ML20210J275

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Draft E4 to Proposed Rule 10CFR50,App J, Leak Tests for Primary & Secondary Containments of Light-Water-Cooled Nuclear Power Plants
ML20210J275
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Issue date: 04/17/1985
From: Arndt G
NRC
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FOIA-85-736 PR-850417, NUDOCS 8604030405
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8 ENCLOSURE 2 Aseendix J. Draft E4 f

B604030405 eMMt27 PDR 901A j

HIATTSS-736 PDR 1

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[7590-01)

G. Arndt x37860 DRAFT E4 Apr11 i'r,1985 e

PROPOSED 10 CFR PART 50, APPENDIX J l

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[7590-01)

TITLE 10 - Energy CNAPTER I - NUCLEAR REGULATORY C0milSSION PART 50 - DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES APPENDIX J Leak Tests for Primary and Secondary Containments of Light-Water-Cooled Nuclear Power Plants Table of Contents I.

INTRODUCTION II.

DEFINITIONS III. GENERAL LEAK TEST REQUIREMENTS A.

Type A Test 1.

Preoperational Test 2.

Periodic Test 3.

Test Frequency 4.

Test Start and Finish 5.

Test Pressure 6.

Protest Requirements 7.

Verification Test 8.

Acceptance Criteria 9.

Retesting 10.

Permissible Periods for Testing B.

Type B Test 1.

Frequency 2.

Pressure 3.

Air Locks 4.

Acceptance Criteria C.

Type C Test 1.

Frequency 2.

Pressure / Medium 3.

Acceptance Criteria 1

4.

Valves That Need Not Be Type C Tested IV.

SPECIAL LEAK TEST REQUIREMENTS A.

Containment Modification or Maintenance B.

Secondary Containments V.

TEST METHOD, PROCEDURES, AND ANALYSES I

A.

Type A, B, and C Test Details B.

Combination of Periodic Type A, B, and C Tests 04/04/85 1

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VI.

REPORTS A.

Submittal B.

Content VII. APPLICATION A.

Applicability B.

Effective Date I.

INTRODUCTION One of the conditions of all operating licenses for light-water-cooled power reactors as specified in 5 50.54(o) of this part is that primary and secondary containments meet the leak test requirements set forth in this Appendix.

The tests ensure that (a) leakage through the primary and secendary containments or systems and components penetrating these containments does not exceed allowable leakage rates specified in the Technical Specifications and (b) inservice inspection of penetra-tions and isolation valves is performed so that proper maintenance and repairs are made during their service life.

This Appendix identifies the general requirements and acceptance criteria for preoperational and subsequent periodic leak testing.1 II. DEFINITIONS ACCEPTANCE CRITERIA Standards against which test results are to be compared for establishing the functional acceptability of the containment system as a leakage limiting boundary.

i

' Specific guidance concerning acceptable leakage test methods, procedures, and i

analyses that may be used to implement these requirements and criteria will be provided in a regulatory guide that is being issued in draf t form for public i

comment with the designation MS XXX-5.

Copies of the regulatory guide may be obtained from the Nuclear Regulatory Commission, Document Management Branch, Washington, DC 20555.

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"As FOUND" LEAKAGE RATE The leakage rate prior to any needed repairs or adjustments to the leakage barrier being tested.

"AS LEFT" LEAKAGE RATE The leakage rate following any needed repairs or adjustments to the leakage barrier being tested.

CONTAINMENT INTEGRATED LEAK RATE TEST (CILRT)

The combination of a Type A test and its verification test.

CONTAlmENT ISOLATION SYSTEM FUNCTIONAL TEST A test to verify the proper performance of the isolation system by normal operation of the valves.

For autcoatic contairment isolation systems, a test of the automatic isolation system performed by actuation of the containment isolation signals.

CONTAINMENT ISOLATION VALVE Any valve defined in General Design Criteria 55, 56, or 57 of Appendix A

" General Design Criteria for Nuclear Power Plants," to this part.

