RA-19-0295, Response to Request for Additional Information - License Amendment Request to Revise Units 1 & 2 Technical Specification 5.5.12 for Permanent Extension of Type a and Type C Leak Rate Test Frequencies

Response to Request for Additional Information - License Amendment Request to Revise Units 1 & 2 Technical Specification 5.5.12 for Permanent Extension of Type a and Type C Leak Rate Test Frequencies

ML19206B231
Person / Time
Site:	Brunswick
Issue date:	07/25/2019
From:	William Gideon Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-19-0295
Download: ML19206B231 (13)

Text

William R. Gideon Vice President Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 o: 910.832.3698 July 25, 2019 Serial: RA-19-0295 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Response to Request for Additional Information - License Amendment Request to Revise Units 1 and 2 Technical Specification 5.5.12 for Permanent Extension of Type A and Type C Leak Rate Test Frequencies

References:

1. Letter from William R. Gideon (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, "License Amendment Request to Revise Units 1 and 2 Technical Specification 5.5.12 for Permanent Extension of Type A and Type C Leak Rate Test Frequencies," dated February 27, 2019, ADAMS Accession Number ML19058A768

2. E-Mail Capture from Dennis Galvin (NRC) to Art Zaremba (Duke Energy), "Request for Additional Information Related to License Amendment Request to Revise Technical Specification TS 5.5.12, 'Primary Containment Leakage Rate Testing Program' for Permanent Extension of Maximum Appendix J Test Intervals," dated June 27, 2019, ADAMS Accession Number ML19179A131 Ladies and Gentlemen:

By letter dated February 27, 2019 (i.e., Reference 1), Duke Energy Progress, LLC (Duke Energy), submitted a license amendment request (LAR) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed amendment revises Technical Specification (TS) 5.5.12, "Primary Containment Leakage Rate Testing Program," to allow for permanent extension of the Type A and Type C leakage rate testing frequencies.

On June 27, 2019 (i.e., Reference 2), the NRC provided a request for additional information (RAI) regarding the LAR. Duke Energy's response to the RAI is provided in the Enclosure.

This document contains no new regulatory commitments.

RA-19-0295 Enclosure Page 1 of 11 Response to Request for Additional Information By letter dated February 27, 2019, Duke Energy Progress, LLC (Duke Energy), submitted a license amendment request (LAR) for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. The proposed amendment revises Technical Specification (TS) 5.5.12, "Primary Containment Leakage Rate Testing Program," to allow for permanent extension of the Type A and Type C leakage rate testing frequencies.

On June 27, 2019, the NRC provided a request for additional information (RAI) regarding the LAR. Duke Energy's responses are provided below.

RAI SCPB-1 Provide the correct values for Tables 3.4.4-3 and 3.4.4-4 or confirm the values originally provided are correct. Provide a description of how the As-Found ILRT values shown in LAR Enclosure Tables 3.4.4-1 and 3.4.4-2 were derived relative to the Performance Leakage Rate values shown in Tables 3.4.4-3 and 3.4.4-4.

Response to RAI SCPB-1 Table 3.4.4-3 and Table 3.4.4-4 Discussion The values originally provided in Table 3.4.4-3 are correct. The following Table 3.4.4-4 provides updated values for the March 30, 2005, Unit 2 Type A test.

Table 3.4.4 Verification of Current Extended ILRT Interval for BSEP Unit 2 Corrections Components Performance for valves Isolated Leakage Measured not in During ILRT Rate Leakage Accident Due to (wt.%/day)

Rate at Water Level Positions Excessive (Acceptance Test 95% UCL Corrections during Test Leakage Criteria 0.5 Test Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) wt.%/day Method 3/30/2005 0.3262 -0.0010 0.0638 -0.1333 0.2557 Total Time 4/1/2015 0.2799 -0.0798 0.0989 0 0.299 Mass Point The incorrect data originally provided for the March 30, 2005, Unit 2 Type A test was copied as written from the vendor report documenting the results of the test. In preparation of this RAI response, those vendor reports associated with historical Unit 1 and Unit 2 Type A testing were reviewed in more detail and additional discrepancies were identified.

The following minor discrepancies, which impact the data reported in Tables 3.4.4-1 and Table 3.4.4-2, were identified.

