ML23163A151

PR-050 - 51FR39538 - Leakage Rate Testing of Containments of Light Water Cooled Nuclear Power Plants (General Revision of Appendix J)

ML23163A151
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Issue date:	10/29/1986
From:	Arlotto G NRC/RES/DE
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PR-050, 51FR39538
Download: ML23163A151 (1)

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ADAMS Template: SECY-067 DOCUMENT DATE: 10/29/1986 TITLE: PR-050 - 51FR39538 - LEAKAGE RATE TESTING OF CONTAINMENTS OF LIGHT WATER COOLED NUCLEAR POWER PLANTS (GENERAL REVISION OF APPENDIX J)

CASE

REFERENCE:

PR-050 51FR39538 KEYWORD: RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

DOCKET NUMBER 1 PROPOSED RULE

{£If R 2/! 6 3~)

awR B'WROG-8960 OWNERS' GROUP 1-i

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1 Stephen D. Floyd, Chairman (919) 546-6901 August 21, 1989 U.S. Nuclear Regulatory Commission Office of Nuclear Regulatory Research Washington, DC 20555 Attention: Eric S. Beckjord, Director Office of Nuclear Regulatory Research

Subject:

Proposed B'WR Owners' Group Containment Testing Program

Dear Mr. Beckjord:

The B'WR Owners' Group (B'WROG) has prepared a draft Licensing Topical Report (LTR) which will facilitate implementation of consistent, unambiguous containment leakage rate testing. This letter formally requests this LTR be reviewed and that the schedule for the revision to 10CFR50 Appendix J allow sufficient time for your staff to consider our approach to contain-ment testing prior to the final rulemaking. The draft LTR, NED0-31722, Standardized Program for Primary Containment Testing, is attached.

The B'WROG established a Containment Testing Committee in November 1986 to address problems with 10CFR50 Appendix J that cause inconsistent utility implementation and inconsistent NRG interpretation of Appendix J require-ments in different NRG regions. The Committee has expended considerable resources in development of a consistent approach to containment testing which is applicable to all containment types. In addition to the benefits of improved standardized testing procedures, this effort was undertaken to enable the B'WROG to provide input to the NRG Staff regarding a feasi.ble containment testing methodology which eliminates inconsistent and excessive requirements.

Upon B'WROG request, Thomas T. Martin (NRR) designated Gunter Arndt (Struc-tural and Seismic Engineering Branch, Office of Nuclear Regulatory Re-search) as the NRG contact for the committee work, and the B'WROG Contain-ment Testing Committee has frequently consulted with Mr. Arndt and other NRG personnel during the preparatio~ of this standard containment testing document.

We are concerned that the NRG Staff's current intent to issue the revised Appendix J in the near future will preclude proper consideration of the B'WROG containment testing methodology. Without such consideration, we believe that the revised Appendix J would not resolve inconsistencies and problems and would, in large part, negate a signi~icant effort that has been undertaken by the B'WROG.

While we do consider the proposed Appendix J revision to represent some improvements, the B'WROG believes if the rule is issued in the current form, it would fail to address some of the more significant issues identified in B'WR experience. As a result, we see the rulemaking effort as failing to

-- -- SEP 1 1 1989 k knowf!"dQ'Pcf by eai'a .*._ . .

BWROG-8960 August 21, 1989 Page 2 t

realize the full benefits of the review by both the NRC and industry. This represents a missed opportunity to improve containment testing requirements in order to enhance safe and efficient plant operations and maintenance.

Participating utilities plan to submit the LTR on plant specific dockets for formal NRG approval as an acceptable method of implementing the provi-sions (and the intent) of the revised 10CFRSO Appendix J. We request that

~he philosophy and methodology expressed in this report be reflected in the Appendix J revision.

The BWROG endorsement represents a large portion of the industry. Because several of the BWROG member utilities are also PWR owners, more than just BWR.s are represented. We also plan to share this topical report with the PWR Owners' Groups.

The BWROG realizes that the NRG review of this containment testing document will require significant time and effort. We welcome the opportunity to meet with your reviewers to explain our technical positions.

This letter has been approved by a majority of the members of the BWR Owners' Group; however, it should not be interpreted as a commitment of any individual member to a specific course of action.

If you desire to discuss this request in more detail please contact me at your convenience.

Very truly yours, J. l. NUCLEAR REGULATORY COMMISSIOR DOCKETING & SERVICE SECTION Stephen D. Floyd, Chairman OFFICE C f THE SECRETARY BWR Owners' Group OF P: E CO.V,MISSION Dxuri.,; nl ~la tisl ics cc: BWROG Primary Representatives BWROG Containment Testing Committee Postmark Date BWROG Executive Oversight Committee r---)

--- l J-&15)

Copies P- ecc*i ve.l T. E. Murley (Director, NRR)

G. Arndt (NRG) Add' I Ccpic.; r.:, 1 ~-~.*r:d J" J. Kudrick (NRG) Special Di;l rib ,,1ic,, (})1) f .-*,:_} DS b,Jt? ~q J. Pulsipher (NRC) An~.J~-f _ __

L. S. Gifford (GE-Rockville)

G. J. Beck (BWROG, Vice-Chairman)

D. N. Grace (GPUN)

R. Warren (INPO)

T. Price (NUMARC)

R. Galer (EPRI)

S. J. Stark (GE, BWROG Program Manager)

R. A. Newton (Chairman, Westinghouse Owners' Group)

J. K. Gasper (Chairman, Combustion Engineering Owners' Group)

W. S. Wilgus (Chairman, Babcock & Wilcox Owners' Group)

USNRC, Docketing and Service Branch

BWROG-8960 August 21, 1989 Page 2 realize the full benefits of the review by both the NRC and industry. This represents a missed opportunity to improve containment testing requirements in order to enhance safe and efficient plant operations and maintenance.

Participating utilities plan to submit the LTR on plant specific dockets for formal NRC approval as an acceptable method of implementing the provi-sions (and the intent) of the revised 10CFR.50 Appendix J. We request that

~he philosophy and methodology expressed in this report be reflected in the Appendix J revision.

The BWROG endorsement represents a large portion of the industry. Because several of the BWR.OG member utilities are also PWR. owners, more than just BWR.s are represented. We also plan to share this topical report with the PWR Owners' Groups.

The BWROG realizes that the NRC review of this containment testing document will require significant time and effort. We welcome the opportunity to meet with your reviewers to explain our technical positions.

This letter has been approved by a majority of t:'he members of the BWR Owners' Group; however, it should not be interpr~ted as a commitment of any individual member to a specific course of action.

If you desire to discuss this request in more detail please contact me at your convenience.

Very truly yours, Stephen D. Floyd, Chairman BWR Owners' Group cc: BWROG Primary Representatives BWR.OG Containment Testing Committee BWR.OG Executive Oversight Committee T. E. Murley (Director, NRR)

G. Arndt (NRG)

J. Kudrick (NRC)

J. Pulsipher (NRC)

L. S. Gifford (GE-Rockville)

G. J. Beck (BWROG, Vice-Chairman)

D. N. Grace (GPUN)

R. Warren (INPO)

T. Price (NUMARC)

R.. Galer (EPRI)

S. J. Stark (GE, BWR.OG Program Manager)

R. A. Newton (Chairman, Westinghouse Owners' Group)

J. K. Gasper (Chairman, Combustion Engineering Owners' Group)

Y. S. Wilgus (Chairman, Babcock & Wilcox Owners' Group)

USNRC , Docketing and Service Branch

NED0-31722 Class I August 1989 Ull-A f T bf P>IBq. .

BWR OWNERS' GROUP CONTAINMENT TESTING COMMITTEE STANDARDIZED PROGRAM FOR PRIMARY CONTAINMENT INTEGRITY TESTING GE Nuclear Energy 175 Curtner Avenue San Jose. CA 95125

NED0-31722 Class I August 1989 DRAFT STANDARDIZED PROGRAM FOR PRIMARY CONTAINMENT INTEGRITY TESTING Compiled by:

R. M. Fairfield, Sr. Program Manager Nuclear Products Licensing Reviewed:

T. A. Green, Sr. Program Manager BWR Owners' Group Programs Approved:

S. J. Stark, Manager BWR Owners' Group Programs WORK PERFORMED BY THE BWR OWNERS' GROUP CONTAINMENT TESTING COMMITTEE

NED0-31722 w

DRAFT DISCLAIMER OF RESPONSIBILITY This document was prepared by the BWR Owners' Group and the General Electric Company. Neither the General Electric Company nor any of the contributors to this document:

A. Makes any warranty or representation, express or implied, with respect to the accuracy, completeness, or usefulness of the information contained 1n this document, or that the use of any information disclosed in this document may not infringe privately owned rights, or B. Assumes any responsibility for liability or damage of any kind which may result from the use of any information disclosed in this document.

ll

NED0-31722 DRAFT TABLE OF CONTENTS 1.0. INTRODUCTION 1-1 1.1 Purpose 1-1 1.2 Scope 1-2 1.3 Relationship to ISI/IST Requirements 1-2 2.0 DEFINITIONS 2-1 3.0 CONTAINMENT DESCRIPTIONS AND DESIGN BASES 3-1 3.1 Mark I Containment 3-1 3.2 Mark II Containment 3-1 3.3 Mark III Containment 3-2 3.4 Design Philosophy of Containment Isolation Systems 3-3 4.0 OPERATING AND REPORTING REQUIREMENTS 4-1 4.1 Operating Requirement 4-1 4.2 Reporting Requirements 4-1 4.3 Valves and Penetrations with Separate Leakage Limits 4-3 5.0 SYSTEM LEAKAGE RATE TESTING REQUIREMENTS 5-1 5.1 General 5-1 5.2 Type Band C Applicability 5-1 5.3 Seal Systems 5-1 5.4 Water-Filled Systems 5-2 5.5 Extensions of Containment Boundaries/Closed Loops Outside Containment 5-2 5.6 Test Connections, Vents, and Drains 5-3 5.7 Instrument Lines 5-3 5.8 Hydraulic Lines to Recirculation Flow Control Valves 5-3 5.9 Control Rod Drive Hydraulic Lines 5-3 5.10 Containment Weld Leakage Test Channels 5-4 6.0 CALCULATION OF COMBINED LEAKAGE RATES 6-1 6.1 Penetration Maximum Pathway Leakage Rate 6-1 6.2 Penetration Minimum Pathway Leakage Rate 6-2 6.3 Total Containment Maximum Pathway Leakage Rate 6-5 6 .4 Running Total Containment .Leakage Rate 6-5 7.0 TESTING REQUIREMENTS 7-1 7.1 General 7-1 7.1.1 Containment Isolation Valve Closure 7-1 7.2 Type A Tests 7-1 7.2.1 Test Intervals 7-1 7.2.2 Test Duration and Choice of Methodology 7-2 7.2.3 As-Found Requirements 7-3 iii

NED0-31722

\.

DRAFT TABLE OF CONTENTS (Continued) 7.2.4 As-Left Requirements 7-5 7.2.5 Data Acquisition 7-6 7.2.6 Data Rejection 7-6 7.2.7 Recording of Data 7-7 7.2.8 Test Pressure 7-8 7.2.9 Venting and Draining 7-8 7.2.10 Test Start Times 7-9 7.2.11 Liquid Level Monitoring 7-9 7.2.12 Continuous Leakage Monitoring Systems 7-9 7.2.13 Containment Modifications 7-10 7.3 Type Band C Tests 7-10 7.3.1 Test Intervals 7-10 7.3.2 As-Found Testing 7-11 7.3.3 As-Left Testing 7-12 7.3.4 Alternative Testing 7-12 7.3.5 Test Pressure 7-13 7.3.6 Venting and Draining 7-13 7.3.7 Reverse Flow Testing 7-13 7.4 Containment Air Locks 7-14 7.5 Corrective Action Plans 7-15 7.6 Acceptance Criteria 7-16 7.6.1 Type A Testing 7-16 7.6.2 Type B/C Testing 7-16 8.0 INSTRUMENTATION 8-1 8.1 General Requirements 8-1 8.2 Instrument Performance and Calibration Requirements for Type A Tests and Verification Tests 8-2 8.2.1 Drybulb Temperature 8-2 8.2.2 Dewpoint Temperature 8-2 8.2.3 Containment Pressure 8-3 8.2.4 Verification Test Flowmeter 8-4 8.2.5 Induced Leakage 8-4 8.2.6 Data Collection Clock 8-4 8.2.7 Ambient Pressure 8-4 8.2.8 Ambient Temperature 8-5 8.2.9 Water Level Measurement 8-5 8.3 Instrument Performance and Calibration Requirements for Type Band C Tests 8-5 8.3.1 Drybulb Temperature 8-5 8.3.2 Test Volume Pressure 8-6 8.3.3 Makeup Flow Rate 8-6 8.3.4 Test Time 8-6 9.0 TYPE A TEST METHODOLOGY 9-1 9.1 General 9-1 9.2 Containment Inspection 9-1 9.3 Temperature Survey 9-1 iv

NE00-31722 I

DRAFT TABLE OF CONTENTS (Continued) 9.4 Instrumentation System 9-2 9.4.1 Minimum Number of Sensors 9-2 9.4.2 System Performance 9-3 9.5 Pressurization 9-4 9.6 Containment Stabilization 9-4 9.6.1 BN-TOP-1 Requirements 9-5 9.6.2 Dry Air Mass Method 9-6 9.6.3 10CFR50 Appendix J Method 9-7 9.7 Calculation of Containment Dry Air Mass 9-7 9.7.1 Average Temperature of Subvolume #i 9-7 9.7.2 Average Dew Temperature of Subvolurne #i 9-8 9.7.3 Total Corrected Pressure #i 9-8 9.7.4 Whole Containment Volume Weighted Average Temperature 9-9 9.7.5 Calculation of the Average Vapor Pressure of Subvolume #i 9-9 9.7.6 Whole Containment Average Vapor Pressure 9-10 9.7.7 Calculation of the Whole Containment Average Dew Temperature 9-10 9.7.8 Average Total Containment Pressure 9-12 9.7.9 Average Total Containment Dry Air Pressure 9-12 9.7.10 Total Containment Dry Air Mass 9-12 9.8 Calculation of Containment Leakage Rates 9-13 9.8.1 Mass Point Method 9-13 9.8.2 Point-to-Point Method 9-15 9.8.3 Total Time Method 9-16 9.8.4 BN-TOP-1 Method 9-17 9.9 Verification Test *9-18 9.9.1 General Requirements 9-18 9.9.2 Test Start Time 9-19 9.9.3 Stabilization Period 9-19 9.9.4 Measurement of Induced Leakage Rate/Verification Test 9-20 9.9.5 Calculation of Target Leakage Rate 9-21 9.9.6 Test Duration 9-22 9.9.7 Acceptance Criteria 9-22 9.10 Depressurization 9-22 10.0 TYPE BAND C TEST METHODOLOGY 10-1

- 10 .1 General 10-1 10.2 Test Methods 10-1 10.2.1 Pressure Decay Method 10-1 10.2.2 Flowmeter Makeup Method 10-3 10.2.3 Water Displacement Method 10-4 10.2.4 Vacuum Testing Method 10-5 V

NED0-31722 DRAFT TABLE OF CONTENTS (Continued) 10-6 10.2.s Bubble Testing Method Continuous Monitoring 10-7 10.2.6 10-7 10.2.1 Reference Vessel Method 11-1

11.0 REFERENCES

BASES A-1 APPENDIX - REPORTING REQUIREMENTS vi

NE00-31722 DRAFT LIST OF ILLUSTRATIONS Figure Title Page Acceptable Test, Vent, and Drain Configurations 5-5 6-1 Dual Valve Pathway 6-1 6-2 Dual Valve Pathway 6-1 6-3 Series Multi-Valve Pathway 6-2 6-4 Series Multi-Valve Pathway 6-3 6-5 Series Multi-Valve Pathway 6-3 vii/viii

NED0-31722 DRAFT ABSTRACT The Boiling Water Reactor Owners' Group Containment Testing Committee was formed in November 1986 to address problems with implementation of 10CFRSO Appendix J that led to inconsistent implementation and enforcement of leakage rate requirements in different regions of the country. This committee initially prepared a unified response to the proposed 10CFRSO Appendix J revision, which was published in the Federal Register on October 29, 1986.

The Committee has since developed this standard testing document which provides a consistent, unambiguous, standardized testing program to verify containment integrity. Related industry testing techniques, as well as ANSI codes and standards, have been studied. The results of these efforts are presented herein.

This report is submitted for the purpose of obtaining NRC review and approval of the standardized testing program developed herein. This document will provide guidance for utilities and NRC inspectors and reviewers so that uniform interpretations and enforcement of the applicable containment testing rules and regulations will result.

The utilities which have participated in preparation of this report are listed on the following page.

ix/x

NED0-31722 DRAFT PARTICIPATING UTILITIES Boston Edison Carolina Power & Light Cleveland Electric Illuminating Commonwealth Edison Detroit Edison Georgia Power GPU Nuclear Gulf States Utilities Illinois Power Iowa Electric Light & Power Nebraska Public Power District New York Power Authority Niagara Mohawk Power Northern States Power Pennsylvania Power & Light Philadelphia Electric Public Service Electric & Gas Systems Energy Resources Tennessee Valley Authority Washington Public Power System xi/xii

NED0-31722 DRAFT

1.0 INTRODUCTION

1.1 PURPOSE At present, containment leak rate testing is performed in accordance with 10CFR50 Appendix J as a license condition. The testing requirements are derived from a variety of sources, including Technical Specifications, Final Safety Analysis Reports (FSARs), Utility/NRC correspondence and dialogues with the NRC. These requirements call for periodic testing to verify the leak-tight integrity of the primary reactor containment, systems, and components which penetrate the containment.

At the time 10CFR50 Appendix J was issued in 1973, there were several reactors in operation throughout the country. The introduction of this new regulatory requirement presented significant new operational problems for these plants, since their designs, in many cases, did not contain provisions which allow meeting all the Appendix J requirements.

Generally, the FSAR describes plant testing programs, including contain-ment testing. The FSAR specifies testing which, in some cases, differs from the requirements of 10CFRS0 Appendix J. Prior to the advent of Standard Technical Specifications, each plant had individualized Technical Specifica-tions that were separately negotiated with the NRC; these specifications often allow exemptions to 10CFRS0 Appendix J. Additionally, some plants have requested and received exemptions after their Technical Specifications were issued.

The NRC, through its network of on-site inspectors and regional offices, provides interpretations and enforcement~£ these regulations. The lack of consistent requirements and guidance has led to the development of testing philosophies which vary from region to region and plant to plant.

As a result of the large number of variations in testing philosophies and enforcement, the BWROG has undertaken this task to develop a consistent, rational approach to containment testing.

1-1

NED0-31722 DRAFT Acceptance of this standardized testing document by Utilities and the NRC will facilitate a common understanding of containment testing regulations and practices, and will allow both organizations to make better utilization of their resources. All NRC regions, as well as all participating Utilities, will be able to apply the same principles to their containment testing pro-grams. Testing techniques and procedures can be standardized, resulting in greatly simplified analysis of testing programs. Information may be more freely exchanged because testing programs will be based on standardized test-ing practices. Data will be easier to track and analyze, due to the standard-ization of reporting formats. This will reduce the amount of paperwork required and make _the review process more streamlined. Fewer exemption requests will be required, saving valuable resources by the Utilities and the NRC. An added benefit will be that most requests can be handled generically.

Plant safety will be enhanced by a freer flow of information, reduced regula-tory review times, and consistent testing standards. Manpower intensive tests, which are of little value to safety, will be eliminated and the resources better applied to those areas where safety is enhanced.

1.2 SCOPE This document covers all testing required by 10CFRSO Appendix J. Since Plant Technical Specifications and 10CFRSO Appendix J are interrelated, this document may have some impact on Plant Technical Specifications.

1.3 RELATIONSHIP TO ISI/IST REQUIREMENTS The purpose of 10CFR50 Appendix J is to establish the surveillance test-ing requirements and leakage rate acceptance criteria for primary containment leakage paths. By defining a total overall leakage limit for Type Band C containment barriers, and applying single failure criteria (maximum pathway leakage) to the calculation of each containment penetration leak rate, 10CFR50 Appendix J effectively limits leakage rates on each co~ponent in multiple valve penetrations to a conservative level.

1-2

NED0-31722 DRAFT The ASME Boiler and Pressure Vessel Code,Section XI, contains require-ments for in-service testing of valves. This code includes surveillance test-ing requirements and acceptance criteria for various characteristics of valves, depe~ding on their safety function. Per ASME Section XI, Article IWV, primary containment isolation valves are classified as Category A valves [i.e., valves for which seat leakage is limited to a specific maximum amount (by the utility) in the closed position for fulfillment of their safety function]. Article IWV disregards the true function of containment isolation boundaries [i.e., to limit the total containment post-LOCA gaseous release to less than the allow-

- able rate as defined by 10CFRl00].

This report acknowledges the integrated safety function of containment isolation valves as they relate to total containment leakage, and recognizes that the 10CFR50 Appendix J philosophy of applying single failure criteria to each potential leakage path does assure an adequate degree of leak-tightness of each barrier in a multiple component penetration. Article IWV of ASME Section XI is being replaced with a new Operations and Maintenance standard (OM-10), which will become the governing standard for in-service testing of valves as plants reach their 10-year ISI interval and adopt the latest standard recognized by 10CFRS0.

In referencing 10CFRS0 Appendix J for leakage rate testing of containment isolation valves, OM-10 acknowledges the integrated safety function of these valves as they relate to total containment leakage. This philosophy is shared by this report.

1-3

NED0-31722 DRAFT 2.0 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.

"As Found" Leakage Rate The leakage rate prior to any needed repairs or adjustments to the leakage barrier being tested.

As-Found Testing Leak rate testing performed prior to repairs or adjustments.

"As-Left" Leakage Rate The leakage rate following any needed repairs or adjustments to the leakage barrier being tested.

As-Left Testing Leak rate testing performed following repairs or adjustments.

CILRT - Containment Integrated Leakage Rate Test The leakage test performed on the primary reactor containment system by

_ pressurizing the containment system to the test pressure and determining the overall integrated leakage rate.

2-1

NED0-31722 DRAFT The CILRT consists of the following phases or activities:

l. Containment inspection

2. Pressurizing the containment system

3. A period of containment atmosphere stabilization

4. A Type A test

5. A Verification test

6. Depressurizing the containment system CIV - Containment Isolation Valve CIVs are those valves and/or components which satisfy the requirements of 10CFR50 Appendix A, Criteria 55, 56, and/or 57. For purposes of this document, any CIV which represents a gaseous leakage pathway from the primary containment under post-accident operating conditions is subjected to Type C testing requirements. Note that there are many valves which are containment isolation valves as defined by 10CFR50, Appendix A, General Design Criteria but are not considered CIVs for the purpose of 10CFR50 Appendix J leak rate testing.

Continuous Leakage Monitoring System A permanently installed system with provisions for continuous or inter-mittent pressurization of individual or groups of containment penetra-tions, which allows for pressurization of the penetrations to ~Pa, provides for measurement of individual or group penetration leakage rates and is monitored for loss of pressure or makeup fluid.

Fluid A substance (liquid or gas) tending to flow or conform to the outline of its container.

2-2

ISG - Instrument Selection Guide

,rx1r A method of determining the ability of an instrumentation system to calculate the integrated leakage rate of a containment system.

La The maximum allowable leakage rate at pressure Pa as specified in Plant Technical Specifications or associated bases, and as specified for peri-odic tests in the operating license. La is ezpressed in terms of the weight percent of containment volume per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (wt%/day).

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.

LLRT - Local Leakage Rate Test The leakage test (Type B or C test) performed on Type Band C components.

LSLR - Least Squares Leakage Rate The leakage rate from containment obtained during the Type A test based on a least squares fit of the dry air masses or total time leakage rates.

Maximum Pathway Leakage Rate (MXPLR)

The maximum leakage rate that can be attributed to a penetration leakage path (e.g., the larger, not total, leakage of two or more valves in 2-3

NED0-31722 DRAFT series). This generally assumes a single active failure of the better of two or more leakage barriers in series when performing Type B or C tests.

Minimum Pathway Leakage Rate (MNPLR)

The minimum leakage rate that can be attributed to a penetration leakage path (e.g., the smallest leakage of two or more valves in series). This generally assumes no single active failure of redundant leakage barriers.

Pa Calculated post-accident peak containment internal pressure related to the design basis accident.

Passive Barrier A component intended to minimize primary containment leakage without being required to change operational configuration (e.g., blind flange, pipe cap, closed manual valve, deactivated automatic valve, piping, etc.).

Pathway A gaseous leakage path from the primary containment. This term is used to differentiate individual leakage paths in multiple line penetrations, such as instrument penetrations. An individual penetration may have more than one pathway.

Primary Reactor Containment System The design feature which acts as the principal leakage barrier (after the reactor coolant pressure boundary) to prevent the release under Design Basis Accident (DBA) conditions of quantities of radioactive material in excess of 10CFRlOO limits. It includes:

2-4

NED0-31722 DRAFT (1) The containment structure, including access openings, penetrations, and appurtenances.

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

(3) Those systems or portions of systems that, by their configuration and functions, become extensions of containment structure boundary.

This does not include the "secondary containment", "containment enclosure building", or "reactor building" that surround some containment systems, whose function is to control containment system leakage that might occur.

R/A - Repair or Adjustment Any work on a containment pressure boundary that may reasonably be expected to affect its primary containment isolation capability (leakage only).

RTCLR - Running Total Containment Leakage Rate A summation of the most recent Minimum Pathway Leakage Rate test results for all Type Band C tested pathways, plus the highest leakage pathway maximum pathway leakage rate minus that pathway's minimum pathway leakage rate, plus 0.25 La.

Type A Test The portion of the CILRT that begins after the containment atmosphere has stabilized and ends prior to the start of the Verification Test. During the Type A test, the overall leakage rate of the primary reKtor containment system is determined under conditions representing design basis loss-of-coolant accident pressure and system alignments:

2-5

NED0-31722 DRAFT The overall leakage rate is calculated by:

1. Measuring containment atmospheric parameters (pressure, temperature, dewpoint temperature) at regular time intervals.

2. Calculating the mass of dry air in the containment at each interval.

3. Determining the leakage from containment from the change in containment dry air mass using a least squares fit and statistical analysis.

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, sealant compounds, expansion bellows, or fitted with flexible metal seal assemblies.

2. Air locks, including door seals and door operating mechanism penetrations that are part of the containment pressure boundary.

Type C Test A pneumatic test to measure containment isolation valve leakage rates.

Upper Confidence Limit A calculated value constructed from sample data with the intention of placing a statistical upper bound on the true leakage rate.

2-6

NE00-31722 DRAFT Verification Test A supplemental test to the Type A test during which a known leakage is induced on the containment system to confirm the capability of the Type A test method and equipment to measure the containment leakage rate.

2-7

NED0-31722 DRAFT 3.0 CONTAINMENT DESCRIPTIONS AND DESIGN BASES 3.1 MARK I CONTAINMENT The Mark I containment system consists of a drywell and wetwell, which are interconnected by vent piping. The drywell is a steel pressure vessel with a spherical lower portion and a cylindrical upper portion, which contains the reactor vessel and associated equipment. The wetwell is a torus-shaped pressure vessel located below and encircling the drywell, which is nominally filled to the centerline with water. The vent piping from the drywell enters the wetwell and discharges approximately four feet beneath the surface of the water, which provides for pressure suppression of the overall containment sys-tem during an accident by condensation of the steam entrained in the blowdown flow.

Personnel and equipment access hatches are provided for access to the containment. Such hatches are provided with gasketed seals and are testable to demonstrate their leak-tightness.

Penetrations for piping and electrical cables are provided for plant sys-tems as required for access to the containment. Electrical penetrations are hermetically sealed with provisions for periodic leak testing at design pres-sure. Provision is also made for testing the leak-tightness capabilities of valves and components of piping systems penetrating the containment. Where bellows are used in piping penetrations, provisions for periodic leak testing are also provided.

3.2 MARK II CONTAINMENT The Mark II containment design employs an over-and-under design pressure suppression system in which the drywell is located directly above the suppres-sion chamber. The containment is a steel pressure vessel which houses the reactor vessel, the reactor coolant recirculating loops and other branch con-nections of the reactor primary system. The pressure suppression-system 3-1

NE00-31722 DRAFT consists of a drywell, a pressure suppression chamber, a connecting submerged vent system between the drywell and water pool, isolation valves, containment cooling system, and other service equipment. In the event of a reactor cool-ant pressure boundary piping failure within the drywell, reactor water and steam would be released into the drywell air space and vented into the sup-pression pool, resulting in the condensation of the steam entrained in the blowdown flow.

Personnel and equipment access hatches are provided for access to the containment. Such hatches are provided with gasketed seals and are testable to demonstrate their leak-tightness.

Penetrations for piping and electrical cables are provided for plant sys-tems as required for access to the containment. Electrical penetrations are hermetically sealed with provisions for periodic leak testing at design pres-sure. Provision is also made for testing the leak-tightness capabilities of valves and components of piping systems penetrating the containment.

3.3 MARK III CONTAINMENT The Mark III containment system consists of a cylindrical concrete build-ing which houses the drywell and suppression pool. The drywell, a cylindrical concrete structure, is designed as the temporary pressure retention boundary which separates the reactor pressure vessel and the recirculation system from the suppression pool and the containment annulus. The drywell connects to the suppression pool through submerged horizontal vents. A cylindrical weir wall inside the drywell keeps the suppression pool water from the drywell floor while allowing for dynamic interaction between the drywell and containment annulus. If a LOCA should occur, the dryw~ll temporarily retains the released steam and channels it around the weir wall and through the horizontal vents and into the suppression pool, resulting 1n condensation of the steam entrained in the blowdown flow.

3-2

NED0-31722 DRAFT Personnel and equipment access hatches are provided for access to the containment. Such hatches are provided with gasketed seals and are testable to demonstrate their leak-tightness.

Penetrations for p1p1ng and electrical cables are provided for plant sys-tems as required for access to the containment. Electrical penetrations are hermetically sealed with provisions for periodic leak testing at design pres-sure. Provision is also made for testing the leak-tightness capabilities of valves and components of piping systems penetrating the containment.

3.4 DESIGN PHILOSOPHY OF CONTAINMENT ISOLATION SYSTEMS The primary containment completely encloses the reactor vessel, and is designed to retain integrity as a radioactive material barrier during and fol-lowing accidents that release radioactive material into the primary contain-ment volume. The containment 1s designed such that periodic testing for leak-tightness may be performed.

Periodic Type A, B, and C tests are performed to assure that leakage through the primary reactor containment and systems and components penetrating primary containment does not exceed allowable leakage rate values specified in the Plant Technical Specifications and/or FSAR.

The main objective of the containment isolation systems is to provide protection by preventing releases of radioactive materials to the environ-ment. This is accomplished by complete isolation of system lines penetrating the containment. Redundancy is provided to satisfy the requirement that single active failures do not prevent *containment isolation.

Electrical redundancy is provided in isolation valve arrangements to eli-minate dependence on one power source to attain isolation.

Containment isolation valves provide the necessary isolation of the con-tainment in the event of accidents or other conditions when the unfiltered release of containment atmospheric contents cannot be permitted. Containment 3-3

NE00-31722 DRAFT isolation valves are either locked closed, automatically actuated, self-actuated, or are remote-manually operated, as appropriate.

Piping that both penetrates the primary containment structure and could serve as a path for the uncontrolled release of radioactive material to the environs is capable of being isolated whenever such uncontrolled radioactive material release is threatened. Such isolations are affected in time to pre-vent radiological effects from exceeding the guideline values of applicable regulations.

3-4

NED0-31722 DRAFT 4.0 OPERATING AND REPORTING REQUIREMENTS r

4.1 OPERATING REQUIREMENTS (1) Prior to startup from a scheduled Type A test outage, the Type A test results must be demonstrated to not exceed 0.75 La.

(2) Prior to startup from a scheduled LLRT outage, the total containment MXPLR (see Section 6.3) must be demonstrated to not exceed 0.6 La.

(3) At all times when containment integrity is required, the Running Total Containment Leakage Rate (see Section 6.4) shall not exceed 1.0 La.

A pathway with excessive leakage shall be isolated to reduce that pathway's MXPLR, 4.2 REPORTING REQUIREMENTS (1) A post-outage report will be submitted within 3 months after the

- completion of the outage presenting the results of the previous cycle's Type Band C testing program and the Type A test, if performed during that outage. This report will be in the format shown in Appendix A of this report, and will be submitted in lieu of any Licensee Event Report reporting requirements per 10CFRS0.73.

(2) Detailed data/information supporting reports of Type A tests shall be maintained and available for HRC review. As a minimum, the following shall be maintained:

a. The access procedure used to limit ingress to containment during Type A testing.

b. A listing of all containment penetrations.

4-1

NED0-31722 DRAFT

c. A listing of instrumentation used for the test, locations, and associated volume fractions.

d. A system status description of all systems involved with the test.

e. An event log.

f. The ISG calculations and documentation of instrumentation calibrations.

g. Temperature stabilization criteria data.

h. A copy of the completed test procedure.

i. A copy of all completed local leak rate test data packages.

j. All pertinent data accumulated during the test.

k. A listing of all test exceptions.

1. All listing of instrument malfunctions and the methods used to adjust volume fractions.

m. Confidence limits of test results.

n. A description of the verification test including data, calculations, and results.

o. Any plots presenting data generated during the test.

p. P&IDs of systems involved in test.

4-2

NED0-31722 DRAFT 4.3 VALVES AND PENETRATIONS WITH SEPARATE LEAKAGE LIMITS If plant-specific analyses are performed to justify increased main steam and/or feedwater line leakages, the leakage rates through these penetrations need not be Type A tested and shall not be included in Type A test results nor in the Type C testing running totals. The applicable plant-specific analyses of other systems will be considered on an individual basis.

4-3

NED0-31722 DRAFT 5.0 SYSTEM LEAKAGE RATE TESTING REQUIREMENTS 5.1 GENERAL The purpose of leak rate testing is to ensure the ability of the primary reactor containment to limit the total gaseous release rate to less than the maximum allowable leakage rate when subjected to peak accident pressure.

"Leakage rate" for test purposes is defined as that leakage which occurs in a unit of time, stated as a percentage of weight of the containment air volume at the leakage rate test pressure that escapes to the outside atmos-phere during a 24-hour test period.

Type B tests are intended to detect local leaks and to measure leakage for non-valve type penetrations. Type C tests are intended to measure con-tainment isolation valve leakage rate through valve type penetrations. See Section 2, Definitions, for descriptions of Type Band C penetrations.

