ML20245A369

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Discusses 10CFR50,App J Re Use of ANSI N45.4-1972 Std When Conducting Containment Integrated Leakage Rate Tests. Forwards Draft marked-up Info Notice to Accomodate Comments
ML20245A369
Person / Time
Issue date: 10/16/1986
From: Ballard R
Office of Nuclear Reactor Regulation
To: Marsh L
Office of Nuclear Reactor Regulation
Shared Package
ML20244D710 List:
References
NUDOCS 8703200216
Download: ML20245A369 (9)
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Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D. C. 20555 g

J . . . . ** OCT 16 WE MEMORANDU" FOR: Those on Attached List FR0": Ronald L. Ballard, Chief Engineering Branch Division of PWR Licensing-A, NRR

SUBJECT:

CONTAINMENT INTEGRATED LEAKAGE RATE TEST (CILRT)

METHODOLOGIES: MASS POINT AND TOTAL TIME Appendix J -to 10 CFR 50 reouires the use of the ANSI N45.4-1972 standard when conducting CILDTs. This standard identifies only.two calculational methods for determining leakage rate from the test data, these being " Total Time" and

" Point-to-Point". However, many licensees have, for some years, used the " Mass Point" method which is described in a later standard, ANSI /ANS-56.8-1981; a method that has been determined to be technically acceptable by the staff for many plants. Through a memorandum from W.1. Olmstead dated iluly 16, 1986, OGC indicated that the Mass Point method should not be used unless an exemption from the regulation were granted. The problem, then, is to decide what to do about this inconsistency between industry practice and the regulatory requirements.

We have prepared two proposed approaches to resolving the problem: li a limited rule change; and 21 an IE Information Notice. Drafts of these iters are attached as Enclosures 1 and 2.

Enclosure 2, the draft IE Information Notice, is a revision of a draft notice provided by IE during an August meeting in Mr. Vollmer's office. The revision has been informally reviewed by knowledgeable technical representatives of DPLA, DPLB, DRL, and DSR0 in NDP; the Offices of IE, RES, GC, and RM; and the five Regions. Their coments are sumarized in Enclosure 3, identified by organization. Minor changes have been made to the attached draft Information Notice to accomodate certain coments (nos. 3, 6, and 7).

The draft rule change alternative (Enclosure 1) has not yet gone throuah anv informal review process. Neither have other possible alternatives, including l issuance of a generic letter or the granting of plant-specific exemptions.

An important factor to be considered in determining the most appropriate course of action is the proposed revisions to Appendix J, which are presentiv before the Commission. The revisions take into account CILP.T as well as a number of other issues. A regulatory guide, which is part of the proposed

Contact:

J. Pulsipher X27793 l r lf Q 2 DO%L -

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l-I Those Listed 2 ET 161986

, Appendix J revision, endorses the mass point method described in l ANSI /ANS-56.8-1481, with certain reservations regarding the statistical )

l treatment of CILRT data.

We intend to arrange a meeting with R. Vollmer and representatives of affected offices in the near future to decide on an appropriate course of action. Please discuss the two attached alternatives with appropriate personnel in your organization so that they will be prepared when the meeting is arranged. Contact me if you have any questions or comments.

QF 81 LM MGM U AOI' Ronald L. Ballard, Chief Engineering Branch Division of PWR Licensina.A Office of Nuclear Reactor Regulation Attachments:

As stated cc: R. Vollmer T. Novak C. E. Rossi D. Crutchfield G. Lainas R. W. Houston E. Jordon G. Arlotto L. Shao G. Bagchi J. Pulsipher DISTRIBUTION:

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LATE :10/N /86  : 10/' /86  : 10/'s/86 - -

OFFICIAL RECORD COPY

Addressees:

l' L. Mars'h, Chief, PBEB, NPR J. Hulman, Chief, BWPS, NRR W. Minners, Chief, 5051, NP.R *

.R. Rosnak, Chief. SOEI, NRR R. Baer, Chief, EGCB, IE J. Richardson, Chief, MSEB, RES W. Shields, OGC

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Port 50, App. J Nuclear Reguletory Commission En cicsure I-close u practical to that thtch sould exist Information on any vahe closure malfune-tion or vahe leakage that recutres corree-under design buis accident conditions (e g..

vented.drajned flooded or pmsurlud) tive action before the test. shall be included

' O. " Acceptance criterta" means the stand- in the report submitted o the Corr.mlaston 4 ard agamst ahtch test res.ilts ue to be com- as specified in V.B.

pared for estabhshing the functional secept* (c) The containment test conditions shall ability of the containment as a leakage lim- stabilize for a period of about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior ~

iting boundary, to the start of a leakage rate test.