• As-found leakage rate data were provided for preoperational Type A testing for Units 1 and 2 (i.e., the September 2, 1976, data for Unit 1, and the October 8, 1974, data for Unit 2). Since these were preoperational tests, this data should not have been identified as as-found results. The associated as-found acceptance criteria were also removed.

RA-19-0295 Enclosure Page 2 of 11

• The as-found leakage value for the April 11, 2010, Unit 1 test is revised from 0.21 weight percent per day to 0.201 weight percent per day.

• The as-found leakage value for the July 14, 1982, Unit 2 test was recorded as 0.653 weight percent per day, however, the actual as-found leakage rate was indeterminate.

• The 95% Upper Confidence Limit (UCL) for the September 24, 1984, Unit 2 test is revised from 0.298 weight percent per day to 0.293 weight percent per day.

• The as-found leakage value of 0.497 weight percent per day is included for the February 19, 1990, Unit 2 test. Also, the as-left leakage value is revised from 0.334 weight percent per day to 0.344 weight percent per day.

• The as-found leakage value for the December 2, 1991, Unit 2 test is revised from 0.4956 weight percent per day to 0.404 weight percent per day.

• The as-found leakage value for the February 26, 1993, Unit 2 test is revised from 0.442 weight percent per day to 0.438 weight percent per day. Also, the as-left leakage value is revised from 0.351 weight percent per day to 0.347 weight percent per day.

• The 95% UCL and performance leakage rate for the March 30, 2005, Unit 2 test were revised to be consistent with the updates to Table 3.4.4-4 discussed above. The as-found leakage value is revised from 0.2922 weight percent per day to 0.426 weight percent per day. The as-left leakage value is revised from 0.256 weight percent per day to 0.389 weight percent per day.

The updates to Table 3.4.4-1 and Table 3.4.4-2 correct the identified discrepancies, and are provided below. These changes are minor and do not impact the conclusions of the LAR.

RA-19-0295 Enclosure Page 3 of 11 Table 3.4.4-1 BSEP Unit 1 Type A Testing History 95% Upper Acceptance Performance Confidence As-Found Acceptance As-Left Criteria Leakage Acceptance Limit Leakage Criteria Leakage (0.75La) Rate Criteria (La)

Test Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) 9/2/1976 0.191 N/A N/A 0.191 0.375 N/A 0.5 6/12/1981 0.307 0.356 0.375 0.352 0.375 N/A 0.5 9/25/1985 0.276 0.365 0.375 0.284 0.375 N/A 0.5 5/19/1987 0.205 (Note 1) 0.375 0.215 0.375 N/A 0.5 0.4956 2/4/1991 0.3251 (Note 2) 0.375 0.3408 0.375 N/A 0.5 3/25/2004 0.1265 0.3351 0.5 0.2602 0.375 0.2602 0.5 4/11/2010 0.1775 0.201 0.5 0.1387 0.375 0.1387 0.5 Note 1 and 2 are provided in the original LAR (Reference 1).

RA-19-0295 Enclosure Page 4 of 11 Table 3.4.4-2 BSEP Unit 2 Type A Test History 95% Upper Acceptance Performance Confidence As-Found Acceptance As-Left Criteria Leakage Acceptance Limit Leakage Criteria Leakage (0.75La) Rate Criteria (La)

Test Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) 10/8/1974 0.153 N/A N/A 0.153 0.375 N/A 0.5 7/14/1982 0.304 (Note 3) 0.375 0.318 0.375 N/A 0.5 9/24/1984 0.293 (Note 4) 0.375 0.293 0.375 N/A 0.5 5/5/1986 0.237 (Note 5) 0.375 0.24 0.375 N/A 0.5 0.497 2/19/1990 0.308 (Note 6) 0.375 0.344 0.375 N/A 0.5 0.404 12/2/1991 0.327 (Note 7) 0.375 0.355 0.375 N/A 0.5 0.438 2/26/1993 0.318 (Note 8) 0.375 0.347 0.375 N/A 0.5 3/30/2005 0.3262 0.426 0.5 0.389 0.375 0.2557 0.5 4/1/2015 0.4237 0.4797 0.5 0.299 0.375 0.299 0.5 Note 3 through Note 8 are provided in the original LAR (Reference 1).

