identify, determine the cause, or implement corrective action for inadequate valve or penetration performance.
To meet these quality assurance program requirements, several licensees have chosen to implement the guidance contained in ANSI N18.7-1976, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."
There are five sections within ANSI N18.7-1976 concerning this issue.
Attachment (Cont'd) 2 Section 5.2.7.1 specifies that evaluation and review of malfunctioning equipment be performed to determine if the replacement component can be expected to perform its function reliably. In the case of containment penetrations, as-found testing would be needed to detect the malfunctioning (leaking) equipment and determine its root cause.
Section 5.2.8 specifies a surveillance test program to ensure that safety-related structures or components will act to place the plant in a safe condition. In order for a surveillance program to accomplish this requirement it has to be able to look at the past performance of such components. This can only be obtained through as-found testing prior to maintenance, in addition to post-maintenance testing.
Section 5.2.11 is a paraphrase of criterion XVI. As with prior paragraphs, as-found testing would be necessary in order to comply with this section.
Section 5.2.19 covers testing for all plant phases. Paragraph 3 of this section states that surveillance tests during the operational phase are "to provide assurance that failures or substandard performance do not remain undetected and that the required reliability of safety-related systems is maintained."
This requirement can not be accomplished if maintenance or adjustments are performed prior to the surveillance test.
Section 5.3.10 covers the instructions and procedures to be used for tests and inspections. The last sentence of this section specifies that the test procedures record as-found conditions, corrective action performed, if any, and as-left conditions.
Based on the above listed sections of ANSI N18.7-1976 implementing the requirements of Appendix B, as-found testing would be a requirement whenever a surveillance test is scheduled.
Type B and C testing of containment penetrations are scheduled surveillance tests.
A third argument for as-found testing can be found in the letter from T. E. Murley to H. B. Tucker of Duke Power dated July 27, 1989.
The last paragraph of both the letter and the enclosure to.
the letter discuss the need for corrective action under 10 CFR Part 50, Appendix B, Criterion XVI. It states, in part that whenever "excessive local (Type B or C) leakage rates are
Attachment (Cont'd) 3 repeatedly found (for example, if the sum of as-found local leakage rates exceeds the 0.6 La limit specified.in Appendix J)..." corrective actions are to be implemented.
Clearly the letter contemplates that the as-found condition of the penetration or valve will be determined, otherwise, the last paragraph of the letter to Duke Power Company would have no meaning.
Based on the above, the Region III staff concluded that as-found testing-was a requirement; however, because of the position taken by DECo, Region III is requesting that NRR make that determination on a generic basis.