ML20138L155

Forwards Summary of AP600 Design & Operational Features That Require Exemptions from Current Regulations in 10CFR50,70 & 100 Per NRC & Dser Open Item 1.8-1 Request

ML20138L155
Person / Time
Site:	05200003
Issue date:	02/14/1997
From:	Mcintyre B WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Quay T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-NSD-97-4986 NUDOCS 9702210121
Download: ML20138L155 (9)

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Westinghouse Energy Systems sa 355 Pittsburgh Pennsylvania 15230-0355 Electric Corporation NRC-NSD-97-4986 DCP/NRC0741 l

Docket No.: STN-52-003 February 14, 1997

. Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 f

l TO:

T.R. QUAY

SUBJECT:

AP600 EXEMPTIONS FROM REGULATIONS I

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Dear Mr. Quay:

in response to a request from the NRC staff and DSER Open item 1.8-1, Westinghouse is submitting the enclosed summary of AP600 design and operational features that require exemptions from current regulations in 10 CFR Parts 50,70, and 100. The exemptions from current regulations are required because of the incorporation of passive safety systems into the AP600 and other changes in technology. These exemptions have been provided for review by the NRC staff and included in the AP600 Standard Safety Analysis Report (SSAR).

The enclosure summarizes the basis for each and the exemptions consistent with the requirements of NRC regulations. It is Westinghouse's understanding that the acceptability of the exemptions will be documented in the Final Safety Evaluation Report and codified in the AP600 Design Certification Rule.

If you have any questions please contact Donald A. Lindgren at (412) 374-4856.

lNI I

Brian A. McIntyre, Manager Advanced Plant Safety and Licensing

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.jml Enclosure cc: T. Kenyon, NRC (1 Enclosure) 9702210121 970214 i

ADOCK 05200003 1

PDR 1

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'AP6'00 ~ DOCUMENT COVER SHEET TDC:

10 5: 1 S

Norm 58202Gt5/94) It:'.xxxx.wpf:1x1 AP600 CENTRAL FILE USE ONLY:

0058.FMM :

RFS#:

RFS ITEM #:

AP600 DOCUMENT NO.

REVISION NO.

ASSIGNED TO

. GW GL-010

'O Page 1 ot.2 B. A. McIntyre J ALTERNATE DOCUMENT NUMBER:

WORK BREAKDOWN #: 2.1 DESIGN AGENT ORGANIZATION: Westinghouse Electric

TITLE

L Exemption to NRC Regulations ATTACHMENTS:

DCP #/REV. INCORPORATED IN THIS DOCUMENT REVISION:

1 CALCULATION / ANALYSIS

REFERENCE:

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ELECTRONIC FILENAME ELECTRONIC FILE FORMAT ELECTRONIC FILE DESCRIPTION 1

- gw gl_.010 Wordperfect 5.2 Wordperfect Text File 1

(C) WESTINGHOUSE ELECTRIC CORPORATION 1982_.

WESTINGHOUSE PROPRIETARY CLASS 2 Thie document contains information proprietary to Westinghouse Electric Corporation; it is submitted in confidence and is to be used solely l

for the purpose for which it is furnsehed and returned upon request. This document and such information is not to be reproduced, i

transmitted, disclosed or used otherwise in whole or in part without prior written authorizateon of Westinghouse Electric CorporatioA. Energy Systems Susiness Unit, subject to the legends contained hereof.

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O WESTINGHOUSE PROPRIETARY CLASS 2C This document is the property of and contains Proprietary information owned by Westinghouse Electric Corporation and/or its subcontractors and suppleets. It is transmitted to you en confidence and trust, and you agree to treet this document in stnct accordance with the terms and conditions of the agreement under which it was provided to you.

@ WESTINGHOUSE CLASS 3 (NON PROPRIETARY) i CSMPLETE 1 IF WORK PERFORMED UNDER DESIGN CERTIFICATION 25 COMPLETE 2 IF WORK PERFORMED

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UNDER FOAKE.