(d) Those portions of the fluid systems Ill.1AAKAct TESTING R8QUtaEMENTs that ut part of the reactor coolant pressure A progra.m consisting of a schedule for boundary and are open directly to the con- d {

conducting Type A. B. and C testa sha'l be . tainment atmosphere under post acetdent -

develcoed for leak testing the primary reac' conditions and become an extension of the tor containment and related systems and boundary of the containment shall be bD components penetrating primary contain- opened or vented to the containment atmos- ~

ment pressure boundary- phere prior to and during the test. Portions I i

Upon completion of construction of the of closed systems inside containment that prtrnary reactor containment includmg in- penetrate containment and rupture as a g % $g (&

stallation of all portions of mechanica.l. result of a lou of coolant accident shall be fluid. electrical, and instrumentation sys- vented to the containment atmosphere. All tems penetrating the prima.ry reactor oon- vented systems sha!! be drained of s'ater or h@@

tainment pressure boundary, knd prior to other fluida to the extent necesary to any reactor operating period. preoperational assure exposure of the system containment and periodic leakage rate tests. as applica- laolation valves to containment air test pres-ble, shall be conducted in accordance with sure and to assure they s1ll be subjected to peacc1hnt dWmnM pmsun. Sys-A. A test-1. hefest rogstrements (a) tems that are required to maintain the Containment inspection in accordance with plant in a safe condition during the test V.A. shall be performed as a DMrequisite to shall be operable in their normal mode. and riormance of Type A tests. During need not be vented. Systems that ue not.

the the pe P' nod betseen the initiation of the con- mully filled with water and operating under 141nment inspection and the performance of post accident condations, such as the con-the Type A test, no repairs or adjustments lainmmt heat Mmoval system, mo not M shall be made so that the containment can vented. However, the containment isolation be tested in as close to the *as is" condition valves in the systems defined in III.A.I.(d) as practical During the period between the shall be tested in accordance with III C. The completion of one Type A test and the 1rtiti, measund leakage rate from these testa shall ation of the containment inspection for the be reported to the Commission.

subsecuent Type A test, repairs of adjust- 2. Conduct ctf tests. Preoperational leakage menta shall be made to components shoa, rate testa at either reduced or at peak pres-leakage stoeeds that specified in the technj. sure, shall be conducted at the intervais cal specification as soon as practica.1 af ter speef fled in I!!.D

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pentification. If during a Type A test. in,

.udmg the supplemental test specified in ~be 3. Test methods. (a) All Type A tests shall conducted in accordance with the pros 1-II.A.3 (b). potentially exceash e leakage paths are identified which will interfere alons of the American National Standard with satisfactory completion of the test, or Nt5 41972.14alage Rate Testing of Con-shich result in the Type A test not meeting tainment Struf,tures for Nuclear Reactors.

the acceptance criteria III A.4.(b) of March 16.197P The method chosen for the III.A.5 (b), the Type A test shall be termt. initial test shall normally be used for the mated and the leakage through such paths periodic tests -

shall be snessured using local leakage test * (c) The accuracy of any Type A test shall ing methods. Repairs and/or adjustments to be vertiled by a supplemental test. An sc.

equipment shall be made and a Type A test eeptable method is desertbed in Appendix C performed The corrective setton taken and the change in leakage rate determined from the tests and overall integrated leslage de. %NSI N45.41972 leakage Rate Testing termined from the local leak and Type A of Containment Structures for Nuclear Re-testa shall be included in the report submit. actors (dated War. 16.1972L Copies snay be ted to the Commission as specified in V.B. obtained from the American Nuclear Boeie.

(b) Closure of containment isolation ty. 344 East Ogden Avenue. Hinsdale. IL vahes for the Type A teet shall be accom. 00521. A copy is available for inspecuen at plished by normal operation and sithout the Commtaslon's Publ1C Document Room.

any preliminary exercising or adjustments 1717 E Street NW.. Washington. DC. The (e.g.. no tightening of valve after closure by incorporation by reference Sas approved by vajve motort Repairs of maloperating or the Director of the FederaJ Register on Oc-letting valves shall be made na necessary. tober 30.1972 495

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,- SSINS No: XXXX

, y g - IN 86-XX

, *L - .'./ UNITED STATES.

./ 7-7 M NUCLEAR REGULATORY COMMISSION

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OF INSPECTION AND ENFORCEMENT WASHINGTON, D. . 20555 -

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l August 1986 1;

IE INFORMATION NOTICE NO. 86-XX: CONTAINMENT INTEGRATED LEAK' RATE TESTS Addressees:

All nuclear power reactor facilities hol. ding an operati license (OL) or a -

3 ' construction persit (CP).