5.2 TYPE BAND C APPLICABILITY Penetrations which have the potential to provide a direct gaseous pathway from inside the primary containment to outside the primary containment under normal and/or post-accident operating conditions require local leak rate testing with air or nitrogen at a pressure not less than Pa. The leakage is required to be included in the LLRT program totals. Type C air or nitrogen tests may be substituted for lines which are required to be water tested.

5.3 SEAL SYSTEMS Pathways which are sealed by a fluid (e.g., air, water, nitrogen) such that they do not represent a gaseous pathway from the primary containment under normal and post-accident conditions are not required to be . Type C tested. In order to qualify, the fluid seal system must be demonstrated 5-1

NED0-31722 DRAFT analytically or empirically to be capable of providing a seal for at least 30 days under post-accident conditions at a pressure of at least 1.1 Pa.

Typical fluid seal systems would include guaranteed water columns upstream or downstream of isolation valves, and fluid injection systems (e.g., service air system, plant service water system, hydraulic control lines, etc.). Fluid seal systems must be safety grade from the fluid supply source to inside the primary containment structure. If a system fails to meet the above qualifica-tions, its isolation valves must be local leak rate tested with air or nitrogen and leakages included in the totals.

For the purpose of a valve lineup during the Type A test, valves sealed with fluid from a seal system are not required to be exposed (i.e., vented and drained) to the containment test atmosphere. This applies to valves sealed with both automatically and manually initiated seal systems. Liquid seal sys-tems may be operated during a Type A test provided any liquid inleakage 1s accounted for. Gaseous systems must be isolated at a pressure~ Pa.

5.4 WATER-FILLED SYSTEMS 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 accident, considering a single active failure of a system component. Valves in lines which take suction or discharge below minimum suppression pool water level may be included in this category.

5.5 EXTENSIONS OF CONTAINMENT BOUNDARIES/CLOSED LOOPS OUTSIDE CONTAINMENT Containment isolation valves in closed systems outside containment which qualify as extensions of containment are not required to be Type C tested.

Passive barriers in branch lines that communicate with closed systems outside containment need not be subjected to leak rate testing.

5-2

NE00-31722 DRAFT 5.6 TEST CONNECTIONS, VENTS, AND DRAINS Test connections, vents, and drains are part of the containment pressure boundary, as defined by GDC 56. Test connections, vents, and drains one inch or less in size do not require leakage rate testing, provided that a multiple barrier configuration is maintained using an administrative control program.

Pipe caps will be tightened (snugged up) with a wrench.

Acceptable configurations include:

(1) Two closed valves in series.

(2) One closed valve followed by a nipple and a cap.

(3) One closed valve followed by a nipple and a blind flange.

All of the configurations shown in Figure 5-1 are acceptable.

5.7 INSTRUMENT LINES Instrument line isolation valves need not be Type C tested provided that:

(l} The lines and valves meet the requirements of Reference 17.

(2} The lines and valves are not isolated from the containment atmos-phere during the performance of the Type A test.

5.8 HYDRAULIC LINES TO RECIRCULATION FLOW CONTROL VALVES (BWR/5 ONLY)

No leakage rate testing is required.

5.9 CONTROL ROD DRIVE HYDRAULIC LINES No leakage rate testing is required.

5-3

NED0-31722 DRAFT 5.10 CONTAINMENT WELD LEAKAGE TEST CHANNELS Containment weld leakage test channels need not be tested if it can be demonstrated that the channel is built to the same quality as the containment liner itself.

5-4

NED0-31722 DRAFT I

I L!..J r.,

CONTAINMENT I

I L.:..J Figure 5-1. Acceptable Test, Vent, and Drain Configurations 5-5

NED0-31722 DRAFT 6.0 CALCULATION OF COMBINED LEAKAGE RATES All local leak rates discussed below are the actual measured leak rates; no allowance for instrument error or uncertainty is made. While the discussions presented in Sections 6.1 and 6.2 are in the context of valve leakage, the same philosophies apply to Type B component testing.

6.1 PENETRATION MAXIMUM PATHWAY LEAKAGE RATE When the leakage rate (Q1 and Q2) from each valve in a dual valve pathway (Figure 6-1) is known, then that pathway's MXPLR is equal to the leakage past the worst of the two valves.

BLOCK VALVE CONTAINMENT __..

Figure 6-1. Dual Valve Pathway When the leakage rate (Q) from a dual valve pathway (Figure 6-2) is measured by pressurizing between the two valves, then that pathway's MXPLR is equal to the measured leakage rate.

a CONTAINMENT Figure 6-2. Dual Valve Pathway 6-1

NED0-31722 DRAFT The MXPLR of a single valve pathway 1s equal to the measured leakage rate past that single valve.

The MXPLR of a series multi-valve pathway (Figure 6-3) 1s equal to the Minimum Pathway Leakage Rate (MNPLR) of that pathway with its best valve assumed to be completely failed.

BLOCK VALVE CONTAINMENT Figure 6-3. Series Multi-Valve Pathway The MXPLR from a parallel multi-valve pathway (Figure 6-4) is equal to the sum of the leakage of the inboard valves or the sum of the leakages of the outboard valves, whichever is larger. If individu~l valve leakages are not known, and the system is tested by pressurizing between all the valves, the MXPLR is equal to the measured leakage rate as shown in Figure 6-5.

When any CIV or barrier in a pathway is retested, that pathway's MXPLR must be recalculated using the new leakage rate.

When the Type Band C surveillance interval has expired on any CIV or barrier in a pathway, that pathway's MXPLR must be recalculated assuming that CIV or barrier to be completely failed.

6.2 PENETRATION MINIMUM PATHWAY LEAKAGE RATE When the leakage rate from each valve in a series multi-valve pathway (Figure 6-3) is known, then that pathway's MNPLR can be assumed to be equal to the leakage past the best of the two valves. This is conservative because it 6-2

NED0-31722 BLOCK VALVE DRAFT

~

o, 02 BLOCK Pt VALVE

~

03 04 BLOCK Pt VALVE 05 05 CONTAINMENT ---.- ~

Pt Figure 6-4. Parallel Multi-Valve Pathway CONTAINMENT ~

Figure 6-5. Parallel Multi-Valve Pathway 6-3

NED0-31722 DRAFT neglects the contribution of the low performance valve. A more accurate calculation for MNPLR using Q1 and Q2 for inboard and outboard valve leakage, respectively, is given by the equation:

MNPLR =

(Q 2 1

When the leakage rate from a dual valve (Figure 6-2) or parallel multi-valve (Figure 6-5) pathway is measured by pressurizing between the two valves or sets of parallel multi-valves, then that pathway's MNPLR is equal to half of the measured leakage rate.

The MNPLR of a dual valve pathway (Figure 6-2) measured by pressurizing between both valves is equal to half of the measured leakage rate. The licensee may reduce this value by repairing one of the two valves and then retesting. For purposes of determining as-found leakage (leakage that existed during the previous cycle), that pathway's as-found MNPLR is the newly determined leakage rate, or half of the measured value prior to repairs, whichever is smaller.

The MNPLR of a single valve pathway 1s equal to the measured leakage rate past that single valve.

The MNPLR of a series multi-valve pathway (Figure 6-3) measured by pressurizing against all closed valves in series is equal to the measured leakage rate.

When any CIV or barrier in a pathway is retested, that pathway's MNPLR must be recalculated using the new leakage rate.

When the Type Band C surveillance interval has expired on any CIV or barrier in a pathway, that pathway's MNPLR must be recalculated assuming that CIV or barrier to be completely failed.

6-4

NED0-31722 DRAFT 6.3 TOTAL CONTAINMENT MAXIMUM PATHWAY LEAKAGE RATE The Total Containment MXPLR is equal to the sum of the as-left MXPLRs from each Type Band C containment pathway.

6.4 RUNNING TOTAL CONTAINMENT LEAKAGE RATE The Type B/C test program verifies the leak-tightness of all Type Band C penetrations. A summary of Type B/C total leak rates will be maintained, and updated whenever a Type B/C test is performed (when containment integrity is required)to obtain the Running Total Containment Leakage Rate (RTCLR).

6.4.1 Calculation of the Running Total Containment Leakage Rate (RTCLR)

RTCLR = r (most recent type B/C MNPLR tests results)+

Highest Leakage Pathway [MXPLR - MNPLR) + 0.25 La The RTCLR must not exceed 1.0 La.

Whenever Type B/C tests are performed on a pathway during operation, then that pathway's as-left leakage shall be determined using both the MXPLR and MNPLR methods, and these leakage rates shall be used to recalculate the RTCLR.

If a Type B/C test cannot be performed without affecting unit operation, then a functional test as described in Section 7.3.4 may be performed in its place.

The RTCLR need not be maintained during periods when containment 1s not required.

The RTCLR shall be calculated prior to startup from any outage.

6-5

NED0-31722 DRAFT 7.0 TESTING REQUIREMENTS 7.1 GENERAL 7.1.1 Containment Isolation Valve Closure Closure of containment isolation valves and hatches for Type A, B, or C tests shall be accomplished by normal operation and without any adjustments (i.e., no manual tightening of valve after closure by valve operator).

7.2 TYPE A TESTS 7.2.1 Test Intervals Containment integrated leak rate tests shall be performed during periods of reactor shutdown at approximately equal intervals throughout the operating life of the plant. As stated in Section 7.2.3, the LSLR at the appropriate UCL shall be determined with the containment in as close to the "as-found" condition as practicable. If two consecutive "as-found" Type A tests fail to meet the ~1.0 La acceptance criteria, the unit shall be placed on an accel-erated test interval until two consecutive "as-found" Type A tests meet the acceptance criteria of <l.0 La, at which time the regular test interval may be resumed.

Alternatives to accelerated Type A testing are presented in Section 7.5.

7.2.1.l Units on Regular Test Intervals The first periodic Type A test shall .be performed within 36 months after the preoperational leakage rate tests with the first time interval conunencing with the date of a successful completion of the preoperational Type A test.

Subsequent Type A tests shall be performed at a maximum interval of 48 months, or a longer interval as approved by the NRC. This surveillance interval may be extended by 25% provided that the total elapsed time for three consecutive 7-1

NED0-31722 DRAFT intervals does not exceed 3.25 times the surveillance interval. This interval shall begin after the previous Type A test and end at the start of the next.

If the test interval ends while primary containment integrity is not required or when primary containment is required solely for shutdown activi-ties (such as handling of irradiated fuel or performing core alterations), I that specific test interval may be extended provided a successful Type A test is completed prior to the time when containment integrity is required for reactor criticality.

7.2.1.2 Units on Accelerated Test Intervals A surveillance interval of 24 months between tests is required. This surveillance interval may be extended by 25% provided that the total elapsed time for three consecutive accelerated test intervals does not exceed 3.25 times the surveillance interval. If the test interval ends while primary containment integrity is not required, or when primary containment integrity is required solely for shutdown activities, that specific test interval may be extended provided a successful Type A test is completed prior to the time when containment integrity for reactor criticality is required.

7.2.2 Test Duration and Choice of Methodology The minimum test duration for the Total Time test method is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The minimum test duration for the Mass Point test method is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The minimum test duration for the BN-TOP-1 test method is 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

_ Preoperational Type A tests shall be run for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

7-2

NED0-31722 DRAFT 7.2.3 As-Found Requirements During an outage when a Type A test is required, tne primary reactor containment shall be tested such that the as-found condition can be determined.

This may be implemented by either of the following:

(1) Conduct a CILRT prior to repairs or adjustments.

(2) Conduct a CILRT after all Type Band C tests are complete, and:

a. Sum the differences between the as-found MNPLR and the as-left MNPLR for each pathway.

b. Add this leakage rate to the Type A test LSLR at the appropriate UCL.

(3) Conduct a CILRT with any portion of the Type Band C tests complete, and, following the CILRT:

a. Sum the differences between the as-found MNPLR and the as-left MNPLR for each pathway tested prior to the CILRT.

b. Add this leakage rate to the Type A test LSLR at the appropriate UCL.

c. Complete the remaining Type Band C tests.

In addition, if during the performance of the CILRT any primary contain-ment pathway is closed, unvented, or not d~ained as specified in Section 7.2~9, then that pathway shall be considered to be isolated. The following is required upon completion of the CILRT:

(1) Perform an as-found Type B or C test on each pathway which was isolated, unvented, or not drained.

7-3

NED0-31722 DRAFT (2) Repair pathway, if necessary.

(3) Perform an as-left Type 8 or C test on each pathway if repairs were performed.

(4) Add the as-found MNPLRs to the Type A test calculated leakage rate at the appropriate UCL.

If a leak from containment is detected after the Type A test is

- officially started, options may be pursued, depending on when during the outage the Type A test is performed.

Options that may be pursued for Type A tests performed at the start of the outage are:

(1) Allow the test to continue.

(2) Stop the test, quantify the leakage, repair the leak, quantify the leakage again and restart the test. A penalty equal to the as-found m1n1mum pathway leakage rate minus the as-left minimum pathway

- leakage rate must then be added to the as-found Type A test results.

(3) Stop the test, isolate the leak in a manner that allows its as-found value to be later quantified and restart the test. Following the test, quantify the as-found minimum pathway leakage rate and add to the as-found Type A test results. In addition, add the as-left minimum pathway leakage rate to the as-left Type A test results.

(4) Stop the test. If the as-found value of the leak was not (or could not be) quantified, it will be assumed to be in excess of La. This results in the Type A test being classified as a failure. It is not necessary to quantify the leak prior to isolation; however, if the as-found leak rate later proves unquantifiable, the as-found Type A test must be declared a failure.

7-4

NED0-31722 DRAFT Options that may be pursued for Type A tests performed at the end of the outage are:

(1) Allow the test to continue.

(2) Stop the test, quantify the leakage, repair the leak, quantify the leakage again and restart the test. Any improvement in leakage rate must be considered when calculating the as-found Type A test results.

(3) Stop the test, isolate the leak in a manner that allows its as-found leakage (MNPLR) to be later quantified and restart the test.

Following the test, quantify the as-found and as-left leakage (MNPLR) and add the as-left MNPLR leakage value to the Type A test results.

When applying the above, if the isolated or repaired pathways as-found MNPLRs cannot be quantified, it must be assumed to be infinite. Therefore, any pathway's as-found MNPLR not quantified results in a failed as-found Type A test.

Regardless of which method or combination of methods are used, any leak-age paths not tested during the Type A test must be Type 8 or C tested and the Type A test LSLR must be adjusted accordingly.

7.2.4 As-Left Requirements The as-left Type A test leakage rate shall be the sum of the Type A test LSLR at the appropriate UCL and the as-left MNPLR of all leakage paths isolated during the performance of the CILRT. If any primary containment pat~way is closed, unvented, or not drained as specified in Section 7.2.9, then that pathway shall have been considered isolated.

7-5

NED0-31722 DRAFT 7.2.5 Data Acquisition CILRT data sets shall be collected at uniform intervals throughout the Type_A test and throughout the verification test, although those two intervals need not be the same. In any case, the maximum allowable interval between data sets is one hour.

Often, wet bulb and dry bulb temperature sensors exhibit a significant amount of scatter. It is acceptable to add physical or mathematical capaci-tance to the measurement system for the purpose of eliminating temperature spikes that are not representative of actual containment conditions. The intentional induction of such a capacitance must be both documented and reported. Also, a complete technical justification considering instrument response times, the rate of change of containment temperature, and the data collection intervals must be performed.

It is not acceptable to intentionally induce a capacitance into the measurement of total containment pressure.

7.2.6 Data Rejection Data may be rejected during the test based upon sound engineering judg-ment. Rejection made without the aid of a formal rejection criteria must be based on knowledge of a specific problem or upon sound physical reasoning.

Any technically sound, consistently applied data rejection criteria may be used. Individual sensors, whole data sets, or specific pieces of data may be rejected during performance of the test. Invalid data shall continue to be collected and discussed in the CILRT report.

If scattered data sets are lost due to equipment malfunction or other such reason, those data sets may be locked out and the calculations performed as if they never existed. Such instances would be exceptions to the above requirement for uniform intervals, although, again, no *more than a one-hour gap is allowed between data sets. All such losses of data must be both documented and reported.

7-6

NED0-31722 DRAFT Records shall be kept to document all rejected data, the justification for rejection, and the alternate calculational method used without the rejected data.

7.2.7 Recording of Data CILRT data sets must contain the following data items:

(1) Individual total containment pressure sensor readings.

(2) Individual containment air dry bulb temperature sensor readings.

(3) Individual containment air dewpoint temperature or relative humidity sensor readings.

(4) The time at which the data set was collected.

The following data must be collected during the CILRT but not necessarily with each data set:

(1) The absolute ambient pressure of the air bounding the outside of the containment vessel being tested.

(2) The liquid levels in containment that may affect the containment's free volume.

(3) Outside air temperature.

(4) Outside absolute ambient pressure if other than the one listed above.

Note, the ambient temperature and pressure must be measured and recorded at corresponding intervals of at least once per hour.

7-7

NED0-31722 DRAFT In order to be able to interpret the data sets, the following information must also be recorded:

(1) A dated log of events and pertinent observations shall be maintained during the test, and the correctness of data shall be attested to by those responsible for the test.

(2) Calibration data for each sensor.

(3) Containment subvolume scheme and associated volumes.

(4) The identity of each sensor assigned to each subvolume.

(5) The mathematical equations used to convert the raw sensor readings into Total Containment Dry Air Mass, and the LSLR and its appro-priate UCL.

7.2.8 Test Pressure Type A test pressure must be Pa !4% (but in no case greater than design pressure) at the start of the test, and must not fall below Pa -4% for the duration of the Type A test, not including the verification test. Reduced pressure testing may be employed where specifically allowed by Plant Technical Specifications.

7.2.9 Venting and Draining Pathways which are required to be Type C tested must be vented inside and outside the containment during the CILRT * . . All vented penetrations must be dralned of water inside the containment, up to and between the containment isolation valves to assure exposure of those valves to containment air test pressure. The degree of draining of vented penetrations outside of containment is controlled by the requirement that the valves be subjected to the post-accident differential pressure, or proof that the system was built to stringent quality assurance standards comparable to those required for a seismic system.

7-8

NED0-31722 DRAFr Systems that are required for proper conduct of the test, or to maintain the plant in a safe condition during the test, shall be operable in their nor-mal mode and need not be vented or drained during the CILRT. Additionally, sys~ems that are normally filled with water and are operable under post-accident conditions, such as the containment heat removal system, need not be vented or drained during the CILRT.

7.2.10 Test Start Times The official test start time for both the Type A test and the verifies- -

tion test may only be declared to be some future time. The official test start time may not be retroactively declared.

The tests may be stopped after starting and then restarted. All starts, stops, and complete justification for restarts must be logged.

7.2.11 Liguid Level Monitoring In cases where a vessel inside of the test volume 1s gaining or losing water from the outside, changes in the resulting total containment free volume may be accounted for 1n the calculation of total containment dry air mass.

The instruments used to make these corrections must be both calibrated and of sufficient accuracy to allow these calculations to be performed.

In cases where a vessel inside of the test volume is losing water to any other location inside of the test volume, no net change in the containment free air volume results.

7.2.12 Continuous Leakage Monitoring Systems When practical, Continuous Leakage Monitoring Systems must not be operating or pressurized during Type A tests. If the Continuous Leakage Monitoring System cannot be isolated, such as by use of inflatable air-lock door seals, leakage into the containment must be accounted for and the Type A test results corrected accordingly.

7-9

NED0-31722 DRAFT 7.2.13 Containment Modifications Type A testing of certain minor modifications, repairs, or replacements may_be deferred to the next regularly scheduled Type A test if local leakage testing is not possible and visual (leakage) examinations or nondestructive examinations have been conducted. Such modifications shall include:

(1) welds of attachments to the surface of the steel pressure retaining boundary; (2) repair cavities, the depth of which does not penetrate the required design steel wall by more than 10%; and (3) welds attaching to the steel pressure-retaining boundary penetrations, the nominal diameter of which does not exceed one inch.

7.3 TYPE BAND C TESTS 7.3.l Test Intervals Type Band C tests may be performed during shutdown periods or normal plant operations. The Type B/C surveillance interval is 24 months, except as specified in Section 7.4 and is applied on a per component basis.

For continuous leakage monitoring systems continuously maintaining con-tainment penetrations at a pressure greater than Pa, leakage must be deter-mined at intervals specified in the Plant Technical Specifications or FSAR.

If leakage cannot be determined by periodic measurements or if the Plant Technical Specifications or FSAR do not specify a different interval, indi-vidual or group containment penetration leakage must be determined at three-year intervals.

The surveillance interval for any scheduled surveillance on an individual or g_roup of penetrations may be extended by 25%, provided the total elapsed time of any three consecutive intervals does not exceed 3.25 times the surveillance interval. If the Type B/C surveillance interval ends while primary containment integrity is not required, the surveillance interval may be extended, provided all deferred testing is successfully completed prior to 7-10

the time containment integrity is required. If Type B components (except air-locks) are opened following a Type A or B test, they must be Type B tested prior to returning the reactor to an operating mode requiring containment integrity.

7.3.2 As-Found Testing In general, periodic leakage rate testing performed to satisfy the 24-month surveillance requirement will be performed with components in the "as-found" condition within the bounds of practicality and professional engineering judgment (i.e., components should not be repaired intentionally for the purpose of improving the leakage rate prior to testing). The following sections provide guidance as to how this position should be implemented during various operational conditions.

7.3.2.1 Non-CILRT Outage or CILRT Outage After Type A Test Completion As-found local leak rate tests (LLRT) shall be performed prior to repairs or adjustments (R/As) on Type Band C components when the tert is being performed to satisfy the 24-month periodic surveillance requirement.

Components may be exempt from as-found (but not as-left) testing in a non-CILRT outage or in a CILRT outage after the Type A test has been performed if there is no reason to expect unacceptable leakage, and:

(1) The component is being replaced with a non-like replacement and there are no other Type B or C components of the same model 1n use as a CIV in the plant, and, -therefore, nothing would be gained by the knowledge of past performance of this component, or (2) The component has documented history of acceptable low leakage per-formance (minimum of two consecutive tests with service time between tests), or 7-11

NED0-31722 DRAFT 7.3.2.2 CILRT Outage Prior to a Type A Test As-found LLRTs shall be performed prior to R/As on Type 8 and C coml>onents, and appropriate adjustments shall be made to obtain "as-found" Type A test results.

7.3.2.3 Unit Operation As-found LLRTs shall be performed prior to R/As on Type Band C components when the test is being performed to satisfy the 24-month periodic surveillance requirement. The exemptions to as-found testing as provided in Section 7.3.2.1 are applicable.

Type Band C components which are repaired during Unit Operation must receive an as-left LLRT and the RTCLR must be recalculated (see Section 6.4.1).

• 7.3.3 As-Left Testing As-left LLRTs are to be performed following any R/As on a Type B or C component. Each activity must be evaluated separately for its potential to affect each specific boundary on which it is performed.

If leakage is identified on a system which is in service, as-left LLRTs need not be performed following any actions performed on Type B or C components, provided the leakage characteristics of the components are analyzed to be not adversely affected, or conservative functional testing is performed to confirm that component leak-tight integrity is maintained.

7.3.4 Alternative Testing A functional test that can be proven to yield results which are conserva-tive relative to an LLRT may be substituted for an as-left LLRT in cases where performing an LLRT poses a personnel hazard, or where it would affect unit operation.

7-12

NED0-31722 DRAFT Use of any functional test should be viewed as a last resort measure, especially when the observation of water leakage is used in place of an air test.

7.3.5 Test Pressure The test volume for Type Band C tests shall be pressurized to obtain a differential pressure across all tested components equal to or greater than the calculated peak containment internal accident pressure (Pa) except as provided by Plant Technical Specifications or FSAR. When necessary, a vacuum may be drawn on the low pressure side of the barrier being tested in combination with pressurizing the containment side to obtain the required differential pressure across the barrier of at least Pa. In no case shall the differential pressure across a valve or leakage barrier exceed 110% of its design rating. Although the test must begin with P > Pa, it is acceptable to go below Pa during the test, provided corrections are made.

7.3.6 Venting and Draining The test volume must be drained, ensuring exposure of all bounding con-tainment isolation valves to air at test pressure. The line(s) on the other side of the volume's containment isolation boundary valve(s) must be drained and vented. If the vent path cannot be drained due to plant conditions, the test pressure must be increased to compensate for the water column in the vent path.

7.3.7 Reverse Flow Testing Testing in the proper flow direction (i.e., from inside containment to outside) shall be done when physically possible. Where it is not feasible to test a valve in the proper direction, reverse flow testing will be evaluated (based on a review of each valve's design) and documented on a case-by-case basis. Leakage paths with containment boundaries which are untestable by LLRTs without substantial modifications shall be either subjected to functional testing or made part of the Type A test boundary.

7-13

NED0-31722 DRAFT 7.4 CONTAINMENT AIR LOCKS Air locks must be tested prior to initial fuel loading and at least once each six-month interval thereafter at an internal pressure of not less than Pa.

Alternatively, for air-lock doors having testable seals, testing the door seals, shaft seals, and equalization valves at a pressure specified in Plant Technical Specifications or FSAR fulfills this requirement. This surveillance interval may be extended by 25%, provided the total elapsed time of any three consecutive intervals does not exceed 3.25 times the surveillance interval.

Alternatively, if there have been no air-lock openings within six months of the last successful test at Pa, this interval may be extended to the next refueling outage or following the next air-lock usage, whichever occurs first.

In no case may the interval between tests exceed two years (during times when primary containment integrity is required).

Air locks opened during periods when containment integrity is required by Plant Technical Specifications must be tested within three days after being opened. For air-lock doors opened more frequently than once every three days, the air-lock must be tested at least once every three days during the period of more frequent openings. For air-lock doors having testable seals, testing the door seals at the pressure specified in Plant Technical Specifications or FSAR fulfills this three-day test requirement.

Air locks opened during periods when primary containment integrity is not required by Plant Technical Specifications do not require testing during such periods, but shall be tested prior to the plant requiring primary containment integrity. For air-lock doors having testable seals, testing the door seals fulfills this test requirement. These tests shall be performed at the test pressure specified in Plant Technical Specifications or FSAR.

A full pressure test at Pa of the airlock barrel shall be performed during each refueling outage.

7-14

NED0-31722 DRAFT Whenever maintenance (other than on seals or equalization valves) has been performed on an air-lock which involves the pressure retaining boundary, a complete air-lock test at a test pressure of not less than Pa is required.

Maintenance on seals or equalization valves requires only that these compo-nents be tested.

7.5 CORRECTIVE ACTION PLANS In general, corrective actions should be focused on those activities that could eliminate the root cause of a component failure with appropriate steps to eliminate recurrence, and to affect early detection of degrading mechanisms and trends.

When two consecutive Type A tests fail due to leaks through non-Type B or C tested pathways, then the frequency of testing should be adjusted per Section 7.2.1.2 When a failure 1s directly related to a Type B or C tested boundary, then the requirements of 10CFRSO Appendix B, Criteria XVI (identify root cause and take corrective action) must be met.

When a Type A test fails to meet the criteria as a result of a procedural error or failure of test instrumentation, then it should be invalidated, the deficiency corrected, corrective action implemented, and the test reperformed.

Correction action plans may be submitted to the NRC as part of the leakage rate test report following startup from a CILRT outage. However, the unit shall be considered to be on an accelerated Type A test interval until NRC approval of the corrective action plan is received.

7-15

NED0-31722 DRAFT 7.6 ACCEPTANCE CRITERIA 7.6.1 Type A Testing (1) The as-found Type A leakage rate at the appropriate upper confidence limit (UCL) must not exceed 1.0 La.

(2) The as-left Type A leakage rate at the appropriate UCL must not exceed 0.75 La prior to entering a mode of operation that requires containment integrity.

7.6.2 Type B/c Testing (1) The Running Total Containment Leakage Rate (RTCLR) must not exceed 1.0 La.

(2) The Total Containment MXPLR must not exceed 0.6 La prior to a start-up from a scheduled LLRT outage.

7-16

NED0-31722 DRAFT 8.0 INSTRUMENTATION 8.1 GENERAL REQUIREMENTS Instrumentation used in the performance of Type A, B, or C tests must be calibrated against standards traceable to the National Bureau of Standards (NBS). During times when those instruments are being used, the proof of current calibration shall be maintained on-site.

The instruments may be purchased commercial grade; however, calibrations must be performed in compliance with the requirements of an approved 10CFR50 Appendix B Quality Assurance Program.

The system calibration must be performed over a range spanning the temperatures or pressures that it shall be used to measure. A minimum of three calibration points are required.

Each instrument's calibration interval shall be determined by the licensee based upon the documented performance history of thEt specific sensor and system. In cases where no such historical data has been accumulated, the manufacturer's recommendations for recalibration intervals shall be followed.

If the above pretest calibration requirements have been followed, and if a successful verification test has been performed, then no post-test calibration is required.

Instruments need not meet the above requirements if their readings are not used in the calculation of any value which must be compared against an acceptance criteria.

8-1

NE00-31722 DRAFT 8.2 INSTRUMENT PERFORMANCE AND CALIBRATION REQUIREMENTS FOR TYPE A TESTS AND VERIFICATION TESTS 8.2.1 Drybulb Temperature

• c1) The accuracy of each channel shall be +0.5°F or better.

(2) The sensitivity of each channel shall be +0.1°F or better.

(3) The repeatability of each channel shall be +O.Ol°F or better.

(4) The resolution of each channel output to be used in the calculations shall be O.Ol°F or better.

(5) At least a three-point calibration must be performed on each sensor and signal conditioning circuit.

Prior to use of the drybulb temperature sensors in a Type A Test, after they are all connected to their signal conditioning cards and display device, a check shall be performed on each sensor. This check shall be performed by comparing the sensor's temperature reading against the reading from a standard measuring the same temperature in the same location. The standard must be in current calibration traceable to an NBS standard. This comparison need not be performed in the location where the sensor is to be used during the Type A test, although a similar cable, the same signal conditioning circuit and the same output device used during the Type A Test shall be used during the comparison. If the air temperature in the location where the comparison is to be made is unstable, it is recommended . that, during the comparison, both the tensor and the standard be simultaneously submerged in a container of water.

No more than a 1°F difference between any sensor being tested and the standard is acceptable.

8.2.2 Dewpoint Temperature (1) The accuracy of each channel shall be +2.0°F or better.

8-2

NED0-31722 DRAFT (2) The sensitivity of each channel shall be !0.5°F or better.

(3) The repeatability of each channel shall be +0.1°F or better.

(4) The resolution of each channel output used in the performance of calculations shall be 0.1°F or better.

NOTE: If relative humidity sensors are to be used, the equivalents to the above parameters, evaluated at the expected drybulb temperatures, must be met.

(5) At least a three-point calibration must be performed on each sensor and signal conditioning circuit.

Prior to use of the dewpoint temperature or relative humidity sensors in a Type A Test, after they are all connected to their signal conditioning cards and display device, a check shall be performed on each sensor. This check shall be performed by comparing the sensor's reading against the reading from a standard in the same location. The standard must be in current calibration traceable to an NBS standard. This comparison need not be performed in the location where the sensor is to be used during the Type A test, although a similar cable, the same signal conditioning circuit and the same output device used during the Type A Test shall be used during the comparison. No more than a 5°F difference between any sensor being tested and the standard 1s acceptable.

8.2.3 Containment Pressure (1) The accuracy of the system in psi shall be +100,000/(containment free air volume, in cubic feet} or better.

(2) The sensitivity of each channel shall be +0.001 psi or better.

(3) The repeatability of each channel shall be +0.001 psi or better.

8-3

NED0-31722 DRAFT (4) The resolution of the output used to perform calculations shall be 0.001 psi or better.

_When the pressure sensors are calibrated, it is recommended that most of the calibration points be clustered very near ~o the expected test pressure.

No in-situ pretest check 1s required for any pressure sensor.

8.2.4 Verification Test Flowmeter (1) The accuracy of the flowmeter shall be +5% of full scale, or better.

(2) The range of the flowmeter shall be up to 2 La*

(3) The sensitivity of the flowmeter shall be +3% of full scale, or better.

8.2.5 Induced Leakage When the verification test is performed, the conditions of the discharge gas may be different from the calibration standards of the instrument. The instruments used to measure the temperature and pressure of the discharge gas are:

Accuracy: +1°F and +0.1 psi, or better Resolution: 0.1°F and 0.01 psi, or better 8.2.6 Data Collection Clock The time of data set collection must be recorded using a clock that is accurate within l minute every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The resolution of the display and of the_output used for any calculations must be 1 second or better.

8.2.7 Ambient Pressure The accuracy of the pressure measuring device used for measuring atmospheric pressure shall be +l in. of mercury or better.

8-4

NED0-31722 DRAFT 8.2.8 Ambient Temperature The accuracy of the temperature gauge used for measuring atmospheric temperature shall be +l°F or better.

8.2.9 Water Level Measurement The requirements for each level channel used to correct Type A test results during performance of the test shall meet the following specifications or justification shall be given for not doing so:

(1) The accuracy of each channel shall be better than +1.0% of full scale.

(2) The repeatability of each channel shall be +0.1% of full scale or better.

(3) The resolution of each channel shall be 0.1% of full scale or better.

8.3 INSTRUMENT PERFORMANCE AND CALIBRATION REQUIREMENTS FOR TYPE BAND C TESTS 8.3.1 Drybulb Temperature (1) Instruments for measuring drybulb temperature shall have a calibrated range of at least ambient !20°F.

(2) The accuracy shall be +1°F or better.

(3) The sensitivity shall be +0.5°F or better.

(4) The resolution shall be 0.5°F or better.

8-5

NED0-31722 DRAFT 8.3.2 Test Volume Pressure (1) The range of the pressure detector shall be no greater than 400% of the test pressure.

(2) The accuracy shall be +1% of full scale, or better.

(3) The sensitivity shall be +0.5% of full scale, or better.

(4) The resolution shall be 0.5% of full scale, or better.

8.3.3 Makeup Flow Rate (1) The accuracy shall be +2% of full scale, or better.

(2) The sensitivity shall be +1% of full scale, or better.

(3) The resolution shall be 1% of full scale, or better.

8.3.4 Test Time When the pressure decay method is used, the clock shall be accurate to within one minute every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The resolution of the display and of the output used for any calculations shall be one second or better.

8-6

NED0-31722 DRAFT 9.0 TYPE A TEST METHODOLOGY 9.1 GENERAL The absolute method of leakage determination shall be utilized for all Type A tests. This method of leakage rate determination depends on the measurement of the temperature and pressure of the containment structure atmosphere with correction for changes in water vapor pressure. It assumes that the temperature and pressure variations during the test will be insuf-ficient to affect significant changes in the internal free air volume of the structure. The verification test shall be performed using the same methodol-ogy and instrumentation used in the Type A test.