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' DOE DESIGN CERTIFICATION PROGRAM - GOVERNMENT LIMITED RIGHTS STATEMENT ISee page 21 5

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Copyright statement: A heense is reserved to the U.S. Government under contract DE ACO3 90SF18496.

j; DOE CONTRACT DELIVERA8LES (DELIVERED DATA)

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' Subtect to specified exceptions, diectosure of this data is restricted until September 30.1996 or Design Certification under DOE contract DE. AC03-90$F18495, whichever is later, EPRI CONFIDENTIAL: NOTICE: 1E 2 3

4 5 O CATEGORY: AE B C

D E

F0 2

ARC FOAKE PROGRAM - ARC LIMITED RIGHTS STATEMENT ISee page 21 Ccpynght statement: A heense is reserved to the U.S. Government under contract DE FC02 NE34267 and subcontract ARC 93 3-SC-001, i

ARC CONTRACT DELIVERABLES (CONTRACT DATA)

Sub,ect to specified onceptions, disetosure of this data is restncied undair ARC Subcontract ARC 93 3 SC 001.

ORIGINATOR SIGNATURE / AT f

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D? Ai Lindgren ~

' AP600 RESPONSISLE MANAGER SIG RE'

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APPROVA DATE

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/ W,/ p B. A. MCintyre :

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. Appr val of the responsibae manager signifies that document is complete,'all reeuwod reviews are compsiste, electronec file is attached and I

p - document is j

, retened for use.

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AP600 DOCUMENT COVER SHEET Pagi 2

• Form 58202G(s194l LIMITED RIGHTS STA TEMENTS DOE GOVERNMENT LIMITED RIGHTS STATEMENT (A)

These data are submetted with hmsted nghts under government contract No. DE ACO3 90SF18495. These data may be reproduced and used by the government with the express limitation that they will not, without written permission of the contractor, be used i

for purposes of manuf acturer nor disclosed outside the government: except that the government may disclose these data outs 6de the government for the following purposes, if any, provided that the government makes such disclosure subject to prohsbition i

against further use and disclosure:

m TNs

• Proprietary Data

• may be disclosed for evaluation purposes under the restnetions at>ove.

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The ' Proprietary Data" may be disclosed to the Electric Power Research Institute (EPRI), electric utility representatives and their direct consultants, excluding direct commercial competitors, and the DOE National Laboratories under the prohibitions and restrictions above.

(B)

TNs notice shall be marked on any reproduction of these data, in whole or en part.

i j

ARC LIMITED RIGHTS STATEMENT:

t This proprietary data, furnished under Subcontract Number ARC 93 3 SC 001 with ARC may be duplicated and used by the government and ARC, subject to the lemstations of Article H-17.F. of that subcontract, with the express limitations that the Mnetary data may not be disclosed outside the government or ARC, or ARC's Class 1 & 3 members or EPRI or be used for purposes of manuce without prior t

i permission of the Subcontractor, except that further disclosure or use may be made solely for the following purposes:

This proprietary data rney be disclosed to other than commercial competitors of Subcontractor for evaluation purposes of this subcontract under the restnction that the propnetary data be retained in confidence and not be further disclosed, and sub ect to the terms of a non-

[

l disclosure agreement between the Subcontractor and that organization, excluding DOE and its contractors.

7 DEFINITIONS CONTRACTIDEUVERED DATA - Consists of documents (e.g. specifications, drawings, reports) which are gsnerated under the DOE or ARC contracts which contain no background proprietary data, i

EPRI CONFIDENTIALITY / OBLIGATIONNOTICES i

N3TICE 1: The data in this document is subject to no confidentiality obligations.

NOTICE 2: The data in tNs document is propnetary and confidential to Westinghouse Electric Corporation and/or its Contractors. ids l

forwarded to recipient under an obhgation of Confidence and Trust for limited purposes only. Any use, disclosure to unauthorized persons, 1

or copying of tNs document or parts thereof is proNbited except as agreed to in advance by the Electric Power Research institute (EPRI) and Westinghouse Electnc Corporation. Recipient of tNs data has a duty to inquire of EPRI and/or Westinghouse as to the uses of the information contained hereen that are permitted.

