ML20210J323

Draft 4 to Proposed Reg Guide,Task Ms 021-5, Containment Sys Leakage Testing

ML20210J323
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Issue date:	05/31/1985
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FOIA-85-736, TASK-MS-021-5, TASK-MS-21-5, TASK-RE REGGD-04.XXX, REGGD-4.XXX, NUDOCS 8604030413
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-i ENCLOSURE 8 (1- ,

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MS 021-5 WorkingPaper03f DRAFT REGULATORY GUIDE MS 021-5 x f.

CONTAINMENT SYSTEM LEAKAGE TESTING y ,

A. INTRODUCTION General Design Criteria 1, " Quality Standards and Records," 16, " Containment Design," 50, " Containment Design Basis," 52, " Capability for Containment Leakage Rate Testing," 53, " Provisions for Containment Testing and Inspection," 54,

" Piping Systems Penetrating Containment," 55, " Reactor Coolant Pressure Boundary Penetrating Containment," 56, " Primary Containment Isolation," and 57, " Closed  !

Systems Isolation Valves," of Appendix A, " General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, " Domestic Licensing of Production and Utili-zation Facilities," require, in part, that the containment system be designed and constructed for periodic integrated and local leakage rate testing at con- )

tainment design pressure. On , 1985, the Commission published proposed amendments (_FR_) to Appendix J, " Leak Tests for Primary and Second-.

ary Containment of Light-Water-Cooled Nuclear Power Plants," to 10 CFR Part 50, which defines the criteria for such testing. This guide describes a method acceptable to the NRC staff for complying with these amended regulations if they are promulgated as published.

B. DISCUSSION I i

Background

i l American National Standard ANSI /ANS 56.8-19811, " Containment System Leakage Testing Requirements," was prepared by the American Nuclear Society Standards Committee, Working Group ANS 56.8, and published in 1981 as a replacement to ANSI N45.4-1972, " Leakage Rate Testing of Containment Structures for Nuclear Reactors" (ANSI-7.60).

2 Copies of the American National Standard, ANSI /ANS 56.8-1981, " Containment System Leakage Testing Requirements," may be obtained from the American Nuclear l Society, 555 North Kensington Avenue, LaGrange Park, IL 60525. It may be inspected at the Nuclear Regulatory Commission's Public Document Room, 1717 H Street NW., Washington, DC.

DRAFT 1 RG TASK MS 021-5

The old ANSI N45.4-1972 standard was endorsed and referenced without exceptions in Appendix J to 10 CFR Part 50. The new ANSI /ANS 56.8-1981 standard has been considerably expanded and updated and it has become difficult to endorse the standard without some exceptions. As a result, the new standard is being endorsed in this regulatory guide instead of in the revised Appendix J to facilitate the listing of exceptions to the standard and their removal as the standard is revised or errata sheets are issued.

In revising Appendix J to 10 CFR Part 50, it was intended that the regula-tion limit itself to general test criteria and leave detailed testing tech-niques and analyses to the ANSI standard. This will permit the standard and its endorsing regulatory guide to be revised as the testing technology changes without affecting the basic test criteria in the regulation and without requir-ing the regulation to be frequently rewritten to keep it up to date with the testing technology.

There will always be some debate over whether certain positions are properly regulatory criteria or details of the testing procedures. However, this division of requirements and procedures is believed to provide the most responsive arrangement that will ensure safe limits on containment system leakage while keeping current with technical advances in testing procedures and analysis methods. Also, by having the regulation address general test criteria and leaving the details of implementation to the standard, it is expected that fewer license exemptions will have to be filed than have been necessary under the previous regulation, thereby reducing an unproductive administrative burden on both licensees and NRC staff.

Discussion of Regulatory Positions In those areas in which the provisions of the referenced standard are insufficient for licensing purposes or where special emphasis is desired, the staff has provided supplementary guidelines (recommendations) it considers needed. These are in the Regulatory Position. Brief reasons for including them are given below.

Position 1. The preemptive authority of a regulation when a standard is in conflict with it is clear, and is provided only as a reminder.

DRAFT 2 RG TASK MS 021-5

Position 2. Paragraph 3.3.7 requires that the leakage rate include an upper confidence limit as described in Section 6 of the standard. Since the Type A test results being corrected are at the UCL, the~ correction being applied to instrument error should also be at the UCL.

Position 3. This supplementary clarification preserves the complete NRC staff definition that all non-seismically designed piping systems which pene-trate containment shall be postulated to "...be open directly to the containment or outside atmosphere under post accident conditions...(ANS 56.8)," and there-fore "...shall be opened or vented to the appropriate atmosphere during the test."