9.2 CONTAINMENT INSPECTION A general inspection of the accessible interior and exterior surfaces of the containment structure and components is required prior to the start of the test to uncover any evidence of structural deterioration that may affect either the containment's structural integrity or leak-tightness. Auy irregularities such as cracking, peeling, delamination, corrosion, and structural deteriora-tion should be recorded. If there is evidence of structural deterioration, a Type A test shall not be performed until corrective action is taken.

9.3 TEMPERATURE SURVEY The containment subvolume partitioning scheme and the location of drybulb and dewpoint temperature sensors must be validated prior to each CILRT. (Note:

All sensors must be located far enough away from heat sources, heat sinks, and sources of thermal radiation such that their temperature readings are not affected.) Either of the following validation methods is acceptable:

(1) The CILRT procedure shall contain a requirement to measure and record a specified number of drybulb and dewpoint temperatures in each accessible subvolume, after hanging instruments prior to the 9-1

NED0-31722 test.

DRAFT If practical, and if no personnel hazards result, then the containment heating and ventilating conditions during this survey must be identical to those during the Type A test. Acceptance criteria for both the maximum temperature difference around each sensor and within each subvolume must be specified in the CILRT procedure.

(2) If a documented temperature survey from a previous survey on a similar unit exists, the sensor positions must be the same as those e in the documented survey. Only if conditions in the containment have changed in any way that could reasonably be expected to alter the temperature distribution since the previous survey must a new survey [as specified in (1) above] be performed.

9.4 INSTRUMENTATION SYSTEM 9.4.1 Minimum Number of Sensors Listed below are the minimum numbers of sensors required to be used in the performance of a Type A test:

(1) At least ohe containment pressure sensor must be in operation during the Type A test.

(2) At least one flow measurement device shall be operational during the verification test.

(3) A sufficient number of drybulb temperature sensors shall be operable to ensure that an accurate value.of volume weighted average containment temperature can be calculated. To achieve this, the licensee should place the greatest number of sensors in areas that the containment temperature survey showed had the most severe temperature gradients.

9-2

NED0-31722 DRAFT (4) A sufficient number of dewpoint or relative humidity sensors shall be operable at the start of the Type A test in order to ensure that an accurate value of volume weighted average containment vapor pressure can be calculated.

(5) In subvolurnes that are known to be saturated, drybulb temperature sensors may be used in place of dewpoint sensors.

(6) If all dewpoint or relative humidity sensors in the entire containment are lost after the start of the Type A Test, the test may continue if enough data has been collected prior to that failure to show that the total containment volume weighted vapor pressure is either remaining effectively constant or is declining.

9.4.2 System Performance The following Instrumentation Selection Guide (ISG) formula shall be used to determine the ability of an instrumentation system to measure the integrated leakage rate of a primary reactor containment system. The ISG formula is not based on a statistical analysis of leakage rate calculations but has been developed for instrumentation selection. Instrumentation errors are combined using a root-sum-square-formula. The ISG computed is not added to the value of the calculated leakage rate but is used for instrument selection and loss of sensor criteria only.

2400 ISG =

t Symbols and Subscripts ISG = instrumentation selection guide (percent per day) t = minimum expected Type A test duration (hours) 9-3

NED0-31722 DRAFT p = containment atmosphere total absolute pressure (psia)

Pv = containment atmosphere volume weighted partial water vapor pressure (psia)

T = containment atmosphere volume weighted absolute drybulb temperature (OF) e = error associated with a measurement of a given parameter (psia or °F).

NOTE: Where multiple independent measurements of a given parameter are taken with sensors of equal precision, the error associated with the average of the multiple measurements equals the error of the individual sensor divided by the square root of the number of sensors.

The ISG calculated fort= 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> shall not exceed 0.25 La prior to the Type A test for purposes of instrumentation selection. This calculation is also applicable for test durations of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

9.5 PRESSURIZATION The containment should be pressurized using a medium that is clean, rela-tively dry, and free of contaminants. A maximum pressurization rate shall be established to minimize the potential for damage to plant equipment. Pres-surizing facilities shall be isolated and vented or disconnected during the test. The test pressure shall be established relative to the external pres-sure of the containment. This may be either atmospheric or the pressure of a secondary containment.

9.6 CONTAINMENT STABILIZATION If the BN-TOP-1 Method is to be used, then Section 9.6.1 must be satis-fied. If Hass Plot or Total Time Methods are used, then Section 9.6.2 or 9.6.3 must be satisfied.

9-4

NED0-31722 DRAFT 9.6.1 BN-TOP-1 Requirements After the containment has been pressurized to test pressure, at least fou~ hours of data must be collected. Then, plots shall be made of both the average containment air temperature and the containment air absolute pressure, both verses time. The pressure-time curve should follow the temperature-time curve.

The atmosphere is considered stabilized when either of the following criteria is satisfied:

(1) The rate of change of the average containment temperature (Ki) shall be less than l.0°F/hr when averaged over the last two hours:

where ti = Time (hours) ti-1 = Time one hour prior to ti (hours)

Ti = The volume weighted average containment dry bulb temperature at time ti The average of K1 and K2 must be less than l.0°F/hr in order for this criteria to be met.

(2) The rate of change of temperature changes (Z) shall be less than 0.5°F/hour/hour when averaged over the last two hours:

9-5

NED0-31722 DRAFT Z must be less than 0.5 in order for this criteria to be met.

9.6.2 Dry Air Hass Method At least 30 data sets must be available in order to use this method. The interval between data sets must be uniform and may be as short as two minutes.

The containment may be considered stable when both of the following criteria are met:

(1) Test for the Rate of Rate of Change of Dry Air Hass where La= The Unit's maximum allowable Primary Containment Leakage Rate as specified in Technical Specifications (%/day)

LN = Statistical Hass Plot Leakage Rate calculated using the equation from Section 9.8.1 and the Total Containment Dry Air Masses from the last 20 data sets (%/day)

LH = Statistical Hass Plot Leakage Rate calculated using the equation from Section 9.8.1 and the Total Containment Dry Air Masses from 20 data sets beginning ten time intervals ago (%/day) tN = Time at which LN was calculated (hours) tH = Time at which LH was calculated (hours)

(2) Test Dry Air Hass Point Scatter UCL - LR< 0.25 La 9-6

NED0-31722 DRAFT where UCL= Mass Plot 95% Upper Confidence Limit of the previous 30 data sets calculated using the equations from Section 9.8.1 and the Total Containment Dry Air Masses from the last 30 data sets (%/day)

LR = Statistical Mass Plot Leakage Rate calculated using the equations from Section 9.8.1 and the Total Containment Dry Air Masses from the last 30 data sets (%/day) 9.6.3 10CFR50 Appendix J Method After the containment has been pressurized to test pressure, at least four hours of data must be collected. Based upon the engineering judgment of the licensee, the containment may be declared to be stable at any time. This

• judgment should be aided with plots of Containment Dry Air Mass.

9.7 CALCULATION OF CONTAINMENT DRY AIR MASS 9.7.1 Average Temperature of Subvolume #i (Ti)

The average temperature of subvolume #i (Ti) equals the average of all RTD temps in subvolume #i:

N T. = _Nl ~ T . .

l L...- 1,J j=l where N = Number of RTDs in subvolume #i.

9-7

NED0-31722 DRAFT 9.7.2 Average Dew Temperature of Subvolume #i (D.)

l The average dew temperature of subvolume #i (Di) equals the average of all-dew cell dew temperatures in subvolume #i:

N D. = _Nl ~ D. .

l L.J l,J j=l

- where N = Number of dew cells in subvolume #i.

If the subvolume in question is the reactor vessel internal air space, then that subvolume's air may be assumed to be saturated and the dewpoint, drybulb, and water temperature equal.

If the subvolume in question is the suppression pool, the above assumption may be used if it can be shown from previous test data that there is a very close correlation between suppression pool airspace and water temperature.

9.7.3 Total Corrected Pressure #i (P.)

l The total corrected pressure #i, (Pi) is:

where Ci = Zero shift correction factor for raw pressure #i Mi = Slope correction factor for raw pressure #i Pri = Raw pressure #i, in decimal form 9-8

NED0-31722 DRAFT 9.7.4 Whole Containment Volume Weighted Average Temperature, (T)

C Calculate Tc using the below equation or one that yields equivalent values to two decimal places:

1 T

C

= N f.

L i=l 1

T.

1 where fi = The volume fraction of the ith subvolume N = The total number of subvolumes in containment 9.7.5 Calculation of the Average Vapor Pressure of Subvolume i, (Pv.)

1 Average Subvolume Vapor Pressure as functions of Average Dew Temperatures (Di) are most accurately found from ASME Steam Tables. A simpler, extremely accurate correlation is given below:

For 32 <Di< 80°F Pvi = 0.2105538 x 10-l + 0.1140313 x 10-2 Di

+ 0.1680644 x 10-4 Di2 + 0.3826294 x 10-6 Di3

+ 0.5787831 x 10-9 Di4 + 0.2056074 x 10-l0 Di5 For 80 <Di< 115°F Pvi = 0.18782 - 0.7740034 x 10-2 Di

+ 0.204009 x 10-3 Di2 - 0.1569692 x 10-5 Di3

+ 0.1065012 x 10-7 Di4 9-9

NE00-31722 DRAFT For 115 <Di< 155°F Pvi = 0.9897124 - 0.3502587 x 10-l Di

+ 0.5537028 x 10-3 Di2 - 0.3570467 x 10-5 Oil

+ 0.1496218 x 10-7 Di4 For 155 <Di< 215°F Pvi = 0.3338872 ~ 101 - 0.9456801 x 10-l Di

+ 0.1121381 x 10-2 Di2 - 0.598361 x 10-5 Di3

+ 0.1882153 x 10-7 Di4 9.7.6 Whole Containment Average Vapor Pressure, (Pv)

C Calculate Pvc using the following equation or one that yields equivalent values to two decimal places:

f. Pv.

l l Pv C T.

l where N = The total of subvolumes in containment fi = Volume fraction of the ith subvolume 9.7.7 Calculation of the Whole Contai_nment Average Dew Temperature, (De)

Whole Containment Average Dew Temperature as functions of Whole Containment Average Vapor Pressures are most accurately found from ASKE Steam Tables. A simpler, extremely accurate correlation is given below:

De is in units of °F.

For 0.08859 < Pvc < 0.50683 psia 9-10

NED0-31722 DRAFT Note: Pc (0.08859) = 32°F, Pc (0.50683) = 80°F De= - 0.5593968 x 101 + 0.6348248 x 103 Pvc

- 0.320306 x 104 Pvc2 + 0.1130089 x 105 Pvc3

- 0.2411539 x 105 Pvc4 + 0.2796469 x 105 Pvc5

- 0.1348916 x 105 Pvc6 For 0.50683 ~ Pvc ~ 1.4711 psia Note: Pc (0.50683) = 80°F, Pc (1.4711) = 115°F De=+ 0.2334173 x 102 + 0.2004024 x 103 Pvc

- 0.2785328 x 103 Pvc2 + 0.2765841 x 103 Pvc3

- 0.168669 x 103 Pvc4 + 0.5658985 x 102 Pvc5

- 0.7977715 x 101 Pvc6 For 1.4711 ~ Pvc ~ 4.2036 psia Note: Pc (1.4711) = 115°F, Pc (4.2036) = 155°F De = 0.5221757 X 102 + 0.7391149 x 102 Pvc

- 0.3306993 X 102 Pvc2 + 0.1074842 X 102 Pvc3

- 0.2169825 X 101 Pvc4 + 0.2432796 Pvc5

- 0 .1155358 X 10-l Pvc6 For 4.2036 ~ Pvc ~ 15.592 psia Note: Pc (4.2036) = 155°F, Pc (15.542) = 215°F De = 0.8512278 X 102 + 0.274613 x 102 Pvc

- 0.3847812 X 101 Pvc2 + 0.3909064 Pvc3

- 0.2451226 X 10-l Pvc4 + 0.8484505 X 10-3 Pvc5

- 0.1237098 X 10-4 Pvc6 9-11

NED0-31722 DRAFT 9.7.8 Average Total Containment Pressure (P) where N = Number of pressure transmitters used.

9.7.9 Average Total Containment Dry Air Pressure, (Pd) 9.7.10 Total Containment Dry Air Mass, (M)

Type 1:

M =

where 0

R = Perfect gas constant of air, 53.35 lb£ - ft/lbm - R Ve= Total containment free volume.

Type 2:

Type 2 dry air mass accounts for changes in Reactor Vessel level.

For uncorrected dry air mass, the following definitions apply:

V. and f. = V. /V l l l C where Vi= Free volume in subvolume i.

9-12

NED0-31722 DRAFT For corrected dry air mass, the same definitions for Ve and fi apply, except that one of the Vis is corrected for changes in vessel level. If k 1s the subvolume number of the corrected subvolume, then:

where a = Number of cubic feet of free volume per inch of vessel level.

b = Base level of the reactor vessel (in.).

C = Actual water level in the reactor vessel (in.).

Vko = Volume of the subvolume k when C equals b.

The volume fractions (fi) are then calculated with the corrected volume, and all other calculations are subsequently performed as previously specified for Type 1 dry air mass.

9.8 CALCULATION OF CONTAINMENT LEAKAGE RATES The BN-TOP-1, Mass Point, or Total Time methods may be used for periodic Type A tests. However, other methods, as may be approved by the NRC, may be -

used.

9.8.1 Mass Point Method For this method, containment dry air mass is calculated for each data set and plotted versus time. It is assumed that the leakage rate is constant during the testing period. The resulting data, when plotted, would ideally yield a straight line with a negative slope. The leakage rate is proportional to the slope of this line.

Based on the least squares fit to the data obtained, the calculated con-tainment mass is represented by the equation:

M = B + At 9-13

NED0-31722 DRAFT where M = Containment dry air mass at time t {lbs)

B = Calculated dry air mass at time t=O {lbs)

A= Calculated leakage rate {lbs/hr) t = Time interval since start of test {hrs)

The values of constants A and B, such that the line is the linear least squares best fitted to the leak rate data, are:

N L{t.){H.)-(L 1 1 t.1 > cL M.)

1 A =

2 2 NL (t.) - ( Lt.)

l. l.

B =

L Mi - A Lti N

where N = Number of mass points used.

By definition, leakage out of the containment is considered positive leakage. Therefore, the statistically averaged least squares containment leakage rate (LSLR) in weight percent per day is given by:

-2400A L = B (weight %/day)

In order to calculate the 95% confidence limit of the least squares averaged leak rate, the standard deviation of the least squares slope and the student's t-Distribution function are used as follows:

NL (M. )2 - (

• l. {weight%

2 per day)

NL(t.)

l.

-c UCL= L + Ta 9-14

NED0-31722 DRAFT where T = l.6449(N-2) + 3.5283 + 0.85602/(N-2)

(N-2) + 1.2209 - 1.5162/(N-2)

N = Number of data sets ti= test duration at the ith data set (hours) a= standard deviation of least squares slope (weight %/day)

T = Value of the single-sided student's T-Distribution function with 2 degrees of freedom at the 95% confidence level L = calculated leak rate (weight %/day)

UCL= 95% upper confidence limit (%/day)

B = calculated containment dry ai~ mass at time t=0 (lbs) 9.8.2 Point-to-Point Method For this method, containment leakage rates are calculated for each data set interval and plotted versus time. It is assumed that the rate of change of this leakage rate is constant. The resulting data, when plotted, would ideally give a straight line with a slightly negative slope. The leakage rate is proportional to the equation of this line.

For every data set, the rate of change of dry air mass (interval leakage rate, Mp.) between the most recent, (t.) and the previous time (t. ) is cal-

,1 1 1- 1 culated using the two-point method shown below:

. 2400 Mp. = ( ) (1 - M./M. )

,1 t.1 - t.1- 1 1 .1- 1 Then the least square fit of the point-to-point leak rates 1s calculated as described for dry air masses in Section 9.8.1, where A is now the slope of the leakage rate curve, and Bis the calculated leakage rate at time t=0, and Li= -(B + Ati)*

9-15

NED0-31722 DRAFT 9.8.3 Total Time Method For this method, total time leakage rates are calculated and plotted versus time for each data set. Each total time leakage rate is calculated for the interval from time= 0 to the time of that data set. It is assumed that the rate of change of this leakage rate is constant. The resulting data, when plotted, would ideally yield a straight line with a slightly negative slope.

The leakage rate is proportional to the equation of this line. As the total time test duration is extended, the amount of data scatter of this plot decreases.

Initially, a reference time (tr) is chosen. For every data set, the total time leakage rate of dry air mass between tr and the most recent time (ti) is calculated using the two-point method shown below.

MT.,1 = 2400 (t. - t )

(1 - M./M) l r l r Then the least squares fit and 95% UCL of the Total Time leak rates are calculated as shown below, where A and Bare as defined in Section 9.8.2:

L MT.

11

~

£.J(t.)

l 2

- ~

£.J t.l L MT . 11 t.l B =

N L (t.

l

>2 -

. - l:

(N I; t. M 1 T,1

• t.

l L~ ,1.>

A =

NL ( t.)

l 2

-(L t. )

1 .

2 L.

l

=- (B . + At.)

l 9-16

NED0-31722 DRAFT T = l.6449(N-2) + 3.5283 + 0.85602/(N-2)

(N-2) + 1.2209 - 1.5162/(N-2)

Note: N 1s the number of data sets minus one.

(t - _1_ ~ (t.))2 p N-2 ~ 1 2

t.)

1 F (

• 2 * * )] 1/2 a = [ N-2 L<tir,i) - 8 L l-tr,i - AL l-tr,i ti UCL= L + Ta 9.8.4 BN-TOP-1 Method This method calculates the rate of change witl respect to the time of dry air mass using the Total Time Method.

Initially, a reference time Ctr) is chosen. For every data set, the rate of change of the data item between tr and the most recent time (ti) is calculated using the two-point method shown below:

Mi = 2400 (t. - t )

(1 - M./M) 1 r 1 r Then the least squares fit of the Total Time leak rates and the BN-TOP-1 95% UCLs are calculated as shown below:

• 2 *

~ M. ~ (t.) ~ t . ~ M. t.

B=-~---~-__1 1_ _ _ _~ ____ 1 ___1__1

~

NL 2

{t.) -

1

{L t.)

1 2

Note: N 1s the number of data sets minus one.

9-17

NEDO-31722 DRAFT N

E t. M. - E t. M.

A =

l l l E l N E ( t. )2 - <E t. )2 l l L _ (B + At)

T = 1.95996 + 2.37226 + 2.8225 (N - 2) 2 (N - 2) where T = Value of the double-sided student's t-distribution function with 2 degrees of freedom at the 97.5% confidence level.

1 1 Ct p - -N-2 L t. )2 l

F = 1 + +

N-2 L(ti)2 - N~2 ( E t.>2 l

a = [/:2 (L ~ - BL M- AE M.l t l

) J'2 UCL= L +To 9.9 THE VERIFICATION TEST The results of the Type A test are validated by the performance of the verification test. Failure of the verification test implies that the leakage rates previously measured by the Type A test could not be verified to be cor-rect. Specific guidelines for one method of performance of the verification test are given below. Other methods may also be acceptable.

9.9.l General Requirements (1) The verification test must be performed utilizing the same instrumen-tation and calculational method used in performance of the Type A test.

9-18

NE00-31722 DRAFT (2) The intervals between verification test data sets should be uniform but need not be equal to those from the Type A test.

(3) If it becomes necessary to lock out a sensor during the verification test, the licensee may choose to recalculate the Type A test results with that sensor locked out. The final LSLR (Section 9.8.1) from the recalculated Type A test is used in Section 9.9.5 to determine the target leakage rate for the verification test.

9.9.2 Test Start Time The stabilization phase of the verification test should begin as soon as possible after the end of the Type A test.

If a delay between the Type A test and the verification test occurs, data must continue to be collected and saved in the interim period at the same intervals as during the Type A test, if possible.

When the Type A test is ended, the value of the LSLR at that time is recorded. This value is later used in Section 9.9.5 to calculate the target leakage rate for the verification test. If a delay occurs between the Type A test and the verification test, it is required to extend the Type A test end time up to the data set prior to the start of the verification test only if the latest LSLR calculated prior to starting the verification test has changed by more than 0.1 La from final LSLR leakage rate from the Type A test.

9.9.3 Stabilization Period The verification test stabilization period begins when the induced leak is first valved in.

(1) When the BN-TOP-1 method is used, the stabilization period must last at least one hour.

9-19

NED0-31722 (2)

DRAFT When any method other than BN-TOP-1 is used, the stabilization period may be of any duration that the licensee chooses.

(3) The stabilization period may continue until the licensee declares it to be completed.

9.9.4 Measurement of Induced Leakage Rate/Verification Test The leakage rate induced from containment must be accurately quantified.

Typically, either a Rotometer or a thermal Hass Flowmeter is used. This does not imply that these are the only acceptable methods of measurement. Any instrument that meets the specifications listed in Section 8.2.4 is acceptable.

(1) At the start of the verification test, the magnitude of the induced leakage rate must be measured and recorded.

(2) After the start of the verification test, the induced leakage rate should not be altered except as specified in Paragraph (4).

(3) After the start of the verification test, the induced leak must be periodically measured and recorded.

Note: Rotameter readings are dependent on the local air temperature and pressure. These parameters should be measured and the necessary correction factors employed.

(4) After the start of the verification test, if the measured value of the induced leakage rate begins to vary from the value measured in Paragraph (1), the leak may be ~djusted in order to maintain the original value.

(5) After the start of the verification test, if the measured value of the induced leakage rate begins to vary from the value measured in Paragraph (1), the leakage may be left alone, and the value from Paragraph (1) may continue to be used in the calculation of target 9-20

NED0-31722 DRAFT leakage rate so long as the net change of induced leakage rate is less than 0.05 La.

9.9.5 Calculation of Target Leakage Rate The target leakage rate for the verification test 1s equal to the LSLR from 9.9.2(3) plus the value of induced leakage rate.

The magnitude of the induced leakage rate must be greater than 0.75 La and less than 1.25 La. This criterion specifies an acceptable range of induced leakage rates in terms of La or percent of containment volume per unit time. This is a volumetric flow rate. The flowmeters used to measure the induced leakage rate do so in terms of a mass flow rate. In order to convert between the two, a standard air temperature and pressure must be defined.

Also, values of containment temperature and pressure must be known.

Pst is the standard pressure and 1s equal to 14.696 psia.

Tst 1s the standard temperature and is equal to 68°F.

The flow rate (Q) to be induced, in units of standard cubic feet per minute, as a function of the %/day value 1s given below.

V P (T + 459.69) )

( 1440~0; ~; + 459.69) st av where Ve = Free volume of containment (ft3)

Tav = Volume weighted average containment temperature (°F)

Pc = Total average containment pressure at the start of the verification test (psia).

9-21

NED0-31722 DRAFT 9.9.6 Test Duration The verification test begins at the end of its stabilization period.

(1) If the BN-TOP-1 method is used, then the verification test duration must be at least half of the duration of the Type A test.

(2) If any method other than BN-TOP-1 is used, then there is no minimum duration for the verification test. However, prior to declaring the test to be successfully completed, the measured leakage must be shown to simultaneously meet the criteria specified in Sections 9.9.7(2) and 9.9.7(3) regardless of the length of time required.

9.9.7 Acceptance Criteria (1) Ideally, the LSLR measured during the verification test will be equal to the Target Leakage Rate, QT* The Target Leakage Rate is equal to the induced leakage rate plus the final LSLR from the Type A test, as specified in 9.9.2(3).

(2) The LSLR of the mass points taken since the start of the verifica-tion test (QM) must be inside the acceptance band in order for the test to be acceptable. The .acceptance band is specified below:

QT - 0.25 La< QM< QT+ 0.25 La (3) The LSLR measured during the verification test must be stable.

Stability should be evaluated based on sound engineering judgment.

9.10 DEPRESSURIZATION The maximum allowable depressurization rate and pathway should be established to assure compliance with Plant Technical specifications, and to minimize the potential for damage to plant equipment.

9-22

NED0-31722 DRAFT 10.0 TYPE BAND C TEST METHODOLOGY 10.l GENERAL Numerous methods are available for detecting, measuring, and locating fluid leak.age across a containment boundary. Often, only a few methods are applicable for testing a component in a given situation after factors such as sensitivity of the test, time required to perform the test, and the cost, weight, and size of testing equipment are considered. This section provides a general description of acceptable methods to determine leakage rates when per-forming Type B or C leakage rate tests. This is not intended to be a compre-hensive list of test methods; the test methods presented here are generally accepted methods of performing Type Band/or C tests.

Upper confidence limits are not calculated for Type Band C test results.

10.2 TEST METHODS 10.2.l Pressure Decay Method Pressure decay testing measures leakage rates by determining the pressure drop in a known volume over a given period of time. The test volume is pres-surized to a pressure greater than test pressure, such that the pressure at the end of the test period is expected to be greater than or equal to the min-imum test pressure. If the component has a large leakage rate, the final test pressure may drop below Pa* When the test volume has stabilized, the pres-sure source is disconnected or vented so as not to affect the test volume due to in-leakage. The initial temperature, pressure, and time are recorded.

The licensee shall consider test volume size when determining test duration.

10-1

NED0-31722 DRAFT The final temperature, pressure, and time are then recorded. The leakage rate is then determined by calculating the known pressure drop and test volume, and corrected for any change in temperature which may have occurred.

This method is best for measuring the leakage rate from large volumes. A disadvantage of this method is that the volume of the tested components must be known. The test volume can be affected by such things as water trapped in the dead legs of the volume, drainability of the volume, size of test line, etc. The formula for computing leakage rate is:

where L = Leakage Rate for a volume tested at> Pa (SCFH)

V = Test volume (ft3) t = Test duration (hr)

T1 = Test volume temperature at start of test ( 0 R)

T2 = Test volume temperature at end of test ( 0 R)

P1 = Test volume pressure at start of test (psia)

P2 = Test volume pressure at end of test (psia)

Ts= Standard temperature, 527.69°R Ps = Standard pressure, 14.696 psia The final test pressure should be equal to or greater than the peak acci-dent pressure. However, if the leak rate is high, this may not be practical.

The most appropriate action in this ca.se would be to change test methods (i.e., flow makeup). Another option is to correct the measured leak rate LM to the leakage rate which would have been measured had the volume remained at peak accident pressure. This may be done using the following equation~

10-2

NED0-31722 L = LM (CF)

DRAFT p - 1/iia a

CF=

where P = Final test pressure (atmospheres) t P = Peak accident pressure (atmospheres) a

~=Measured leakage rate at test pressure (SCFH)

NOTE: One atmosphere equals 14.696 psia.

10.2.2 Flowmeter Makeup Method Flowmeter testing is a method in which the component(s) being tested are exposed to test pressure with the leakage rate being determined by measuring the in-flow of fluid required to maintain the test volume at the test pres-sure. Various means of measurement may be used. The most popular are rota-meter and mass flow meters. This method is best suited for small and medium sized test volumes. When using rotameters or mass flow meters, the test rig and length of test hose should be considered for pressure drop, since the actual test pressure in the test volume may be significantly less than what 1s indicated at the test rig, Kost mass flow meters have a direct readout of leakage rate. No compen-sation for variations in temperature or pressure are required when mass flow meters are used. The following equation may be used when a rotameter is the measuring device:

p T )1/2 L=F _fx_.!

c ( ps Tf 10-3

NED0-31722 DRAFT where L = Corrected local leakage rate (SCFH), where the standard conditions are the parameters at the rotameter discharge Fe= Indicated flow (SCFH)

Pf= Pressure at rotameter discharge (psia)

Tf = Temperature at rotameter discharge ( R) 0 P8 = Calibration pressure of the rotameter discharge (psia)

Ts= Calibration temperature of the rotameter discharge ( R) 0 10.2.3 Water Displacement Method This method cannot be used for Type B or C testing, but may be used for determination of water leakage rates through components that are water filled or sealed. A water-filled container is utilized with a regulated air or nitrogen pressure source. The amount of water in the container is measured at the beginning and end of the test period, with the difference being the amount of leakage over the test period. During the test period, the water source to the container must be disconnected or vented to ensure no inleakage to the container. The water displacement method is very sensitive to entrapped air in the test volume. The following may be used in computing the leakage rate.

60 L= tt X AX t 10-4

NED0-31722 DRAFT where L = Leakage rate (CFH) 11.t = Water level drop in test container (in.)

A = Shape factor for the test tank (ft3/in.)

t = test duration (min)

When pressurizing the test volume, system pressures on the low-pressure side of each component(s) being tested must be known and compensated for. The test rig and length of hose should be considered for pressure drop. The elevation between the test container and the elevation of the component(s) being tested must also be compensated for. The following may be used in computing the test pressure:

Pt= (ELv - ELT) x 0.4331 + Pv + Pac where Pt = Test pressure (psig)

ELv = Component elevation (ft)

ELT = Test container elevation (ft)

Pv = Pressure on low side of component (psig)

Pac = Accident pressure (psig) 10.2.4 Vacuum Testing Method In combination with pressurizing the penetration being tested, a vacuum may be drawn on the opposite side. The combination of the two must create the desired differential test pressure. A flqw-measuring device may be used at the discharge of the vacuum pump. Alternatively, a vacuum decay may be measured. This is identical to the pressure decay method except the vacuum 10-5

NED0-31722 DRAFT decay method measures pressure buildup. The formula for computing leakage rate using the vacuum decay method 1s as follows:

All terms are defined in Section 10.2.1.

10.2.5 Bubble Testing Method 10.2.5.1 Immersion Bubble emissions from leaks are observed after pressurizing a device or system with a gas and covering the suspected leak area with a liquid. The test object can be completely immersed or portions of the object can be covered with liquid. Bubble emission sensitivity increases with the pressure differential applied to the test device and with the care taken by the opera-tor. The test sensitivity can be increased by use of special fluids, adequate illumination, and the use of optical magnification. A disadvantage of this method is that leakage rates cannot be quantified.

10.2.5.2 Liquid Application Method When it is not possible to immerse the test object, a small quantity of soap solution may be applied directly to the suspected leak area. A bubble-free solution should be applied gently to preclude bubble formation during application. The solution should be flowed rather than sprayed or brushed onto the surface. The sensitivity of this technique is dependent upon the time and care taken to observe bubble formation. Two mandatory requirements are:_

(1) When testing flanges, threads, or any joint ~hich has a large exposure area, it is absolutely necessary that the solution bridge the entire joint. Gas will invariably slip out through the smallest pinhole which is not covered.

10-6

NED0-31722 (2)

DRAFT The second requirement is in the choice of a suitable solution. For high sensitivity, it is necessary that the film does not break away from the joint and that the bubbles formed are not broken by air drying or low surface tension.

The major advantage of a topically applied bubble solution is that independent leaks can be located. A major disadvantage of bubble testing is that porosity leaks cannot be detected if the pores are very small, whereas vacuum or chemical methods may reveal them. Although a topically applied bubble solution will locate a leak very accurately, the leakage rates cannot be quantified using this method.

10.2.5.3 Bubbler Column This test method utilizes a column of water through which any makeup gas flow must pass. The test volume is pressurized through the water column and test pressure maintained by a regulator. Any bubbles visible in the water column during the test indicate a leak in the test volume. This method is best suited for detecting small amounts of leakage in small and medium sized volumes. This method has the disadvantage that the leakage cannot be quantified.

10.2.6 Continuous Monitoring A continuous leakage monitoring system must allow for determination of the leakage rate of the penetrations served by the system; otherwise, the penetrations must be Type Band/or C tested. Determination of the leakage rate may be by pressure decay, by calculation of makeup fluid volume or flow rate, or by another justifiable method.

10.2.7 Reference Vessel Method The reference vessel method may be used to perform a pressure decay test when the test volume is unknown. This method involves using a reference vessel (tank) of a known volume. The reference vessel is connected through a 10-7

NED0-31722 DRAFT pressure regulator to the test volume. Both are pressurized higher than the test pressure. The pressurization source to the reference volume is discon-nected, and the volumes are allowed to stabilize. The initial temperature and pressure of the reference vessel is recorded. The pressure in the test volume is maintained by the pressure regulator from the reference volume at all times during the test. At the completion of the test, the final temperature and pressure of the reference vessel is recorded. The recorded temperatures and pressures are used in the following equation to calculate the test volume leak rate:

where L = Leakage rate (SCFH)

P1 = Initial pressure in reference vessel (psia)

P2 = Final pressure in reference vessel (psia)

T1 = Initial temperature in reference vessel ( 0 R)

T2 = Final temperature in reference vessel ( 0 R)

V = Volume of reference vessel (ft3) t = Test duration (hrs)

T5 = Standard temperature, 527.69°R P5 = Standard pressure, 14.696 psia 10-8

NED0-31722 DRAFT

11.0 REFERENCES

1. NRC Memorandum, W.R. Butler and G. C. Lainas to K. V. Seyfrit, "Requirements for Type C testing after valve repairs", May 15, 1978.

2. Safety Evaluation by the Office of Nuclear Reactor Regulation Supporting Amendment No. 140TO, EI Hatch Unit 1 Docket No. 50-321.

3. Issuance of Exemption to a Provision of Appendix J and Amendment No. 41 to Facility Operating License No. NPF-21 WPPSS Nuclear Project No. 2 (TAC No. 60740).

4. NEDC-31643P, "Increasing Main Steam Isolation Valve Leakage Rate Limits and Elimination of Leakage Control Systems", L. S. Lee, November 1988.

5. Nuclear Regulatory Cormnission; Office of Inspection and Enforcement, Containment Integrated Leak Rate Tests, IE Information Notice, No. 85-71, August 1985.

6. Proposed revision to 10CFR50 Appendix J, as published in the Federal Register on October 29, 1986.

7. Nuclear Regulatory Commission, Office of Inspection and Enforcement, "Failures to Identify Containment Leakage Due to Inadequate Local Testing of BWR Vacuum Relief System Valves", IE Information Notice, No. 86-16, March 1986.

8. 10CFRSO Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors".

9. ANSI/ANS 56.8 - 1987, "Containment System Leakage Testing Requirements".

10. ANSI/ANS N45.4 - 1972, "Leakage Rate Testing of Containment Structures for Nuclear reactors", March 16, 1972.

11. TID-20583, "Leakage Characteristics of Steel Containment Vessels and the Analysis of Leakage Rate Determinations", USAEC, May 1964.

12. Draft Regulatory Guide, Task MS 021-5, "Containment Leakage Testing",

October 1986.

13. 10CFR50 Appendix A, "General Design Criteria for Nuclear Power Plants".

14. - "Alternative Method for Leakage Rate Testing", 53 Fed Reg 45890, Nov 15, 1988, Amendment to 10CFRSO Appendix J. "Primary Containment Leakage Testing for Water-Cooled Power Reactors".

15. ANS 3.2/ANSI 18.7 - 1976, "Administrative Controla and Quality Assurance for the Operational Phase of Nuclear Power Plants".