RA-19-0295 Enclosure Page 5 of 11 Discussion of As-Found ILRT Values from Table 3.4.4-1 and Table 3.4.4-2 Relative to Tables 3.4.4-3 and 3.4.4-4 As-Found Type A Test Calculations The As-Found Type A test leakage rate is used for determining an acceptable Type A test for operability considerations. The As-Found leakage rate is calculated by summing the Type A Upper Confidence Limit (UCL) with the positive differences between the As-Found Minimum Pathway Leakage Rate (MNPLR) and the As-Left MNPLR for each pathway tested and adjusted prior to the ILRT (i.e., leakage savings) and the As-Left MNPLR of all leakage paths that were inservice, isolated, or not lined up in their test position (i.e., drained and vented to containment atmosphere) prior to the performance of the Type A test (i.e., leakage penalties). Tables 1 and 2 also provide volume correction values due to water level changes during the ILRT. These values are added to the corrections and leakage savings to yield the As-Found leakage rate.

The As-Found Type A test leakage rate shall be less than the acceptance criterion of 1.0 La, given in the plant Technical Specifications. Tables 1 and 2 provide the inputs for the BSEP Units 1 and 2 As-Found Type A test calculations, respectively.

The Unit 2 1984, 95% UCL has been corrected and is reflected in Table 2. Additionally, the Unit 2 2005, As-Found leak rate and 95% UCL have been corrected and are reflected in Table

2. This error was due to incorrect data provided in the original ILRT report.

Table 1: BSEP Unit 1 As-Found Type A Test Calculation Corrections for valves Measured not in Total As-Leakage Accident Found Rate at 95% Water Level Position Leakage Leakage Test UCL Corrections during test Savings Rate Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) 9/2/1976 0.191 0 0 Note 1 Note 1 6/12/1981 0.307 0 0.0446 0.0042 0.356 9/25/1985 0.276 -0.084 0.008 0.081 0.365 5/19/1987 0.205 0 0.01 Note 2 Note 2 0.4956 2/4/1991 0.3251 0 0.0157 0.1548 (Note 3) 3/25/2004 0.1265 0.0306 0.1031 0.0749 0.3351 4/11/2010 0.1775 -0.0862 0.0474 0.0623 0.201 Note 1: Leakage savings not applicable to the September 1976 test because the test was preoperational; therefore, no As-Found data existed for the test.

Note 2: The BSEP Unit 1 1987 ILRT As-Found leakage rate exceeded its limit of 0.75 La (i.e.,

0.375 wt.%/day) with a leakage rate greater than La. This was primarily due to

RA-19-0295 Enclosure Page 6 of 11 immeasurable leakage on Penetration X9A, Feedwater Loop A Injection and Penetration X54E, Containment Monitor, CAC-AT-1262, Discharge. Penetration X9A was repaired during the 1987 refueling outage by repairing valve B21-F010B and repairing the leak-off line and packing on valve B21-F032A. Penetration X54E was repaired by replacing the discs in valves CAC-SV-1211E and CAC-SV-3439. Without the leakage additions from penetrations X9A and X54E, the as-found leakage savings would have been approximately 0.049 wt.%/day.

Note 3: The BSEP Unit 1 1991, As-Found Leakage rate exceeded its limit of 0.75 La (i.e.,

0.375 wt.%/day) with a leakage rate of 0.4956 wt.%/day. This was primarily due to excessive leakage on Penetration X9B, Feedwater Loop B Injection, Penetration X14, Reactor Water Clean Up Suction Line and Penetration X10, Reactor Core Isolation Cooling Turbine Steam Supply Line. Penetration X9B was repaired by replacing the soft seat ring on valve B21-F010B. Penetration X14 was repaired by replacing valves G31-F001 and G31-F004. Penetration X10 was repaired by replacing valves E51-F007 and E51-F008.