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Purpose:

This infomation notice. is prdvided as a n'otificatio'n o ,a pote,ntially signiIf ,

j cant problem pertaining to containment integrated leak rate tests (CILRTs). , _'

l It is expected that recipie'nts will review the information for applicability to their facilities and consider actions, if appropriate, to preclude this probles from occurring at their facilities. However, the suggestion contained -

in this infomation notice (name.ly, at licensees rev'tew their programs with respect to the guidelines provided) oes not constitute an NRC requirement.

. Therefore, no specific action or wr tten response is required.

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I Description of Circumstances: ' ~ '

g..oc A recent NRC Office of General Counsel review of the legality of the different C ' ~ CC '

types of test computations utilized to detemine leakage rate for absolute +s. ue / c -

methodCILRTsperformedthroughouttheing hasindicatedthatmanylijjn-J~

sees are currently using a test computation at :: =t =:0 th'Fegu_latory requirements of 10 CFR 50, Appendix J. Thi f' rT - - method.Jof og/J, ,- i computation is the mass point. calculation described in ANSI /ANS-56.8-1981,

" Containment Systes Leakage Testing Requirements".

I s

I In order to meet the regulatory requirements of Appendix J, licensees must f-eJ g l

. measure the integrated leakage rate using one of the CILRT nethods described in ANSI N45.4-1972, " Leakage-Rate Testing of Containment Structures for Nuclea d h j, ,

eactors". This standard provides the on of perfoming either the absolut p/

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-Qp^ ]eethod or reference-vessel methodwoCILRT types of leakage rate computa- 1 q* # (tions are allowed for the 24-gour_ period bsolute method CILRT. These consist -

or the; point-to-point'and the fo y J 3 e>ca Wu'1stionsP Additiona11y, the

'FW is e .< o~ ]rf M &t:f ;:Hed total time tesft fydelnted in the Bechtel Topical Report f

.We, oddBN-TOP-1, Revision 1, " Testing Criteria for Integrated Leakage Rate Testing of

. Primary Containment Structures for Nuclear Power Plants" has been approved for

-yce' luk[u in accordance with ANSI N45.4, wi% a 4es? &n~j,n.as de&J h EN-ToF-l,

f. use

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$L '. ansaa dettraittes that the mass point computational mother! ="Mh a more accurate technical ~measWahe-eenteL-nmntegrated leakage i rate, the licens c :.y evomii~a mass point method Ju W iieettaa me an eXteption reques440r NRC starf review. - . - -

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IN 86-XX

' Date

_ Page 1 of 2 Discussion: kcWRd bY " ~

5 ction III. A.3.(a) of Appendix J requires that all CILRTs shall be conducted 1 in *cordance with the provisions of ANSI N45.4. In Section 5.1 of ANSI N45.

the fb lowing two methods of CILRTs are rovided: the absolute method and ie referen. -vessel method. In addition, the types ction 7.9 of the standard dese es leakage rate computations fs'rmitted for the absolute e od M CILRTs. The ly types of leakage rate computations allowed in $!%t are the point t s standard oint and the total time calculations. Henc , compliance with the regulator requirements of Appendix J for absolut ethod CILRTs can only be achieved thro b the use of the point to point total time leakage t r, ate computational metho .

  • It should be noted that CILR.T uits obtained roug'h'useofthetotal~ time /

c'omputation which exceed 0.75 La stitute failure to meet the acceptance'.

p ., ! .r criteria of Appendix J regardless o M ^ the concurrent use of the mass point e ulations.the' Failure he sults licensee obtained through to meet the

$m Jg%tance cru.eria through 1use of Jrf6 poM to point or total time _ computa-

'T bions cenerally constitutes a lo w e ea*==

as defined in the

' nteen ty N4 M ph Abnical Specifications and ' be reportable the licensee under the grovisions of 10 CFR 50.73 ections (a)(2)(ii) a (a)(2)(v)(c).

yhf.nIt ove is suggested that censees review their CILRT progr - ith respect to the guidelines.

4 f i M o specific a on or written response is required by this inform ion notice; f)owever, if ou have any questions regarding this notice, please. con at the H 4 Regional administrator of the appropriate NRC regional office or the tec ' al h contac listed below.

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L, b Edward L. Jordan, Director .

Division of Emergency Preparedness ~

and Engineering Response f Office of Inspection and Enforcement J. C. Pulslger; Technical Contacts: Y. S. ;: :.v NRR . .