11-1

NED0-31722 DRAFT

16. BN-TOP-1, Revision 1, Testing Criteria for Integrated Leakage Rate Testing of Primary Containment Structures for Nuclear Power Plants, Bechtel Power Corporation, November 1, 1972.

17. Safety Guide 11, "Instrument Lines Penetrating Primary Reactor Gontainment", (Safety Guide 11), March 1971, and Supplement to Safety Guide 11, "Backfitting Considerations", January 1973.

18. Letter, R. C. DeYoung, Assistant Director for Pressurized Water Reactors, Directorate of Licensing, to R. D. Allen, Vice President, Bechtel Corporation, February 1, 1973, Evaluation of Bechtel Topical Report BN-TOP-1, Revision 1.

19. ASME Steam Tables, Fifth Edition.

20. Letter, J. A. Silady, Commonwealth Edison Company to Dr. T. E. Murley, NRC, "Reporting Practices for Local Leak Rate Testing, January 10, 1989.

21. Letter, D.R. Muller, NRC to T. J. Kovach, Commonwealth Edison Company, "Commonwealth Edison Company's Proposed Improvement in Reporting Practices for Local Leak Rate Testing", May 3, 1989.

11-2

NED0-31722 DRAFT BASES 84.0 OPERATING AND REPORTING REQUIREMENTS 84.i PHILOSOPHY OF TESTING This section provides the basis for the containment integrity testing philosophy presented in Section 4.1 which the authors of this document believe satisfies all regulatory requirements, minimizes testing of components which are not significant fission product release pathways, and emphasizes an aggressive maintenance program.

The stated purposes of 10CFRSO Appendix J are to assure that (1) "Leakage through the primary reactor containment and systems and components penetrat.ing primary containment shall not exceed allowable leakage rate values as speci-fied in the technical specifications or associated bases and (2) periodic sur-veillance of reactor containment penetrations and isolation valves is per-formed so that proper maintenance and repairs are made during the service life of the containment, and systems and components penetrating primary containment."

Containment integrity is defined as having a total leakage rate not to exceed 1.0 La. This will be demonstrated by:

1. Periodic Type A tests which verify overall structural integrity and demonstrate the leak tightness of not only the containment but also the Type Band C penetrations.

Type A Acceptance Criteria: <0.75 La (As Left) and <1.0 La (As Found)

2. Periodic Type B/C tests. A summation of Type Band C total leak rates will be maintained and corrected whenever a Type B/C test is performed to recalculate the Running Total Containment Leakage Rate (RTCLR).

Bases-1

NED0-31722 DRAFT Type B/C running totals will be maintained using the MNPLR calculational method, since this represents a realistic post-accident leak.age rate from containment. Whenever Type 8/C tests are performed during the operating cycle (i.e., between refueling outages), then each pathway's as-left leak.age rate shall be determined using both the HXPLR and MNPLR methods, and the RTCLR will be recalculated. The RTCLR is based on a summation of the last Type B/C test result for each Type B/C pathway.

The RTCLR demonstrates the leakage to not exceed 1.0 La based on minimum pathway calculations of Type Band C leakage rates at all times when contain-ment is required. The RTCLR need not be maintained when primary containment is not required. The Minimum Pathway Leakage Rate requirement most closely reflects the actual containment leak-tightness capability. The Type Band C MNPLR running total is modified by adding in the as-left HXPLR from the worst leaking penetration and subtracting the MNPLR of the same penetration. This modification to the MNPLR total is intended to account for the potential failure to close of the best valve in the worst penetration under design basis accident conditions (single failure criteria). Subtracting the MNPLR of the worst penetration prevents "double counting" the leakage of the better valve in the worst penetration. Since the Type B/C leakages are not used to modify previous Type A test results, a 0.25 La correction factor is added in to account for containment structural leakage, which is nominally zero, and any other leakage pathways which may not have been identified by the Type B/C test program. Such leakage is monitored during the periodic Type A tests.

Type B/C Acceptance Criteria:

Operational (RTCLR) 1.0 La ~ t (most recent type 8/C MNPLR test results)+ highest leakage pathway [MXPLR - MNPLR) +

0.25 La Startup from Refueling Outage Total Containment MXPLR < 0.6 La Bases-2

NED0-31722 DRAFT In a recent BWROG survey, it was determined that the average measured containment leakage rate was 0.34 La, based on the most recent Type A tests at 33 BWRs. Most of that leakage is believed to be through Type Band C leak pat~s. Another survey of 11 Type A tests with their corresponding Type Band C test programs demonstrated an average difference of 0.13 La between the two.

Thus, the selection of 0.25 La as a correction factor for structural leakage is appropriate and conservative.

Pathways which are found during operation to have excessive leakage shall be isolated in accordance with the plant Technical Specifications. This could be accomplished by closing a good valve(s) in the line to reduce that pathway's MNPLR. A pathway so isolated is considered a single valve pathway, and its MXPLR is the same as its MNPLR, which is the leakage through the isolated valve, since that valve is closed and has become a passive containment boundary. This minimizes any risk caused by a loss of isolation redundancy, until repairs can be made.

For example, consider the following situation. Assume the plant is oper-ating at full power and the Reactor Core Isolation Cooling (RCIC) inboard steam supply isolation valve fails in the open position. The Technical Speci-fications generally would require that the outboard valve be closed and deac-tivated and, subsequently, the RCIC system be declared inoperable and the appropriate action taken. In this scenario, the proper Tech. Spec. actions have been taken but an evaluation must still be performed to ensure that the overall containment leakage is less than La.

This evaluation entails making adjustments to the RTCLR. In the above example, the portion of the MNPLR runn'ing total attributed to the RCIC steam supply pathway would be subtracted from th~ running total. In its place, the las~ measured leakage of the outboard steam supply isolation valve would be added to the running total MNPLR. No adjustment to the MXPLR term of the operational limit equation is necessary, since the pen~tration in question has been sealed by a passive barrier and no longer has the potential to be the single failure following an accident.

Bases-3

NED0-31722 DRAFT The Type 8/C MXPLR startup limit of 0.6 La is required to be met prior to startup from a scheduled refueling outage. This limit is not required to be met at other times. These maximum pathway calculations have little safety significance, and are to be used as a maintenance indicator, to assure that component degradation is monitored and containment isolation components are maintained in good operating condition.

There are cases where the containment pathway configuration consists of a check valve inside containment and an automatic isolation valve outside con-tainment. Typically, this arrangement exists on ECCS injection pathways where credit is taken for the closed loop system piping as the second penetration barrier. If the outboard isolation valve were to fail open, then there is no previously leak rate tested valve which could be closed as required by the Technical Specifications. In such a situation, operating personnel may close the nearest valve to the inoperable valve and declare the affected system inoperable. The intact closed loop piping is considered adequate short-term

• protection against the potential release of fission products. If the above situation arises in a pathway for which no credit is taken for the system piping as a containment barrier, then the nearest valve to the inoperable valve must be closed and the primary containment considered inoperable.

The preceding criteria and philosophy conservatively demonstrate contain-ment integrity, while taking credit for realistic isolation capabilities.

B.4.2 REPORTING REQUIREMENTS Within 90 days following startup from a refueling outage, the "Reactor Containment Building Integrated Leakage Rate Test" report will be submitted to the NRC for review. The report will be generated in accordance with the Appendix of this report. The appendix provides detailed format and content requirements. There are substantial benefits to both utilities and NRC by having leak test reports uniformly written and all encompassing (i.e., not simply reporting failures). Over a relatively short time frame, a valuable leakage rate test {both LLRT and CILRT) database may be established. This may provide a basis for current regulations to be revised, eliminating unnecessary Bases-4

NED0-31722 DRAFT leakage rate testing and upgrading leakage rate testing requirements to better monitor maintenance activities and containment performance. Similar positions have been presented and subsequently accepted by NRC, as indicated in References 20 and 21.

The "Reactor Containment Building Integrated Leakage Rate Test" report will include all containment leak test information currently reportable as required by 10CFR50.73, 10CFR50 Appendix J, and ANSI/ANS N45.4. Potential future requirements of ANSI/ANS 56.8 are also included. The present reporting frequency, with the exception of LERs as defined in 10CFR50.73, is following each CILRT. Once a unit is shut down and primary containment is no longer required, then obviously only one LER would be generated if as-found leakage rate tests identified a failed primary containment. It should be recognized that this report does not eliminate LERs relating to leak tests conducted during times when primary containment is required to be operational, only those currently required due to LLRT and CILRT failures during refueling outages. Therefore, the reporting requirements as defined in this report effectively coincide with the intent of present reporting requirements, and thus an LER would be a duplication of effort.

B4.3 VALVES AND PENETRATIONS WITH SEPARATE LEAKAGE LIMITS Main steam line and feedwater line leakages are not included in current Type A (0.75 La) and Type B + C (0.6 La) leakage rate requirements for some plants. The BWR Owners' Group believes that separate limits for these lines should be established for all plants since leakage into these lines bypasses treatment equipment typically used to process containment leakage. Other BWROG Committees or plant-specific programs are underway to demonstrate this

• s part of their activities to increase allowable leakage rates in the main steam and feedwater lines.

Work has already been completed to justify increasing allowable MSIV leakage rates and eliminating the MSIV Leakage control Systems. The results of this study are presented in NEDC-31643-P (Reference 4). This study Bases-5

NED0-31722 DRAFT demonstrates that using the main steam lines and main condenser is an effec-tive method of reducing off-site doses due to MSIV leakage.

The analysis (from Reference 4) typically shows that increasing allowable MSIV leak.age rates up to 200 SCFH per steam line have an insignificant effect on control room and site boundary doses previously calculated for a postulated design basis LOCA. Furthermore, for some BWRs, the results show that MSIV leakage rates up to 500 SCFH per steam line would not exceed the regulatory dose limits. The actual MSIV leakage values that can be tolerated for any given site depend on plant-specific parameters.

Work has not yet been completed on a similar analysis for the feedwater lines, but the methodology and results are expected to be the same as that for the main steam lines.

This method of independently recalculating the radiological consequences from main steam and feedwater line leakages justifies excluding the main steam and feedwater lines from Appendix J Type A and Type C leakage limits. The actual leakage limits for individual plants will be evaluated and presented 1n plant specific submittals.

Several plants have performed main steamline leak.age calculations. For the Hope Creek Generating Station, at a HSIV leak.age rate of 200 scfh per steamline, the resulting Low Population Zone (LPZ) calculated doses from main steamline leakage are 0.07 rem whole body and 6.8 rem thyroid; these doses are 0.3% and 2.3% of the 10CFRl00 limits, respectively. When these values are added to the previously calculated doses (which includes dose contributions from the main steamline leakage at the* current maximum leakage rate permitted in the Technical Specifications), the tota~ thyroid dose is 14.5 rem (300 rem allowed). For the same 200 scfh per steamline leakage rate, the resulting control room doses are only 0.04 rem whole body and 0.4 rem thyroid, whereas the General Design Criteria (GDC -19) control room limits are 5 rem whole body and 30 rem thyroid. For Hatch 2, at a MSIV leakage rate of 100 scfh per steam line, the corresponding LPZ doses are 0.4 rem whole body and 4.8 rem thyroid, whereas the control room doses are 0.01 rem whole body and 0.001 rem thyroid.

Bases-6

NED0-31722 DRAFT Similarly for Fermi-2, at 100 scfh per steamline leakage rates, the calculated LPZ doses are 0.02 rem whole body and 0.003 rem thyroid, whereas the control room doses are 0.3 rem whole body and 0.04 rem thyroid.

• These calculations provide an acceptable basis for not including evaluated leakage paths in the Type A (0.75 La) and Type C (0.6 La) acceptance criteria.

Bases-7

NED0-31722 DRAFT B5.0 SYSTEM LEAKAGE RATE TESTING REQUIREMENTS B5.1 GENERAL This section provides the basis for system leakage rate testing require-ments as specified in Section 5.0.

85.2 TYPE BAND C APPLICABILITY The function of the primary containment isolation system is to limit the release of gaseous fission products from the primary containment during any postulated accident scenario. The system is designed to minimize the radio-logical consequences of the design basis accident for 30 days post-accident.

Thus, the Type Band C test program shall include only those pathways that could potentially provide a gaseous route for fission products to escape out-side the primary containment during the 30 days after an accident. 10CFR50, Appendix J states that only these particular pathways need to be included in the Type Band C test program. Pathways that are fluid sealed may not have to be included in the Type Band C test program (Sections 5.3 a~d 5.4).

B5.3 SEAL SYSTEMS Valves sealed with a fluid from a qualified seal system are excluded from Type Band C leakage rate testing because they do not present a post-accident fission product release pathway. Any leakage through such penetrations will be into the primary containment; thus, determination of the leakage charac-teristics of such penetrations from inside to outside does not provide mean-ingful input to an assessment of the leak tightness of the primary containment structure.

In order for a fluid supply to be considered a "seal system", it must be

.clearly demonstrated that there is a high probability that the fluid supply system will remain intact for at least 30 days following any design basis event (e.g., LOCA, earthquake, fire, etc.).

Bases-8

NED0-31722 DRAFT A qualified seal system can result from an active system design or be the result of analysis of passive system features.

85.4 WATER-FILLED SYSTEMS Valves in lines which terminate below the minimum suppression pool water level are sealed by the suppression pool and do not require leak testing on the basis that the suppression pool will remain water filled post-accident; therefore, an atmospheric leak path is not possible. Note, however, that in some plants the HPCI exhaust line is below suppression chamber water level but cannot be assumed to be water sealed. This is because of the vacuum breaker line which taps into the exhaust line and terminates into the suppression chamber airspace.

B5.5 EXTENSIONS OF CONTAINMENT BOUNDARIES/CLOSED LOOPS OUTSIDE CONTAINMENT The terms "extensions of containment boundaries" and "closed loops out-side containment" are used interchangeably in the industry and both will be covered by the latter term in this discussion. A closed system outside con-tainment is defined as one that:

(1) Penetrates the primary containment.

(2) Does not communicate with the outside atmosphere.

(3) Meets (as a minimum) Safety Class 2 design requirements.

(4) Can withstand a temperature and pressure equal to containment design conditions.

(5) Can withstand a LOCA transient environment.

(6) Meets Seismic Category 1 design requirements.

(7) Is protected against overpressure.

Bases-9

NE00-31722 DRAFT (8) Is protected against a high energy line break outside containment when this system is needed for containment isolation.

Any leakage through isolation valves in closed loops outside containment will be into closed systems designed to remain operable and to handle contam-inated fluids after an accident. The leak-tight integrity of these closed systems is assured by the leakage reduction and maintenance programs developed in response to NUREG-0737, Item III.0.1.1.

Valves in branch lines communicating with closed systems outside contain-ment are passive components and are not assumed to fail. Furthermore, exter-nal leakage would be identified via system walkdowns during system in-service/

functional inspection in accordance with NUREG-0737.

B5.6 TEST CONNECTIONS, VENTS, AND DRAINS Due to their infrequent use, small size, and multiple passive barriers, test connections, vents, and drains do not require leakage rate testing. The barrier configurations are taken from ANSI-56.8.

Past experience has shown that valves of <l in. size typically used in these applications do not exhibit significant leakage (i.e., leakage to the extent that CILRT or LLRT results are not impacted). Furthermore, these valves are typically challenged during the CILRT.

B5.7 INSTRUMENT LINES Instrument lines which penetrate the primary containment have containment isolation provisions as described in the FSAR and Safety Guide 11 (Regulatory Guide 1.11). Isolation provisions for instrument penetrations are considered acceptable if they meet the following criteria:

The line 1s sized or orificed such that in the event of pipe rupture:

(1) The leakage 1s reduced to the maximum extent practicable.

Bases-10

NED0-31722 (2)

DRAFT The rate and extent of coolant loss are within the capability of the reactor coolant makeup system.

(3) The integrity and performance of the secondary containment and associated safety systems will be maintained.

(4) The potential off-site exposure will be substantially below the limits contained in 10CFRlOO.

Instrument lines provide channels for the transfer of information about conditions inside the containment. They are typically equipped with check valves or orifices which automatically limit excessive flow through the line.

The operability of excess flow check valves are verified once per cycle and are not required to be leak rate tested under 10CFR50 Appendix J.

The instrument system outside the containment, including sensing lines, instruments, and instrument racks, is essentially leak-tight and is designed to withstand design basis seismic events. Therefore, this section of piping would be expected to remain intact and would constitute an additional barrier outside of the containment isolation valves to the release of radioactive materials in the event of a Design Basic Accident.

Manually operated valves are not routinely tested because they are not normally closed in the event of a primary containment isolation, nor should they be. They are not relied upon to limit the consequences of an accident, and there is no basis for them to be periodically tested.

Administrative control of the local instrument valves makes it highly unlikely that these valves would be mispositioned at the onset of an acci-dent. Therefore, the "minimum path" leakage rate of instrument penetrations is assumed to be zero for 10CFR50 Appendix J purposes.

Bases-11

NED0-31722 DRAFT Instrument maintenance, isolation, or replacement can be performed with-out performing leak rate tests, since this work is performed outside of the containment pressure boundary (excess flow check valve).

Some instrument lines, such as containment atmospheric monitoring lines, are not designed to Regulatory Guide 1.11. These lines are, however, considered to be extensions of primary containment.

Isolation valves on instrument lines which are normally closed during power operation but open during the CILRT cannot be exempt from Type C testing. These pathways must be Type C tested and the test results used 1n the adjustment of the CILRT results.

Installation of new instrument penetrations generally results in modifi-cations to the primary containment pressure boundary which can only be tested by a Type A containment Integrated Leak Rate Test. If the penetration is one inch diameter or smaller, the leakage test required by 10CFRS0 Appendix J can be deferred until the next scheduled Type A test under the provisions of ASME Code Case N-236-1, "Repair and Replacement of Class MC VesselsSection XI, Division 111 (endorsed by the NRC in Regulatory Guide 1.147).

85.8 HYDRAULIC LINES TO FCVs (BWR/5 ONLY)

The Recirculation Flow Control Valve Hydraulic Control lines inside the containment are Seismic Category I and Quality Group B. Each line is provided with two fail-closed solenoid-operated isolation valves, which automatically close upon receipt of an isolation signal. The isolation valves are located outside containment, which provides more favorable environmental conditions, ease of maintenance, and provision for ma~ual override operation, if required.

Integrity of the system inside the primary containment is, essentially, continually monitored, since the system is under a constant operating pressure of approximately 1800 psig. Any leakage through this system would be noticed because of erratic operation and because of alarms for abnormal operation provided on the hydraulic control unit.

Bases-12

NED0-31722 DRAFT In order to perform Type C tests on these lines, the system would have to be disabled and drained of the hydraulic fluid. This is considered to be detrimental to the proper operation of the system in that possible damage could occur in establishing the test condition or restoring the system to normal.

For these reasons, the lines and associated isolation valves are con-sidered to be exempt from Type C testing.

B5.9 CONTROL ROD DRIVE HYDRAULIC LINES Control rod drive hydraulic lines have no automatic isolation valves, are not considered as extensions of the reactor coolant pressure boundary, and are assigned quality group D standards as permitted by Regulatory Guide 1.26.

Since the CRD insert-and-withdraw lines are small in diameter and perform safety-related functions, automatic isolation valves are not provided. The CRD lines will be included in the Type A test leakage, since the reactor pres-sure vessel is vented during the performance of the Type A test. This posi-tion has been previously reviewed and accepted by the NRC in NUREG-O803.

B5.10 CONTAINMENT WELD LEAKAGE TEST CHANNELS Leak chase channels are channels which are fillet welded over a number of primary containment liner seam welds for leak testing the seam welds during construction. The channel creates a volume which is pressurized to the design pressure during construction to demonstrate leak tightness of the liner seam welds. Following each test, a plug may be installed in the test tap to seal this volume. These plugs may be left in place if the leak chase system (channels and plugs) can classify as the primary containment boundary by meeting the applicable code and quality requirements for a containment liner.

The existence of the plugs will require that administrative controls be developed. These controls must ensure that the containment boundary, which includes the aforementioned plugs, will not be altered (i.e., the installation or removal of any plugs) unless some means of leak rate testing can be Bases-13

NE00-31722 DRAFT conducted. 10CFR50, Appendix J, Paragraph IV.A requires that any alteration to the primary containment boundary must be followed by either a Type A, Type B or Type C test.

Bases-14

NED0-31722 86.0 DRAFT CALCULATION OF COMBINED LEAKAGE RATES 86.1 PENETRATION MAXIMUM PATHWAY LEAKAGE RATE The calculation of a pathway's maximum pathway leakage rate (MXPLR) assumes the failure of the one active component in the pathway which yields the highest pathway leakage rate.

As discussed in NRC Information Notice 85-71, the MXPLR is the greater

- leakage of the redundant valves in a pathway. When each valve is tested independently, the MXPLR is obviously the greater of the measured leakage rates. When two valves are tested together by pressurizing between them, the measured leakage is the MXPLR. This conservatively assumes that all leakage is through one valve.

The MXPLR of a single valve pathway is the measured leakage of the single valve. Since there is only one valve, the MXPLR and MNPLR are the same. For series multi-valve (more than two valves) penetrations where each valve is tested independently, the single active failure is applied to the best (lowest leakage) valve. Thus, the MXPLR is the leakage of the better (or best) of the

- remaining valves. For multiple parallel valve pathways, the worst single active failure is the failure of any valve on the better set of barriers either inboard or outboard. Thus, the MXPLR is the sum of the leakages of the greater leakage group (inboard or outboard) of the valves. This may be applied if individual valve leakages are known. If the combination of valves is tested by pressurizing between the inboard and outboard set, then it must be conservatively assumed that all leakage is through one set (inboard or outboard) of valves. Thus, the MXPLR becomes the measured leakage rate.

Valves and other leakage barriers have critical components which may degrade over time. Leakage testing verifies the performance and condition of these components. The established surveillance intervals are consistent with generally confirmed leakage rate characteristics of these components. The length of the surveillance interval provides confidence that degradation of Bases-15

NE00-31722 these components will not affect the performance of their safety function.

When this surveillance interval has expired, it is conservatively assumed that

• the valve or barrier has failed. Since a new leakage value (>0.6 La) has been assumed for that valve or barrier, the MXPLR for that pathway must be recalculated, using the last assigned leakage rate for the remaining valves or barriers. The MXPLR must be recalculated for any pathway with an expired surveillance of one barrier (valve).

86.2 PENETRATION MINIMUM PATH LEAKAGE RATE Under post-accident conditions, any leakage out of containment through a -

dual valve isolation system would have to pass through both closed isolation valves. The minimum pathway method is overly conservative because it fails to account for the restriction from the worst leaker of the two valves. It should be noted that the order of magnitude of allowable leakage is such that the total restriction from the valves' associated piping system is usually negligible compared to the restriction from the test valve.

Pressurizing from containment through two closed valves in series is the actual condition the system would be subjected to during a Type A test. Test-ing the valves in series is therefore a physically realistic method of measur-ing system leakage. This eliminates the overconservatism from ignoring the worst leaker of the two valves. This method is not suitable, however, for determining the MXPLR without performing additional tests.

There are many cases where it is not physically possible or practical to test both valves in series from containment. A conservative analytical method of calculating the total system through leakage from measured individual valve leakages is described below.

Bases-16

NED0-31722 DRAFT Leakage through the valves is assumed to be both turbulent and incom-pressible. The relationships between measured leakages and imposed pressure differentials for each valve are:

In this analysis, let Q2 be the smaller of the two leakages. For turbulent flow, C1 and C2 are nearly constant over a wide range of flow rates, (or range of Reynolds numbers). Actual flow (Qa) leaving containment under post-accident conditions undergoes a pressure drop as it crosses valve #1 (AP1) and valve #2 (AP2). The following equations can be written:

(3)

(4)

Since APa must equal AP1 + AP2, from Equations 3 and 4:

AP Q2 1 + l )

a a ( c~ c~

By substituting Equations (1) and (2) into the above expression:

AP Q2 a l

AP AP

a

_..! + a L+ 1 Q2 Q2 Q2 Q2 l 2 l 2 or equivalently (5)

Bases-17

NED0-31722 DRAFT When Q2 approaches m, application of L' Hospital's rule to Equation (5) above indicates that Qa becomes equal to Q1. When valve #2 leaks badly, the Minimum Path method of Section 6.2 is physically realistic and yields leakages equivalent to those given by Equation (5). The other extreme corresponds to the case when valve #2 is as good as valve #1. When Q1 = Q2, then Qa = 0.707 Q1. Thus, it is seen that a maximum of almost 30% conservatism can result from using the Minimum Path method.

Flow through the valves was assumed to be turbulent. There is no way to tell from the leak test results if the flow was, in fact, laminar. For laminar flow, Equations (1) and (2) would be replaced by the following expressions:

(6)

(7)

By performing an analysis similar to that done for turbulent flow, the following equation 1s derived in place of Equation (5):

(8)

Again, let Q1 be the smaller of the two leakages. When Q2 approaches m, application of L' Hospital's rule to Equation (8) indicates that Qa becomes equal to Q1. When Q1 equals Q2, then Qa = 1/2 Q1. This shows up to a 50%

reduction is possible for laminar flow, while only a 30% reduction is possible for turbulent flow. To ensure conservative results, leakage is always assumed to be turbulent.

- Flow was also assumed to be incompressible. This is not a realistic assumption, since air flowing through the valves undergoes approximately a 77%

Bases-18

NE00-31722 DRAFT pressure drop. The proper expressions for a compressible flow should include the expansion factors Y1 and Y2 as shown below.

(9)

{10)

Y is always less than 1.0. By conservatively assuming incompressible flow and setting Y equal to 1.0, Equations (9) and {10) reduce to Equations

- (1) and (2) from which Equation (5) was derived.

For MNPLR when testing by pressurizing between two valves or parallel multi-valves, it is conservative to assume one half the measured leakage.

Actual MNPLR is the lesser of the leakages through the two valves or sets of valves. The worst case is if the measured leakage is equally divided between the inboard and outboard valves or sets of valves. Any other distribution will result in a lower actual MNPLR and, thus, the equal distribution assumption is conservative.

For purposes of as-found MNPLR, if one of the two valves is repaired, it is conservative to assume that all leakage was through the unrepaired valve (i.e., "perfect" repair). This is useful during a Type A outage when as-found and as-left MNPLRs may need to be determined. For example, occasionally a high Type C test leakage is measured by pressurizing between large vent and purge butterfly valves. One half of this measured leakage may result in a high as-found MNPLR. The worst leaking valve can then be determined or guessed, repaired, and a retest performed. The retest leakage may be assumed to be going through the unrepaired valve, and, hopefully, this would be less than one-half of the pre-repair test leakage and could be considered the as-found MNPLR.

For the single valve penetration, MNPLR = MXPLR = measured leakage rate.

Bases-19

NE00-31722 DRAFT For multi-valve series penetrations with each valve tested independently, the MNPLR is the lowest of the measured leakage rates.

Valves and other leakage barriers have critical components which may degrade over time. Leakage testing verifies the performance and condition of these components. The established surveillance intervals are consistent with generally confirmed leakage rate characteristics of these components. The length of the surveillance interval provides confidence that degradation of these components will not affect the performance of their safety function.

When this surveillance interval has expired, it is conservatively assumed that the valve or barrier has failed. Since a new leakage value (>0.6 La) has been assumed for that valve or barrier, the MNPLR for that pathway must be recalculated, using the last assigned leakage rate for the remaining valves or barriers. Therefore, the HNPLR must be recalculated for any pathway with an expired surveillance of one barrier (valve).

B6.3 TOTAL CONTAINMENT MAXIMUM PATHWAY LEAKAGE RATE The total containment MXPLR is equal to the sum of the ¥'<PLRs from each containment penetration. This is the intent of 10CFR50 Appendix J and is discussed in NRC Information Notice 85-71.

B6.4 RUNNING TOTAL CONTAINMENT LEAKAGE RATE (RTCLR)

See Bases 4.1.

Bases-20

NED0-31722 87.0 DRAFT TESTING REQUIREMENTS B.7.1.1 Containment Isolation Valve Closure Closure of Containment Isolation Valves for Type A, Band C tests is to be accomplished by normal means without preliminary exercising or adjustment (e.g., no manual tightening of MOVs after closure by valve motor). This is to ensure that leak testing of each penetration is representative of post-accident conditions. This is consistent with the requirements of 10CFR50 Appendix J.

B.7.2.1 Type A Test Intervals 10CFR50 Appendix J currently requires that a set of three Type A tests shall be performed at approximately equal intervals during each 10-year service period. The third test of each set is required by 10CFR50 Appendix J to be conducted when the plant is shutdown for the 10-year plant in-service inspection.

The proposed revision to 10CFR50 Appendix J, published in the Federal Register on October 29, 1986, decouples the Type A test frequency from the year IS! interval of ASHE Section XI code. Additionally, the proposed revision allows the interval between Type A tests to be a period not exceeding four years.

The 48-month Type A test interval allows plants on 24-month fuel cycles to test every other refueling outage, such that an early shutdown is not required solely to meet the Type A test interval time limit. The 48-month interval is within the 40 + 10-month 1ntervals which are typically in many Plant Technical Specifications. Since the tests are decoupled from the 3-tests-in-10-years requirement, there is no minimum interval; the next interval begins when the current Type A test 1s completed.

Extensions of the 48-month interval are allowed if the interval ends while primary containment is not required, or if primary containment is Bases-21

NED0-31722 DRAFT BWR Hark III containment designs, without jeopardizing the health and safety of the public because, in the practical sense, containment barriers do not instantly degrade due to an expired interval. Due to long unscheduled outages or other unforeseen conditions, if a plant requires additional time over the 24 or 48 month surveillance interval to reach a convenient point to shut down for *the Type A test, a 25% grace period is allowed. This is consistent with Plant Technical Specifications, where a 25% grace period is allowed for most surveillance intervals. The 3.25 limit prevents abuse of the 25% grace period. The time clock for the 3.25 limit (for three consecutive surveillance intervals) resets to zero when two consecutive as-found accelerated Type A tests meet the <1.0 La acceptance criteria and the regular test intervals are resumed.

The accelerated Type A test intervals are to be used when required by Section 7.2.1 unless an acceptable corrective action plan is developed (Section 7.5).

These intervals are measured only by calendar time. Unit operability does not enter into these intervals except that, if the calendar interval expires during a time when primary containment integrity is not required, the Type A test may be deferred until such time as primary containment integrity is required.

87.2.2 Type A Test Duration and Choice of Methodology The Total Time Method for 24-hour testing is listed as being acceptable in Reference 10. The point-to-point method, also allowed by Reference 10, is not recommended because experience has- shown that consistent results are more difficult to achieve with this method than with the total time method.

The Mass Point Method for 24-hour testing is listed as being acceptable to the HRC in Reference 14.

Both the Total Time and the Mass Point Methods have a long and documented history of acceptable usage in the nuclear industry in 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Type A Leakage Bases-22

NE00-31722 DRAFT Rate Testing. Experience has shown, however, that 8-hour mass point tests yield acceptably accurate test results, while significantly reducing test time. The 8-hour test is endorsed by Reference 9.

The BN-TOP-1 Method for a CILRT is listed as being acceptable to the NRC in Reference 18. A minimum Type A test duration of six hours is specified for the BN-TOP-1 method.

Our experience with running parallel calculations with Mass Point and Total Time methodologies indicates that conservative, reliable Type A test results can be obtained in six (6) hours. The reported Type A leakage rate is reported at the upper confidence level (UCL). This UCL leakage rate is the measured leakage rate plus a statistical uncertainty factor. The statistical uncertainty factor is a function of the number of data points and the amount of data scatter. Assuming a constant degree of data scatter, a longer Type A test will result in a lower reported leakage rate at the 95% UCL. Thus, a reduced duration Type A test (six hours) yields conservative results.

B7.2.3 Type A Test As-Found Requirements The ultimate purpose of determining the as-found LSLR is to verify the adequacy of the maintenance performed since the last CILRT. Type A test results will be adjusted in accordance with the direction provided by the NRC in Information Notice 85-71, since this is an acceptable method of determining the as-found Type A LSLR.

The adjustment to Type A test results to derive the as-found Type A leakage rate consists of summing the differences between the as-found MNPLR and the as-left MNPLR for each pathway. This summation is in turn added to the_Type A LSLR. Under most circumstances, the difference between as-left and as-found leak rates is a positive value. This is due to R/As associated with correcting high as-found leakage rates. However, in certain instances, this difference may be a negative number, i.e., the as-left leakage is greater than the as-found leakage. Common examples are where valve motor-operator work is performed resulting in a decrease in torque switch setting, or stem packing is Bases-23

NED0-31722 DRAFT relaxed to meet stroke time requirements. As-left leakage rates may still be at an acceptable level while being greater than the as-found measured value.

It is justified in such cases to use the negative value obtained from the difference between as-found and as-left MNPLR in deriving the as-found Type A leakage rate.

If, during the performance of the Type A test, a leak were detected through a locally testable penetration, acceptable options must be made available to the Utility to satisfactorily complete the test. These options are dependent upon whether the Type A test is being performed at the start or end of the outage. ANSI/ANS 56.8 provides the bases for some of the guidance given in this report.

The option of stopping the test, quantifying the leak, repairing the leak and restarting the test is standard industry practice. For Type A tests that are performed at the start of the outage, corrections must be made to accu-rately determine the as-found Type A test result. Otherwise, the true as-found leakage from a penetration that was repaired would be masked. This adjustment to the as-found Type A test result is an accepted industry practice when Utilities perform Type A tests at the start of an outage. For Type A tests that are performed at the end of the outage, an as-found value for the locally testable penetration would have already been determined prior to the start of the test thereby precluding the need to make any corrections to the Type A test results.

The option of stopping the test, isolating the leak and restarting the test is standard industry practice as long as the leakage through all isolated locally testable penetrations is accounted for in the Type A test results.

If, during the performance of the Type A test, excessive leakage occurs through locally testable penetrations or isolation valves to the extent that it would interfere with the satisfactory completion of the test, these leakage paths may be isolated and the Type A test continued until completion. It further states that a local leakage test shall be performed before and after the repair of each isolated leakage path. The as-left minimum path leakage rate would then be added to the Type A test results.

Bases-24

NED0-31722 DRAFT The purpose of allowing the isolation of a detected leak is to allow completion of the Type A test irrespective of whether the test will later be determined to be a failure or acceptable. The test results will then be corrected to determine the as-found test results per Section 7.2.3.

87.2.4 Type A Test As-Left Requirements The purpose of measuring the primary containment integrated leakage rate 1s to ensure that, during operation, there is sufficient margin established so

- that primary containment will be maintained. The only way to do this is to leak test the entire containment; therefore, any systems not challenged during the Type A test must be Type B or C tested. The measured leakage rates of these Type B or C tests are then used to adjust the Type A LSLR at the appropriate UCL. This adjustment is consistent with 10CFR50 Appendix Jin that 10CFR50 Appendix J allows systems to be 1n operation during the CILRT.