Position 4. Some plant design's have auxiliary steam lines penetrating primary containment for use during outages. Where possible, such lines should

, be isolated and vented to prevent the introduction of another energy source that may prove difficult to account for in the calculations.

Position 5. The fact that "... the water that fills the sump was present in the air that filled the containment" is not relevant. The amount of error resulting from the neglect of changes in sump level is not related to the fact that the water condensed from the air. This is because the air mass equa-tions, provided elsewhere in the standard, subtract out the effect of the water vapor changes in air mass but make no provision for the volume changes resulting from the conversion to (or from) water.

Position 6. a. Based upon experience with the existing verification test criteria, several clarifications need to be documented. For periodic Type A tests, consideration is being given to the future use of a zero pressure test to verify the ability of the Type A test instrumentation to read the Type A test leakage. This is, however, still in the future, and to what extent it could supplement or replace the current verification test or current instru-ment selection guide criteria has still to be determined.

b. The measurement of W2 is subject to the same statistical errors as the measurement of the air mass values used in the calculation of the leak rate. It is not likely that a believable determination of the step change could be made with one air mass data set. Since 20 sets of data points are required to establish the leak rate (paragraph 5.4, page 11 of the standard),

it would be appropriate to require a minimum number of data sets for the verification test also. The formula result is reformatted to more clearly represent the preceding text.

DRAFT 3 RG TASK MS 021-5

4 Position 7. In order for the test results to be valid, either the test differential pressure must be equal to P ac r a method must exist to cor-rectly extrapolate to P ac. At present, much controversy exits on how to extrapolate test results to a much higher pressure. Until such controversy can be satisfactorily resolved, it is prudent to perform all Type B and C tests at P ac. The NRC staff intcods to approve Type B and C vacuum tests only on a case-by-case basis.

Position 8. Visual inspection of air lock door seals is an item the NRC staff feels is a common sense practice but one that belongs in the ANSI standard rather than in Appendix J to 10 CFR Part 50. If visual inspection requirements were placed in the regulation, the administrative controls on such a practice could become disproportionate to the level of effort required for visual inspections.

Position 9. The NRC staff always applies the single-failure criterion in the review of containment related systems.

Postion 10. a. As presently written, the only requirement is for a one-point in situ calibration check within six months of performing the preopera-tional or periodic test. This is poor practice because no requirements really exist to ensure system accuracy, linearity, sensitivity, and repeatability.

The requirements of paragraph 4.2.1 of the standard for initial calibration data do not state when such calibration is to be performed. Therefore, as presently written, one could have the instruments initially calibrated at the time of purchase (perhaps two years before performing the preoperational test) and then perform a one point check within six months of each test for the next forty years. In addition, installing equipment and performing calibration checks six months prior to the preoperational Type A test will almost guarantee damage to the equipment prior to its use, as considerable construction work is still in progress at this time. Typically, licensees have the instruments calibrated within the six-month period and then installed and the calibration checked within two weeks to a month prior to performing the test.

b. A one point check is not very informativ., and, in practice, responsible licensees are actually performing calibration daily when the instruments are in use.

Position 11. a. An important definition missing from the ANSI standard is that concerning the senuor weighting factors. Although these factors are generally understood to be volume fractions determined by an assessment of the DRAFT ..

4 RG TASK MS 021-5

amount of volume a particular sensor is assumed to represent, no clear technique r is presented for determining them. Licensees have not been required to verify that these factors are accurately determined. Along the same lines, there is no guidance provided for determining sensor placement. A technique for deter-mining weighting factors and sensor placement should be developed and presented 4 in the ANSI standard, along with a requirement that the placement and the weighting factors be verified.

b. The ANS 56.8 standard partially addresses the issue of temperature surveys, but the supplementary guidance provides a consistency that is lacking.

Conducting surveys with fans on and with fans off ensures that baselines are available, regardless of condition, on later tests. Since operational heat sources are so different from preoperational conditions, the surveys should ba rerun at least for the first periodic Type A leakage rate test.

Position 12. The absolute test method should reflect spatial tempera-ture variability over the c'ontainment volume when it exists. The current equa-tion, although correct, inadequately defines the temperature ters, permitting its calculation by allowing the assumption of a uniform density throughout the containment. This density may not, however, be uniform because the temperature ady not be uniform. Although this assumption yields similar, acceptable results with temperature distributions normally experienced, it is still not a techni-cally correct assumption. Therefore, the derivation of the temperature value to be used in the equation, Tg , should be shown, using a definition that allows accommodation of spatial temperature variation through the containment.

Position 13. A uniform format for reporting Type A, B, and C test results

! is being encouraged in order to make better use of the data history being generated.

l Position 14. The NRC staff always applies the single-failure criterion j

in the review of containment-related systems.