NOTICE 3: The data in tNs document is proprietary and confidential to Westinghouse Electric Corporation and/or its Contractors. It is forwarded to recipient under an obligation of Confidence and Trust for use only in evaluation tasks specifically authorized by the Electric Power Research Institute (EPRI). Any use, disclosure to unauthorized persons, or copying tNs document or parts thereof is prohibited sucept as agreed to in advance by EPRI and Westinghouse Electric Corporation. Recipient of this data has a duty to inquire of EPRI and/or Westinghouse as to the uses of the information contained herein that are permitted. TNs document and any copies or excerpts thereof that may have been generated are to be returned to Westinghouse, defectly or through EPRI, when requested to do so.

N3TICE 4: The data in tNs document is propnetary and confidential to Westinghouse Electric Corporation and/or its Contractors, it is b:eng revealed in confidence and trust only to Employees of EPRI and to certain contractors of EPRI for limited evaluation tasks authorized by EPRI. Any use, disclosure to unauthonted persons, or copying of tNs document or parts thereof is proNbated. TNs Document and any copies or excerpts thereof that may have been generated are to be returned to Westsnghouse, directly or through EPRI, when requested to do so.

N3TICE S: The data in tNs document is proprietary and confidential to Westinghouse Electric Corporation and/or its Contractors. Access to tNs data is geven in Confidence and Trust only at Westinghouse facileties for limited evaluation ' asks assigned by EPRI. Any use, disclosure to unauthorized persons, or copying of tNs document or parts thereof is proNbeted. Neither tNs document nor any excerpts therefrom are to be removed from Westinghouse facileties.

i EPRI CONFIDENTIALITY / OBLIGATION CATEGORIES I

CATEGORY *A* - (See Dehvered Detal Consists of CONTRACTOR Foreground Data that is contained in an issued reported.

CATEGORY "B" - (See Dehvored Detal Consists of CONTRACTOR Fotoground Data that is not contained in an issued report, except for computer programs.

f CATPJORY *C" - Consists of CONTRACTOR Sackground Data except for computer programs.

I CAftOORY *O* - Consists of computer programs developed in the course of performing the Work.

i CATEGORY *E' - Consists of computer programs deve4ed voor to the Effective Date or after the Effective Date but outside the scope of the Work.

CATEGORY *F* - Consists of admenestrative plans and admitustrative reports.

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o GW-GL-010 EXEMPTIONS TO NRC REGULATIONS In some cases the regulations in 10 CFR Parts 50. 70, and 100 are not appropriate for the design j

certification of the AP600. These rules are not appropriate because of the incorporation of passive safety systems into the AP600 and other changes in technology.

1 1.

Exemption from dedicated containment penetration requirement. SSAR Section 1.9.3 This requirement is as specified as 10 CFR 50.34 (3)(iv) Dedicated Containment Penetrations (NUREG-0660 ftem 11.B.8) Provide one or more dedicated containment penetrations, equivalent in size to a single 3-foot diameter opening, in order not to preclude future installation of systems to prevent containmentfailure, such as afiltered vented containment system.

The containment analysis for the AP600, including PRA and severe accident assessments, demonstrate that the containment, with its passive heat rejection capability, does not need a future installation of such a system to prevent overpressurization.

This evaluation of AP600 containment integrity meets the exemption criteria of 10 CFR 50.12 (a)(1) and (a)(2)(ii).

2.

Exemption from General Design Criteria 17 requirement for physically independent circuit (second off-site electrical power source) SSAR Section 3.1 This requirement is found in 10 CFR 50 Appendix A. General Design Criterion 17 - Electrical Power Systems An onsite electric power system and an ofsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. De safety function for each system (assuming that the other system is notfunctioning) shall be to provide suficient capacity and capability to assure that (1) specified acceptablefuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vitalfunctions are maintained in the event ofpostulated accidents.