Table 2: BSEP Unit 2 As-Found Type A Test Calculation Corrections for valves Measured not in Total As-Leakage Accident Found Rate at 95% Water Level Position Leakage Leakage Test UCL Corrections during test Savings Rate Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) 10/8/1974 0.153 0 0 N/A N/A 0

7/14/1982 0.304 (Note 4) 0.014 Note 5 Note 5 0

9/24/1984 0.293 (Note 4) 0.0003 Note 6 Note 6 5/5/1986 0.237 0 0.003 Note 7 Note 7 0.497 2/19/1990 0.308 0 0.036 0.153 (Note 8) 0.4035 12/2/1991 0.327 0 0.028 0.049 (Note 9) 0.4381 2/26/1993 0.318 0 0.0292 0.0909 (Note 10) 3/30/2005 0.3262* -0.0010 0.0638 0.0365 0.4255 0.4237 -0.0274 0.0834 0 0.4797 4/1/2015 (Note 11) (Note 11) (Note 11) (Note 11) (Note 11)

RA-19-0295 Enclosure Page 7 of 11 Note 4: The 1982 and 1984 BSEP Unit 2 water level corrections were recorded as negative values but were determined to be negligible with regard to the overall leakage rate and therefore assumed to be zero.

Note 5: During the 1982 Unit 2 ILRT, excessive leakage was noted in several areas of the containment structure following initial pressurization. One of the areas found to be contributing to the leakage was a root valve on a pressure instrument which was incorrectly left open. The valve was subsequently closed. Another area found to be contributing to the high leakage readings was a leak on a tubing connector to pressure recorder CAC-PT-2685 which was repaired. A third area contributing to the leakage was the Residual Heat Removal (RHR) A Loop heat exchanger relief valve, E11-F055A. The leakage was secured by installing a gagging bolt and subsequent snooping of the relief valve confirmed no other leaks in the area. Also, during the data gathering phase, personnel performing leak searches found a number of small leaks throughout the plant, contributing to the excessive leakage, though no large leaks were found. Leakages in the stem and packing of the temporary piping valves used for the pressurization were found and repaired. Caps were installed on lines which had no leakage but were discovered to be missing caps. Following the repairs of the items above, components were found to be mispositioned which were also leading to the excessive measured leakage. High Pressure Coolant Injection (HPCI) valves E41-F075 and E41-F079, along with Reactor Core Isolation Cooling (RCIC) valves E51-F066 and E51-F062 were positioned open rather than the required test position of closed. The other mispositioning event involved a sample line which was in service during the ILRT. These valves were subsequently correctly positioned.

Note 6: Local leakage rate testing of Unit 2 primary Containment Isolation Valves (CIVs) revealed a nonquantifiable leakage rate on several containment penetrations. These observed conditions made the calculation of the "As-Found" containment leakage indeterminate. The components contributing to the excessive leakage were B21-F010A and B21-F010B which were repaired by machining the disc and replacing the soft seat; B21-F032B, E51-F013 and G31-F039 which were repaired by removing G31-F039 from the flow path and installing a freeze seal to isolate the line; CAC-V47 which was repaired by resetting the actuator; CAC-X20A, CAC-V16 which were repaired by replacing V16; CAC-SV1263-4 and CAC-SV4409-3 which were removed from the system via design change; CAC-PV1218C which was repaired by replacing the component and the valve internals; E11-F008, E11-F009 which was repaired by lapping the seats of E11-F009; E11-F001B which was repaired by performing maintenance on the test boundary valves; E11-F020A which was repaired by adjusting the Belville springs and resetting the torque switch; E11-F020B which was repaired by replacing the stem, resetting the torque switch, and lapping the seats; E21-F001A which was repaired by machining the disc and lapping the seat; E41-F021, E41-F049 which were repaired by lubricating the packing; E51-F001, E51-F040 which were repaired by lapping the seats and lubricating the valve stem; G31-F001, G31-F004 which were repaired by flushing the seats of the valve, lapping the seats, repacking the valve and retorquing the bonnet bolts; G31-F042 which was repaired by replacing the valve; RXS-PV1222B, RXS-PV1222C which were repaired by replacing the internals on both valves; and TD-V22, TD-V1 which were repaired by replacing all gaskets.

RA-19-0295 Enclosure Page 8 of 11 Note 7: During the 1986 Unit 2 ILRT, the total leakage savings due to performing Type B and C tests prior to the Type A test indicated that the acceptance criteria would have been exceeded due to two penetrations that could not be pressurized. The two penetrations which were unable to be pressurized were Penetration 13B (i.e., valves E11-F015B and E11-F017B) and Penetration 77C (i.e., valve RXS-SV-1222C). Both penetrations were repaired and retested with an As-Left leakage rate of 0 scfh.