Position 15. This recommendation is being made to avoid the use of an l

air discharge test method since there are many inherent inaccuracies in tryirig to capture and measure discharged air, e.g. , leak paths from the tested volume l other than that being metered.

Position 16. The best determinant of leakage rate, whether the fluid used is air or water, is to measure the makeup required to maintain test pressure. In addition, certain piping configurations will not permit the collection of valve (water) leakage thus requiring that makeup be monitored.

DRAFT 5 RG TASK MS 021-5 i

, yy Position 17. Same as 7.

Position 18. Clarification in the standard is recomended for a concern on packing leakage that seems logical but that has had to be clarified in the past.

Positions 19, 20, 21. Incorporation of these supplementary recomendations with those of ANSI /ANS 56-8-1981 will allow discontinuing the use in licensing reviews of Bechtel Topical Report BN-TOP-1, " Testing Criteria for Integrated Leakage Rate Testing of Primary Containment Structures for Nuclear Power Plants," Revision 1, November 7,1982. It should be noted that these recommendations eliminate the requirement for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> periodic test. The preoperational test is still intended to be at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to be available as a baseline test. Position 21 presents two methods of data reduction acceptable to the NRC staff fcr controlling the quality of the data obtained during the Type A and verification tests, and determining test acceptability.

The first method (Position 21.d.1)) establishes conditions on the quality of the regression fit obtained using the method of ANSI /ANS 56.8-1981.

Condition (a) represents a limit on the deviation from straight line behavior permitted in the data. Condition (b) is esser.tially a condition on the minimum test duration as a function of the observed scatter in the data about the regression line. This second condition is analogous to the requirement that ISG [0.25 La but applied to data scatter rather than instrumentation errors.

Condition (a.1) is a standard statistical test used to measure if a higher order term in the regression analysis is warranted. When satisfied, the interpretation is that, with a confidence of 95!, the data is better fit by a prabola than by a straight line. The right hand side of the inquality is a parametrization of the 95th percentile F distribution with one degree of freedom in the numerator and N-3 degrees of freedom in the denominatcr.

6 RG TASK MS 021-5

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Condition (a.2) is a limit on the magnitude of the ratio of the average time varying leak rate component to the constant component. This ratio is estimated by fitting the data with a parabola.

The left hand side of the inequality in Condition (b) is the coefficient of determination (the square of the correlation coefficient). The corresponding limit on the right hand side is derived using the following considerations: thE standard deviation of the data scatter about the regression line is compared to the estimate nade of the instrumentation errors (with an extra 251 allowance for uncounted errors), the resultant chi-square distribution with n-2 degrees of freedom, and the condition that ISG 0.25 La is imposed.

The first method does not change the way the leakage rate or upper confidence level are calculated. It imposes two additional conditions on the data behavior, and puts limits on how much data scatter and nonlinearity are acceptable.

The second method is a hybrid combining elements of both the mass point and BN TOP-1 total time methods. IE has the advantage of not assigning too much weight to the first point, and ensures that the width of the

~

confidence interval does not approach zero as the number of readings increases. It is a different way to calculate leakage rate and upper confidence level (UCL), while forcing the width of the confidence interval to be positive.

C. REGULATORY POSITION The procedures, requirements, measurements, and analytical techniques

- reconvr, ended by American National Standard ANSI /ANS 56.8-1981, " Containment 6.a RG TASK MS 021-5

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l Position 17. Same as 7. l Posti. ion 18. Clarification in the standard is recommended for a concern  !

on packing leakage that seems logical but that has had to be clarified in the past. '

Positions 19, 20 21. Incorporation of these supplementary recommendations ,

1981 will allow discontinuing the use in licensing ,

withthoseofANSI/ANS5'6.{ReportBN-TOP-1,"TestingCriteriaf reviews of Bechtel Topical LeakageRateTestingofPrimar\yntainment Structures for Nuclear Power Plants,"

s Revision 1, November 7,1972. At the_same time, better definition will be pro-  :

vided than is currently available in A'NSI/ANS 56.8-1981 for determining initial N

and continuing stability of the containment tmosphere and instrumentation as well as for determining when a sufficiently stable containment integrated leakage rat'e has been achieved to terminate the test. Ithhouldbenotedthata24-hour periodic test is no longer mandated. The preoperational test is still intended to be at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in order to validate test assumptions and analytic extrapolations to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from shorter test durations and t'o be available as a baseline test.

s C. REGULATORY POSITION ,

s The procedures, requirements, measurements, and analytical techniques recommended by American National Standard ANSI /ANS 56.8-1981, " Containment f

System. Leakage Testing Requirements," together with its Appendices are i generally acceptable to the NRC staff. They provide an adequate basis for complying with the Commission's regulations with regard to the leakage testing of containment systems, subject to the following:

1. Conflict. If any provisions of the standard conflict with the require-l

! ments of Appendix J to 10 CFR Part 50, the requirements of Appendix J govern.

l l 2. Preoperational and Periodic Tests. Paragraphs 3.2.1.2 and 3.2.1.3 (page 3) should have their last sentence changed to read:

"Any Type B and C test leakages, including instrument error, not accounted for in the Type A test shall be added to UCL to estimate the overall integrated leakage rate."