De onsite electric power supplies, including the batteries, and the onsite electric distribution system shall have suficient independence, redundancy, and testability to perform their safetyfunctions, assuming a singlefailure.

i Electric powerfrom the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights-of-way) designed and located so as to minimize, to the extent practical, the likelihood of their simultaneousfailure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time, following a loss of all onsite alternating current power supplies and other ofsite electric power circuit, to assure that specified acceptablefuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available 3

GW-GL-010 within afew seconds following a loss of coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

Provisions shall be included to minimize the probability oflosing electric powerfrom any of the remaining supplies as a result of, or coincident with, the loss ofpower generated by the nuclear power unit, the loss ofpowerfrom the transmission network, or the loss ofpowerfrom the onsite electric power supplies.

The AP600 plant design supports an exemption to the requirement of GDC 17 for two physically independent offsite circuits by providing safety-related passive systems for core cooling and containment integrity, and multiple nonsafety-related onsite and offsite electric power sources for other functions. See SSAR Section 6.3 for additional information on the systems for core cooling.

A reliable de power source supplied by batteries provides power for the safety-related valves and instrumentation during transient and accident conditions.

The Class IE de and UPS system is the only safety-related power source required to monitor and actuate the safety-related passive systems. Otherwise, the plant is designed to maintain core cooling and containment integrity, independent of nonsafety-related ac power sources indefinitely. The only electric power source necessary to accomplish these safety-related functions is the Class IE de and UPS power system which includes the associated safety-related 120V ac distribution switchgear.

Although the AP600 is designed with reliable nonsafety-related offsite and onsite ac power that are normally expected to be available for important plant functions, nonsafety-related ac power is not relied upon to maintain the core cooling or containment integrity.

The nonsafety related ac power system is designed suel. that plant auxiliaries can be powered from the grid under all modes of operation. During loss of offsite power, the ac power is supplied by the i

onsite standby diesel-generators. Preassigned loads and equipment are automatically loaded on the diesel-generators in a predetermined sequence. Additional loads can be manually added as required.

The onsite standby power system is not required for safe shutdown of the plant.

This evalunion of power sources required for AP600 meets the exemption criteria of 10 CFR 50.12 (a)(1) and (a)(2)(ii).

3.

Exemption from use of ASME Code,Section III for Class C gas storage vessels SSAR Subsection 3.2.2 10 CFR 50.55a requires that safety related systems and components that are designated Quality C should meet the requirements of ASME Code Section III. For Class C air and gas storage tanks fabricated without welding ASME Code, Section Vill, Appendix 22 provides a more appropriate set of criteria than does ASME Code, Section 111 Class 3. The air storage tanks are constructed of forged, seamless pipe, with no welds, The rules of Section Vill for gas storage vessels of the type included in AP600 for safety-related functions are found in Section Vill mandatory Appendix 22 and have been developed specifically for the storage of gas under high pressure. These tanks are used in a variety of industries to store gas.

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These tanks are fabricated without welding. Because there is no weld joint to consider, weld strength reduction factors do not apply which increase the wall thickness.

The material for the integrally forged tanks is ordered to a material specification (SA-372) developed specifically for that type of tank. The material specification is included in Section II of the ASME Code. The tanks are formed from a forging that is essentially a seamless pipe. The ends are swaged down to reduce the size of the opening. After completion of the forming operation the vessel is heat treated. No welding is permitted in the fabrication of the vessel by the Section VIII, Appendix 22 rules required for this type of vessel.10 CFR 50, Appendix B requirements and 10 CFR 21 apply to the manufacture of safety-related air and gas storage tanks.

i This evaluation of AP600 air tank integrity meets the exemption criteria of 10 CFR 50.12 (a)(1),

(a)(2)(ii), and (a)(2)(iii).

4.

Exemption from operating-basis earthquake design requirement in 10 CFR Part 100, Appendix A. SSAR Section 3.7 Item I.M of SECY-93-087 established the following policy: The staff recommends that the Commission approve the approach to eliminate the OBE from the design of systems, structures, and components. When the OBE is eliminated from the design, no replacement earthquake loading should be used to establish the postulated pipe rupture and leakage crack locations. The SECY also established the requirements for consideration of seismic events for equipment qualification and fatigue evaluations.

The operating basis earthquake (OBE) has been eliminated as a design requirement for the AP600.