Using the Type A LSLR at the appropriate UCL is conservative, since 10CFR50 Appendix J does not require addition of any uncertainty factor.

87.2.5 Data Acquisition Data set collection at uniform intervals is currently an accepted standard practice, and it is required by Section 7.8 of ANSI N45.4. This practice allows for later direct verification of any data sets which may have been locked out.

Typically, the verification test is of much shorter duration than the Type A test. It may be desirable to decrease the interval between data set collections during the verification test in order to obtain enough data sets to perform a statistically meaningful least squares analysis.

The maximum allowable interval between data sets is one hour. This is an ANSI N45.4 requirement. Imposing this maximum interval ensures that a sufficient number of data sets shall be collected to allow the rate of change of dry air mass in the containment to be properly trended.

Bases-25

NED0-31722 DRAFT B7.2.6 Data Rejection Type A test data can be rejected on solid technical grounds in order to more closely reflect the test conditions inside primary containment. The calculation of a true primary containment leakage rate value requires that meaningful test data be used. Test data that is inconsistent should be carefully analyzed to assure that erroneous data will not skew test results.

Failures in computer equipment, the data acquisition system, or any data transmission path have in the past caused the unexpected loss of data sets. -

The locking out of individual data sets is not desirable, but it does not have enough of a negative effect to justify a test restart. Parametric studies on existing CILRT data shows that scattered data set lockouts have little effect upon either the LSLR or its UCL.

B7.2.7 Recording of Data Sufficient and timely data must be recorded to ensure that the conditions inside and outside the primary containment are being accurattly modeled and to support the calculational methods used in determining the Type A test LSLR.

B7.2.8 Test Pressure Tests performed at a pressure within 4% of Pa will yield results representative of those which would be expected at a pressure of Pa.

B7.2.9 Venting and Draining Consistent with current regulations, *venting and draining must be per(ormed to ensure that the primary containment isolation barriers are tested at a differential pressure equivalent to post-accident conditions.

Bases-26

NED0-31722 DRAFT 87.2.10 Test Start Times The official test start time must be declared at the current-time or some future time to avoid the arbitrary selection of an official test start time fro~ the past. This regulation would disallow Utilities from attempting to manipulate the official start times in order to yield more favorable test results.

B7.2.11 Liquid Level Monitoring During performance of the CILRT, the level(s) of water contained_ in a vessel inside of the pressurized volume may change. In some cases, this change may be great enough to have a significant effect upon the calculation of dry air mass.

In a case where water vapor condensing or evaporating from the air is the cause of any level changes, the change in total containment air pressure resulting from the change in containment free air volume is negligible compared to the change in pressure resulting from the difference in vapor pressure. This is not a significant cause of free volume changes.

B7.2.12 Continuous Leakage Monitoring Systems Continuous leakage monitoring systems have the potential to leak into the containment during a Type A test, if the pressure of the continuous monitoring system is greater than the Type A test pressure. Depressurizing the continu-ous monitoring system assures that all leakage through affected penetrations will be out of containment. This position is consistent with Reference 6.

87.2.13 Containment Modifications Visual and/or non-destructive examinations may be.performed when local leakage rate testing of certain minor modifications is not possible. Type A testing at the next regularly scheduled Type A test is required. This allows Bases-27

NED0-31722 DRAFT operational flexibility while still verifying containment integrity. This position is consistent with Reference 6.

87.3.1 Type Band C Test Intervals 10CFRSO Appendix J states that Type Band C tests shall be performed during reactor shutdown for refueling, or other convenient intervals, but in no case at intervals greater than two years. With longer fuel cycles and outages, no refueling outage or "convenient interval" may be available during the surveillance interval, and an early shutdown to perform Appendix J testing -

may be required. This is clearly not the intent of Appendix J. Utilities need operational flexibility in this regard. The variability of the refueling schedule must be considered. Therefore, a six-month (25%) grace period, similar to that allowed in Plant Technical Specifications, is necessary.

The many extensions requested by the Utilities, and granted by the NRC, give testament to both the Utility need and NRC acceptance of the intent of 10CFRSO Appendix J to perform Type Band C tests during normal periods of shutdown, and not to require a shutdown solely for local leak rate testing.

One plant has received a permanent three-month extension to the 24-month Type Band C test interval (Reference 3). Continuing the present policy of individual NRC reviews of plant-specific extension requests is not manpower effective for the Utilities or the NRC.

A 25% grace period is allowed for most surveillance intervals specified 1n existing Technical Specifications. Applying this philosophy to Appendix J testing would be an interpretation change only.

The original 24-month Type B/C survei~lance period was apparently not based on an engineering evaluation of component design lifetimes or main-tenance histories. There is no evidence to indicate that containment isolation components lose their isolation capability when the surveillance period expires.

Bases-28

NED0-31722 DRAFT If a continuous leakage monitoring system is employed, 10CFR50 Appendix J allows the interval between Type 8 tests to be three years. The extension of this three-year interval to Type C components should be allowed as an administrative change, since the acceptance criteria and the intervals between tests are the same in Appendix J for Type Band C tests.

87.3.2 Type 8/C As-Found Testing As stated in 10CFR50 Appendix J, "The purposes of the tests are to assure that (a) leakage through the primary reactor containment and systems and com-ponents penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases, and (b) periodic surveillance of reactor containment penetrations and isola-tion valves is performed so that proper maintenance and repairs are made dur-ing the service life of the containment, and systems and components penetrat-ing primary containment".

10CFR50 Appendix J requires that the primary containment be subjected to a Type A test in as close to the "as is" condition as practicable. Informa-tion Notice 85-71, issued August 22, 1985, provided two acceptable methods for complying with the 10CFR50 Appendix J requirement. Simply paraphrased, Information Notice 85-71 suggests doing the Type A test at the "front end of an outage or do the CILRT at the "tail end" of an outage and compensate for repairs made to Type 8/C components during the outage by correcting for their "as found" leakage in the CILRT results.

Since the issuance of Information Notice 85-71, the NRC, through the Regional inspection program, has imposed as-found testing of Type 8/C components as a regulatory requirement ap~licable to all Type 8/C tests, not jus~ those associated with a CILRT. Some individuals in the NRC have argued that as-found testing is not a 10CFR50 Appendix J requirement, but rather an ANSI 18.7 requirement in that the ANSI standard requires that surveillance testing be performed on components "as is".

Bases-29

NED0-31722 DRAFT The BWROG agrees that 10CFRSO Appendix J testing is a periodic surveil-lance and that components should be tested in the as-found or as is condi-tion within the bounds of practicality and professional engineering judgment (i.~., components should not be repaired intentionally for the purpose of imp!oving the leakage rate prior to testing). This position has been adopted because of the value of as-found testing as a maintenance/design/operation performance indicator. By maintaining and analyzing as-found Type B/C test data collected in conjunction with periodic surveillance testing, Utilities are able to focus attention on historically poor performing components and develop and implement corrective action to minimize recurring problems.

Furthermore, there are components which might be never recognized as a problem area unless as-found testing is performed. For example, a licensee recently identified through as-found testing that the wrong material had been ordered and installed for the drywell head seal. Had the licensee not per-formed a test of the head seal prior to removing the drywell head, the same, incorrect seal material would have been installed when the drywell head was reinstalled.

The BWROG does not believe that there 1s any current, regulatory require-ment to perform as-found testing of Type Band C components during either Type -

A or non-Type A outages. As-found testing of every component, every outage, is not required if there is no reason to expect unacceptable leakage (i.e.,

there have been no operational problems with the component in question), and the component has a documented history of acceptable low leakage performance.

Experience has shown that Type B/C test components typically exhibit one of two leakage patterns over time. First, the majority of components display stable, predictable leakages test after test. Second, some components exhibit erratic, unpredictable leakages from test to test. Typically, for components in the first category, only one test is performed which is considered to be both the as-found and as-left test. For components in the second category, typically an as-found test 1s performed, the component .is repaired, and an '

as-left test 1s performed. Normally, two consecutive successful as-found test results are not obtained. If corrective measures are successful in obtaining two consecutive successful as-found tests, then it is reasonable to assume Bases-30

NED0-31722 DRAFT that the component has moved into the category of components with stable, predictable leakages.

- If a Type B or C component requires repair during reactor operation or at any time other than in conjunction with a scheduled LLRT or CILRT surveil-lance, as-found testing is not required. This is consistent with the general philosophy of surveillance testing. For example, suppose that during normal operation the HPCI turbine governor control cable is found to be disconnected.

In this case, a surveillance test would not be performed to prove that the HPCI system would not have worked. Rather, the system would be declared inoperable, the cable would be repaired and then the surveillance test would be performed to prove operability.

Applying this philosophy to CIVs yields the following scenario. If plant conditions indicate excessive leakage in a CIV, then that component should be declared inoperable, repaired and then leak tested.

In either the case of HPCI or any CIV, if the required surveillance test is due, then work should not be performed prior to conducting the test. The purpose of the test is to determine if repair work is necessary.

87.3.3 As-Left Testing As-left LLRTs are performed following repairs or adjustments on Type B and C components if the primary containment isolation capability (leakage only) may have been affected. This document complies with this requirement; however, clarification is included for. systems which are in service that have been or are suspected of excessive leakage. 10CFR50 Appendix J addresses Type Band C tests of containment boundaries during refueling outages. It does not specifically define requirements for systems in service during operation. In this case a conservative approach shall be taken. Either the component(s) will be Type B or C tested, or a conservative functional test shall be performed to ensure leak-tight integrity. This as a minimum meets the intent of 10CFRSO Appendix J.

Bases-31

NED0-31722 DRAFT 87.3.4 Alternative Type 8/C Testing In-service functional testing 1s an effective method of dete~mining if rep~irs or adjustments to a component have affected its leak-tightness capa-bilities. One such functional testing method is discussed here.

Visual Testing In cases where the performance of a Type 8 or C test is not practical, a visual examination for external leakage on any component that underwent R/As may provide adequate qualitative evidence that the component is leak tight.

Reference 10, Section 4.5, supports this position. This sort of in-service visual inspection is particularly useful when inspecting stem packing. The system must be conservatively pressurized to challenge the questionable component at a pressure differential of at least Pa. Any leakage past that component must be observable.

Since it is not possible to quantify a leakage rate by visual inspection, the acceptance criteria must be no observed leakage.

87.3.5 Type Band C Test Pressure A test pressure of Pa is required by 10CFR50 Appendix J for Type Band C tests. However, individual plants' Technical Specifications may have special test requirements such as testing HSIVs at 25 psig or testing air locks at reduced pressure.

When system pressure on the low pressure side of the leakage barrier cannot be reduced to atmospheric pressure,. then the test pressure must be raised to ensure the leakage rate measured is for a differential pressure of at least Pa.

The only consideration for maximum test pressure 1s the design pressure of the components involved and the potential for inducement of nonconservative results.

Bases-32

NED0-31722 DRAFT 87.3.6 Venting and Draining The proper draining of the test volume and the down*stream side of a Con~ainment Isolation Valve is critical in the determination of the actual CIV leakage. If the system is not properly vented and drained, a seal may form and a false leakage rate may be obtained. Also, a proper vent path must be maintained so that the post-accident differential pressure exists across the CIV being tested.

A water column does not have to be drained if it can be demonstrated that the water will be present during post-accident conditions. This is required to demonstrate that system integrity is maintained and the water column will not be lost.

B7.3.7 Reverse Flow Testing The leakage rate testing of a CIV is always done in the accident direc-tion except when a system is designed so that such testing is physically impossible. All reverse flow tests must be demonstrated to yield equivalent or conservative results, as compared to accident direction testing.

In many cases, because of a valve's design, the packing and bonnet are relied upon to perform a containment isolation function. Because reverse flow testing may not subject these boundaries to the test pressure, alternative methods must be used to test such boundaries. Examples of such testing are CILRTs and functional tests which are coupled with a visual inspection.

87.4 CONTAINMENT AIR LOCKS

- This section requires that a complete airlock test at Pa be performed during each refueling outage, and whenever maintenance involving the airlock's pressure retaining boundary is performed. Full barrel .testing due to maintenance on airlock seals is not required if they are locally leak testable.

8ases-33

NED0-31722 DRAFT Past experience has shown that the overwhelming majority of airlock leaks are from the shaft seals or equalization valves. Except for structural leaks, the shaft seals, equalization valves and door seals are the only possible leak.age paths for most types of airlocks. By performing full pressure local leak tests on those three locations, the total leakage out of the airlock can be determined. Total leakage measured in this manner will probably be more accurate than that measured from the complete airlock test. This is because the shaft seals are locally leak tested by pressurizing the volume between the inner and outer seals on both doors. This results in at least one of the seals on each door being pressurized in the proper direction (from containment toward the outside). When a full airlock test is performed, only the seals on the outer door are tested in the proper direction; both seals on the inner door are tested in the wrong direction. Shaft seals have been shown to be particularly directional sensitive. In many past instances, airlocks have passed the full airlock test while failing the subsequent Type A test due to leaking inner door shaft seals. It is for these reasons that tests of the door seals, equalization valves, and shaft seals are substituted for the six month barrel test at Pa*

This change would increase safety by enabling the licensee to obtain more accurate airlock leakage rates while minimizing testing time. Also, eliminating full airlock testing during plant operation would eliminate the risk of pressurizing the inner door off its hinges due to improper or lack of strong-back placement.

87.5 CORRECTIVE ACTION PLANS 10CFR50 Appendix J requires a unit that fails two consecutive Type A tests be placed on an accelerated testing schedule. The unit would remain on that schedule until it passes two consecutive tests. While on an accelerated schedule, a CILRT must be performed every 24 months. This requirement could result in the performance of up to three additional CILRTs in a 12-year period.

The average costs incurred during a CILRT, based upon most of the tests examined here, are summarized in Table 1. Assuming a replacement power cost Bases-34

NED0-31722 DRAFT Table 1 CILRT COSTS Item Range Mean Value

. Man-REM 0.3 + 6 3 Compressor Rental $7,000 + $25,000 $12,000 Personnel Overtime J' $15,000 Instrumentation J' $10,000 Lost Operation Time 1.7 + 11.25 days 3.9 days

NED0-31722 DRAFT of $600,000 per day, the mean total cost of a single test is $2,400,000. The worst case of a plant doing three extra tests in the 12-year interval corres-ponds to a penalty averaging $600,000 and 0.75 Man-Rem per year per unit. It should be noted that although the above average costs are only estimates, they are sufficiently accurate for their intended usage here (i.e., to show that a significant amount of resources are spent meeting accelerated CILRT schedules).

The final test reports from 23 CILRTs were assembled in order to evaluate the effectiveness of accelerated testing for ensuring containment integrity.

To ensure representative results, tests from both BWRs and PWRs owned by a number of different utilities across the country were used. Both local and integrated leakage rates for each Type A test are listed in Table 2. This data is used to evaluate the concept of corrective action plans with respect to their adequacy and cost effectiveness to ensure containment integrity.

The second column 1n Table 2 contains the total 'As-Found Minimum Path' leakages from all Type Band C tested valves, penetrations, and closure sys-tems. This leakage is measured prior to the Type A test and prior to any repairs or adjustments (R/As) performed that outage. These numbers are intended to represent the contribution to total measured leakage out of containment from all Type Band C tested components had the CILRT been conducted prior to any R/As on those components. The third column contains the total 'As-Left Minimum Path' leakages. These numbers represent the total leakage out of containment from all Type Band C tested components after R/As and prior to the CILRT. For the earlier test reports examined, the 'Minimum Path' leakages were not available. In those cases, individual valve leakages were used to calculate the 'Minimum Path' leakage. Where only the combined leakage from simultaneously testing both valves was available, half that value was used. The fourth column is the leakage found, measured, and repaired during the CILRT or found, isolated and then measured and repaired after the CILRT. The difference between the values in the second and third column plus the values in the fourth column are added to the 'Final Measured CILRT Leakage' values in the fifth column to obtain the 'Total As-Found CILRT Leakage' in the sixth column. Note that, since penalties for unvented paths (no longer required in most cases) and other causes are not listed, the Bases-36

- Table 2

SUMMARY

OF LOCAL AND INTEGRATED LEAK RATE TEST RESULTS Total Minimum Path Total Minimum Path Leakage Found and Repaired Final Measured Total "As Found" As-Found 8 & C As-Left 8 & C During the CILRT, and Type A Leakage Type A Leakage Test Leakage (SCFH) Leakage (SCFH) Reason for that Leakage (SCFH) (SCFH) 1 250 154 No repairs 215 344 2 5268 + UD'k 142 1778 SCFH, Deficiency in 250 7154 + UD*

B & C Testing Program 3 239 104 No Repairs 280 435 4 377 163 No Repairs 199 504 5 446 + UD* 102 No Repairs 113 525 + UO'k to II>

6 226 137 5 SCFH, Omission in B & C 191 319 c:,~

1/)

11) 1/)

Testing Program  :=a? w I

UD,;t::- ~

w....., 7 1913 + UO'k + UO'k 157 315 SCFH, Omission in B & C Testing Program 322 2422 + UD* +

..., ~

-f 8 1887 135 No Repairs 133 1950 9 1550 150 50 SCFH, Non Type B or C 168 1650 Tested Area 10 3200 50 .r70 SCFH, New Modification 316 3600 not Previously Leak Tested 11 1651 90 UD*, Non Type 8 or C Tested 157 1727 +* UD*

Area 12 375 + UD* 103 Less than 2 SCFM 242 434 + UO'k

• UD: Un-Defined, leakage was too large to measure.

Table 2 (Continued)

SUMMARY

OF LOCAL AND INTEGRATED LEAK RATE TEST RESULTS Total Minimum Path Total Minimum Path Leakage Found and Repaired Final Measured Total "As Found" As-Found 8 & C As-Left 8 & C During the CILRT, and Type A Leakage Type A Leakage Test Leakage (SCFH) Leakage (SCFH) Reason for that Leakage (SCFH) (SCFH) 13 29 29 Less than 2 SCFH 14 16 14 344 44 No Repairs 222 526 15 30 30 No Repairs 107 107 16 20 20 No Repairs 107 107 17 NA, Pre-Op Test 113 No Repairs 26 NA, Pre-Op Test 18 NA, Pre-Op Test 94 750 SCFH, Instrument Lines 227 NA, Pre-Op Test tJ:I I>>

and Valve Packing c:,~

Ill n,

Ill 19 NA, Pre-Op Test 102 No Repairs 114 NA, Pre-Op Test

a~w w

00 I

z=-~

N 20 95 60 No Repairs 130 172 *-r,N

--1 21 771 6 No Repairs 13 778 22 X (X - y = 37) y No Repairs 35 72 23 X (X - y = 25) y No Repairs 71 96

NED0-31722 arithmetic will not come out exact.

DRAFT It is the leakage in the sixth column that is compared to the 0.75 La acceptance criteria to determine Type A test passage or failure. For the plants examined, 0.75 La fell between approximately 160 and 1600 SCFH.

The CILRTs examined can be separated into four categories:

(1) The total 'As-Found Minimum Path' local leak test results were greater than the 0.75 La acceptance criteria. Those leaks were repaired and the total as-left local leakage was well below 0.75 La.

The subsequent measured Type A leakage was also less than the acceptance criteria.

2. The total 'As-Found Minimum Path' local leak test results were greater than the 0.75 La acceptance criteria. Those leaks were repaired and the as-left total local leakage was well below 0.75 La.

The subsequent measured Type A leakage was greater than the acceptance criteria, repairs were required for test passage.

3. The total 'As-Found Minimum Path' local leak test results were less than the 0.75 La acceptance criteria. The subsequent measured Type A leakage was greater 0.75 La, repairs were required for test passage.

4. The total 'As-Found Minimum Path' local leak test results were less than the 0.75 La acceptance criteria. The subsequent measured Type A leakage was also less than 0.75 La.

The distribution of tests between these four categories is shown in Table 3.

It is significant that no test fell into Category _3. If the total as-found local leakage was less than the 0.75 La criteria, then the additional leakage measured during the subsequent Type A test was never enough to put the total over the acceptance criteria. This, in effect, says that passage or Bases-39

NED0-31722 DRAFT Table 3 LISTING OF CILRTs BY CATEGORIES Category Number Description Number of Tests Percent of Total 1 Failed as-found 6 30 2 Failed as-found and 3 15 initial as-left 3 Failed initial 0 0 as-left 4 Passed as-found and 11 55 initial as-left Bases-40

NED0-31722 DRAFT failure of the Type A tests was always determined by local leak test results performed before the Type A test began. Leakage from the structure and other parts of containment detectable only by Type A testing is almost ~lways very low and does not change much over time. The leaks found during Type A tests were usually caused by either omissions in the local leakage testing program, or leaks in non B&C tested instrument lines and manifolds. NRC Information Notice 86-16 also mentions cases where CILRTs found deficiencies in Type Band C testing programs.

There were three instances in Table 2 where the total as-left local

- leakages (third column) were low and the subsequent Type A test identified large leaks. Test 18 was a Pre-Op test where most of the leakage was from instrument lines not subject to local leak testing. In another case (test #2) the leakage was from an area that was improperly locally leak tested prior to the CILRT. The third case (Test 11) was a leak from a fan cooler tube, an area that is not locally leak tested. This system was depressurized during the CILRT, but during unit operation or post-accident conditions, it would have been maintained at greater than accident pressure. This leakage would have been found prior to startup when the system was re-pressurized.

Type A testing has definitely been useful in finding the above types of problems. Accelerated schedules in response to failures due to leaks found during the type A test seems reasonable. In contrast, 66% of the as-found failures found here were due solely to high local leakage paths (Category 1).

The performance of additional Type A tests in response to these failures yields no new information. NRC Information Notice 85-71 states that, in some cases, a high degree of containment integrity may be better achieved through improved maintenance and testing programs for containment penetration boundaries and isolation valves rather than by performing more frequent CILRTs. To implement this, after failing two consecutive CILRTs, the licensee would submit a corrective action plan as an Appendix J exemption request. If approved, the licensee may implement the plan in lieu of going on an accelerated CILRT schedule.

Bases-41

NED0-31722 DRAFT A corrective action plan would address correction and surveillance of the specific source(s) of leakage responsible for the Type A test failure. The vast majority of major leaks are from valves, closures, and penetrations.

Since surveillance of these areas can be performed by local leak testing alone, implementation of corrective action plans could sharply reduce the number of unnecessary CILRTs performed. If even a small fraction of the cost per CILRT saved is applied toward the permanent fixes of recurring problem containment isolation systems, overall containment integrity would be improved.

A good corrective action plan would:

(1) Address the root cause(s) of leakage in such a way as to prevent recurrence.

(2) Ensure that the unit in question has a comprehensive Type Band C testing program.

(3) Ensure that the local leak tests performed next outage in place of the accelerated CILRT are as-found tests on the problem areas.

(4) Not include any additional costly requirements (such as mid-cycle testing) that add nothing to safety and thereby induce the utility to reject the plan.

The ultimate purpose of determining the as-found integrated leak rate 1s to verify the adequacy of the maintenance performed since the last CILRT. The requirement to perform more frequent CILRTs in response to as-found failures can help achieve the above objective only by shortening the time between leakage discoveries, and thereby decreasing total unit operation time with diminished containment integrity. For plants with comprehensive local leak rate testing programs, this benefit will be realized only if the leaks found are of the kind only detectable by Type A testing, since Type Band C tests are performed every outage anyway.

Bases-42

NED0-31722 DRAFT By far, the most common cause of as-found Type A test failures has been shown to be leaks in locally tested areas. The requirement to perform additional Type A tests for those cases makes little sense. In s~me cases, the source of the leakage is not adequately addressed and the next test fails for the same reason. If, instead, a corrective action plan that addresses permanently eliminating the specific source of leakage is implemented, then accelerated Type A testing would serve little purpose. By implementing a root cause specific corrective action plan, both cost and Man-Rem would be reduced while improving confidence in the integrity of the primary containment system.

87.6 ACCEPTANCE CRITERIA 87.6.1 Type A Testing The intent of 10CFR50 Appendix J Type A testing is to verify the primary containment is capable of maintaining its leak-tight integrity during normal and post-accident conditions. Leakage rate criteria are based on 10CFRl00 calculations. Consistent with 10CFR50 Appendix J, the CILRT is either conducted in the "as-is" condition or the CILRT LSLR is adjusted to provide an as-found leakage rate. The as-found criterion has been established as

<l.0 La. This verifies that containment leakage was acceptable throughout the previous operating cycle. The as-left criterion has been established as

<0.75 La. This provides a 25% margin for primary containment degradation over the operating cycle. Both of the above limits are consistent with the proposed 10CFR50 Appendix J rule changed published in the Federal Register on October 29, 1986.

87.6.2 Type B/C Testing As was established for Type A test criteria, the Type Band C test cri-teria also have a margin for primary containment isolation barrier degradation.

Prior to startup, the sum of all Type Band C componen~s must be ~0.6 La using MXPLRs. This provides a 40% margin of degradation and is consistent with 10CFR50 Appendix J. Appendix J does not explicitly require running totals during unit operation; its intent is to ensure primary containment integrity Bases-43

NED0-31722 is maintained during operation.

ORAfl Therefore, if R/As are performed during operation, the Running Total Containment Leakage Rate must be adjusted and verified to be <1.0 La. This provides adequate assurance that primary containment integrity is maintained as established by 10CFRlOO calculations.

Bases-44

NED0-31722 88.0 DRAfl INSTRUMENTATION 88.l GENERAL REQUIREMENTS The practices as described in Section 8.1 are standard throughout the nuclear industry. 10CFRS0 Appendix J does not provide guidance in these areas. Generally, post-test calibrations are used in all cases; performance of a verification test however, is not a normal practice, but is done with the CILRT. A verification test as described in Section 9.9 is in itself a calibration check of the Type A test instrumentation and thus precludes the need for costly post test calibrations.

88.2 INSTRUMENT PERFORMANCE AND CALIBRATION REQUIREMENTS FOR TYPE A TESTS Instrumentation requirements are consistent with the characteristics of commonly used equipment. Experience has shown that the calibration interval required for each instrument may be different. The licensee may select his own calibration interval based on a documented performance history of each instrument.

88.2.8 Atmospheric Conditions Since measurements of the environmental atmospheric changes are not used in the leakage rate calculations, the precision of the measuring equipment shall be such that significant atmospheric changes could be recorded for possible correlation with test data. Hourly recordings of atmospheric temperature to l°F and pressure to 1 inch mercury are sufficient. NBS traceability is not required.

88.2.9 Water Level Measurement Experience has shown that the accuracies given for water level measure-ment 1n the reactor vessel and in the suppression chamber are adequate to account for water level differences when calculating the Type A leakage rate.

Bases-45

NEDO-31722 B8.3 DR~fl INSTRUMENT PERFORMANCE AND CALIBRATION REQUIREMENTS FOR TYPE BAND C TESTS Instrument requirements are consistent with the characteristics of cormnonly used equipment. Experience has shown that the calibration interval required for each instrument may be different. The licensee may select his own calibration interval based on a documented performance history of each instrument.

Bases-46

NED0-31722 DRAFT B9.0 TYPE A TEST METHODOLOGY B9.1 GENERAL Although allowed by Reference 10, the reference volume method is not recommended. Past experience has shown that the absolute method is far superior. Specific areas of difficulty with the reference volume method are temperature stabilization and test volume leakage.

89.2 CONTAINMENT INSPECTION This requirement is consistent with 10CFRS0 Appendix J.

B9.3 TEMPERATURE SURVEY Area temperature surveys of primary containment must be conducted prior to the Type A test. The survey is used to determine placement of the tempera-ture measuring instruments and assignment of volume fractions. Unidentified temperature variations have the potential to effect the measurement of the containment dry air mass and, in effect, create large data scatter. It is acceptable to use fans or other means to circulate air within the containment to reduce temperature stratifications, as long as the survey is conducted under the same conditions. It is also acceptable to use a survey of a different unit if it can be shown to have similar configurations and proportions. This is consistent with ANSI N45.4 and 56.8.

89.4.l Minimum Number of Sensors No minimum number of drybulb temperature and dewpoint sensors are speci-fied because quadrature theory shows that, in many cases, the quantity volume fraction per sensor is not a relevant factor in good containment modeling. A better basis for determining the number of required temperature elements is a containment temperature survey which determines temperature gradients within the containment.

Bases-47

NED0-31722 B9.4.2 System Performance The instrument selection guide formula is consistent with Reference 9.

For..purposes of instrument selection and loss of sensor criteria, the ISG is only calculated fort= 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The ISG need not be calculated for a smaller t if a shorter duration BN-TOP-1 test is run, because the BN-TOP-1 method contains a factor (97.5% UCL) that corrects the measured leakage rate for ending the test in less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This 97.5% UCL calculation so conservatively compensates for a short duration (<24 hours) test, that no addition conservatism in instrument accuracy is required.

B9.5 PRESSURIZATION No specific pressurization rate has been dictated by this document. Due to the vast variety of containments, no one pressurization criterion could ensure equipment safety from in-gassing. The intent of Section 9.5 is to ensure that the reader is aware of the potential for equipment damage.

B9.6 CONTAINMENT STABILIZATION Containment stabilization tests are performed following pressurization but prior to beginning the Type A test.

B9.6.1 BN-TOP-1 Requirements Reference 16, Section 2.2.B, requires that plots be made of both the average containment air temperature and the containment air pressure versus time. That section also stipulates that the pressure-time curve should follow the temperature-time curve.

Reference 16, Section 2.3.A, requires that the containment be allowed to stabilize for about four hours, and that the containment satisfy stabilization criteria 9.6.1.1 or 9.6.1.2.

Bases-48

NED0-31722 ORAfl Reference 16, Section 2.3.A.l, states, "The rate of change of average temperature is less than 1.0 F/hour averaged over the last two hours".

9.6.1.l is this report's interpretation of that requirement. The equation chos~n is a first-order, two-point, backwards finite difference approximation for the rate of change. This approximate rate of change is calculated for each of the last two hours. The average of those two rates of change is the parameter that is compared against the acceptance criteria.

Reference 16, Section 2.J.A.2, states, "The rate of change of temperature changes less than 0.5 F/hour/hour averaged over the last two hours". 9.6.1.2 is this report's interpretation of this requirement. The equation chosen is a first-order, two-point, backwards finite difference approximation for this rate of rate of change.

Reference 18 provides NRC acceptance of BN-TOP-1 Revision 1.

89.6.2 Dry Air Mass Method The dry air mass method tests for containment stability by examining both the rate of change of containment dry air mass and the amount of scatter of those masses. The two specific tests chosen are intentionally simple. The parameters required to perform the required calculations are currently avail-able at most plants, and most plants have the capability to perform the calcu-lations without requiring software changes.

Other methods test for containment stability by examining the rate of change of containment temperature. If a containment is properly modeled and instrumented, it may have a large temperature transient with no resulting change in calculated dry air mass. This is due to the containment pressure changing in response to the temperature change.

The dry air mass containment stabilization method eliminates any specific minimum time interval, while at the same time imposing.physically meaningful criteria. The time savings is encouragement for the licensee to improve the Bases-49

NED0-31722 ORAFl Type A test instrumentation system, containment modeling, and pump-up techniques.

89.b.2.l Test for the Rate of Change of Dry Air Hass If the calculated leakage rate is not close to being constant, the Type A test should not start. A changing leakage rate may indicate unstable containment atmospheric conditions or suggest specific types of leakage (leaks through airlock shaft seals are known to be nonsteady). This test requires the rate of change of the leakage rate to be less than a value which would result in a 0.01 La change in one hour.

It is believed that a valid Least Squares fit cannot be performed with-out utilizing at least 20 data sets. In order to accomplish this while not requiring an inordinate length of time for data collection, the sample inter-val must be decreased. Intervals as short as two minutes are allowed. This interval is long enough to accommodate the transient response characteristics of most RTDs. The leakage rates for two overlapping 20 data set intervals are calculated. The difference between these two leakage rates divided by the time between intervals, is the rate of change of leakage rate.

B9.6.2.2 Test for Dry Air Hass Point Scatter An excessive amount of scatter in dry air mass data points may indicate unstable containment conditions or instrument problems. In either case, the test should not begin until the scatter is within reasonable limits. The UCL is calculated from the average of the deviation of mass points from the least squares calculated leakage rate. The difference between the UCL and the Least Squares line of leakage rate may be used as an indicator of the amount of data scatter.

The amount of data scatter is considered acceptable for determining con-tainment stabilization if the difference between the UCL and the Least Squares leakage rate is less than 0.25 La for the 30 data sets used. The 0.25 La Bases-50

NE00-31722 DRAFT value was chosen to be consistent with the acceptance criteria used for the verification test.

B.9.6.3 Appendix J Method This method is consistent with the requirements of Section III.A.l.(c) of Reference 8. Unlike the method described above, there are no specific checks on the allowable rates of change or scatter. The decision of when to start the test is left to the judgment of the licensee. If that judgment proves to be flawed, then the result would be either an extended Type A Test, a Type A test restart, or failure of the Verification Test. In no case would this result in the passing of a bad Type A test.

B9.7 CALCULATION OF CONTAINMENT DRY AIR MASS The determination of the overall dry air mass for containment at any point in time is based on the application of the fundamental ideal gas equation PV = NRT.

Thus, the overall dry air mass at time t can be determined using the total containment average values for pressure, vapor pressure, temperature, and free air volume. For the thermodynamic conditions present during the CILRT, the assumption that the containment air will behave as an ideal gas is valid.

89.7.5 Vapor Pressure Correlations Curve Fit of Vapor Pressures for Dew Temperatures 32.0 through 80°F, based on data from Reference 19.