3. System Venting and Draining. Paragraph 3.2.1.5 (page 3) should have i

the following paragraph added between its two current paragraphs:

"Nonseismically designed piping systems that penetrate containment i

shall be postulated to rupture and must be vented and drained on both DRAFT 6.L RG TASK MS 021-5

the upstream and downstream sides of the containment isolation valves unless approval has been received from the NRC staff that certain systems must remain filled for practical considerations such as operational safety."

4. Pressurizing Considerations. Paragraph 3.2.1.7 (page 4) should have its second sentence changed to read:

"Unless needed for operational safety, all possible sources of instrument air, service air, and auxiliary steam into the containment..."

5. Liquid Level Monitoring. In paragraph 3.2.1.8 (page 4) the last two sentences of the second paragraph, that exclude the sump level from those items affecting containment volume, should be deleted.

6. Verification Test. a. Paragraph 3.2.6(b) (page 5) should contain the following additional material:

"1. The purpose of the verification test is to verify the ability of the Type A test instrumentation to detect leakage rates approaching L,.

2. The verification test should measure a change in the leakage rate not a change in the mass. Therefore, a "one point check" is insuffi-cient, and sufficient points should be used to establish a continuous definitive line slope extension following directly from the Type A test line plot.

3. The start time for the verification test should be within I hour of imposing the leakage rate.

4. Data acquisition should not be interrupted without justification that will be acceptable to the NRC staff from the end of the st:c-l cessful Type A test to the start of the verification test. In some cases, this period of time could be several hours and should then be considered to be part of the Type A test. Data acquisition, of course, should also not be interrupted without justification that will be acceptable to the NRC staff from the start to the finish of

, the verification test.

5. A satisfactory verification test is to be performed following comple-tion of a Type A test regardless of whether any other verification tests were performed prior to the successful Type A test.

6. The Type A test leakage rate calculated at the start of the verifi-

! cation test is to be used for comparison with the verification test."

i DRAFT .. 7 RG TASK MS 021-5

. I

b. In Paragraph 3.2.6.(b)(2) (page 5), the method described is acceptable g only if it includes a requirement for a statistically adequate number of air mass measurement data sets for the measurement of W2 used in the equation for t , where the step-change verification test and if the formula result is 5, O. p t is the time required to pump daily allowable leakage at the rate being p

pumped.

7. Type B and C Test Pressures. Paragraph 3.3.2 (page 6) should have the last sentence of its first paragraph changed to read:

" Substituting a vacuum test for pressurization to Pac shall be per-mitted as long as the differential pressure across the item under test is at least p and each such test has been approved by the ac regulatory authorities."

8. Type B and C Test Schedule. Paragraph 3.3.4(b) (page 6) the following should be added:

" Visual inspection of air lock door seals must be performed af ter each opening of a door and just prior to its closing to detect worn, damaged, or unseated seals or readily apparent obstructions that would prevent proper closing and sealing of the door."

9. Test Medium. In 3.3.5(b) (page 6) the following should be added to the first sentence, after "... subsequent to an accident...":

"... assuming a single active failure in the affected system..."

10. Calibration. a. Paragraph 4.2.2 (page 7) should be changed to read:

" Instrumentation used for Type A containment integrated leakage rate tests (ILRT) shall be individually calibrated no more than six months prior to the start of the Type A test and shall be calibration checked no more than one month prior to the performance of the Type A test.

Primary test..."

b. Paragraph 4.2.4 (page 8) should delete the words " calibration checks",

" checks", and " checked", and replace them with " calibration", " calibrations",

or " calibrated" as appropriate.

11. Temperature Measurement (location of sensors). a. Unless and until the ANSI standard incorporates, in paragraph 5.5 (page 11) or elsewhere, detailed guidance on how to determine sensor placement and weighting factors, licensees should use and have available for review by the regulatory authorities, DRAFT : .. 7 8 RG TASK MS 021-5

a technique that allows verification of sensor placement and of weighting factors.

b. Area surveys for dry-bulb and dewpoint temperature within the containment structure should be made with and without forced air circulation.