Low-level seismic effects are included in the design of certain equipment potentially sensitive to a number of such events based on a percentage of the responses calculated for the safe shutdown canhquake. Criteria for evaluating the need to shut down the plant following an canhquake are established using the cumulative absolute velocity approach according to EPRI Report NP-5930 (Reference 1) and EPRI Report TR-100082 (Reference 17). For the purposes of the shutdown criteria in Reference i the operating basis earthquake for shutdown is considered to be one-third of the safe shutdown earthquake. The AP600 satisfies the policy outlined in SECY-93-087.

Removal of the OBE decreases the number of analyses required and results in improved piping and equipment support systems.

This evaluation of elimination of the OBE for the AP600 meets the exemption criteria of 10 CFR 50.12 (a)(1), (a)(2)(ii), and (a)(2)(iii).

5.

Exemption from use of ASME OM Code 1987 Edition. SSAR Subsection 3.9.6 10CFR 50.55a specifies that the OMa-1988 Addenda to the 1987 Edition of the OM requirements be used for the requirements for inservice testing of active safety-related valves. The 1990 OM Code represented a significant restructuring of the format of the requirements. The information in the AP600 SSAR on inservice testing has been developed and reviewed using the 1990 Edition. The use of the 1990 requirements does not represent a diminution of the inservice testing requirements.

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GW-GL-010 This evaluation of AP600 inservice testing requirements meets the exemption criteria of 10 CFR

' 50.12 (a)(1) and (a)(2)(ii).

6.

Exemption from ASME OM Code valve inservice testing frequency. SSAR Subsection 3.9.6.3 10CFR 50.55a specifies the use of ASME OM requirements for inservice testing of active safety-related valves. The ASME OM Code frequency requirement for most valves, unless a deferral is I

justified, is three months. The inservice testing frequency for the AP600 automatic depressurization system valve is six months;.

Considerable experience has been used in designing and locating systems and valves to permit preservice and inservice testing required by Section XI of the ASME Code. Relief from the testing requirements of the ASME OM Code is requested when full compliance with requirements of the ASME OM Code of the Code is not practical or constructive. In such cases, specific information is provided which identifies the applicable code requirements, justification for the relief request, and the testing method to be used as an alternative. The following relief request has been identified to be included in design certification.

Automatic depressurization system stage I through 3 valve exercise testing represents a risk of loss of reactor coolant and depressurization of the reactor coolant system if the proper test sequence is not followed. For this reason, the frequency of this valve exercise testing should be minimized.

Conversely, the probabilistic risk assessment assumes that valve reliability for these valves is a function of test frequency. The recommended test frequency considers these two factors. The recommended test frequency for the stage I through 3 automatic depressurization systems valve is every six months. The PRA results show that the AP600 meets its safety goals. The assumptions in the PRA are consistent with a six month test frequency for the ADS valves.

This evaluation of AP600 inservice testing relief request meets the exemption criteria of 10 CFR 50.12 (a)(1), (a)(2)(ii), and (a)(2)(iv).

7.

Exemption from leak rate testing requiresnents of Appendix J to 10 CFR Part 50. SSAR Subsection 6.2.5 10 CFR 50, Appendix J provides testing requirements for containment leak rate testing. The AP600 containment leak rate testing program outlined in SSAR subsection 6.2.5 satisfies 10 CFR 50, Appendix J requirements except as described in SSAR Table 6.2.5-1 which is repeated as Table 1 of this document and lists specific exemptions and justifications. The exemptions include changes that reflect industry practice, updated industry standards, and provisions to extend testing intervals.

This evaluation of AP600 containment leak rate testing meets the exemption criteria of 10 CFR 50.12 (a)(1), (a)(2)(ii), and (a)(2)(iii).

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GW-GL-010 8.

Exemption from 10 CFR 70.24 requirement for criticality meters in the fuel storage area.

SSAR Subsection 11.5.6 s

i 10 CFR 70.24 requires monitoring for criticality in areas where more than specified amounts of special nuclear material are stored. The AP600 does not include criticality meters in the fuel storage area. The fuel rack limits the criticality of stored fuel to a Keff less than 1.0 and obviates the need for criticality meters. Subsections 9.1.1.3 and 9.1.2.3 provide information on criticality. The design of the new fuel storage rack is such that K rg remains less than or equal to 0.95 with new fuel of the e

maximum design basis enrichment. For a postulated accident condition of flooding of the new fuel storage area with unborated water, K rg does not exceed 0.98.