CONTAINMENT LEAK TEST PROGRAM The comprehensive testing of the containment system that includes Type A, B, and C tests.

CONTAINMENT SYSTEM The principal barrier, af ter the reactor coolant pressure boundary, to prevent the release of quantitles of radioactive material that would have a significant radiological effect on the health of the public.

It includes:

(1) the primary containment, including access openings and penetrations.

(2) containment isolation valves, pipes, closed systems, and other components used to effect isolatiop of the containment atmosphere from the outside environs, and l

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(3) those systems or pc,rtions of systems that by their functions extend the primary containment boendary to include their system boundary.

This definition does not include a secondary containment.

Excluded from the provisions of this Appendix are the interior barriers such as the SWR Mark II drywell floor and the drywell perimeters of the SWR Mark III and the PWR ice condenser.

L,(WEIGHT PERCENT /24 HR)

The maximum allowable Type A test leakage rate in units of weight percent per 24-hour period at pressure P,g as specified in the Technical Specifications.

L,(WEIGHT PERCENT /24 HR)

The measured Type A test leakage rate in units of weight percent per 24-hour period at pressure Pac, obtained from testing the containment system in the state ss close as practical to that that would exist under design basis accident conditions (e.g., vented, drained, flooded, or pressurized).

LEAK An opening that allows the passage of a fluid.

LEAKAGE The quantity of fluid escaping from a leak.

LEAKAGE RATE The rate at which the contained fluid escapes from the test volume at a specified test pressure.

I MAXIMUM PATHWAY LEAKAGE RATE The maximum leakage rate that can be attributed to a penetration leakage path (e.g., the larger, not total, leakage of two valves in series).

This generally assumes a single active failure of the better of two leakage barriers in series when performing Type B or C tests.

MINIMUM PATHWAY LEAKAGE RATE The minimum leakage rate that can be attributed to a penetration leakage path (e.g., the smallest leakage of two valves in series).

This is used when 04/04/85 4

PROPOSED 10 CFR 50 APP J f

(7590-01) correcting the measured value of containment leakage rate from the Type A test (L,) to obtain the overall integrated leakage rate and genera 17y assumes no single active failure of redundant leakage barriers under these test conditions.

OVERALL INTEGRATED LEAKAGE RATE The total leakage rate through all leakage paths, including containment welds, valves, fittings, and components that penetrate the containment system, expressed in units of weight percent of contained air mass at test pressure per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

P,c (psig)

The calculated peak containment internal pressure related to the design basis loss-of-coolant accident as specified in the technical specifications.

PERIODIC LEAK TEST Test conducted during plant operating lifetime.

PREOPERATIONAL LEAK TEST Test conducted upon completion of construction of a primary or secondary containment, including installation of mechanical, fluid, electrical, and instrumentation systems penetrating these containment systems, and prior to the time containment integrity is required by the Technical Specifications.

PRIMARY CONTAlpetENT The structure or vessel that encloses the major components of the reactor coolant pressure boundary as defined in 5 50.2(v) of this part and is designed to contain accident pressure and serve as a leakage barrier against the uncon-trolled release of radioactivity to the environment.

The term " containment" as used in this Appendix refers to the primary containment structure and associated leakage barriers.

SECONDARY CONTAINMENT A structure or vessel surrounding the primary containment that is not designed to contain accident pressures but serves a combination of functions as a shielding structure or an additional leakage barrier to control leakage from 04/04/85 5

PROPOSED 10 CFR 50 APP J

[7590-01) the containment system.

Examples of these structures are a shield building, containment enclosure building,'or a reactor building.

STRUCTURAL INTEGRITY TEST A pneumatic test that demonstrates the capability of a primary containment to withstand a specified internal design pressure load.