As a minimum, such surveys should be made prior to the preoperational and initial periodic leakage tests. (Supplements 5.5.1 and 5.5.2)

12. Absolute Test Method. Paragraph 5.7.3 (page 12) should explicitly define the temperature term to be used in its equation as being derived froe I

T'. = n "j 1 -

j=1 T j

where w is a weighting factor or the percentibe of overall containment volume assigned to a particular temperature sensor and n is the number of temperature sensors used in the test.

13. Reporting of Results. The format and content of paragraph 5.8 (page 12) should be used for the submittal of reports required by Appendix J to 10 CFR Part 50, including the individual Type A, B, and C "as found" and "as left" leakage readings required by 10 CFR Part 50, Appendix J.

14. Water-Filled Systems. Paragraph 6.4 (page 14) should have the following added, after "...for at least 30 days,...":

"..., assuming a single active failure in the affected system...."

15. Flow Rate (Air, Water, Nitrogen). In paragraph 6.5.2 (page 14) the second sentence should be revised to read:

" Makeup fluid to the test volume required to maintain test pressure shall be the same type fluid as the test volume and shall be measured using a flowmeter that directly measures valve leakage rate."

16. Water Collection. In paragraph 6.5.3. the following sentence should be added:

"Where it is uncertain that all water is being collected, the water makeup to the test volume, provided to maintain test pressure,shall be measured."

17. Vacuum Retention. In paragraph 6.5.4 (page 15), delete the sentence,

" Alternatively, a pressure (vacuum) gauge may be used to measure pressure build-up (vacuum decay) versus time," and the remainder of 6.5.4 following that sentence.

DRAFT " -

9 RG TASK MS 021-5

. . _ . = _ . . - - . __

. . S?.VifY[ ,

19. Containment __ Atmosphere Stablization. The following supplementary l recommendations should be used as noted: I

a. Unchanged l b. Revise to read "The calculated contaire.ent leakage rate should be equal to or greater than zero prior to declaring the start of the test (Supplerrents 5.2.1)."

c. Unchanged

d. Unchanged i e. Unchanged 4

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18. Recording of Leakage Rates. In paragraph 6.6 (page 15) the following subparagraph should be added:

"6.6.4 Packing Leakage. Any packing leakage that provides a leakage path outside the containment system must be included in Type C test results. Packing leakage that remains within the containment system need not be included in the Type C test results."

19. Containment Atmosphere Stabilization. The following supplementary recommendations should be used as noted:

" a. A plot of containment partial pressure of water vapor versus time should be made. The vapor partial pressure should remain relatively stable to ensure that it does not adversely affect the leak rate calculation. (Supplements 5.3.2.1 and 5.5.2)

b. -Anegative4ofntainment-Jeakagerate-shouldnot-be-evident-prior-to ,, .m

-declar4ag-the-star-t-of-the test. (Supplements 5.2.lf -

c. The recorded data from the individual sensors should be continually reviewed to identify unexpected behavior ~ that may indicate a faulty sensor or a change in test conditions. The trend of each sensor within a specific subvolume should follow the trend of the average for the subvolume. Where only one sensor per subvolume exists, its performance should be evaluated for erratic behavior, for example by comparison with adjacent subvolumes or change with respect to previous readings cf that sensor. (Supplements 5.6)

d. Containment air temp 1rature is stabilized when:

(i) the slope of the temperature vs time curve is less than U

0.5 F/ hour averaged over the last two hours, and (ii) the rate of change of the slope of the temperature vs time curve U

is less than 0.5 F/ hour / hour averaged ever the last two hours.

(Supplements 5.3.1.3)

- e. Containment air temperature shculd remain stabilized over the entire test period, including the verification test, and the tests should be continued only so long as the temperature is stabilized."

(Supplements 5.3.1)

20. Sensor Stability. The following supplementary recommendation should be used as noted:

The number of sensors that may be lost without having to abort the test is a function of the number of sensors used to monitor a particular parameter, the sensor locations, and the volume fraction assigned DRAFT 10 RG TASK MS 021-5

to each sensor. The remaining sensors should be no less than the minimum number specified in paragraph 4.4 of ANS 56.8, should continue to demon-

- strate stabilized test conditions, and should be the only sensors used in I calculating the containment leak rate for'the entire test duration. For sensors suspected of being faulty, data should still continue to be recorded so that it is available if needed for,, post.-test evaluation."

(Supplements 4.4.2.2)

21. Data Recording and Analysis. The following supplementary recommenda-tions should be used as noted:

"a. The start time of the containment integrated leak rate test should be declared following a determination that test conditions have stabilized and is not subject to change during or after data collection. If any test is restarted, the restart time should be selected as " time forward" not as " time backward." (Supplements 5.4)

! b. Instantaneous (unaveraged) sensor readings should be recorded at approximately equal intervals but in no case at intervals greater than one hour. (Supplements 5.6)

c. The minimum test duration after the containment atmosphere and instrument readings have stabilized should be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for a preoperational Type A test and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for periodic Type A tests.