Note 8: During the Unit 2 1990 ILRT, the addition of leakage savings (0.153 wt.%/day) resulted in an As-Found leakage rate that exceeded the acceptance criteria of 0.75 La.

Note 9: The BSEP Unit 2 1991 As-Found Leakage rate exceeded its limit of 0.75 La (i.e.,

0.375 wt.%/day) with a leakage rate 0.4956 wt.%/day. This was primarily due to excessive leakage on Penetration X220, Torus Purge to Standby Gas and Penetration X8, Main Steam Line Drain. Penetration X220 was repaired by repairing valves CAC-V7 and CAC-V8. Penetration X8 was repaired by rebuilding valve B21-F016 to restore the low spots found on the inboard disc seat and by lapping the seats and rebuilding valve B21-F019.

Note 10: The BSEP Unit 2 1992 As-Found Leakage rate exceeded its limit of 0.75La (i.e.,

0.375 wt.%/day) with a leakage rate 0.442 wt.%/day. This was primarily due to excessive leakage on Penetration X14, Reactor Water Clean Up Suction and Penetration X12, RHR Cooling Suction. Penetration X14 was repaired by rebuilding valve G31-F001 to close the sealing gap and repair casting flaws found in the upper and lower wedges. Penetration X12 was repaired by rebuilding valve E11-F009 to restore low spots on the in-body seats.

Note 11: During the 2015 ILRT, two Hold tests were conducted. The first Hold test was terminated due to excessive leakage but was of sufficient duration (11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, 43 minutes) to determine the As-found integrated leakage rate was acceptable. The second Hold test measured the As-left integrated leakage rate and was also acceptable. The second Hold test was successfully verified in accordance with ANSI/ANS-56.8-1994. Verification of the second Hold test demonstrated the measurement system was capable of detecting and reporting a leakage rate equal to the Technical Specification allowable leakage rate of La.

As-Left Type A Test Calculations The As-Left Type A test leakage rate is calculated by summing the Type A test UCL and the As-Left MNPLR of all leakage paths that were inservice, isolated, or not lined up in their test position (i.e., drained and vented to containment atmosphere) prior to the performance of the Type A test. Prior to entering into a mode where containment integrity is required, the As-Left leakage rate shall be less than 0.75 La. Tables 3 and 4 provide the inputs for the BSEP Units 1 and 2 As-Left Type A test calculations, respectively.

No corrections or revisions were made in Table 3.

The Unit 2 1984 95% UCL has been corrected and is reflected in Table 4. Additionally, The Unit 2 1990 As-Left leak rate has been corrected and is reflected in Table 4. This was due to an addition error in the original ILRT report. The 1993 As-Left leak rate was corrected and is

RA-19-0295 Enclosure Page 9 of 11 reflected in Table 4. The 2005, As-left leak rate was corrected and is reflected in Table 4. This error was due to incorrect data provided in the original ILRT report.

Table 3: BSEP Unit 1 As-Left Type A Test Calculation Corrections for valves Measured not in Total As-Leakage Accident Left Rate at 95% Water Level Position Leakage UCL Corrections during test Rate Test Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) 9/2/1976 0.191 0 0 0.191 6/12/1981 0.307 0 0.0446 0.352 9/25/1985 0.276 -0.084 0.008 0.284 5/19/1987 0.205 0 0.01 0.215 2/4/1991 0.3251 0 0.0157 0.3408 3/25/2004 0.1265 0.0306 0.1031 0.2602 4/11/2010 0.1775 -0.0862 0.0474 0.1387 Table 4: BSEP Unit 2 As-Left Type A Test Calculation Corrections for valves Measured not in Total As-Leakage Accident Left Rate at 95% Water Level Position Leakage UCL Corrections during test Rate Test Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) 10/8/1974 0.153 0 0 0.153 7/14/1982 0.304 0 0.014 0.318 0.0003 9/24/1984 0.293 0 (Note 12) 0.293 5/5/1986 0.237 0 0.003 0.24 2/19/1990 0.308 0 0.036 0.344 12/2/1991 0.327 0 0.028 0.355 2/26/1993 0.318 0 0.0292 0.3472

RA-19-0295 Enclosure Page 10 of 11 Table 4: BSEP Unit 2 As-Left Type A Test Calculation Corrections for valves Measured not in Total As-Leakage Accident Left Rate at 95% Water Level Position Leakage UCL Corrections during test Rate Test Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) 3/30/2005 0.3262 -0.0010 0.0638 0.389 0.2799 -0.0798 0.0989 0.299 4/1/2015 (Note 13) (Note 13) (Note 13) (Note 13)

Note 12: The value for Type B and C leakage penalties (0.0003 wt.%/day) was considered to be negligible and therefore not included in the As-Left leakage rate.