TYPE A TEST A test to measure the containment system overall integrated leakage rate under conditions representing design basis loss-of-coolant accident containment pressure and systems alignments (1) after the containment system has been completed and is ready for operation and (2) at periodic intervals thereafter.

The verification test is not part of this definition - see CILRT.

TYPE B TEST A pneumatic test to detect and measure local leakage through the following containment penetrations:

(1) Those whose design incorporates resilient seals, gaskets, or sealant compounds; piping penetrations fitted with expansion bellows; or electrical penetrations fitted with flexible metal seal assemblies.

(2) Air locks, including door seals and door operating mechanism penetra-tions that are part of the containment pressure boundary.

TYPE C TEST A pneumatic test to measure containment isolation valve leakage rates.

VERIFICATION TEST Test to confirm the capability of the Type A test method ano equipment to I

measure L '

a III. GENERAL LEAK TEST REQUIREMENTS A.

Type A Test (1) Preoperational Test.

A preoperational Type A test must be conducted on the containment system and must be preceded by:

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(a) A visual inspection of the accessible interior and exterior surfaces of the primary containment for deterioration that may affect either the containment structural or leak tight integrity,

)

(b) Type B and Type C tests, (c) A containment isolation system functional test, and f

(d) A structural integrity test.

(2) Periodic Test.

A periodic Type A test must be performed on the containment system and must be preceded by:

(a) A visual inspection of the accessible interior and exterior surfaces of the primary containment for deterioration that may affect either the containment structural or leak tight integrity, and (b) A containment isolation system functional test.

(3) Test Freq'2ency.

Unless a longer interval is specifically approved by the NRC staff, the interval between the preoperational and first periodic Type A tests must r.ot exceed three years, and the interval between subsequent periodic Type A tests must not exceed four years.

If the initial fuel loading is delayed so that the three year interval between the first preoperational test and the first periodic test is exceeded, another preoperational test will be necessary.

If such an additional preoperational Type A test or an additional Type A test required by Section IV.A. of this Appendix is performed, the Type A test interval may be restarted.

(4) Test Pressure.

The Type A test pressure must be equal to or greater than P at the start of the test but must not exceed the containment design ac pressure and must not fall more than 1 psi below P for the duration of the ac test, not including the verification test. The test pressure must be established relative to the external pressure of the containment. This may be either atmospheric pressure or the subatmospheric pressure of a secondary containment.

(5) Pretest Requirements. Closure of containment isolation valves for l

the Type A test must be accomplished by normal operation and without any l

preliminary exercising or adjustments for the purpose of improving performance (e.g., no tightening of valve after closure by valve motor).

Repairs of malfunctioning or leaking valves must be made as necessary.

Information on any valve closure malfunction or valve leakage that requires corrective action prior to, during, or af ter the test (see Section V.B.) must be included in the report submitted to the Commission as specified in Section VI of this Appendix.

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(6) Verification Test. A leakage rate verification test must be performed af ter a Type A test in which the leakage rate meets the criteria in III.A.(7)(b)(ii). The verification test selected must be conducted for a duration sufficient to establish accurately the change in leakage rate between the Type A and verification tests.

The results of the Type A test are acceptable if the sum of the verification test imposed leakage and the contal'nment leakage rate calculated from the Type A test (L,,) does not differ from the leakage rate calculated from the verification test by more than 10.25 L,.

(7) Acceptance Criteria.

(a) For the preoperational Type A Test, the "as left" leakage rate must not exceed 0.75L,, as determined by a statistical analysis acceptable to the NRC staff. The "as found" leakage rate does not apply to the preoperational test.

(b) For each periodic Type A test, the leakage rate, as determined by a statistical analysis acceptable to the NRC staff, must not exceed:

(i)

L,, for the "as found" condition, (ii) 0.75L,, for the "as left" condition, (c) In meeting these Type A test acceptance criteria, isolation, repair, or adjustment to a leakage barrier that may affect the leakage rate through that barrier is permitted prior to or during the Type A test provided:

(i) all potential leakage paths of the isolated, repaired or adjusted leakage barrier are locally leak testable, and (11) the local leakage rates are measured before and after the isolation, repair, or adjustment and are reported under Section VI of this i

l Appendix.