Polynominal Constants:

C1=0.2105538xlO-l C2=0.1140313xl0-2 C3=0.1680644xl0-4 C4=0.3826294xl0-6 C5=0.S78783lxl0-9 C6=0.2056074xl0-10 Bases-51

NED0-31722 DR Af I ~

Dew Vapor Pressure Vapor Pressure Temperatures From Curve From Steam (OF) Fit (psia) Tables (psia)  % Error 0.3200000E+02 0.8858999E-Ol 0.8859000E-Ol 0.1619697E-04 0.3300000E+02 0.9222951E-Ol 0.9223000E-Ol 0.5299960E-03 0.3400000E+02 0.9600076E-01 0.9600000E-Ol O. 7911609E-03 0.3500000E+02 0.9990788E-Ol 0.9991000E-Ol 0.2125389E-02 0.3600000E+02 0.1039551E+OO 0.1039500E+OO 0.4911858E-02 0.3700000E+02 0.1081468E+OO 0.1081500E+OO 0.2966732E-02 0.3800000E+02 0.1124874E+OO 0.1124900E+OO 0.2329136E-02 0.3900000E+02 0.1169814E+OO 0 .1169800E+OO 0.1216536E-02 0.4000000E+02 0.1216336E+OO 0.1216300E+OO 0.2943663E-02 0.4100000E+02 0.1264486E+OO 0.1264500E+OO 0.1090281E-02 0.4200000E+02 0.1314314E+OO 0.1314300E+OO 0.1086615E-02 0.4300000E+02 0.1365870E+OO 0.1365900E+OO 0.2197841E-02 0.4400000E+02 0.1419204E+OO 0.1419200E+OO 0.3139417E-03 0.4500000E+02 0.1474370E+OO 0.1474400E+OO 0.2030949E-02 0.4600000E+02 0.1531420E+OO 0.1531400E+OO 0.1328970E-02 0.4700000E+02 0.1590410E+OO 0.1590400E+OO 0.6391241E-03 0.4800000E+02 0.1651396E+OO 0.1651400E+OO 0.2671318E-03 0.4900000E+02 0.1714434E+OO 0.1714400E+OO 0.1984180E-02 O.SOOOOOOE+02 0.1779584E+OO 0. l 779600E+OO 0.889777SE-03 0.5100000E+02 0.1846906E+OO 0.1846900E+OO 0.3302262E-03 0.5200000E+02 0.1916461E+OO 0.1916500E+OO 0.2021717E-02 0.5300000E+02 0.1988312E+OO 0.1988300E+OO 0.6268664E-03 0.5400000E+02 0.2062524E+OO 0.2062500E+OO 0.1162927E-02 O.SSOOOOOE+02 0.2139162E+OO 0.2139200E+OO 0.1798786E-02 0.5600000E+02 0.2218292E+OO 0.2218300E+OO 0.3496987E-03 0.5700000E+02 0.2299985E+OO 0.2300000E+OO 0.6599249E-03 0.5800000E+02 0.2384309E+OO 0.2384300E+OO 0.3962514E-03 0.5900000E+02 0.2471338E+OO 0.2471300E+OO 0.1531839E-02 0.6000000E+02 0. 2561143E+OO 0.2561100E+OO 0.1692735E-02 0.6100000E+02 0.2653801E+OO 0.2653800E+OO 0.3152803E-04 0.6200000E+02 0.2749387E+OO 0.2749400E+OO 0.4790955E-03 0.6300000E+02 0.2847979E+OO 0.2848000E+OO 0.7201891E-03 0.6400000E+02 0.2949659E+OO 0.2949700E+OO 0.1401759E-02 0.6500000E+02 0.3054506E+OO 0.3054500E+OO 0.1912852E-03 0.6600000E+02 0.3162604E+OO 0.3162600E+OO 0.1360769E-03 0.6700000E+02 0.3274039E+OO 0.3274000E+OO 0.1191825E-02 0.6800000E+02 0.3388897E+OO 0.3388900E+OO 0.9601184E-04 0.6900000E+02 0.3507266E+OO 0.3507300E+OO 0.9686565E-03 0.7000000E+02 0.3629237E+OO 0.3629200E+OO 0.1025632E-02 0.7100000E+02 0.3754903E+OO 0.3754900E+OO 0.6756906E-04 0.7200000E+02 0.3884356E+OO 0.3884400E+OO 0.1131704E-02 0.7300000E+02 0.4017694E+OO 0.4017700E+OO 0.1570357E-03 0.7400000E+02 0.4155013E+OO 0.415SOOOE+OO 0.3216457E-03 0.7500000E+02 0.4296415E+OO 0.4296400E+OO 0.3462439E-03 0.7600000E+02 0.4442000E+OO 0.4442000E+OD 0.1248129E-06 0.7700000E+02 0.4591873E+OO 0.4591900E+OO 0.5983978E-03 0.7800000E+02 0.4746138E+OO 0.4746100E+OO 0.8050644E-03 Bases-52

NED0-31722 Dew Vapor Pressure Vapor Pressure Temperatures From Curve From Steam (OF) Fit (psia) Tables (psia)  % Error 0.7900000E+02 0.4904905E+OO 0.4904900E+OO 0.9966587E-04

- 0. 8000000E+02 0.5068282E+OO 0.5068300E+OO 0.3463568E-03 Maximum Error= 0.005% at 36 °F Average Error= 0.001%

Curve Fit of Vapor Pressures for Dew Temperatures 80 through 115°F.

Polynominal Constants:

C1= 0.18782 C2=-0.7740034xl0-2 C3= 0.204009xl0-3 C4=-0.1569692xl0-5 C5= 0.1065012xl0-7 Dew Vapor Pressure Vapor Pressure Temperatures From Curve From Steam (OF) Fit (psia) Tables (psia)  % Error

0. 7100000E+02 0.3755143E+OO 0.3754900E+OO 0.6478411E-02 0.7200000E+02 0.3884456E+OO 0.3884400E+OO . 0.1429217E-02 0.7300000E+02 0.4017692E+OO 0.4017700E+OO 0.1910036E-03 0.7400000E+02 0.4154945E+OO 0.4155000E+OO 0.1328107E-02 0.7500000E+02 0.4296307E+OO 0.4296400E+OO 0.2172134E-02 0.7600000E+02 0.4441874E+OO 0.4442000E+OO 0.2833261E-02 0.7700000E+02 0.4591746E+OO 0.4591900E+OO 0.3353162E-02 0.7800000E+02 0.4746024E+OO 0.4746100E+OO 0.1608268E-02 0.7900000E+02 0 .4904811E+OO 0.4904900E+OO 0.1814741E-02 0.8000000E+02 0.5068214E+OO 0.5068300E+00 0.1687956E-02 0.8100000E+02 0.5236343E+OO 0.5236400E+00 0 .1087113E-02 0.8200000E+02 0.5409308E+OO 0.5409300E+00 0.1560802E-03 0.8300000E+02 0.5587225E+00 0.5587200E+00 0.4418945E-03 0.8400000E+02 0. 5 770209E+OO 0.5770200E+OO 0.1474011E-03 0.8500000E+02 0.5958379E+OO 0.5958300E+00 0.1328184E-02 0.8600000E+02 0.6151858E+OO 0.6151800E+00 0.9491209E-03 0.8700000E+02 0.6350771E+OO 0.6350700E+00 0.1111953E-02 0.8800000E+02 0.6555243E+OO 0.6555100E+00 0.2177520E-02 0.8900000E+02 0.6765404E+OO 0.6765300E+OO 0.1540573E-02 0.9000000E+02 0.6981387E+OO 0.6981300E+OO 0.1247636E-02 0.9100000E+02 0.7203326E+OO 0.7203200E+OO 0.1748559E-02 0.9200000E+02 0.7431358E+OO 0.7431300E+OO 0.7793591E-03 0.9300000E+02 0.7665623E+OO 0.7665500E+00 0.1600538E-02 0.9400000E+02 0.7906263E+OO 0.7906200E+OO 0.7907920E-03 0.9500000E+02 0.8153422E+OO 0.8153400E+OO 0.2725339E-03 0.9600000E+02 0.8407249E+OO 0.8407200E+OO 0.5846183E-03 0.9700000E+02 0.8667893E+OO 0.8667900E+OO 0.7812014E-04 Bases-53

NED0-31722 DRAtl Dew Vapor Pressure Vapor Pressure Temperatures From Curve From Steam (OF) Fit (psia) Tables (psia)  % Error 0.9800000E+02 0.8935507E+OO 0.8935600E+OO 0.1041543E-02

. 0.9900000E+02 0.9210245E+OO 0.9210300E+OO 0.5939975E-03 O.lOOOOOOE+03 0.9492266E+OO 0.9492400E+OO 0.1412777E-02 0.1010000E+03 0.9781729£+00 0.9781800E+OO 0.7270361E-03 0.1020000E+03 0.1007880E+Ol 0.1007890E+Ol 0.1022352E-02 0.1030000E+03 0.1038364E+Ol 0.1038380E+Ol 0.1585402E-02 0.1040000E+03 0.1069641E+Ol 0.1069650E+Ol 0.8232134£-03 0.1050000E+03 0 .1101730E+Ol 0 .1101740E+Ol 0.9345629E-03 0.1060000E+03 0 .1134646E+Ol 0.1134700E+Ol 0.4727505E-02 0.1070000E+03 0 .1168409E+Ol 0.1168400E+Ol 0.7448495E-03 0.1080000E+03 0.1203035E+Ol 0.1203000E+Ol 0.2871535E-02 0.1090000E+03 0.1238542E+Ol 0.1238500E+Ol 0.3386467E-02

0. llOOOOOE+OJ 0.1274949E+Ol 0.1275000E+Ol 0.3983681E-02 O.lllOOOOE+OJ 0.1312275E+Ol 0.1312300E+Ol 0. l 911533E-02 0.1120000E+OJ 0.1350538E+Ol O.lJSOSOOE+Ol 0.2805482E-02 0.1130000E+OJ 0.1389757E+Ol 0.1389800E+Ol 0.3078941E-02 0.1140000E+03 0.1429952E+Ol 0.1429900E+Ol O.J6516JOE-02

0. llSOOOOE+OJ 0 .14 71142E+Ol 0.1471100E+Ol 0.2888869E-02 0 .1160000E+03 0.1513348E+Ol 0.1513300E+Ol 0.3165780E-02 0.1170000E+03 0.1556589E+Ol 0.1556600E+Ol 0.7357424E-03 0.1180000E+03 0.1600885E+Ol 0.1600900E+Ol 0.9509159E-03 0.1190000E+03 0.1646257E+Ol 0.1646300E+Ol 0.2599101E-02 Maximum Error = 0.006% at 71 o F Average Error= 0.002%

Curve Fit of Vapor Pressures for Dew Temperatures 115 through 155°F.

Polynominal Constants:

C1= 0.9897124 C2=-0.3502587xlO-l C3= 0.5537028xl0-3 C4=-0.3570467xl0-5 C5= 0.1496218xl0-7 Dew Vapor Pressure Vapor Pressure Temperatures From Curve From Steam (OF) Fit (psia) Tables (psia)  % Error 0.1110000E+03 0.1312297E+Ol 0.1312300E+Ol 0.1997888E-03 0 .1120000E+OJ 0.1350543E+Ol 0.1350500E+Ol 0.3204286E-02 O.llJOOOOE+OJ 0.1389749E+Ol 0.1389800E+Ol 0.3635127E-02 0.1140000E+03 0.1429935E+Ol 0.1429900E+Ol 0.2445527E-02 0 .1150000E+03 0.1471119E+Ol 0.1471100E+Ol 0.1296776E-02 0 .1160000E+03 0.1513321E+Ol 0.1513JOOE+Ol 0.1420544E-02 0.1170000E+03 0.1556562E+Ol 0.1556600E+Ol 0.2423124E-02 Bases-54

NED0-31722 DRAfl Dew Vapor Pressure Vapor Pressure Temperatures From Curve From Steam (OF) Fit (psia) Tables (psia)  % Error O. ll80000E+OJ 0.1600862E+Ol O.l600900E+Ol 0.2383534£-02

_ O.ll90000E+OJ O.l646241E+Ol O.l646300E+Ol 0.3586910E-02 O.l200000E+03 O.l692721E+Ol 0.1692700E+Ol 0.1224753£-02

• O.l210000E+OJ O.l740323E+Ol 0.1740300E+Ol O.l303156E-02 0.1220000E+OJ O.l789069E+Ol 0.1789100E+Ol 0.1752901E-02 0.1230000E+OJ 0.1838981E+Ol 0.1839000E+Ol 0.1043047E-02 0.1240000E+03 0.1890082E+Ol 0.1890100E+Ol 0.9637902E-03 0.1250000E+03 0.1942394£+01 0.1942400E+Ol 0.2852617E-03 0.1260000E+OJ 0.1995942£+01 0.1995900E+Ol 0.2110807E-02 0.1270000E+OJ 0.2050748E+Ol 0.2050700E+Ol 0.2362034£-02 0.1280000E+OJ 0.2106837E+Ol 0.2106800E+Ol 0. l 774607E-02 0.1290000E+OJ 0.2164233£+01 0.2164200E+Ol 0.1540458E-02 O.lJOOOOOE+OJ 0.2222961£+01 0.2223000E+Ol 0.1753830E-02 0.1310000E+03 0.2283D45E+Ol 0.2283000E+Ol 0.1992482E-02 0.1320000E+OJ 0.2344512E+Ol 0.2344500E+Ol 0.5205957E-03 O.lJJOOOOE+OJ 0.2407387E+Ol 0.2407400E+Ol 0.5416120E-03 O.l340000E+03 0.2471696E+Ol 0.2471700E+Ol 0.1653558E-03 O.l350000E+03 0.2537466E+Ol 0.2537500E+Ol 0.1356595E-02 0.1360000E+OJ 0.2604723E+Ol 0.2604700E+Ol 0.8763723E-03 0.1370000E+OJ 0.2673495E+Ol 0.2673500E+Ol O.l908164E-03 O.l380000E+OJ 0.2743809E+Ol 0.2743800E+Ol 0.3420320E-03 0.1390000E+03 0.2815694E+Ol 0.2815700E+Ol 0.2046479£-03 0.1400000E+03 0.2889178E+Ol 0.2889200E+Ol 0.7694453E-03 0.1410000E+OJ 0.2964289E+Ol 0.2964300E+Ol 0.3829019E-03 0.142DOOOE+03 0.3041056E+Ol 0.3041100E+Ol 0.1449845E-02 0.1430000E+03 0.3119509E+Ol O.Jll9500E+Ol 0.2864351E-03 0.1440000E+03 0.3199677E+Ol 0.3199700E+Ol 0.7039022E-03 O.l450000E+D3 0.3281592E+Ol 0.3281600E+Ol 0.2547106E-03 O.l460000E+03 0.3365282E+Ol 0.3365300E+Ol 0.5380225E-03 0.1470000E+OJ 0.3450779E+Ol 0.3450800E+Ol 0.6068183E-03 O.l480000E+03 0.3538114E+Ol 0.3538100E+Ol 0.4048392E-03 0.1490000E+03 0.3627319E+Ol 0.3627300E+Ol 0.5301013E-03 O.l500000E+03 0.3718426E+Ol 0.37l8400E+Ol 0.6905276E-03 0.1510000E+OJ 0. 38ll466E+Ol 0.3811400E+Ol 0. l 729805E-02 O.l520000E+OJ 0.3906473E+Ol 0.3906500E+Ol 0.7011761E-03 O.l530000E+OJ 0.4003479E+Ol 0.4003500E+Ol 0.5322185E-03 0.1540000E+03 0.4102518E+Ol 0.4102500E+Ol 0.4270758E-03 0.1550000E+OJ 0.4203623E+Ol 0.4203600E+Ol 0.5421759E-03 0.1560000E+03 0.4306829E+Ol 0.4306800E+Ol 0.6631366E-03 O.l570000E+OJ 0.4412169E+Ol 0.4412200E+Ol 0.6970663E-03 O.l580000E+03 0.4519680E+Ol 0.4519700E+Ol 0.4509528E-03 O.l590000E+OJ 0.4629395E+Ol 0.4629400E+Ol 0.1119592E-03 Maximum Error= 0.004% at 113 °F Average Error= 0.001%

Curve Fit of Vapor Pressures for Dew Temperatures 155 through 215°F.

Bases-55

NED0-31722 UKAtl  :

Polynominal Constants:

C1= 0.3338872xlOl C2=-0.945680lxlO-l C3= 0.112138lxl0-2 C4=-0.59836lxl0-5 C5= 0.1882153xl0-7 Dew Vapor Pressure Vapor Pressure Temperatures From Curve From Steam

{OF) Fit (psia) Tables (psia)  % Error 0.1510000E+OJ 0.3811474E+Ol 0.3811400E+Ol 0.1949095£-02 0.1530000E+03 0.4003458E+Ol 0.4003500E+Ol 0.1060794E-02 0.1550000E+03 0.4203589E+Ol 0.4203600E+Ol 0.2598553E-03 0.1570000E+OJ 0.4412138E+Ol 0.4412200E+Ol 0.1400069E-02 0.1590000E+OJ 0.4629382E+Ol 0.4629400E+Ol 0.3994363E-03 0.1610000E+OJ 0.4855603E+Ol 0.4855600E+Ol 0.5519925E-04 0.1630000E+03 0.5091093E+Ol 0. 5091100E+Ol 0.1428882E-03 0.1650000E+OJ 0.5336150E+Ol 0.5336100E+Ol 0.9343050E-03 0.1670000E+03 0.5591080E+Ol 0. 5591100E+Ol 0.3664885E-03 0.1690000E+OJ 0.5856194E+Ol 0.5856200E+Ol 0.9642365E-04 0.17lOOOOE+OJ 0.6131814E+Ol 0.6131800E+Ol 0.2329044E-03 0.1730000E+OJ 0.6418266E+Ol 0.6418200E+Ol 0.1034785E-02 0.1750000E+03 0.67l5885E+Ol 0.6715900E+Ol 0.2218314E-03

0. l 770000E+03 0.7025012E+Ol 0.7025000E+Ol 0.1696775E-03 0.1790000E+03 0.7345996E+Ol 0.7346000E+Ol 0.5891972E-04 0.1810000E+03 0.7679192E+Ol 0.7679000E+Ol 0.2505390E-02 0.1830000E+03 0.8024965E+Ol 0.8025000E+Ol 0.4320245E-03 0.1850000E+03 0.8383685E+Ol 0.8384000E+Ol 0.3757381E-02 0.1870000E+03 0.8755729E+Ol 0.8756000E+Ol 0.3094382E-02 0.1890000E+03 0.9141482E+Ol 0.9141000E+Ol 0.5278364E-02 0.1910000E+03 0.9541337E+Ol 0.9541000E+Ol 0.3537028E-02 0.1930000E+03 0.9955693E+Ol 0.9956000E+Ol 0.3079856E-02 0.1950000E+03 0.1038496E+02 0.1038500E+02 0.4157551E-03 0.1970000E+OJ 0.1082954E+02 0.1083000E+02 0.4231933E-02 0.1990000E+03 0.1128987E+02 0 .1129000E+02 0.1160130E-02 0.2010000E+OJ O.ll76637E+02 0.1176600E+02 0.3120421E-02 0.2030000E+03 0.1225947E+02 0.1225900E+02 0.3846946E-02 0.2050000E+03 0.1276963E+02 0 .1277000E+02 0.2935573E-02 0.2070000E+03 0.1329728E+02 0.1329700E+02 0.2088649E-02 0.2090000E+03 0.1384289E+02 0.1384300E+02 0.8190882E-03 0.2110000E+03 0.1440692E+02 0.1440700E+02 0.5814635E-03 0.2130000E+OJ 0.1498984E+02 0.1499000E+02 0.1079099E-02 0.2150000E+03 0.1559213E+02 0.1559200E+02 0.8437353E-03 Maximum Error= 0.005% at 189 °F Average Error= 0.002%

Bases-56

NED0-31722 UKl\t I 89.7.7 Dew Temperature Correlations Curve Fit of Dew Temperatures as a function of Vapor Pressures for Dew Temperatures from 32 through ao°F, based on data from Reference 19.

Polynominal Constants:

C1=-0.5593968x1Ql C2= 0.6348248xlQ3 C3=-0.3203036xl04 C4= 0.1130089xl05 C5=-0.2411539xl05 C6= 0.2796469xl05

- C7=-0.1348916xl05 Vapor Pressure, (psia)

Dew Temperature From Curve Fit (°F)

Dew Temperature From Steam Tables (°F)  % Error 0.8859000E-Ol 0.3202502E+02 0.3200000E+02 0.7819382E-Ol 0.9223000E-Ol 0.3300911E+02 0.3300000E+02 0.2760768E-Ol 0.9600000E-Ol 0.3399756E+02 0.3400000E+02 0.7162642E-02 0.9991000E-Ol 0.3499116E+02 0.3SOOOOOE+02 0.2526038E-Ol 0.1039SOOE+OO 0.3598564E+02 0.3600000E+02 0.3989949E-Ol 0.1081500E+OO 0.3698657E+02 0.3700000E+02 0.3629156E-Ol 0 .1124900E+OO 0.3798742E+02 0.3800000E+02 0.3309399E-Ol 0.1169800E+OO 0.3898900E+02 0.3900000E+02 0.2820744E-Ol 0.1216300E+OO 0.3999197E+02 0.4000000E+02 0.2008654E-Ol 0.1264SOOE+OO 0.4099687E+02 0.4100000E+02 0.7626970E-02 0.1314300E+OO 0.4200021E+02 0.4200000E+02 0.5007572E-03 0.1365900E+OO 0.4300466E+02 0.4300000E+02 0 .1084117E-Ol 0.1419200E+OO 0.4400702E+02 0.4400000E+02 0.1594799E-Ol 0.1474400E+OO 0.4500987E+02 0.4500000E+02 0.2192372E-Ol 0.1531400E+OO 0.4601031E+02 0.4600000E+02 0.2240552E-Ol 0.1590400E+OO 0.4701086E+02 0.4700000E+02 0.2310520E-Ol 0.1651400E+OO 0.4801053E+02 0.4800000E+02 0.2194742E-Ol 0.1714400E+OO 0.4900852E+02 0.4900000E+02 0.1737864E-Ol 0.1779600E+OO 0.5000715E+02 0.5000000E+02 0.1430511E-Ol 0.1846900E+OO 0.5100417E+02 0.5100000E+02 0.8171766E-02 0.1916500E+OO 0.5200184E+02 0.5200000E+02 0.3540309E-02 0.1988300E+OO 0.5299810E+02 O.SJOOOOOE+02 0.3582854E-02 0.2062500E+OO O.S399512E+02 0.5400000E+02 0.9039948E-02 0.2139200E+OO 0.5499352E+02 0.5500000E+02 O.ll78353E-Ol 0.2218300E+OO 0.5599135E+02 O.S600000E+02 0.1S44756E-01 0.2300000E+OO 0.5699047E+02 0.5700000E+02 0.1672661E-Ol 0.2384300E+OO 0. 5 799011E+02 0.5800000E+02 0.1704840E-Ol 0.2471300E+OO 0.5899067E+02 0.5900000E+02 0.1580583E-Ol 0 .2561100E+OO O.S999240E+02 0.6000000E+02 0.126676SE-Ol 0.2653800E+OO 0.6099539E+02 0.6100000E+02 0.7554701E-02 0.2749400E+OO 0.6199859E+02 0.6200000E+02 0.2276401E-02 0.2848000E+OO 0.6300193E+02 0.6300000E+02 0.3070938E-02 Bases-57

NE00-31722 UliAtl 0.2949700E+00 0.6400527E+02 0.6400000E+02 0.8236639E-02 0.3054500E+00 0.6500743E+02 0.6500000E+02 0.1142988E-0l 0.3162600E+00 0.6600915E+02 0.6600000E+02 0.1386966E-0l 0.3274000E+00 0.6700933E+02 0.6700000E+02 0.1392742E-0l 0.3388900E+00 0.6800876E+02 0.6800000E+02 0.1287985E-0l

- 0.3507300E+00 0.6900661E+02 0.6900000E+02 0.9584023E-02 0.3629200E+00 0.7000239E+02 0.7000000E+02 0.3413607E-02 0.3754900E+00 0.7099827E+02 0.7100000E+02 0.2432081E-02 0.3884400E+00 0.7199426E+02 0.7200000E+02 0.7978767E-02 0.4017700E+00 0.7299065E+02 0.7300000E+02 0.1281234E-0l 0.4155000E+00 0.7398937E+02 0.7400000E+02 0.1436423E-0l 0.4296400E+00 0.7499140E+02 0.7500000E+02 0.1146487E-0l 0.4442000E+00 0.7599709E+02 0.7600000E+02 0.3829232E-02 0.4591900E+00 0.7700542E+02 0.7700000E+02 0.7044502E-02 0.4746100E+00 0.7801227E+02 0.7800000E+02 0.1573171E-0l 0.4904900E+00 O. 7901133E+02 0.7900000E+02 0.1434091E-0l 0.5068300E+00 0.7998788E+02 0.8000000E+02 0.1515177E-0l Maximum Error= 0.078% at 0.08859 psia Average Error= 0.015%

Curve Fit of Dew Temperatures as a function of Vapor Pressures for Dew Temperatures from 80 through 11S°F.

Polynominal Constants:

C1= 0.2334173xl02 C2= 0.2004024xl03 C3=-0.2785328xl03 C4= 0.276584lxl03 C5=-0 .168669xl03 C6= 0.5658985xl02 C7=-0.7977715xl0l Vapor Dew Temperature Dew Temperature Pressure, From Curve From Steam (psia) Fit ( °F) Tables (°F)  % Error 0.3754900E+00 0.7100953E+02 0.7100000E+02 0.1342295E-0l 0.3884400E+00 0.7200306E+02 0.7200000E+02 0.4256681E-02 0.4017700E+00 0.7299827E+02 0.7300000E+02 0.2372104E-02 0.4155000E+00 0.7399550E+02 0.7400000E+02 0.6080000E-02 0.4296400E+00 0.7499436E+02 0.7500000E+02 0.7520705E-02 0.4442000E+00 0.7599446E+02 0.7600000E+02 0.7287569E-02 0.4591900E+00 0.7699545E+02 0.7700000E+02 0.5912163E-02 0.4746100E+00 0.7799635E+02 0.7800000E+02 0.4684036E-02 0.4904900E+00 0.7899815E+02 0.7900000E+02 0.2335893E-02 0.5068300E+00 0.7999995E+02 0.8000000E+02 0.6808914E-04 0.5236400E+00 0.8100149E+02 0.8100000E+02 0.1833783E-02 0.5409300E+00 0.8200258E+02 0.8200000E+02 0.3141252E-02 0.5587200E+00 0.8300361E+02 0.8300000E+02 0.4347933E-02 Bases-58

NED0-31722 UKAtl Vapor Dew Temperature Dew Temperature Pressure, From Curve From Steam (psia) Fit (°F) Tables (°F)  % Error 0.5770200E+OO 0.8400441E+02 0.8400000E+02 0.5249195E-02

- 0.5958300E+OO 0.8500431E+02 0.8500000E+02 0.5075679E-02 0.6151800E+OO 0.8600428E+02 0.8600000E+02 0.4977837E-02 0.6350700E+OO 0.8700369E+02 0.8700000E+02 0.4246109E-02 0.6555100E+OO 0.8800250E+02 0.8800000E+02 0.2844840E-02 0.6765300E+OO 0.8900162E+02 0.8900000E+02 O.l816425E-02 0.6981300E+OO 0.9000049E+02 0.9000000E+02 0.5401995E-03 0.7203200E+OO 0.9099907E+02 0.9100000E+02 0.1020517E-02 O. 7431300E+OO 0.9199820E+02 0.9200000E+02 0.1956429E-02 0.7665500E+OO 0.9299692E+02 0.9300000E+02 0.3307606E-02 0.7906200E+OO 0.9399643E+02 0.9400000E+02 0.3800823E-02 0.8153400E+OO 0.9499616E+02 0.9500000E+02 0.4047220E-02 0.8407200E+OO 0.9599597E+02 0.9600000E+02 0.4198899E~02 0.8667900E+OO 0.9699647E+02 0.9700000E+02 0.3641474E-02 0.8935600E+OO 0.9799741E+02 0.9800000E+02 0.2641576E-02 0.9210300E+OO 0.9899818E+02 0.9900000E+02 O.l838738E-02 0.9492400E+OO 0.9999957E+02 O.lOOOOOOE+03 0.4271935E-03 0.9781800E+OO 0.1010006E+03 0.1010000E+03 0.5541569E-03 0.1007890E+Ol O.l020018E+03 0.1020000E+03 0.1802002E-02 0.1038380E+Ol 0.1030030E+03 0.10JOOOOE+03 0.2945070E-02 0.1069650E+Ol 0.1040035E+03 0.1040000E+03 0.3341630E-02 0 .1101740E+Ol 0.1050038E+03 0.1050000E+03 0.3611020E-02 0 .1134 700E+Ol 0.1060049E+03 0.1060000E+03 0.4591062E-02 0 .1168400E+Ol 0.1070023E+03 0.1070000E+03 :t>.2126922E-02 0.1203000E+Ol 0.1080004E+03 0.1080000E+03 0.3359629E-03 0.1238500E+Ol 0.1089987E+03 0.1090000E+03 0.1205647E-02

- 0.1275000E+Ol 0.1312300E+Ol 0.1350500E+Ol 0.1389800E+Ol 0.1429900E+Ol 0.1471100E+Ol 0.1099997E+03 0.1109976E+03 0 .1119952E+03 0.1129975E+03 0.1139965E+03 0.1149993E+03 0.1100000E+03 0.1110000E+03 0.1120000E+03 0.1130000E+03 O.ll40000E+03 0.1150000E+OJ 0.3178315E-03 0.2165804E-02 0.4275723E-02 0.2236629E-02 0.3074132E-02 0.6279212E-03 0.1513JOOE+Ol 0.1160022E+03 0.1160000E+OJ 0.1935785E-02 0.1556600E+Ol 0.1170058E+03 O.ll70000E+OJ 0.4949983E-02 O.l600900E+Ol 0.1180043E+OJ 0.1180000E+03 0.3628784E-02 0.1646JOOE+Ol 0.1189947E+03 O.ll90000E+03 0.4490884E-02 Maximum Error= 0.013% at 0.37544 psia Average Error= 0.003%

Curve Fit of Dew Temperatures as a function of Vapor Pressures for Dew Temperatures from 115 through 155°F.

Bases-59

NE00-31722 z

UK At 1*

Polynominal Constants:

C1= 0.5221757xl02 C2= 0.7391149xl02 C3=-0.3306993xl02 C4= 0.1074842xl02 C5=-0.2169825xlOl C6= 0.2432796 C7=-0.1155358xlO-l Vapor Dew Temperature Dew Temperature Pressure, From Curve From Steam (psia) Fit (°F) Tables ( °F)  % Error 0.1312300E+Ol 0 .1110045E+03 0.1110000E+03 0.4024497E-02 0.1350500E+Ol 0.1120000E+03 0. ll 20000E+03 0.1451971E-05 0.1389800E+Ol 0 .1130003E+03 0 .1130000E+03 0.2612683E-03 0.1429900E+Ol 0 .1139970E+03 0.1140000E+03 0.2616460E-02 0.1471100E+Ol 0.1149970E+03 0.1150000E+03 0.2615431E-02 0.1513300E+Ol 0.1159970E+03 0.1160000E+03 0.2546806E-02 0.1556600E+Ol O.ll69989E+03 O.ll70000E+03 0.9696468E-03 O.l600900E+Ol 0. ll 79995E+03 0 .1180000E+03 0.4083872E-03 0.1646300E+Ol 0.1190007E+03 0.1190000E+03 0.5919577E-03 0.1692700E+Ol 0. ll 99997E+03 0.1200000E+03 0.2343818E-03 0.1740300E+Ol 0.1210003E+03 0.1210000E+03 0.2871804E-03 0.1789100E+Ol 0.1220020E+03 0.1220000E+03 0.1620864E-02 0.1839000E+Ol 0.1230021E+03 0.1230000E+03 0.1687400E-02 0.1890100E+Ol 0.1240022E+03 0.1240000E+03 0.1789635E-02 0.1942400E+Ol 0.1250020E+03 0.1250000E+03 0.1569020E-02 0.1995900E+Ol 0.1260009E+03 0.1260000E+03 0.7165354E-03 0.2050700E+Ol 0.1270005E+03 0.1270000E+03 0.3867286E-03 0.2106800E+Ol 0.2164200E+Ol 0.2223000E+Ol 0.2283000E+Ol 0.2344500E+Ol 0.2407400E+Ol 0.1280003E+03 0.1289999E+03 0.1300006E+03 0.1309987E+03 0.1319989E+03 0.1329989E+03 0.1280000E+03 0.1290000E+03 0.1300000E+03 0.1310000E+03 0.1320000E+03 0.1330000E+03 0.2228687E-03 0.8900727E-04 0.4686566E-03 0.9763053E-03 0.8706790E-03 0.8076684E-03 0.2471700E+Ol 0.1339986E+03 0.1340000E+OJ 0.1059724E-02 0.2537500E+Ol 0.1349990E+03 0.1350000E+03 0.7629131E-03 0.2604700E+Ol 0.1359982E+03 0.1360000E+03 0.1326146E-02 0.2673500E+Ol 0.1369988E+03 0.1370000E+OJ 0.8593914E-03 0.2743800E+Ol 0.1379990E+03 0.1380000E+03 0.7588215E-03 0.2815700E+Ol 0.1389996E+03 0.1390000E+OJ 0.2964305E-03 0.2889200E+Ol 0.1400003E+03 0.1400000E+OJ 0.1998474E-03 0.2964300E+Ol 0.1410006E+OJ 0.1410000E+OJ 0.4272596E-03

0. 3041100E+Ol 0.1420014E+03 0.1420000E+OJ 0.1016589E-02 0.3119500E+Ol 0 .1430011E+03 0.1430000E+OJ 0.7584491E-03 0.3199700E+Ol 0.1440017E+03 0.1440000E+OJ 0.1148014E-02 0.3281600E+Ol 0.1450015E+03 0.1450000E+OJ 0.1019106E-02 0.3365300E+Ol 0.1460014E+03 0.1460000E+03 0.9600075E-03 0.3450800E+Ol 0 .14 70011E+03 0.1470000E+OJ 0.7203139E-03 0.3538100E+Ol O.l480001E+03 0.1480000E+03 0.9334596E-04 0.3627300E+Ol 0.1489995E+03 O.l490000E+03 0.3409511E-03 Bases-60

NED0-31722 UK At 1.

Vapor Dew Temperature Dew Temperature Pressure, From Curve From Steam (psia) Fit (°F) Tables (°F)  % Error 0.3718400E+Ol 0.1499988E+03 0.1500000E+OJ 0.7684084E-03

. 0. 3811400E+Ol 0.1509980E+03 0.1510000E+OJ 0.1338078E-02 0.3906500E+Ol 0.1519988E+03 0.1520000E+OJ 0.8031968E-03

• o.4003500E+Ol 0.1529989E+03 0.1530000E+03 0.7234146E-03 0.4102500E+Ol 0.1539991E+03 0.1540000E+OJ 0.5798802E-03 0.4203600E+Ol 0.1550000E+03 0.1550000E+OJ 0.2367873E-04 0.4306800E+Ol 0 .1560011E+03 0.1560000E+OJ 0.7009355E-03 0.4412200E+Ol 0.1570024E+03 0.1570000E+03 0.1500414E-02 0.4519700E+Ol 0.1580016E+03 0.1580000E+OJ 0.9892659E-03 0.4629400E+Ol 0.1589977E+03 0.1590000E+OJ 0.1430746E-02 Maximum Error= 0.004% at 0.3123 psia Average Error= 0.001%

Curve Fit of Dew Temperatures as a function of Vapor Pressures for Dew Temperatures from 155 through 215°F.