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The design of the spent fuel racks is such that Keff remains less than or equal to 0.95 under design l

basis conditions, including fuel handling accidents. Because of the close spacing of the cells, it is impossible to insert a fuel assembly in other than design locations. Inadvertent insertion of a fuel assembly between the rack periphery and the pool wall or placement of a fuel assembly across the top of a fuel rack is considered a postulated accident, and as such, realistic initial conditions such as of less than boron in the pool water are assumed. These accident conditions have an acceptable Kerf j

0.95.

j This evaluation of AP600 fuel rack criticality meets the exemption criteria of 10 CFR 70.14 (a).

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GW-GL-010 Table 1 EXCEPTIONS TO 10 CFR 50 APPENDIX J LEAK TESTING REQUIREMENTS Appendix J Requireanent AP600 Exception and Justification i

Paragraph Ill. A.I.(a) - Type A Type A tests are to be conducted in accordance with ANSI-56.8, which tests are required to be permits testing to proceed provided that the leak (s) can be isolated and terminated if excessive leak that subsequent local leak rate testing is performed to demonstrate ths.t paths, which would interfere with the Type A test criteria are met. This approach can potentially reduce 4

satisfactory completion of the plant outage time and is in accordance with ANSI-56.8 and industry test, are identified.

practice.

l Paragraph Ill.A.3.(a) - Type A Type A tests are to be conducted in accordance with ANSI-56.8, which tests shall be conducted in superseded ANSI N45.4. Leak rate testing will be conducted pursuant accordance with the provisions of to 10 CFR 50, Appendix J Option A or Option B. Option A will be ANSI N45.4-1972.

conducted in accordance with ANSI 56.8 while Option B will be conducted with the methodology defined in NEl 94-01, Revision 0 as modified by Regulatory Guide 1.163 and in accordance testing i

procedures of. ANSI 56.8.

l Paragraph Ill. A.3.(a) - A Type Type A tests are to be conducted for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, in A test duration of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is accordance with ANSI 56.8. Industry experience has shown that

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required, accurate test results can be achieved in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i

Paragraph lil.D. I.(a) - Three Type A tests under 10 CFR 50, Appendix J, Option A are to be l

Type A tests are to be performed conducted at intervals not exceeding four years, except that, if the test at approximately equal intervals interval ends while contamment integrity is not required or is required during each 10-year service solely for cold shutdown or refueling activities, the test interval may be period.

extended indefinitely provided all deferred testing is successfully completed prior to the time contamment integrity is required. The 4-year interval accommodates extended fuel cycles without requiring 1

Combined License applicants to perform excessive Type A tests. The i

exception complies with Appendix J and meets the intent of Section XI

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j of the ASME Boiler and Pressure Vessel Code.

Paragraph Ill.D.2 Type B tests Type B tests under 10 CFR 50, Appendix J, Option A are to be are required to be performed at conducted at intervals not exceeding 30 months, except that if the test i

intervals not greater than 2 years. interval ends while contmnment integrity is not required or is required solely for cold soutdown or refueling activities, the test interval may be extended indefinitely provided all deferred testing is successfully completed prior to the time containment integrity is required.

j Paragraph Ill.D.2.(b)(i)- Air Type B testing under 10 CFR 50, Appendix J, Option A is to be locks shall be tested prior to conducted in accordance with ANSI 56.8.

initial fuel loading and at 6 month intervals themaner at a i

pressure not less than Pa-Paragraph Ill.D.3 - Type C tests Type C tests under 10 CFR 50, Appendix J, Option A are to be are required to be performed as conducted at intervals not exceeding 30 months, except that if the test intervals not greater than 2 years, interval ends while centmament integrity is not required or is required solely for cold shutdown or refueling activities, the test interval may be i

extended indefinitely provided all deferred testing is successfully completed prior to the time containment integrity is required.

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