(iii) ' All changes in leakage rates resulting from isolation, repair, or adjustment of leakage barriers subject to Type B or Type C testing are determined using the minimum pathway leakage method and added to the Type A test result to obtain the "as found" and "as lef t" containment leakage rates.

(d) The effects of isolation, repair, or adjustments to the containment boundary made after the start of the Type A test sequence on the Type A test I

j results must be quantified and the appropriate analytical corrections made (this includes tightening valve stem packing, additional tightening of manual valves, or any action taken that will affect the leakage rates).

I (8) Retesting.

(a) If, for any periodic Type A test, the as found leakage rate fails to meet the acceptance criteria of 1.0L,, a Corrective Action Plan that 04/04/85 8

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I focuses attention on the cause of the problem must be developed and laplemented by the licensee and then submitted together with the Containment Leak Test Report as required by Section VI of this Appendix. The test schedule applicable to subsequent Type A tests (III. A.(3)) will be reviewed and approved by the NRC staff.

An as left Type A test that meets the acceptance criterion of 0.75L, is required prior to plant sttrtup.

(b) If two consecutive periodic as found Type A tests exceed the as found acceptance criterion of 1.0L,:

(1) Regardless of the periodic retest schedule of III. A.(3),

a Type A test must be performed at least every 24 months (based on the refuel-ing cycle normally being about 18 months) unless an alternative leakage test program is acceptable to the NRC staff on some other defined basis.

This testing must be performed until two consecutive periodic "as found" Type A tests meet the acceptance criterion of 1.0L, after which the retest schedule specified in III.A.(3) may be resumed.

(ii) Investigation as to the cause and nature of the Type A test failure might indicate that an alternative leakage test program such as more frequent Type B or Type C testing may be more appropriate than the perfor-mance of two consecutive successful Type A leakage tests. The licensee may then submit a Corrective Action Plan and an alternative leakage test program proposal 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 one or both of the Type A leakage tests required by Section III. A.(8)(b)(1).

(9) Permissible periods for testing.

The performance of Type A tests must be limited to periods when the plant facility is secured in the shutdown condition under the administrative controls and safety procedures defined in the license.

B.

Type B Test (1) Frequency.

(a) Type B tests, except tests for air locks, must be performed on containment penetrations during shutdown for refueling or at other convenient intervals but in no case at intervals greater than 2 years.

If opened following a Type A or B test, containment penetrations subject to Type B testing must be Type B tested prior to returning the reactor to an operating mode requiring containment integrity.

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(b) For containment penetrations employing a continuous leakage monitoring system that is at a pressure not less than P,g, leakage readings of sufficient sensitivity to pemit comparison with Type 8 test leak rates must be taken at intervals specified in the Technical Specifications.

These leakage readings must be part of the Type B reporting of VI.A.

Continuous leakage monitoring systems must not be operating or pressurized during Type A tests.

(2) Pressure. Type B tests must be conducted, whether individually or in groups, at a pneumatic pressure not less than P except as provided in ac paragraph III.B.(3)(b) of this section or in the Technical Specifications.

(3) Air Locks.

(a) Initial and periodi:: tests. Air locks must be tested prior to initial fuel loading and at least once each 6-month interval thereafter at an internal pressure not less than P Alternatively, if there have been no ac.

air lock openings within 6 months of the last successful test at Pac, this interval may be extended to the next refueling outage or airlock opening (but in no case may the interval exceed 2 years) provided reduced pressure tests continue to be performed on the air lock or its door seals at 6 month intervals.

Opening of the air lock for the purpose of removing air lock testing equipment following an air lock test does not require further testing of the air lock.