Polynominal Constants:

C1= 0.8512278xl02 Cz= 0.274613xl02 C3=-0.3847812xlOl C4= 0.3909064 C5=-0.2451226xlO-l C6= 0.8484504xl0-3 C7=-0.1237098xl0-4 Vapor Dew Temperature Dew Temperature Pressure, From Curve From Steam (psia) Fit (°F) Tables (°F)  % Error 0.3811400E+Ol 0 .1510077E+03 O.lSlOOOOE+OJ 0.5078563E-02 0.4003500E+Ol 0.1529996E+03 0.1530000E+03 0.2672165E-03 0.4203600E+Ol 0.1549950E+03 0.1550000E+OJ 0.3237440E-02 0.4412200E+Ol 0.1569946E+03 0.1570000E+0J 0.3415842E-02 0.4629400E+Ol 0.1589956E+03 0.1590000E+03 0.2798371E-02 0.4855600E+Ol 0.1609977E+03 0.1610000E+03 0.1398257E-02 0.5091100E+Ol 0.1630004E+03 0.1630000E+0J 0.2688916E-03 0.5336100E+Ol 0.1650022E+03 0.1650000E+03 0.1329770E-02 0.5591100E+0l 0.1670042E+03 0.1670000E+03 0.2513443E-02 0.5856200E+0l 0.1690046E+03 0.1690000E+OJ 0.2714698E-02 0.6131800E+Ol 0. l 710040E+03 0. l 710000E+OJ 0.2352777E-02 0.6418200E+Ol 0. l 730025E+03 0.1730000E+03 0.1435203E-02 0.6715900E+Ol O.l750014E+03 0.1750000E+OJ 0.7722225E-03 0.702SOOOE+Ol 0.1769993E+03 0.1770000E+03 0.3800440E-03 0.7346000E+Ol 0.1789978E+03 0.1790000E+03 0.1253766E-02 0.7679000E+Ol 0.1809954E+03 0.1810000E+03 0.2539142E-02 Bases-61

NED0-31722 DRAfJ Vapor Dew Temperature Dew Temperature Pressure, From Curve From Steam (psia) Fit (°F) Tables (°F)  % Error 0.8025000E+Ol 0.1829962E+03 0.1830000E+03 0.2052003E-02

- 0.8384000E+Ol 0.1849981E+03 0.1850000E+03 0.1034624E-02 0.8756000E+Ol 0.1869989E+03 0.1870000E+03 0.6094057E-03 0.9141000E+Ol 0.1889966E+03 0.1890000E+03 0.1801452E-02 0.9541000E+Ol 0.1909992E+03 0.1910000E+03 0.3947329E-03 0.9956000E+Ol 0.1930040E+03 0.1930000E+03 0.2081895E-02 0.1038500E+02 0.1950038E+03 0.1950000E+OJ 0.1944087E-02 0.1083000E+02 0.1970057E+03 0.1970000E+OJ 0.2881478E-02 0 .1129000E+02 0.1990032E+03 0.1990000E+03 0.1583944E-02

0. ll 76600E+02 0.2009991E+03 0.2010000E+OJ 0.4575235E-03 0.1225900E+02 0.2029963E+03 0.2030000E+03 0.1804865E-02 0.1277000E+02 0.2049978E+03 0.2050000E+03 0.1057432E-02 0.1329700E+02 0.2069952E+03 0.2070000E+03 0.2328161E-02 0.1384300E+02 0.2089989E+03 0.2090000E+OJ 0.5342516E-03 0.1440700E+02 0.2110029E+03 0.2110000E+03 0.1386672E-02 0.1499000E+02 0.2130057E+03 0.2130000E+03 0.2685980E-02 0.1559200E+02 0.2149964E+03 0.2150000E+03 0.1660816E-02 Maximum Error= 0.005% at 3.8114 psia Average Error= 0.002%

89.8.1 Mass Point Method This method is based upon the assumption that the true leakage rate is constant during the testing period. If this assumption is true and if there was perfect containment modeling and instrumentation, a plot of the measured containment dry air mass versus time would yield a straight line with a nega-tive slope. The leakage rate is proportional to the slope of this line. In a real case, the mass points are scattered about any straight line drawn through them. The Mass Point Method calls for performing a Least Squares Fit of the mass points. This fit determines the Slope and Y-Intercept of the line that minimizes the total amount of scatter of these points along its path. The methodology for calculation of this leakage rate and its 95 percent upper con-fidence limit is presented here.

Each time a data set is collected during the Type-A test, the time of collection and the Total Containment Dry Air Mass at that time are calculated and stored. A collection of K such times/mass pairs are shown below.

Bases-62

NED0-31722 DRAFT where ti= Time (hours) at which data set i was collected. By definition, the time at t1 equals zero.

Mi= Total Containment Dry Air Mass (Lbm) at time ti*

Let ST= Starting data set number of the calculational range.

SP= Ending data set number of the calculational range.

N = Number of data sets to be Least Squares Fit.

N = SP - ST+ 1 For the above set of data points when containment mass M=At+B, A and B for the range of points starting from ST and extending to SP are calculated as shown below.

SP SP SP N

L -L L t. M.

l l t.

l M.

l A = i=ST N

SP L. - L i=ST

( t. )2 l

i=ST

( SP i=ST ti y

i=ST i=ST i=ST B =

N Bases-63

NED0-31722 URAfl substituting for A, SP SP SP SP L L i=ST M.

l i=ST (t.)

l 2

L tiL i=ST i=ST M. t.

l l B =

SP

-(f t:)

2 N

L i=ST

( t.)

l 2

i=ST where A= Rate of change of Total Containment Dry Air Mass, the slope of the straight line discussed above (lbm/hr).

B = Calculated value of Total Containment Dry Air Mass (lbm) at t1.

The leakage rate of dry air from containment at ti, Li, expressed in units of percent per day is shown below.

L. = -2400A l B + At st Let T be the student's t distribution function at the 95th percentile, expressed as a function of N.

T = l.6449(N-2) + 3.5283 + 0.85602/(N-2)

(N-2) + 1.2209 - 1.5162/(N-2)

Ignoring negligible terms, the 95 percent Upper Confidence Limit (UCL) of the true leakage rate in units of percent per day is given below.

Bases-64

NED0-31722 UKAtI UCL = L + To SP L -L M~ ( SP y Mi l/2 c:T y-i l

l i=ST (2400) a = (N-2) SP (weight%

B + AtST per day)

L -L i=ST t.

2 l

i=ST ti

- 89.8.2 Point-to-Point Method The point-to-point method is not reconunended for use in determining over-all leakage rate acceptance criteria for Type A tests. However, this method can be useful in providing quick assessments of leakage rate changes during the test.

This method is based upon the assumption that the rate of change of leak-age rate is constant during the testing period. If this is true, and if there was perfect containment modeling and instrumentation, a plot of containment leakage rates versus time would be a straight line with a negative slope. The

- mass out of containment leakage rate of dry air is proportional to the equa-tion of the line. In a real case, the leakage rates are scattered about any straight line drawn through them.

The point-to-point method calls for performing a Least Squares Fit of the leakage rates determined from each data point interval. This fit determines the slope and the Y-Intercept of the line that minimizes the total amount of scatter of these points along its path. The methodology for calculation of this leakage rate is presented here.

Each time a data set is collected during the Type A test, the time of collection, the Total Containment Dry Air Mass, and the point-to-point leakage rate for the last two data sets are calculated and stored.

Bases-65

NED0-31722 UKAfl A collection of K such points are shown below.

tl ,Ml t2,M2 t3,M3 r

tK-1'~-l

~ ...

tK,MK I

I I .

' ... I

.-...L

... I

'.-L . ' ...

I

--.~

I ' . I

.... -4 MP,2 MP,3 MP,K-1 Mp , K where

= Time (hours) at which data set 1 was collected. By definition, the time at t1 equals zero.

Mi = Total Containment Dry Air Mass (Lbm) at time ti*

Hp,i = Point-to-point leakage rate for the interval of Ti-1 to ti (weight percent per day).

The point-to-point leakage rate at time i is calculated as Mp. =

2400

,1 t l. - t.1- l The leakage rate of dry air from containment at ti, Li, expressed 1n units of percent per day is shown below.

Li = - (B + Aq) where A = Rate of change of Point to Point leakage rates, (%/day/hr).

B = Calculated value of Point to Point leakage rate at t1 (%/day).

Bases-66

NED0-31722 UKAtl Let ST= Starting data set number of the calculation range.

SP= Ending data set number of the calculation range.

N = Number of Point to Point Leakage rates to be Least Squares Fit.

N = SP - ST For the above set of point-to-point leakage rates, A and B for the range of internal leakage rates starting from ST+l and extending to SP are calcu-lated as shown below:

SP

. SP L. L SP N

L t. Mp. -

l ,1 t.

l Mp.,1 A =

i=ST+l N

SP L.

i=ST+l

( t.) 2 l

i=ST+l

- L( SP i=ST+l ti y

i=ST+l SP SP SP SP B =

L i=ST+l Mp ,1.

L i=ST+l (t.)

l 2

L tiL i=ST+l i=ST+l Mp.

,1 t.

l SP N

L i=ST+l

( t.)

l 2

89.8.3 Total Time Method This method is based upon the assumption that the rate of change of leak-age rate is constant during the testing period. If this is true, and if there was perfect containment modeling and instrumentation, a plot of containment leakage rates versus time would be a straight line with a negative slope. The leakage rate of dry air mass out of containment is proportional to the equa-tion of the line. In a real case, the leakage rates are scattered about any straight line drawn through them.

Bases-67

NE00-31722 UttAtl The Total Time Method calls for performing a Least Squares Fit of the total time leakage calculations. This fit determines the slope and the Y-Intercept of the line that minimizes the total amount of scatter of these points along its path.

Each time a data set is collected during the Type A test, the time of collection, the total containment dry air mass, and the total time leakage rate at that time are calculated and stored.

A collection of K such points are shown below.

where ti = Time (hours) at which data set 1 was collected. By definition, the time at t1 equals zero.

= Total Containment Dry Air Mass (Lbm) at time ti*

MT,i = Total Time Leakage Rate at time ti (weight percent per day).

The total time leakage rate at time ti 1s calculated as shown below.

2400 MT.,1

=

Bases-68

NED0-31722 Let UMAfT ST = Starting data set number of the calculational .range.

SP= Ending data set number of the calculational range.

N = Number of Total Time Leakage rates to be Least Squares Fit.

N = SP - ST For the above set of total time leakage rates, A and B for the range of mass points starting from ST and extending to SP are calculated as shown below.

SP SP SP .

N L

i=ST+l

t. MT. -

1 ,1 L L i=ST+l t.

1 i=ST+l MT.,1 A=

- L )2 SP N

L i=ST+l (t.)2 1

( SP i=ST+l ti SP SP SP SP L L ( t. )2 -

L L t. t.

r MT.

,1 l. l.

MT.

, l. 1

- = i=ST+l B

i=ST+l i=ST+l i=ST+l SP N

L i=ST+l (t.)2

l. - L

( SP i=ST+l ti where A= Rate of change of Total Time Leakage Rates, (%/day/hr).

B = Calculated value of Total Time Leakage Rates at tsT (%/day).

The leakage rate of dry air from containment at ti, Li, expressed in units of percent per day is shown below.

Li= - (B + Ati)

Bases-69

NED0-31722 DRA fl Let T be the student's t distribution function at the 95th percentile, expressed as a function of N.

T = l.6449(N-2) + 3.5283 + 0.85602/(N-2)

(N-2) + 1.2209 - 1.5162/(N-2)

Ignoring negligible terms, the 95% Upper Confidence Limit (UCL) of the true Leakage Rate is given below in units of percent per day.

UCL= L + To Let SP 2 1

(tp 1 N-2 L ti) i=ST+3 F = N-2 + SP L

i=ST+3 t~ - N:2

(

L SP i=ST+3 ti

)

Then 1/2 SP SP a =

L i=ST+3 M_

-T, i - A 'L....J°"

i=ST+3 Kr,i 89.8.4 BN-TOP-1 Method This method calculates total time leakage rates and the statistical leak-age rate in a manner identical to that specified in Section 89.8.3. Only the Upper Confidence Limit (UCL) is calculated differently, and that methodology is described here.

Bases-70

NED0-31722 URAFT The student's t distribution used for the 8N-TOP-l Method is a double sided distribution at the 97.5 percentile.

T = 1.95996 + 2.37226 2.8225 (N-2) + (N-2)2 Ignoring negligible terms, the 97.5% Upper Confidence Limit of the leakage rate is given below in units of percent per day.

UCL= L + To L was given in Section 9.8.3.

Let F = l + -

l+

(tp - (N-2) l SP L ti i=ST+3 y

~L N-2 SP SP )2 L

i=ST+3 t~ -

i=ST+3 ti

- Then 1/2 a *[(N~2) ( f i=ST+3

<Iir ,1. )2 - 8 SP L

i=ST+3 t-lr--A

,1 SP L

i=ST+3 1'lr, i t~

89.9 VERIFICATION TEST 89.9.1 General Requirements The same calculational methods, time steps, and instrumentation should be used for both the Type A test and the verification test, because the purpose of the verification test is to qualify the instruments used for the Type A 8ases-71

NED0-31722 test.

DRAFT Any changes to the calculational methods, time steps, or instrumenta-tion might change the calculated leakage rate and nullify the verification process.

89.9.2 Test Start Time The verification test procedure is based on the assumption that the actual containment leakage rate is constant. The error resulting from any small rate of change in leakage rate may become large over a long time period.

Data must continue to be collected during the interim period in case the start of the verification test is unexpectedly delayed long enough to result in a significant difference between leakage rates at the end of the Type A test and the start of the verification test. Then the data is used as part of the Type A test, and the error is eliminated by sliding the Type A test end time forward to the start of the verification test. A difference of less than 0.1 La was chosen as the criteria. In most cases, this much error in the Type A test will still allow passage of the verification test within the

+0.25 La band.

89.9.3 Stabilization Period 8N-TOP-l, Section 2.3.C.l, states that containment atmospheric conditions shall be allowed to stabilize for about one hour after superimposing a known leakage rate.

Although starting the verification test stabilization period too soon or extending the period too long will result in an unnecessary extension in the time required to verify the Type A test results, it will not result in verification of an invalid Type A test.

8ases-72

NED0-31722 DRAFT B9.9.4 Measurement of Induced Leakage Rate/Verification Test The verification test compares a known leak.age rate against the measured containment leakage rate. Any flow measurement instrument that meets the spe-cifications listed in Section 8.2.4 is sufficiently accurate to quantify the induced leakage relative to the known acceptance criteria for the measured leakage rate.

The verification test methodology is based upon the assumption that the induced leakage is constant, therefore it should not be intentionally varied.

Since the differential pressure across the flow measurement device is essen-tially constant over the duration of the verification test, no manual adjust-ments should be required in order to maintain this constant flow rate. In some cases, however, the measured value of induced leakage rate may drift a small amount. Readings of the leakage rate should be periodically taken in order to verify that the amount of drift has not become excessive, and to alert the licensee to make corrections if needed. Typically, a drift of less than 0.05 La should not adversely affect results, and therefore no correction would be required.

B9.9.5 Calculation of Target Leakage Rate Once the final value of the LSLR is known from the Type A test, a known additional leakage is induced from the containment. The new containment leakage rate is expected to equal the LSLR plus this induced leakage rate. It should be noted that the above statement is based upon the assumption that the LSLR remains constant during the course of the induced leak.age rate test.

The acceptable range of induced leakage rates was chosen to be between 0.75 La and 1.25 La. This is due to the fact that this range conunonly appears in many plant's existing Technical Specifications. Also, use of induced leakages in this range for many CILRTs has proven to be. both practical and acceptable.

Bases-73

NED0-31722 URAfI Flow meters commonly measure the induced leakage rate in units of scfm or seem. Since these volumetric flow rates are specified at a standard temper-ature and pressure, the density of the air is known. Thus, the mass flow rate is specified.

Plant Technical Specifications list acceptance criteria in units of

%/day. An equation must be used to relate leakage in %/day to scfm.

Percent/day implies the percent of the total containment inventory per day that is leaking out of containment. The fact that the inventory is changing during the verification test is ignored, and the containment dry air mass present at the start of the verification test is used at all future times.

Many different values of standard temperature and pressure are listed in various references. One pair was specified here for the sake of uniformity.

The mass flow rate M.1n d of the induced leakage rate equals Qscfm Pstd" Substituting, M.

Q scfm d = R (T P

st (144) lbm/min 10 + 459.69) st The total dry air mass of containment at the start of the verification test M0 is 144 P V C C Mo= R (T + 459.69 )

av Bases-74

NED0-31722 DR Afl The leakage rate Qin percent/day is

. M. d Q = ~n (100) (1440) %/day 0

Substituting, Q Pt (144) R (T + 459.69) (144,000) scfm s av R (T t + 459.69) P V (144)

S C C

• ( VC P C (T St + 459.69) )

89.9.6 Test Duration BN-TOP-1, Section 2.3.C.2, states that the verification test duration shall be approximately equal to half of the integrated leak rate test duration.

If a method other than BN-TOP-1 is used, no minimum duration for the ver-

- ification test is required. However, for the verification test to be declared successful, the LSLR measured during the verification test must be stable and within the acceptance band described in Section 9.9.7(2). Continuation of the test after these two conditions are met will only serve to unnecessarily extend the time to perform the verification test and will not result in veri-fication of an invalid Type A test.

89.9.7 Acceptance Criteria The accuracy of the Type A test measuring system and the leakage rate test results are verified provided the difference between the induced leakage rate and the Type A test leakage rate is within 0.25 La** The acceptance band specified in Section 9.9.7 is consistent with Reference 8.

Bases-75

NE00-31722 B9.10 DEPRESSURIZATION DRAFT Like Section 9.5, Section 9.10 only provides awareness of the potential for equipment damage. Each plant must determine the appropriate depressuriza-tion rate to avoid equipment damage due to outgassing.

Bases-76

f NED0-31722 URAFT 810.0 TYPE 8 AND C TEST METHODOLOGY 810.1 GENERAL This section provides acceptable Type 8 and C test methodology. ANSI N45.4 and 10CFR50 Appendix J do not provide specific test methods (only test parameters). ANSI/ANS 56.8 (which has yet to be endorsed by the NRC) does provide pressure decay, flow rate, water collection, and vacuum retention as acceptable test methods. All these methods are outlined in Section 10.0. In

- addition water displacement and bubble testing are included.

810.2 TEST METHODS 810.2.1 Pressure Decay Method Pressure decay is probably the most frequently used test method. This method employs the ideal gas law to measure the change in volume with respect to changes in temperature and pressure. The methodology and leak rate equa-tion in Section 10.2.1 is consistent with ANSI/ANS 56.8. The derivation for the pressure decay formula is provided below.

From the ideal gas law PV n =

RT Leakage is obtained by taking the derivative with respect to time L' = dn = V d(P/T) dt R dt V[1 dtdP P dT]

= R T T2 dt 8ases-77

NE00-31722 DRAFT '

If we assume that P and Tare linear functions of time L' ~ [~P _P~TJ

=

RT~t T where T = Average temperature=

P = Average pressure=

Substituting, Bases-78

NED0-31722 DR Afl L' = a!t [:~ - ::] in lbm mole/hr where V = molar volume of air at 14.696 psia and temperature T.

Since V = _T__

R 14.696 If T = Tst, standard temperature (68°F) Lis in Standard Cubic Feet per Hour.

Bases-79

NED0-31722 where URAfl Vis in ft3 p lS in psia T is in OR At is in hr Ts is in OR V [pl p2] 527.69 L' = At T - T 14.696 scfh 1 2 L' = !t [:: - ::] 35.9 scfh To conservatively correct the leakage rate to what it would have been if the test volume had been maintained above Pa:

L = LI (CF) where 1

p - p CF = 1 PAVE ---

PAVE Pl + p2 2 + 14.696 Pl + p2 PAVE = 14.696 =2 X 14.696

+ 1 L = Corrected leak rate (SCFH)

V = Total test volume (ft3)

Bases-80

NED0-31722 DRAFT At= Elapsed time (hr)

P1 = Initial pressure (psia)

P2 = Final pressure (psia)

PAVE = Average test pressure of the test (atmospheres) p = Peak accident pressure (atmospheres)

T1 = Initial temperature ( 0 R)

T2 = Final temperature ( 0 R)

L' = Measured leakage rate (SCFH)

In some cases, when the pressure decay method is used, the pressure in the test volume drops below Pa* Reference 11, page 26, Equation 39 can be used to correct the measured leakage rates for this drop in pressure. A short derivation of this correction factor is shown below.

Fully developed, isothermal viscous gas flow through a circular channel is described by the Hagen-Poiseville equation.

p - p =

a o where M = Air's viscosity V = Average velocity 1 = Channel's length D = Channel's diameter Sc = Gravitational constant Pa = Pressure (psi)

Pa = Ambient pressure (psi)

The mass flow rate of the air (Wa) at test pressure Pa is equal to Q Pavg, where Q is the air's volumetric flow rate and Pavg is the air's average den-sity. The channel cross sectional area, A is equal tow n2/4. Also, V = Q/A.

Bases-81

NED0-31722 UKAtI From the above equations, it can be seen that 4

g ,r D W = _c_ __

(p ) (Pa - Pa) a 128 Ml avg For a perfect gas, Pavg is equivalent to Pavg/R Ta*

where Pavg = Average pressure Ta = Average temperature R = Appropriate gas constant For isothermal conditions, this flow's Pavg may be approximated by p + p a a 1 Pavg = 2 R T a

gc ,r D4 wa = 256 Mt R T1 (P a 2 p 2) a a

Let 4

gc ,r D 1

= a constant K 256 Mt RT a 2 2 W = K (P - P )

a a a Bases-82

NED0-31722

Let p

p a

=

a P'a

-p 2 = p 2/P 2 a a a

- wa = K CPa 2 p 2 a

p 2) = K p 2 The correction factor CF =

a L

a a

CPa 2 - 1>

Lt where La = Leakage rate expected if the test were conducted at Pa Lt= Leakage rate at the actual test pressure Wa = Mass flow rate at the test pressure Pa Wt= Mass flow rate at the actual test pressure Pt= Final test pressure {atmospheres)

Pa= Peak accident pressure (atmospheres)

Converting mass to volume (leakage rate),

wa La= and Pa where Pa and Pt are the densities of the gas at Pa and Pt, respectively.

RT p

a CF=

RT pt Bases-83

NED0-31722 w

DRAFT CF= a wt 2 - 1) P K (Pa_____

CF = ___ t K (P 2 - 1) P t a P - 1/P a a CF=

Pt - 1/Pt B10.2.2 Flowmeter Makeup Method The use of rotameters or mass flow meters is useful in measuring large leak rates where a pressure decay test is not practical, or when the test volume is unknown, therefore not allowing the use of the pressure decay method. The test methodology is consistent with ANSI/ANS 56.8.

B10.2.3 Water Displacement Method The water displacement method is an easy leak test to perform. Typically water displacement tests are conducted on systems normally filled with water, thereby saving time. The water displacement method assumes any loss from the test container is a direct measurement of component leakage. As long as the water source has been vented or disconnected, it is a safe assumption. The test methodology and leak rate equation in Section 10.2.3 is not addressed in ANSI/ANS 56.8, ANSI N45.4 or 10CFR50 Appendix J.

B10.2.4 Vacuum Testing Method The vacuum testing method is basically the same as the flowmeter method.

To use this method it has to be proven that all the leakage is passing through the flowmeter.

Bases-84

NEDO-31722 Bl0.2.5 Bubble Testing Method DRAFT Bl0.2.5.1 Immersion Immersion testing is seldom used due to the need to immerse the test com-ponent. Immersion testing is typically used in locating leaks rather than quantifying leak rates.

Bl0.2.5.2 Liquid Application Method This method is usually used 1n conjunction with other methods.

Quantifying leak rates with this method is not practical. To use this method the acceptance criteria must be zero leakage.

Bl0.2.5.3 Bubbler Column This method is useful in detecting very small leaks, but quantification of the leak is not possible.

Bl0.2.6 Continuous Monitoring This section requires that penetrations served by continuous leakage mon-itoring systems must be leak rate tested, as required by Paragraph II.D.2{a) of 10CFR50 Appendix J. The method of determining the leakage rates must be technically justifiable. Both pressure decay and makeup volume are accepted methods for determining leakage rate.

Bl0.2.7 Reference Vessel Method The reference vessel method may be used to measure the leak rate of a test volume when its volume is unknown. This is basically a pressure decay test using an additional test tank of known volume. The leakage rate equation is the same as that developed in Section 10.2.1.

Bases-85

NED0-31722 APPENDIX REPORTING REQUIREMENTS REPORTING FORMAT The following format shall be used in reporting Type A, Band C test results. Each format section has editorial comments delineating the required information. If a Type A test is not performed, these sections shall be marked "N/A."

REACTOR CONTAINMENT BUILDING INTEGRATED LEAKAGE RATE TEST TABLE OF CONTENTS DEFINITION OF SYMBOLS AND ABBREVIATIONS Provide a listing of all symbols and abbreviations used in text of report. Symbols and abbreviations used in attachments should not be included here.

1.0 ABSTRACT Identify plant, plant docket number, plant owner, plant location, outage cycle, date of test completion, a description of primary containment, and test results. This section should be short and concise.

2.0 INTRODUCTION

2.1 TYPE A TEST (as applicable) 2.1.1 Test Summary Identify test instruction and technical data, such as design temperature and pressure, peak accident temperature and pressure, test duration, contain-ment volume, and allowable leakage rate.

A-1

NED0-31722 2.1.2 Conclusion DRAFT Provide comparison of test results, both total time*and mass point for as~found and as-left conditions. Provide a positive statement as to whether the test passed or failed as-found and as-left criteria.

2.2 TYPE BAND C TESTS 2.2.1 Test Sununary Identify test instructions and types of tests.

2.2.2 Conclusion Provide minimum and maximum pathway leakage rates for as-found and as-left conditions. Provide positive statement as to whether accumulation of path leakage rates passed or failed criteria. Do not discuss individual components in this section.

3.0 CONTAINMENT INTEGRATED LEAK RATE TEST (as applicable) 3.1 GENERAL TEST DESCRIPTION 3.1.1 Containment Inspection Briefly discuss how primary containment was inspected and any findings and corrective action.

3.1.2 Equipment and Instrumentation Briefly discuss pressurization equipment, types and quantities of instru-mentation, verification test equipment, and depressuri~ation equipment.

A-2

NED0-31722 DRAFT 3.1.3 Data Acquisition System Provide a description of the data acquisition system. This section sho~ld be detailed enough so that it stands alone. No other portion of the report discusses the data acquisition system.

3.1.4 Systems and Penetrations Not Tested Provide a list and explanation of all systems and penetrations that were in service or isolated during the test.

3.2 EDITED LOG OF EVENTS Provide an edited version of the log maintained during the performance of the CILRT.

3.3 TEST RESULTS 3.3.1 Mass Point Analysis Provide a detailed description of Type A test results using the mass point analysis. Provide figures in Attachment 1 (see Paragraph 6.1) as aids for clarification. Do not provide equations if a standard or technical report can be referenced. Provide justification for rejected data, as applicable.

3.3.2 Total Time Analysis Provide the same information as in 3.3.l using total time analysis.

Refer to Attachment 2 (see Paragraph 6.2) for clarification of results.

3.3.3 Instrument Selection Guide Provide the results of .the instrument error analysis.

A-3

NED0-31722 3.3.4 Verification Test DRAFT Provide the amount of imposed leakage and the measured leakage by the CI)'.JtT measurement system.

3.3.5 Leakage Penalties Added to the Calculated Type A Leakage Rate Identify all penalties added to the calculated Type A leakage rate as a result of systems in service and penetrations isolated.

4.0 TYPE BAND C TESTS 4.1 COMPONENTS NOT TESTED Provide a list of components/pathways not subjected to Type B or C testing and a brief description of the reason why they were not tested.

4.2 AS-FOUND LLRTs 4.2.1 MXPLRs and MNPLRs Provide the totals for the HXPLRs and MNPLRs. Refer to Attachment 3 (see Paragraph 6.3) for list of individual HXPLRs and MNPLRs.

4.3 REPAIRS AND ADJUSTMENTS Provide a description of any repairs or adjustments made as a result of the as-found testing. Use the following format. Do not include components on which no repairs or adjustments were made.

A-4

NED0-31722 DRAFT Penetration Component Repair Description

-X-10 2-FCV-71-2 Replaced valve seat and increased torque switch set-ting from 2.25 to 2.5.

4.4 AS-LEFT LLRTs 4.4.l MXPLRs and HNPLRs Provide the totals for the MXPLRs and MNPLRs. Refer to Attachment 3 for list of individual MXPLRs and MNPLRs.

4.4.2 Type Band C Running Total Provide the as-left Type Band C Running Total Containment Leakage Rate (RTCLR) and the Total Containment MXPLR.

5.0 CORRECTIVE ACTION PLAN (as applicable)

Provide a detailed corrective action plan in lieu of increased CILRT testing frequency.

6.0 ATTACHMENTS 6.1 ATTACHMENT 1, PRIMARY CONTAINMENT LEAKAGE RATE AND UCL vs. TIME, MASS POINT ANALYSIS This is to be used 1n conjunction with Section 3.3.1 to explain analysis of test results.

A-5

fl-NE00-31722 6.2 u~AFT ATTACHMENT 2, PRIMARY CONTAINMENT LEAKAGE RATE AND UCL vs. TIME, TOTAL TIME ANALYSIS This is to be used in conjunction with Section 3.3.2 to explain analysis of test results.

6.3 ATTACHMENT 3, TYPE BAND C TEST RESULTS Provide a list of as-found and as-left LLRTs in tabular form. Use the format of Table 1 on the following page. This table should include all containment penetrations tested. The tables prepared per Section 4.3 will be a subset of this table.

A-6

Table 1 Leakage (SCFH) MXPLR MNPLR Penetration Test Procedure Test Test As-Found As-Found As-Found MNPLR Number Description No. & Rev. Date Date Method As-Left As-Left As-Left Reduction X-10 2-FCV-71-2 2-S1-4. 7-71a 3/16/89 A 100 2/11/79 3/20/89 10 2-FCV-71-3 2-Sl-4.7-71b 3/16/89 B 50 100 50 2/11/79 3/20/89 --5 10 -5 45 X-11

)>

I

-.I The column labeled "Test Method" shall be used to delineate how the component was tested. Use the following codes:

A - Inboard component tested separately.

B - Outboard component tested separately.

C - Inboard component tested simultaneously with other components.

D - Outboard component tested simultaneously with other components.

E - Inboard and outboard component(s) tested simultaneously.

DOCKET((

LONG ISLAND LIGHTING COMPANl¥C SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY ROAD* WADING RIVER, N.v8f, 7d'fflY 13 P12 :19 JOHN D. LEONARD, JR .

VICE PRESIDENT

• NUCLEAR OPERATIONS May 4, 1987 VP-NO 87-94 Mr. Samuel J. Chilk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Request for 10 CFR 50,Public Comment on the NRC's Proposed Amendment of Appendix J - Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors - Federal Register, Vol. 51, No. 209, Wednesday October 29, 1986.

Dear Mr. Chilk:

The Long Island Lighting Company (LILCO), owner and operator of the Shoreham Nuclear Power Station, respectfully desires to comment on the subject NRC proposal to revise Appendix J of 10 CFR 50.

LILCO wishes to endorse the positions expressed in the Boiling Water Reactor Owners Group (BWROG) Comments as submitted to the NRC on this proposed revision.

• In particular, LILCO agrees with BWROG wherein they suggest in the proposed revision that clarification should be provided as to when "as found testing" is or is not required. We propose that in certain cases it may not be required, either based on past performance of components, or in other cases it might not be feasible to be performed.

We also agree with BWROG that the purpose and scope of the "Corrective Action Plan" proposed by the revision be delineated in order to provide a common ground for obtaining consistent maintenance and leakage rate testing objectives.

Further, in order to promote a common basis of understanding and to limit misunderstanding, we recommend that unambiguous definitions be given for all terms used as test and acceptance criteria including such terms as "major modification" and "hydraulic test".

b.Cknowledged by card *................ , *, rw,,

• bstf

r

VP-NO 87-94 Page 2 LILCO also wishes to endorse the comments on the Appendix J rulemaking submitted by the Nuclear Utility Backfitting and Reform Group (NUBARG).

In general, LILCO along with NUBARG, welcomes efforts to streamline the leakage rate testing regulations and to present the requirements in "plain language". However, we suggest that in view of our understanding that within the next year or two the Commission is planning a more comprehensive updating and streamlining of Appendix J and because, as has been stated by the NRC, there appears to be no safety concern requiring adoption of the proposed revisions at this time, the Commission might consider deferring the proposed rulemaking at this time until the more comprehensive rulemaking is proposed. However, in the light of the extensive review and comments which have now been provided by the industry in general, LILCO believes that it would be prudent to expedite the more comphrehensive rule making in order to resolve the open issues concerning leak rate testing in the near future.

LILCO welcomes the opportunity to supply its comments on this important proposal to amend the Commission's regulations on leakage rate testing.

Sincerely, Leonard, r ce President-Nu

- oocKET NUMBER PRO OSED RULE R_o?J

.~ &-

5 / F~ .39I~(L, DOL'KETEO U5NHC TESTING' ENGINEERING & Rl8£AMtJ-t2,~S TER-87-007 April 20, 1987 Mr. Gunter Arndt Office of Nuclear Regulatory Research

u. S. Nuclear Regulatory Commission Washington, D. c.

Subject:

Response to 10 CFR 50, Appendix J Revisions

Dear Mr. Arndt:

In accordance with the Federal Register, the fol lowing comments consist of my response to the Revised Appendix J:

1. Ref: III.A(4) & III.A(6) Full pressure test.

Comment: About 15 ILRT's annually are performed at reduced pressure. While it is logical that an ILRT at full pressure best simulates an LOCA condition, provisions to preclude alternatives to reduced pressure (eg. 2 psig) or subatmospheric as a montioring device with the intent to extend the interval between ILRT should not be thrown out (which this revision would do).

NUREG/CR-4398 assumes erroneously that there is no cost difference for BWR's versus PWR's. A typical PWR has an ILRT pressure of 40 psig where the typical BWR (I, II, & III) have an ILRT a~er~~ pressure of 20 psig. Considering the designed volume and pressure differences, this revision represents a significant hardship to PWR's. This quantification, based on over 400 ILRT reports, is 20 psig divided by 5 psig / hr time two (press. & depress.) or 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> minimum additional. Further not addressed is the increase in compressor costs for additional time and/or increased rate (faster than 5 psig/hr).