(Supplements 5.4) i

d. Upon completion of the test, the rate of change of the calculated L leakage rate at the one sided, 95% upper confidence limit should indicate,that the containment leakage rate is stabilized at a value equal to A less tnan 75% of the maximum allowable leakage rate, within a negligible positive or negligible negative slope.

e. Upon completion of the test, the one-sided, 95% upper confidence limit for the leakage rate'should be positive and equal to or less l

than 75% of the maximum allowable leakage rate, using a mass point analysis technique.

f. The difference between the calculated least squares fit leakage rate and the one-sided 95% upper confidence level leakage . rate shall. not be increas ng over the last half-hour of the test. 'N.

A N l

/

I DRAFT 11 RG TASK MS 021-5

3

21. Data Recording and Analysh. The following supplementary recommendations should be used as noted:

a, b, c. Unchanged d, e, f. . Delete existing wording and replace with:

d. Two different methods of data reduction are presented. Either method would be acceptable to the NRC staff for determining test acceptability .

(1) Method 1 - ANSI Extended Method For double generated during the Type A and verification tests the mass point method of ANSI /ANS 56.8 is utilized.

In addition, the following two conditior.s must be met at the end of the test, at time t:

-. (a) If:

1 11.a

. FNrs (B'-8)1Wg +(A'-A)IWg t,+C'IWg t 3.6414 (n -5.3n+8.0394)

(n-3) > (a.1)

Iwg -B'Iwg-A'Iw gt,-C'Iw tgg (n -7.7098n+14.9069)

Then: C't 1 0.25 , (a.2)

A' (b)

[n(Iwjgt ) - (It )(Zw y y )] Lam 1(t-I)#

g

~

~

(n(It )-(It )g J [n(Iwg )-(Iw )#]

g g L$m Z(tg -i) +Lat (n-2)(n+1.33)(n+42.f.03) 18.803(n-1.202)(n+28.155)

In the above the notation of ANSI /AN5-56.8-1981 is used.

A', B', and C' are the solutions to the equations:

I Iw g = B'n + A'Itg + C'It Iw tg g = B'Itg + A'It + C'It g Iwt{=B'It + A'Itl + C'Itj g

i I

and are the coefficients for the least-squares parabola:

W = B' + A' t

• C ' t 1

11b I

'?l+I}Yf (2) Method 2 - Hybrid Methoc Tho following procedure may be used to determine an acceptable leakage rate.

a. Notations i = point index, i=1,2, ..., n ts = time, in hours, since the beginning of the test W, = neasured containment mass at the it" point A., B = slope and intercept of the regression line constructed from n points (n > 21 and using Mass Point analysis Y. = Leakage rate at n'a point calculated as -2400Ao/B.

b. At each time point i obtain the corresponding time to in hours and the associated containment mass W..

c. If the number of point collected, n, is 3 or larger, construct a regression line for the n points following the Mass Point analysis.

From this regression line calculate A.. the slope of the line, and B ,the intercept of the line.

d. Calculate the estiaate of the leakage rate at n'" point (time to) as -240C^.,0.. Call this estimate Y.. Obtain r such estimates:

Ys, Y., ..., Y..

o. Now cansider a plot in which the horizontal aufs denotes time (t )

and the vertical axis denotes the corresponding estimate of the containment leakage (Y ). This plot is " dynamic" in the sense that as the test progresses more points are added to the plot and the estimate of the leakage is revised accordingly,

f. If the test ends at time t., then r = a - 2 points (t. ,Y ), i=3, ..., a are. plotted, ll . c

<l7 ?lyf

g. Using standard regression analysis, derive S, the gstimate of the standard deviation of the estimated leakage rate (Y) f rom the regression line. This quantity is formally defined as the square root S*, where a

I (Y -Y)2

• S* =

r-2 and where the suaeation extends from 3 to a (f or r time points).

h. The working formula for S" is developed below Let Q1 = E Y where the Q2 = I Y2 sussation Q3=It is carried Q4 = I t2 over r=a-2 05 = E Yt elements Calculations:

Total Sus of Squares, TSS = Q2 - (Q1)*/r Regression Sua of Sqyares, Pts = (Q5 - (QI)(Q3)/r3" / (Q4 - (03)*/r3 Degrees of freedos, df = r-2 Standard deviation of leakage rate estimateabouttheregressionline,S=[(TSS-RSSI/(r-2)

1. The 951 upper confidence limit for the leakage rate is calculated ast UCL=f+t...Sp/t1+1/r+(t,i-tl'/>(t. - t l')

where 5 = (1Y )/r , average of r = a-2 estimates of leakage rate t = ($te)/r,averageofr=a-2timeintervals t=3 t, = time at the end of the intended end of the test (24 hrs.)

i l

l t,. = 95** percentile of the Student's t distribution for r-2 df, as obtained from Table B1 of ANSI /ANS-56.8-1981.