Note 13: During the 2015 ILRT, two Hold tests were conducted. The first Hold test was terminated due to excessive leakage but was of sufficient duration (11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, 43 minutes) to determine the As-found integrated leakage rate was acceptable. The second Hold test measured the As-left integrated leakage rate and was also acceptable. The second Hold test was successfully verified in accordance with ANSI/ANS-56.8-1994. Verification of the second Hold test demonstrated the measurement system was capable of detecting and reporting a leakage rate equal to the Technical Specification allowable leakage rate of La.

Type A Test Performance Leakage Rate Calculations The definition of "performance leakage rate" was first introduced in NEI 94-01, Revision 0 following the addition of Option B to 10 CFR 50 Appendix J. On February 1, 1996, the NRC issued Amendment Nos 181 (BSEP Unit 1) and 213 (BSEP Unit 2) which revised TS 5.5.12 to incorporate 10 CFR Part 50, Appendix J, Option B at BSEP. Therefore, 1976, 1981, 1985, 1987 and 1991 Unit 1 ILRTs along with the 1974, 1982, 1984, 1986, 1990, 1991 and 1993 Unit 2 ILRTs were not performed under the performance-based standard as they were performed prior to the adoption of Appendix J, Option B.

The definition of performance leakage rate has remained unchanged from NEI 94-01, Revisions 0, 2-A, 3-A. As noted in Section 3.1.1.1 of the NRC Safety Evaluation for NEI 94-01 Revision 2-A dated June 25, 2008, the "performance leakage rate" definition is different from that of ANSI/ANS 56.8-2002. The definition contained in NEI 94-01 Revisions 0, 2-A and 3-A is more inclusive as it considers excessive leakage in the performance determination. The following definition was used to calculate the performance leakage rates for the 2004 and 2010 Unit 1 ILRTs and 2005 and 2015 Unit 2 ILRTs:

The performance criteria for Type A test allowable leakage is less than 1.0 La. This allowable leakage rate is calculated as the sum of the Type A UCL and As-Left MNPLR for all Type B and Type C pathways that were in service, isolated or not lined up in their test position (i.e., drained and vented to containment atmosphere) prior to performing the Type A test. In addition, leakage pathways that were isolated during performance of the

RA-19-0295 Enclosure Page 11 of 11 test because of excessive leakage must be factored into the performance determination.

If the leakage can be determined by a local leakage rate test, the As-Found MNPLR for that leakage path must also be added to the Type A UCL. If the leakage cannot be determined by local leakage rate testing, the ILRT performance criteria are not met.

Tables 5 and 6 provide the inputs for the BSEP Units 1 and 2 Type A Test Performance Leakage Rate calculations, respectively.

The Unit 2 2005, Type A Test Performance Leakage Rate Calculation values were revised and are reflected in Table 6. The original values were found to be erroneous due to an error made in the original 2005, ILRT report.

Table 5: BSEP Unit 1 Type A Test Performance Leakage Rate Calculation Corrections Components for valves isolated Measured not in during test Total Leakage Accident due to Performance Rate at Water Level Position excessive Leakage Test 95% UCL Corrections during test leakage Rate Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) 3/25/2004 0.1265 0.0306 0.1031 0 0.2602 4/11/2010 0.1775 -0.0862 0.0474 0 0.1387 Table 6: BSEP Unit 2 Type A Test Performance Leakage Rate Calculation Corrections Components for valves isolated Measured not in during test Total Leakage Accident due to Performance Rate at Water Level Position excessive Leakage Test 95% UCL Corrections during test leakage Rate Date (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) (wt.%/day) 3/30/2005 0.3262 -0.0010 0.0638 -0.1333 0.2557 4/1/2015 0.2799 -0.0798 0.0989 0 0.299