(301) 492-949S r7H3 D. C. Kirkpatrick, IE (301) 492-4510 J. A. Isom, IE (301)492-9673

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b Discussion:

Section III.A.3.(a) of Appendix J requires that all CILRTs shall be conducted in accordance with the provisions of ANSI H45.4;Section III.A.3 (qi of l Appendix J also requires that test leakage rates be calculated using absolute values corrected for instrument error. In Section 5.1 of ANSI N45.4 the followino two methods of CILRTs are provided: the absolute method and the reference-vessel method. In addition, Section 7.3 of the standard describes the types of leakage rate computations permitted for the absolute method CILRTs. The only types of leakage rate computations allowed in this standard are the point-to-point and the total time calculations. Hence, compliance with the regulatory requirements of Appendix J for absolute method CILRTs can only be achieved through the use of the point-to-point or total time leakage rate computational methods, corrected for instrument error.

The NRC is in the process of making a general revision to Appendix J to 10 CFR 50; such a revision may alter the permitted CILRT calculations and, g consequently, the guidelines described in this notice. However, until a revision is complete and in effect, the following guidelines apply.

Paragraph 7.9 of ANSI N45.a reovires that a " statistically averaged" leakege rate be determined. However, ANSI N45.4 does not provide a specific method for eccounting for random and instrument error during a CILRT, as required by Appendix J. The NRC staff believes that the calculated leakege rate as determined by using the mass point method described by ANSI /ANS-56.8-1981 has technical merit. However, a CILPT test result is only considered acceptable if the leakage rate calculated by total time or point-to-point, including an acceptable calculation of 95% UCL, meets the acceptance criterion of Appendix J (i.e., does not exceed 0.75 Le or 0.75 Lt. as appropriate 1, with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> except as provided for in BN-TOP-1. An alternative method is considered acceptable if the leakage rate calculated by total time or point-to-point method, not including a UCL amount, meets the acceptance criterion of Appendix J, and concurrently, a mass point calculation, including a 95% UCL, calculated in accordance with ANSI /ANS-56.8-1981, also meets the acceptance criterion of Appendix J, with a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The verification test leakage rates must, however, be calculated using the total time or point-to-point method.

It is suggested that licensees review their CILRT program with respect to the above guidelines to assure consistency with regulatory requirements.

No specific action or written response is reovired by this information notice, however, if you have any questions regarding this notice, please contact the Regional Administrator of the appropriate NRC regional office or the technical contacts listed below.

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ENCLOSukE 3 L

INFORMAL COMMENTS ON DRAFT IE INFORMATION NOTICE .

1. Enferec this new position in a " time-forward" manner only; don't back'it to completed tests. (RII,RIII) y 2. Is a Tech Spec that says " mass point is OK" equivalent to an exemption?

This needs written clarification. (Rill

3. When the verification test is considered in conjunction with the CILRT, the combining of total time and mass point can become very confusing; methodology would be cumbersome and must be explained clearly in I.N.

(RII) 4 Suggestec methodology (using T.T. With M.P.) does not appear to meet the spirit of regs and may not be technically valid; appears to skirt the issue; pick a single methodology (T.T., M.P.) and go with it  ;

consistently, takino whatever steps are necessary to allow it (in the case of M.P.). (RI,RII,RIII)

5. Mey not be a temporary solution; may become permanent if general revision of App. J isn't completed. (RII,RIII) l
6. Mass pt. has technical merit, but 95% UCL is not good enough, and a 24 hr test period is not, by itself, good enough (see proposed Reg. Guidel.  !

(RIII)

7. BN-TOP-1 is only officially approved methodology that includes a 95t UCL and satisfies ANSI N45.4-1972; after the 24th hour of the test is reached, the BN-TOP-1 95! UCL is quite similar to ANSI 56.8-1981; we should promote the use of FN-TOP-1. (RIII)
8. IF.E management reportedly discourages issuance of an I.N.; they don't want to promote total time; want to do whatever is necessary to allow mass pt. (IE) l

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9. -Mass pt. + 95% UCL + additional requirements-could be made to be as conservative as or more conservative than total time or point2 to-point; this should be legally acceptable. (RI)

.30. The.l.N. skirts'the' issue. (DSRO,IE) 11.. If we don't intend to grant any exemptions, we should say so. (DSPD)

12. CRGR/ACRS have already reviewed / approved proposed Reg. Guide, so why gc.

back to old method (total time), (DSRO) 13.- The I.N.. appears to be legally. acceptable. (OGC) 14 .Doesn't (or may not) account for instrument error (reouired by III.A.3.(c) of App. J). (RIII)

15. Do not grant permanent exemptions to allow use of mass pt. a-la ANSI 56.8-1981; either 1) grant for limited time; or 2) with additional requirements of proposed Reg. Guide. If we grant the " goodies" from ,

revised rule.and Reg. Guide now, industry will be less likely to accept new rule / Reg. Guide and they may never be issued. (RIII)

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