J. UCL aust be positive and aust not exceed 0.75 L..

II.d

D. IMPLEMENTATION The purpose of this section is to provide information to applicants and licensees regarding the NRC staff's plans for using this regulatory guide.

This draft guide has been released to encourage public participation in its development. Except in those cases in which an applicant proposes an acceptable alternative method, the method to be described in the active guide reflecting public comments will be used by the NRC staff in evaluating procedures for containment system leakage testing for compliance with the amended Appendix J to 10 CFR Part 50 if the amendments are promulgated as proposed in FR .

t 4

e DRAFT ' '. . 'i : 12 RG TASK MS 021-5

[ o,, UNITED STATES

$ n NUCLEAR REGULATORY COMMISSION

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JUL 8 1985 MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM: Victor Stello, Jr., Chaiman Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 77 The Comittee to Review Generic Requirements (CRGR) met on Mggday, June 3,

' ~

1985 from 1-5 p.m. A list of attendees for this meeting is enclosed (Enclosure 1).

J. Richardson, and G. Arndt (RES) presented for CRGR review the proposed Revision of Appendix J (Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors) of 10 CFR Part 50 and the related Regulatory Guide (Task No. MS 021-5) entitled " Containment System Leakage Testing" which would provide a qualified endorsement of an industry standard on this matter (ANSI /ANS 56.8-1981). (Category 2 item.) The CRGR also had benefit of dis-( cussions with Regional personnel relative to their direct experience with licensee containment leak rate surveillance testing and Technical Specifi-cations. CRGR reviewed the proposed Appendix J revisions and sampled a number of the 21 regulatory positions being proposed in the Regulatory Guide endorse-re .t cf ?!!/?.'!S 56.9-1981. CRGR was, however, unable to conclude its review and recorsnendations on this matter and decided an additional CRGR meeting would be required. A more complete set of minutes on this matter will follow this concluding CRGR meeting.

This document contains no predecisicnal information and therefore will be released to the Public Document Room.

Questions concerning these meeting minutes should be referred to Walt Schwink (492-8639).

/'

/u .

V ctor SteHo, Jr Chairman Comittee to R ew Generic Requirements

Enclosure:

As Stated cc: See next page b

l4

D JUL 8 1985

(

cc: Cocinission (5)

SECY Office Directors Regional Administrators CRGR Members G. Cunningham J. Richardson G. Arndt J. Glynn I

l

w-I k

Enclosure 1 LIST OF ATTENDEES CRGR MEETING NO. 77 June 3, 1985 CRGR MEMBERS V. Stello R. Bernero E. Jordan J. Scinto T. Ippolito (for J. Heltemes)

R. Cunningham OTHERS J. Richardson G. Arndt J. Burns J. Shapaker

/ J. Huang

\ M. Taylor R. Hernan G. Arlotto A. Tse

~

S. Feld B. Richter C. A. Petraute J. Pulsipher M. Federline D. Kirkpatrick F. Jape F. Maura S. Rozal S. Hare D. Lurie 1

. =

1. 'o, UNITED STATES

![com y, g ' NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 i

1 g E

\ *****

/ .

JUL 151985 MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM: Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 76 The Comittee to Review Generic Requirements (CRGR) met on Wednesday, May 29, 1985 from 1-5 p.m. A list of attendees for this meeting is enclosed (Enclosure 1).

1. G. Arlotto and A. Hintze (RES) presented for CRGR review a proposed Regulatory Guide (IC 609-5) entitled " Criteria for Power. Instrumentation and Control Portions of Safety Systems." This proposed Guide has received public coment and RES intends its issuance as an endorsement (with ex-ceptions) of IEEE Std. 603-1980. This IEEE Std is a broad scope standard integratin Std. 279 1968 (g aand number 1971). of existing2IEEE Enclosure standards sumarizes and(Category this matter would supersede 2 IE

( Item).

2. J. Richardson, G. 'Arndt and J. Glynn (RES) completed the CRGR briefing on the proposed Revision of Appendix J (Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors) of 10 CFR Part 50 and the related Regulatory Guide (Task No. MS 021-5) entitled " Containment System Leakage .

Testing" which is intended to endorse with exceptions the ANSI /ANS 56-8-1981 standard for leakage testing. Enclosure 3 sumarizes this matter (Category 2 Item).

Enclosures 2 and 3 of this document contain predecisional information and there-fore will not be released to the Public Document Room until the NRC has con-sidered (in a public forum) or decided the matters addressed by the infomation.