(b) Intermediate tests must be conducted as follows:

(i) Air locks opened during priods when containment integrity is required by the plant's Technical Specifications must be tested within 3 days after being opened.

For air lock doors opened more frequently than once every 3 days, the air lock must be tested at least once every 3 days during the period of frequent openings.

Air locks opened during periods when containment

. integrity is not required by the plant's Technical Specifications need not be tested while containment integrity is not required but must be tested prior to returning the reactor to an operating mode requiring containment integrity.

For air lock doors having testable seals, testing the seals fulfills the inter-mediate test requirements of this paragraph.

In the event that this intermediate testing cannot be done at Pac, the test pressure must be as stated in the Technical Specifications.

(ii) Whenever maintenance other than on door seals has been performed on an air lock, a complete air lock test at a test pressure of not less than P is required.

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(iii) Air lock door seal testing or reduced pressure testing may not be substituted for the initial or periodic full pressure test of the entire air lock required in paragraph III.B.(3)(a) of this Section.

(4) Acceptance Criteria.

(a) The sum of the as found or as left Type B and C tes,t results must not exceed 0.60L, using maximum pathway leakage and including leakage rate

. readings from continuous leakage monitoring systems.

(b) Leakage measurements are acceptable if obtained through component leakage surveillance systems (e.g., continuous pressurization of individual or clustered containment components) that maintain a pres-sure not less than P,c at individual test chambers of those same contain-ment penetrations during normal reactor operation.

Similar penetrations not included in the companent leakage surveillance system are still subje:t to individual Type B tests.

(c) An air lock, penetration, or set of penetrations that fails to pass a Type B test must be retested following determination of cause and completion of corrective action.

Corrective action to correct the leak and to prevent its future recurrence must be developed and implemented.

(d) Individual acceptance criteria for all air lock tests must be stated in the Technical Specifications.

C.

Type C Test (1) Frequency. Type C tests must be performed on containment isolation valves during each reactor shutdown for refueling or at other convenient intervals but in no case at intervals greater than 2 years.

(2) Pressure / Medium.

(a) Containment isolation valves unless pressurized with a qualified water seal system must be pressurized with air or nitrogen at a pressure not less than Pac*

(b) Containment isolation valves, that are sealed with qualified water from a seal system must be tested with water at a pressure not less than 1.10 Pac*

(3) Acceptance Criteria.

(a) The sum of the as found or as left Type B and C test results must not exceed 0.60L, using maximum pathway leakage and including leakage rate readings from continuous leakage monitoring systems.

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(b) Leakage from containment isolation valves that are sealed with water from a seal system may be excluded when determining the combined Type B and C leakage rate if:

(i) The valves have been demonstrated to have leakage rates that do not exceed those specified in the Technical Specifications, and (ii) The installed isolation valve seal system inventory is sufficient to ensure the sealing function for at least 30 days at a pressure of 1.10 P,c.

(4) Valves That Need Not Be Type C Tested.

(a) With prior NRC approval, a containment isolation valve need not be Type C tested if it can be shown that the valve does not constitute a potential containment atmosphere leak path during or following an acci-dent, considering a single active failure of a system component.

(b) Other valves may be excluded from Type C testing only when approved by the NRC staff under the provisions of paragraph VII.A.

IV.

SPECIAL LEAK TEST REQUIREMENTS l

A.

Containment Modification or Maintenance Any modification, repair, or replacement.of a component that is part of the containment system boundary and that may affect containment integrity must be followed by either a Type A, Type B, or Type C test. Any modification, repair, or replacement of a component subject to Type 8 or Type C testing must also be preceded by a Type B or Type C test. The measured leakage from this test must be included in the report to the Commission required by Section VI of this Appendix.

Following structural changes or repairs that affect the pressure boundary, the licensee shall submit for NRC staff review a determination of need to perform a structural integrity test prior to the next Type A test. The acceptance criteria of paragraphs III.A.(7), III.B.(4), or III.C.(3) of this Appendix, as appropriate, must be met.

l B.