Questions concerning these meeting minutes should be referred to Walt Schwink (492-8639).

,-, - r }]-

y -b 54i7 Victor Stello, Jr'. , Chaiman Comittee to Review Generic Requirenents

Enclosures:

As Stated cc: See next page ,

r' . Ci q

[ ( O (, < l~

4 cc: Comission (5)

SECY Office Directors Regional Administrators CEGP Members G. Cunningham J. Richardson C Arndt G. Arlotto A. Hintze J. Glynn

(

l 1

l l

I l

l t

I

! Enclosure 1 LIST OF ATTENnEES CRGR MEETING NO. 76 May 29, 1985 CkGP MEMBERS V. Stello R. Bernero E. Jordan J. Scinto T. Ippolito (for J. Heltemes)

D. Ross R. Cunningham OTHERS W. Schwink J. Richardson G. Arndt S. McNeil J. Burns J. Shapaker

( J. Huang M. Taylor R. Hernan B. Morris A. Hintze

.G. Arlotto D. Sullivan G. Marcus F. Rosa J. Watt R. A. Rohrbacher A. Tse E. Shomaker M. Ernst P. Williams S. Brown W. Houston J. Slynn

1. [o,, UNITED STATES

! c NUCLEAR REGULATORY COMMISSION p wAsHiscrow. o. c. rosss

..','..+ AUS 2 01985 i

MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM: Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

SUBJECT:

' MINUTES OF CRGR MEETING NUMBER 78 Tne Co raittee to Review Generic Requirements (CRGR) met on Monday, July 8,1985 from 12-6 p.m. A list of attendees for this meeting is enclosed (Enclosure 1).

1. T. Speis (NRR) presented for CRGR review the proposed resolution of A-46,

" Seismic Qualification of Equipment in O Enclosure 2 sunriarizes this matter (Category 2 Item)perating Plants.

2. .B. Jchnston (NRR) briefed the CRGR concerning updated recomendations on Fire brotection Policy and Program actions. Enclosure 3 sumarizes this matter (Category 2 item).

{

3. F. Congel (NRR) briefed the CRGR concerning SRP 12.6 series pertaining to expansion of spent fuel storage. pools. Enclosure 4 sumarics this matter (Category 2 item).

I 4 C. Serpan (RES) briefed the CRGR concerning agency activities in the development of NDE qualification and performance demonstration criteria.

Enclosure 5 sumarizes this matter (Category 2 item).

l

5. G. Arndt (RES) presented for CRGP review the proposed Revision of l Appendix J (Primary Reactor Containment t.eakage Testing for Water-Cooled Power Reactors) of 10 CFR Part 50 Enclosure 6 summarizes this matter (Category 2 Item).

6. J. Zudans (IE) presented for CRG'l review, the proposed amendments to 10 CFR 21. " Reporting of Defects and Noncompliance: and 20 CFR 50.55(e),

" Reporting of Defects in Design and Construction." Enclosure 7 sumarizes this matter (Category 2 item).

Enclosures 2 through 7 contain predecisional infonnation and therefore will not l

be released to the Public Document Room until the NRC has considered (in a public forum) or decided the matters addressed by the enclosures.

.g l

! cc c.

,c >

f/

_ .g . AUG 20 GS5 Questions concerning these meeting minutes should be referred to. Welt Schwink (492-8639). t

~

i ,

s

/_T ctor Stello, . airman C >mmittee to Revi neric (jhequirements

Enclosures:

As Stated cc: Commission (5)

SECY Office Directors Regional Administrators CRGR Members G. Cunningham T. Speis W. Johnston F. Congel C. Serpan

[ G. Arndt J. Zudans 6

e 4

4

e -

. . s Enclosure 1 LIST OF ATTENDEES "~

CRGR MEETING NO. 78 .

July 8, 1985 I CRGR MEMBERS V. Stello R. Bernero E. Jordan J. Scinto C. Seyfrit (for J. Heltenes)

R. Cunningham OTHERS J. Sniezek J. Austin M. Taylor J. Zudans T. Cox C. Cameron J. Conran G. Lanik W. Brach C. Browr T. Spets M. Federline

[\ N. Anderson D. Kirkpatrick F. Schroeder F. Jape -

K. Kniel F. Maura T. Chang S. Rozak

. G. Bagchi S. Hare V. Benaroya D. Lurie B. Johnston F. Congel D. Notley O. Lynch B. Shields J. Muscara i F. Rosa C..Z. Serpan T. Wambach S. Block D. Muller J. Richardson G. Arndt i J. Burns

! J. Shapaker

! J. Huang l M. Taylor R. Hernan G. Arlotto A. Tse i S. Feld .

8. Richter - i C. A. Petraute - ;

J. Pulsipher i

l