Secondary Containments f

Leak tests, acceptance criteria, and procedures for determining the functional effectiveness of secondary containments addressing at least required l

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[7590-01) pressure levels and response times must be specified in the plant's Technical Specifications. These tests must be conducted upon cospletion of the secondary containment, including installation of all portions of mechanical, fluid, electrical, and instrumentation systems that penetrate the secondary contain-ment and prior to the time containment integrity is required by the, Technical Specifications. These tests must also be conducted periodically, and in accor-dance with the methods and frequencies specified in the Technical Specifications.

V.

TEST METHODS, PROCEDURES, AND ANALYSES A.

Type A. B, and C Test Details Leak test methods, procedures, and analyses for a steel, concrete, or combination steel and concrete primary containment and its penetrations and isolation valves for light-water-cooled power reactors must be referenced or defined in the Technical Specifications.

B.

Combination of Periodic Type A, B, and C Tests Type B and C tests are considered to be conducted in conjunction with the periodic Type A test when performed during the same outage as the Type A test. The licensee shall perform, record, interpret, and report the tests in such a manner that the containment system leak-tight status is determined on both an as found basis and an as left basis, i.e., its leak status prior to j

this periodic Type A test together with the related Type B and C tests and its status following the conclusion of these tests.

l t

i VI. REPORTS 1

l A.

Submittal 1.

The preoperational and periodic Type A tests, including summaries of i

the results of Type B and C tests conducted in conjunction with the Type A test, must be reported in a summary technical report sent not later than 3 months after the conduct of each test to the Administrator of the appropriate Regional Office with a copy to the Director of the Office of Nuclear Reactor Regulation, Nuclear Regulatory Commission, Washington, DC 20555. The report is to be titled " Containment Leakage Test."

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[7590-01) 2.

Reports of periodic Type B and C tests conducted at intervals intermediate to the Type A tests must also be submitted to the NRC as in para-graph VI.A.1 at the time of the next Type A test submittal.

Reports musi be submitted to the NRC Regional Administrator within 30 days of completion of any Type B or C tests that fail to meet their as found acceptance criteria.

B.

Content A Type A test Corrective Action Plan, when required under paragraph III.A.(8) of this Appendix, must be included in the report. Any correc-tive action required for those Type B and C tests included as a part of the Type A test sequence must also be included in the report.

VII. APPLICATION A.

Applicability The requirements of this Appendix apply to all operating nuclear power reactor licensees as specified in $$ 50.54(o) of this part unless it can be demonstrated that alternative leak test requirements (e.g., for certain con-tainment designs, leakage mitigation systems, or different test pressures not specifically addressed in this Appendix) are acceptable to the NRC staff on some other defined basis. Alternative leak test requirements and the bases for them will be made a part of the plant Technical Specifications if approved by the NRC staff.

B.

Effective Date This Appendix is effective (30 days after publication).

By (insert a date 180 days after the effective date of this amenhent), each licensee and each applicant for an operating license shall develop and submit to the Director of the Office of Nuclear Reactor Regulation a plan acceptable to the NRC staff for implementing the provisions of this Appendix. This submittal must include an explanation of the implementation schedule along with a justification if the schedule calls for final implementation later than (insert a date days / months after the effective date of this amendment). The final implementstion schedule will then be agreed upon by the licensee and the NRC staff.

Until the date on which the licensee finally implements the provisions of this amendment, the licensee shall continue to use existing technical specifications and the 04/04/85 14 PROPOSED 10 CFR 50 APP J

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Appendix J on which they are based in their entirety.

Thereaf ter, the licensee shall use this amendment and the Technical Specifications confoming to this amendment in their entirety.

Dated at Washington, DC, this day of

, 1985.

For the Nuclear Regulatory Commission.

Samuel J. Chilk Secretary of the Commission l

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