Rec: Modify the Appendix to provide for a monitoring system as a trade-off (incentive) for full pressure ILRT at l onger than four year intervals (1 per 5 years).

• 5800 E. Skelly Drive, Suite 175

• Tulsa, OK 74135 * (918) 664-0300

.J t0M ECTI~*

ETARY OF ION Ootument Stati tic, tmark Oat 0/11 I

Add'/ o..,.. . *~ * '2-lipecial Distribution ~ 6.s;, --::r-,-

H/l

_ {r

2. Ref: Testing Methods per Reg Guide Comment: Attachment 1 is a list of 32 cases in which the Reg Guide formulas were applied. Since many plant already perform a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ILRT there exist individually some saving of time but a potential for all to run the Type A and Verification far longer than the current 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> rule-of-thumb.

For those pl ants that perform a BN-TOP short duration ILRT, this revision offers little in terms of time economics and offers little more in statistical improvement. With regard to the formulas per se, after running all these data sets, there is not a closed mathematical expression for A', B', and C' therefore, problems can take place. Further, it is difficult to visualize the physical containment based on the

• Rec:

results. A least squares fit assumes a constant 1 eakage rate where a parabo 1 a assumes a non-uniform leak time independent.

To apply the criteria to both the Type A and Verification, is not necessary and should be deleted. A mathematically closed equation should bein the RegGuide for A', B', and C' along with the correction of Formulas 2.17, 2.18, and 2.19 for ti and definitions for all variables. The formulas should be evaluated against as many ILRT's as possible as to identify problems (industry generic, containment type relevant, or by plant method), or for equation refinement.

The practical details are not yet clear. If both conditions are SAT for the first time, does the user quit and perform the verification? My review indicates that the condition may change of may be intermittantly SAT. What does the user do if the test is run "too long" and then one condition becomes UNSAT? Examples of practical applications will result in a better understanding of intended use. Also, I firmly believe that there exists two better Type A termination criterias (EPRI NP-3400 and WJE&A's predictor).

I commend the NRC on its effort in clarifying the old Appendix J version. I believe this revision has some positives and can be workable given some refinement and research which hopefully can occur during the processing cycle. If this cannot occur, I recommend that this Version be withdrawn until such time a pristeen Version can be created.

2

ILRT Cond.1 Cond.2 Poss.Term Actual ANO 1-84 Always Sat. Sat @l.25hrs 1.5hrs. 8hrs.

2-85 Always Sat. Sat >4hrs 4hrs. 8hrs.

Beaver Valley 1-86 Intermittant Intermittant 2.33hrs. 8hrs.

Browns Ferry 1-81 Inter to SAT Always SAT 2 18.25 2-83 Always SAT Always SAT ASAP 24 Brunswick 1-81 Inter Inter 19.75 24 1-85 Always SAT Always SAT ASAP 13.25 2-82 SAT> 4.25hrs. Always SAT 4.5 24

• Byron 1-83F 1-83H Always SAT Intermittant Calvert Cliffs SAT >9.75hrs SAT >12.5hrs.

10 12.75 24 24 1-78 Always SAT Always SAT ASAP 9.25hrs.

1-82 Always SAT SAT >1. 5hrs. 1.5hrs. 8hrs.

1-85 Always SAT SAT >1.25hrs. 1.25hrs. lOhrs.

2-82 Always SAT SAT >lhrs. 1hr. 8hrs.

2-85 Always SAT SAT >6.5hrs. 1.5hrs. 16hrs.

Clinton 1-86 Always SAT Always SAT ASAP 9.25hrs.

D. C. Cook 1-74 Always Sat. Sat. @20hrs. 20hrs. 24hrs.

1-78 Always Sat. Int.until 8.5hrs. 8.5hrs. 14hrs.

1-81 Int.until 9hrs. Int.until 9.5hrs. 9.5hrs. 24hrs .

1-85-1 Sat.until llhrs Unsat.until 8.5hrs. 8.5hrs. 26.5hrs.

1-85-2 Always Sat. Unsat.until 10.5hrs.10.5hrs. 24hrs.

2-77 Always Sat. Always Sat. Anytime 31.5hrs.

Conneticut Yankee 1972 SAT <15hrs. SAT at 10-14hrs. lOhrs. 24hrs.

1984 SAT to 18.75hr.SAT after 20.5hrs. NOT MET 36hrs.

Cooper 1-85 Always SAT Always SAT ASAP 24hrs.

Diablo Canyon 1-85 Always SAT Inter SAT to >2.5 2.5hrs 24hrs.

3

ILRT Cond.1 Cond.2 Poss.Term Actual Grand Gulf 1-85 Always SAT Always SAT ASAP 8.5hrs.

Ginna 1982 Always SAT SAT >6.5 hrs. 6.5hrs. 24hrs.

1985 Always SAT SAT >7.5 hrs. 7.5hrs. 24hrs.

Hatch 1-82 Always SAT Always SAT ASAP 10.75hrs.

2-78 Always SAT Always SAT ASAP 9hrs.

Indian Point 3-82 Always SAT SAT >2.25hrs. 2.25hrs. 24hrs.

• Average Type A Test 6.5*hrs 18.4hrs.

• If ASAP not counted and no minimum. If minimum of 8hrs., then the average time is 9.2hrs .

4

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

AN0184.DAT PAGE 1 DATE 24-1987 TIME - 12:04:09 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1 ) ( 1. 1) < .25 (1) (2. 1) ( 2. 1 ) ( 2) 1 0 0.0000 0.0000 0.0000 0.0000 SAT 0.0000 0.0000 UNSAT 2 15 0.0000 0.0000 0.0000 0.0000 SAT 0.0000 0.0000 UNSAT 3 30 0.2229 0.0000 5.6294 1.6887 SAT 0.8394 0.8325 SAT 4 45 0.0594 0.0338 161.1086 1.6212 SAT 0.1405 0.3290 UNSAT 5 100 0.0446 0.0240 18.4995 0.8299 SAT 0.1527 0.2444 UNSAT 6 115 0.0455 0.0063 10.1152 0.3739 SAT 0.2476 0.2715 UNSAT 7 130 0.0352 0.0171 7.7071 0.3715 SAT 0.2315 0.1927 SAT ~

8 145 0.0404 0.0042 6.6086 0.1238 SAT 0.3681 0.2483 SAT 9 200 0.0410 0.0012 5.9883 0.0661 SAT 0.4615 0.2618 SAT 10 215 0.0405 0.0010 5.5920 0.0495 SAT 0.5354 0.2640 SAT 11 230 0.0341 0.0093 5.3179 0.1535 SAT 0.4945 0.2075 SAT

~

245 0.0224 0.0979 5.1173 0.3405 SAT 0.2669 0.1034 SAT 300 0.0154 0.1213 4.9643 0.3867 SAT 0.1592 0.0530 SAT 315 0.0207 0.0365 4.8438 0.1812 SAT 0.2767 0.0928 SAT 15 330 0.0205 0.0428 4.7466 0.1420 SAT 0.3167 0.0929 SAT 16 345 0.0298 0.0232 4.6664 0.0823 SAT 0.4357 0.1798 SAT 17 400 0.0345 0.0762 4.5993 0. 1641 SAT 0.5270 0.2297 SAT 18 415 0.0372 0.0936 4.5422 0.1881 SAT 0.5959 0.2600 SAT 19 430 0.0347 0.0400 4.4931 0.0984 SAT 0.5913 0.2363 SAT 20 445 0.0347 0.0293 4.4503 0.0807 SAT 0.6281 0.2383 SAT 21 500 0.0383 0.1713 4.4129 0.1455 SAT 0.6777 0.2779 SAT 22 515 0.0370 0.1987 4.3797 0.0926 SAT 0.6893 0.2662 SAT 23 530 0.0392 0.2231 4,3502 0.1253 SAT 0.7281 0.2906 SAT 24 545 0.0376 0.1893 4.3238 0.0715 SAT 0.7301 0.2756 SAT 25 600 0.0385 0.3207 4.2999 0.0812 SAT 0.7599 0.2869 SAT 26 615 0.0394 0.1754 4.2783 0.0884 SAT 0.7858 0.2975 SAT 27 630 0.0404 0.5203 4.2587 0.0989 SAT 0.8087 0.3097 SAT 28 645 0.0380 0.0590 4.2407 0.0312 SAT 0.7855 0.2857 SAT 29 700 0.0379 0.0347 4.2242 0.0243 SAT 0.8014 0.2855 SAT 715 0.0387 0.0782 4.2090 0.0413 SAT 0.8204 0.2960 SAT 730 0.0395 0.3409 4.1950 0.0548 SAT 0.8372 0.3058 SAT 32 745 0.0389 -0.2530 4.1820 0.0339 SAT 0.8435 0.3000 SAT 33 800 0.0408 -2.2763 4.1700 0.0743 SAT 0.8498 0.3220 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

AN0285.DAT PAGE 1 DATE 24-1987 TIME - 12:04:43 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) ( 2. 1 ) (2 . 1 ) ( 2) 1 0 0.0000 -2.2763 4.1700 0.0743 SAT 0.8498 0.3220 SAT 2 15 0.0000 -2.2763 4.1700 0.0743 SAT 0.8498 0.3220 SAT 3 30 0.1161 0.0000 5.6294 0.7008 SAT 0.9705 0.8436 SAT 4 45 0.0606 0.0235 161.1086 1.5578 SAT 0.6231 0.6711 UNSAT 5 100 0.0672 0.0038 18.4995 0.4053 SAT 0.7964 0.7462 SAT 6 115 0.0611 0.0027 10.1152 0.3822 SAT 0.8399 0.7282 SAT 7 130 0.0559 0,0184 7.7071 0.3745 SAT 0.8651 0.7067 SAT 8 145 0.0407 0.0288 6.6086 0.7462 SAT 0.6772 0.5732 SAT 9 200 0.0196 0.0854 5.9883 1.2318 SAT 0.1949 0.2453 UNSAT 10 215 0.0092 0.2274 5.5920 1.1980 SAT 0.0555 0.0691 UNSAT

-245 11 230 300 315 0.0188 0.0188 0.0332 0.0397 0.4184 0.1084 0.1028 0.2884 5.3179 5.1173 4.9643 4.8438 0.4613 0.3242 0.3463 0.5312 SAT SAT SAT SAT 0.2067 0.2530 0.4100 0.5225 0.2410 0.2455 0.5082 0.6019 UNSAT SAT UNSAT UNSAT 15 330 0.0428 1.0633 4.7466 0.5287 SAT 0.6019 0.6406 UNSAT 16 345 0.0385 -0.1018 4.6664 0.2312 SAT 0.5786 0.5948 UNSAT 17 400 0.0382 0.1676 4.5993 0.1674 SAT 0.6180 0.5938 SAT.,

18 415 0.0426 -0.3366 4.5422 0.3220 SAT 0.6776 0.6486 SAT 19 430 0.0406 -0.4412 4.4931 0.1700 SAT 0.6842 0.6283 SAT 20 445 0.0430 0.6297 4.4503 0.2449 SAT 0.7289 0.6571 SAT 21 500 0.0406 0.0949 4.4129 0.1002 SAT 0.7230 0.6330 SAT 22 515 0.0415 -0.1019 4,3797 0.1226 SAT 0.7569 0.6459 SAT 23 530 0.0423 -0.1083 4.3502 0.1359 SAT 0.7854 0.6562 SAT 24 545 0.0434 -0.1475 4.3238 0. 1624 SAT 0.8110 0.6692 SAT 25 600 0.0428 -0.0547 4.2999 0.1176 SAT 0.8247 0.6657 SAT 26 615 0.0442 -0.1135 4.2783 0.1632 SAT 0.8436 0.6812 SAT 27 630 0.0435 -0.0621 4.2587 0.1063 SAT 0.8518 0.6750 SAT 28 645 0.0462 -0.3827 4.2407 0.2149 SAT 0.8559 0.7028 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

BEVAL186.DAT PAGE 1 DATE 24-1987 TIME - 12:05:24 REC TIME LAM LEFT < RIGHT EQ (1.2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2.1) (2. 1 ) ( 2) 1 0 0.0000 -0.3827 4.2407 0.2149 SAT 0.8559 0,7028 SAT 2 10 0.0000 -0.3827 4.2407 0.2149 SAT 0.8559 0.7028 SAT 3 20 0.1933 0.0000 5.6294 0.5078 SAT 0.9890 0.9374 SAT 4 30 0.1539 -0.0002 161.1086 0.8598 SAT 0.9516 0.9293 SAT 5 40 0.0976 -0.0071 18.4995 1.8993 SAT 0.7161 0.8613 UNSAT 6 50 0.1082 -0.0021 10.1152 0.5635 SAT 0.8339 0.8938 UNSAT 7 100 0.1005 -0.0062 7.7071 0.5591 SAT 0.8663 0.8860 UNSAT 8 110 0.0966 -0.0041 6.6086 0.4674 SAT 0.8980 0.8833 SAT 9 120 0.0866 -0.0080 5.9883 0.6488 SAT 0.8851 0.8638 SAT 10 130 0.0795 -0.0145 5.5920 0.6933 SAT 0.8821 0.8466 SAT 11 140 0.0811 -0.0106 5.3179 0.4079 SAT 0.9108 0.8552 SAT 4'

150 0.0806 -0.0091 5.1173 0.3007 SAT 0.9286 0.8568 SAT 200 0.0773 -0.0406 4.9643 0.3507 SAT 0.9325 0.8489 SAT 210 0.0773 -0.0153 4.8438 0.2669 SAT 0.9461 0.8512 SAT 15 220 0.0748 -0.0230 4.7466 0.3006 SAT 0.9480 0.8449 SAT-16 230 0.0608 -0.1679 4.6664 0.8109 SAT 0.7605 0.7852 UNSAT 17 240 0.0488 -0.4564 4.5993 1.1388 SAT 0.5836 0.7043 UNSAT 18 250 0.0419 -0.5960 4.5422 1.1967 SAT 0.5123 0.6410 UNSAT 19 300 0.0364 -0.7055 4,4931 1.2025 SAT 0.4536 0.5765 UNSAT 20 310 0.0317 -0.8165 4.4503 1.1841 SAT 0.4015 0.5110 UNSAT 21 320 0.0247 -1.0607 4.4129 1.2836 SAT 0.2738 0.3893 UNSAT 22 330 0.0182 -1.5608 4.3797 1.3502 SAT 0.1645 0,2593 UNSAT 23 340 0.0144 -2.2769 4.3502 1.2993 SAT 0.1167 0.1814 UNSAT 24 350 0.0085 -3.3585 4.3238 1.3613 SAT 0.0417 0.0715 UNSAT 25 400 0.0080 -4.5263 4.2999 1. 1758 SAT 0.0426 0.0656 UNSAT 26 410 0.0034 -31.3131 4.2783 1.2113 SAT 0.0079 0.0126 UNSAT 27 420 0.0003 7.3170 4.2587 1,1846 UNSAT 0.0001 0.0001 UNSAT 28 430 -0.0019 4.1672 4.2407 1.1193 SAT 0.0027 0.0038 UNSAT 29 440 -0.0035 4.2812 4.2242 1.0473 UNSAT 0.0100 0,0132 UNSAT 450 -0.0070 3.3514 4.2090 1,0763 SAT 0.0397 0.0519 UNSAT 500 -0.0076 3.0731 4.1950 0.9725 SAT 0.0507 0.0608 UNSAT 32 510 -0.0085 3.4831 4.1820 0.8976 SAT 0.0678 0.0751 UNSAT 33 520 -0.0072 3.3670 4.1700 0.7372 SAT 0.0538 0.0559 UNSAT

BF181.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 12:32:36 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2. 1) ( 2. 1) (2 )

1 100 0.0000 0.4886 4.0297 0.0151 SAT 0.9907 0.7955 SAT 2 107 0.0000 0.4886 4.0297 0.0151 SAT 0.9907 0.7955 SAT 3 115 1.2597 0.0000 5.6294 0.8338 SAT 0.9603 0.8485 SAT 4 122 0.8922 -0.0088 161.1086 0.6551 SAT 0.8729 0.7958 SAT 5 130 0.7754 -0.0776 18.4995 0.5630 SAT 0.8936 0.7754 SAT 6 137 0.7462 -0.1810 10.1152 0.3517 SAT 0.9302 0.7792 SAT 7 145 0.6449 1. 8712 7.7071 0.5050 SAT 0.9061 0.7385 SAT 8 152 0.6697 -0.1213 6.6086 0.2097 SAT 0.9369 0.7623 SAT 9 200 0.6564 0.0753 5.9883 0.1763 SAT 0.9524 0.7624 SAT 10 207 0.5273 69.8427 5.5920 0.5689 UNSAT 0.8221 0.6817 SAT 11 215 0.4347 5.3304 5.3179 0.7233 UNSAT 0.7273 0.5995 SAT 222 4'

0.4542 -3.1248 5.1173 0.4395 SAT 0.7873 0.6261 SAT 230 0.4511 -0.7306 4.9643 0.3316 SAT 0.8228 0.6278 SAT 237 0.4406 -1. 2723 4.8438 0.2865 SAT 0.8454 0.6211 SAT 15 245 0.4352 4.1320 4.7466 0.2379 SAT 0.8672 0.6192 SAT 16 252 0,4595 0.3033 4.6664 0.0882 SAT 0.8879 0.6480 SAT 17 300 0.4606 0.2459 4.5993 0.0649 SAT 0.9052 0.6522 SAT 18 307 0.4584 0.1020 4.5422 0.0607 SAT 0.9181 0.6528 SAT 19 315 0.4523 0.2335 4.4931 0.0734 SAT 0.9270 0.6494 SAT 20 322 0.4348 19.1197 4.4503 0.1312 SAT 0.9235 0.6337 SAT 21 330 0.4140 4.9659 4.4129 0.1930 SAT 0.9133 0.6130 SAT 22 337 0.4106 2.8817 4.3797 0.1741 SAT 0.9222 0.6113 SAT 23 345 0.3584 5.4138 4.3502 0.3613 UNSAT 0.8028 0.5473 SAT 24 352 0.3057 13.4531 4.3238 0.5237 UNSAT 0.6603 0.4701 SAT 25 400 0.2774 20.3806 4.2999 0.5633 UNSAT 0.6123 0.4239 SAT 26 407 0.2927 6.7597 4.2783 0.4177 UNSAT 0.6547 0.4521 SAT 27 415 0.2908 7.2175 4.2587 0.3671 UNSAT 0.6769 0.4508 SAT 28 422 0.2736 8.8271 4.2407 0.3906 UNSAT 0.6587 0.4223 SAT 29 430 0.2765 8.4679 4,2242 0.3274 UNSAT 0.6860 0.4289 SAT 437 0.2792 5.3512 4.2090 0.2745 UNSAT 0.7111 0.4352 SAT 445 0.2826 3.1557 4,1950 0.2264 SAT 0.7348 0.4426 SAT 32 452 0.2933 1.5669 4.1820 0.1538 SAT 0.7588 0.4624 SAT 33 500 0.2931 1.6631 4.1700 0.1369 SAT 0.7751 0.4633 SAT 34 507 0.3017 0.6351 4.1587 0.0845 SAT 0.7943 0,4790 SAT 35 515 0.3077 0.2068 4.1482 0.0493 SAT 0,8114 0.4901 SAT 36 522 0.3077 0.1683 4.1384 0.0445 SAT 0.8240 0.4912 SAT 37 530 0.3031 0.3126 4.1291 0.0597 SAT 0.8295 0.4848 SAT 38 537 0.3001 0.4883 4.1205 0.0669 SAT 0.8370 0.4808 SAT 39 545 0.3054 0.1913 4.1123 0.0370 SAT 0.8491 0.4908 SAT 40 552 0.3074 0.0887 4.1046 0.0249 SAT 0.8598 0.4950 SAT 41 600 0.3119 0.0016 4.0973 0.0031 SAT 0.8697 0.5031 SAT 42 607 0.3089 0.0422 4.0905 0.0157 SAT 0.8747 0.4993 SAT 43 615 0.3078 0.0860 4.0839 0.0193 SAT 0.8813 0.4984 SAT 44 622 0.3087 0.0388 4.0778 0.0136 SAT 0.8889 0.5007 SAT 45 630 0.3039 0.2690 4.0719 0.0333 SAT 0.8897 0.4938 SAT 46 637 0.3013 0.4830 4.0663 0.0421 SAT 0.8934 0.4903 SAT 47 645 0.2963 0.9143 4.0609 0.0607 SAT 0.8929 0.4827 SAT 48 652 0.2918 1.7322 4.0559 0.0759 SAT 0.8930 0.4758 SAT 49 700 0.2906 1.6182 4.0510 0.0752 SAT 0.8978 0.4745 SAT 50 707 0.2854 2.4231 4.0464 0.0922 SAT 0.8958 0.4663 SAT

BF181.DAT NRC REPORT ***************************

PAGE 2 DATE 24-1987 TIME - 12:32:42 REC TIME LAM LEFT < RIGHT EQ (1.2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2 . 1) ( 2. 1) (2 )

51 722 0.2836 2.7450 4.0419 0.0935 SAT 0.9001 0.4548 SAT 52 730 0.2850 1.9023 4.0377 0.0788 SAT 0.9060 0.4586 SAT 53 737 0.2838 1.8016 4.0336 0.0775 SAT 0.9102 0.4581 SAT 54 745 0.2858 1.4065 4.0297 0.0622 SAT 0.9154 0.4630 SAT 55 752 0.2871 0.9695 4.0259 0.0517 SAT 0.9201 0.4664 SAT 56 800 0.2849 1.2646 4.0223 0.0576 SAT 0.9222 0.4638 SAT 57 807 0.2828 1.4840 4.0189 0.0625 SAT 0.9243 0.4614 SAT 58 815 0.2813 1.5655 4.0155 0.0647 SAT 0.9269 0.4599 SAT 59 822 0.2801 1.7132 4.0123 0.0658 SAT 0.9295 0.4587 SAT 60 830 0.2814 1.2694 4.0092 0.0559 SAT 0.9330 0.4619 SAT 61 837 0.2794 1.6044 4.0062 0.0611 SAT 0.9345 0.4594 SAT e 65 66 845 852 900 907 915 0.2750 0.2728 0.2714 0.2702 0.2697 2.6119 3.2497 3.5879 4.0337 3.9440 4.0034 4.0006 3.9979 3.9953 3.9928 0.0764 0.0813 0.0825 0.0829 0.0803 SAT SAT SAT SAT SAT 0.9312 0.9322 0.9340 0.9360 0.9385 0.4524 0.4493 0.4475 0.4461 0.4460 SAT SAT SAT SAT SAT 67 922 0.2693 3.5740 3.9903 0.0779 SAT 0.9408 0.4458 SAT 68 930 0.2693 3.4162 3.9880 0.0732 SAT 0.9433 0.4466 SAT 69 937 0.2694 3.1447 3.9857 0.0688 SAT 0.9456 0.4474 SAT 70 945 0.2688 2.9872 3.9835 0.0679 SAT 0.9475 0.4469 SAT 71 952 0.2675 3.1483 3.9813 0.0697 SAT 0.9487 0.4452 SAT 72 1000 0.2666 3.2862 3.9792 0.0701 SAT 0.9501 0.4441 SAT 73 1007 0.2664 3.0384 3.9772 0.0675 SAT 0.9520 0.4442 SAT 74 1015 0.2666 2.9923 3.9753 0.0630 SAT 0.9538 0.4452 SAT 75 1022 0.2667 2.8299 3.9734 0.0596 SAT 0.9556 0.4458 SAT 76 1030 0.2673 2.2663 3.9715 0.0536 SAT 0.9573 0.4475 SAT 77 1037 0.2672 2.3032 3.9697 0.0515 SAT 0.9588 0.4478 SAT 78 1045 0.2682 1. 8960 3.9679 0.0444 SAT 0.9603 0.4501 SAT 79 1052 0.2669 2.2715 3.9662 0.0482 SAT 0.9608 0.4481 SAT

• 1100 0.2665 2.3102 3.9646 0.0477 SAT 0.9620 0.4479 SAT 1107 0.2657 2.7399 3.9630 0.0492 SAT 0.9629 0.4467 SAT 82 1115 0.2657 2.6322 3.9614 0.0467 SAT 0.9642 0.4472 SAT 83 1122 0.2660 2.3451 3.9598 0.0431 SAT 0.9654 0.4482 SAT 84 1130 0.2652 2.8337 3.9584 0.0449 SAT 0.9662 0.4471 SAT 85 1137 0.2646 2.8280 3.9569 0.0456 SAT 0.9670 0.4463 SAT 86 1145 0.2638 2.9915 3.9555 0.0474 SAT 0.9676 0.4451 SAT 87 1152 0.2627 3.7453 3.9541 0.0500 SAT 0.9680 0.4435 SAT 88 1200 0.2625 3.8345 3.9527 0.0489 SAT 0.9690 0.4434 SAT 89 1207 0.2622 3.9587 3.9514 0.0480 SAT 0.9699 0.4433 SAT 90 1215 0.2619 3.7931 3.9501 0.0474 SAT 0.9708 0.4430 SAT 91 1222 0.2621 3.5445 3.9488 0.0443 SAT 0.9717 0.4438 SAT 92 1230 0.2610 4.4745 3.9476 0.0478 SAT 0.9717 0.4419 SAT 93 1237 0.2606 4.3787 3.9464 0.0472 SAT 0.9725 0.4416 SAT 94 1245 0.2589 5.7944 3.9452 0.0533 SAT 0.9717 0.4386 SAT 95 1252 0.2570 7.1998 3.9441 0.0597 SAT 0.9705 0.4353 SAT 96 1300 0.2554 8.9464 3.9430 0.0649 SAT 0.9698 0.4324 SAT 97 1307 0.2538 10.6443 3.9419 0.0694 SAT 0.9693 0.4297 SAT 98 1315 0.2531 10.7341 3.9408 0.0698 SAT 0 .19698 0.4287 SAT 99 1322 0.2527 11.5815 3.9397 0.0688 SAT 0.9705 0.4282 SAT 100 1330 0.2518 12.4950 3.9387 0.0706 SAT 0.9707 0.4266 SAT

BF283.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 12:09:17 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < . 25 (1) (2. 1) (2. 1) ( 2) 1 0 0.0000 4.3886 3.9397 0.0000 SAT 0.0273 1.0000 UNSAT 2 10 0.0000 4.3886 3.9397 0.0000 SAT 0.0273 1.0000 UNSAT 3 20 0.2935 0.0000 5.6294 0,9713 SAT 0.2126 0.0794 SAT 4 30 0.1402 -0.0452 161.1086 0. 0511 SAT 0.1206 0.0265 SAT 5 40 0.1588 -0.0033 18.4995 0.0445 SAT 0.2596 0.0394 SAT 6 50 0.3392 -0.4724 10.1152 0.3014 SAT 0.5767 0.1713 SAT 7 100 0.3949 0.5081 7.7071 0.2535 SAT 0.7290 0,2308 SAT_,..

8 110 0.4637 0.4961 6.6086 0.2687 SAT 0.8171 0.3035 SAT 9 120 0.5344 1.2025 5.9883 0.2962 SAT 0.8629 0.3762 SAT 10 130 0.5857 5.1555 5.5920 0.2899 SAT 0.8958 0.4283 SAT 11 140 0.6325 -15.1814 5.3179 0.2877 SAT 0.9164 0.4733 SAT

~ 150 200 0.5945 -1.7306 0.5915 -0.3851 5.1173 4.9643 0.1284 0,0874 SAT SAT 0.9150 0.9312 0.4485 SAT 0.4512 SAT 210 0.5829 -0.1116 4.8438 0.0477 SAT 0.9419 0.4486 SAT 15 220 0.5759 -0.0428 4.7466 0.0221 SAT 0.9505 0.4467 SAT 16 230 0.5674 -0.0001 4.6664 0.0007 SAT 0.9567 0,4431 SAT 17 240 0.5596 -0.2507 4.5993 0.0170 SAT 0.9618 0.4397 SAT 18 250 0.5627 0.0180 4.5422 0.0073 SAT 0.9679 0.4455 SAT 19 300 0.5638 0.0023 4.4931 0.0031 SAT 0.9726 0.4493 SAT 20 310 0.5587 0.0501 4.4503 0.0137 SAT 0.9755 0.4474 SAT 21 320 0.5478 0.3622 4.4129 0.0348 SAT 0.9755 0.4402 SAT 22 330 0.5444 0.3512 4.3797 0.0361 SAT 0.9781 0,4395 SAT 23 340 0.5406 0.8963 4.3502 0.0386 SAT 0.9801 0,4382 SAT 24 350 0.5295 2.1976 4.3238 0.0573 SAT 0.9786 0.4300 SAT 25 400 0.5206 6.8899 4,2999 0.0684 SAT 0.9783 0.4236 SAT 26 410 0.5047 11. 9522 4,2783 0,0941 SAT 0.9719 0,4103 SAT 27 420 0.4924 11. 2238 4,2587 0.1086 SAT 0.9687 0.4001 SAT 28 430 0.4779 9.9628 4.2407 0.1265 SAT 0.9627 0.3874 SAT 29 440 0.4636 17.9923 4.2242 0,1424 SAT 0.9563 0.3745 SAT 450 0.4552 15.7664 4.2090 0,1433 SAT 0.9561 0.3674 SAT 500 0.4477 23.0476 4.1950 0,1430 SAT 0.9562 0.3610 SAT 32 510 0.4421 30.2515 4.1820 0.1388 SAT 0.9575 0.3565 SAT 33 520 0.4398 37.9324 4.1700 0.1280 SAT 0.9605 0,3553 SAT 34 530 0.4393 16.5235 4.1587 0.1147 SAT 0.9636 0.3560 SAT 35 540 0.4364 22.7554 4.1482 0,1090 SAT 0.9657 0.3540 SAT 36 550 0.4364 22.8749 4.1384 0.0975 SAT 0.9684 0.3550 SAT 37 600 0.4339 19.7182 4.1291 0.0931 SAT 0,9702 0.3535 SAT 38 610 0.4312 40.9155 4.1205 0.0901 SAT 0.9716 0.3516 SAT 39 620 0.4284 21. 0772 4.1123 0.0876 SAT 0.9729 0,3496 SAT 40 630 0.4256 26.7889 4.1046 0.0858 SAT 0.9739 0.3475 SAT 41 640 0.4218 42.6680 4.0973 0.0865 SAT 0.9743 0.3443 SAT 42 650 0.4190 155.1483 4.0905 0,0851 SAT 0.9752 0.3422 SAT 43 700 0.4171 38.7165 4.0839 0.0819 SAT 0.9764 0,3410 SAT 44 710 0.4176 30.0636 4.0778 0.0736 SAT 0.9780 0.3423 SAT 45 720 0.4148 89.4199 4.0719 0.0740 SAT 0.9784 0.3400 SAT 46 730 0.4141%-1396.8748 4.0663 0.0692 SAT 0.9797 0.3400 SAT 47 740 0.4153-114.1464 4.0609 0.0608 SAT 0.9809 0.3420 SAT 48 750 0.4133 64.0268 4.0559 0.0606 SAT 0.9815 0.3405 SAT 49 800 0.4147 36.7621 4.0510 0.0526 SAT 0.9826 0.3427 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

BRUNS181.DAT PAGE 1 DATE 24-1987 TIME - 12:10:19 REC TIME LAM LEFT < RIGHT EQ (1.2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) ( 2. 1) ( 2. 1 ) (2 )

1 0 0.0000 45.2280 3.9630 0.0558 SAT 0.9887 0.4126 SAT 2 15 0.0000 45.2280 3.9630 0.0558 SAT 0.9887 0.4126 SAT 3 30 0.5464 0.0000 5.6294 1.3119 SAT 0.8928 0.8270 SAT 4 45 -0.1092 -0.4680 161.1086 3.6106 SAT 0.0381 0.2093 UNSAT 5 100 0.0656 -0.9836 18.4995 0.3767 SAT 0.0232 0.1008 UNSAT 6 115 0.1529 0.0810 10.1152 0.3712 SAT 0.1707 0.4019 UNSAT 7 130 0.2614 9.0493 7.7071 0.9208 UNSAT 0.4300 0.6778 UNSAT 8 145 0.2940 2.9930 6.6086 0.7655 SAT 0.5804 0.7370 UNSAT 9 200 0.2313 0.0017 5,9883 0.0212 SAT 0.5027 0.6437 UNSAT 10 215 0.2820 0.5516 5.5920 0.3958 SAT 0.6368 0.7354 UNSAT

-245 11 15 230 300 315 330 0.1181

-0.0356

-0.0444

-0.0300

-0.0199 1.6485 7.7980 4.8009 2.2003 1.1494 5.3179 5.1173 4.9643 4.8438 4.7466 0.9888

1. 9071 1.4588 0.9697 0.6539 SAT UNSAT SAT SAT SAT 0.1085 0.0075 0.0148 0.0084 0.3340 0.0445 0.0692 0.0334 UNSAT UNSAT UNSAT UNSAT 0.0046 0.0152 UNSAT 16 345 0.0307 0.0204 4.6664 0.0851 SAT 0.0112 0.0359 UNSAT 17 400 0.0327 0.0086 4.5993 0.0502 SAT 0.0151 0.0410 UNSAT 18 415 0.0488 0.0422 4.5422 0.0972 SAT 0.0383 0.0882 UNSAT 19 430 0.0544 0.0953 4.4931 0.1269 SAT 0.0548 0. 1084 UNSAT 20 445 0.0640 0.2472 4.4503 0.1862 SAT 0.0846 0,1452 UNSAT 21 500 0.0830 0.8981 4.4129 0.3188 SAT 0.1452 0.2240 UNSAT 22 515 0.0950 1.4075 4.3797 0.3700 SAT 0.1995 0,2763 UNSAT 23 530 0.1114 2.4412 4.3502 0.4544 SAT 0.2700 0.3463 UNSAT 24 545 0.1382 5.3321 4.3238 0.6213 UNSAT 0.3544 0.4512 UNSAT 25 600 0.1497 6.9491 4.2999 0.6306 UNSAT 0.4135 0.4931 UNSAT 26 615 0.1697 9.6520 4.2783 0.7175 UNSAT 0.4779 0.5571 UNSAT 27 630 0.1729 9.3325 4.2587 0.6460 UNSAT 0.5148 0.5680 UNSAT 28 645 0.1798 9.4693 4.2407 0.6216 UNSAT 0.5574 0.5888 UNSAT 29 700 0.1849 9.9277 4.2242 0.5867 UNSAT 0.5944 0.6038 UNSAT 715 0.1864 8.8701 4.2090 0.5269 UNSAT 0.6223 0.6092 SAT 730 0.1866 7.5334 4.1950 0.4636 UNSAT 0.6455 0.6109 SAT 32 745 0.1863 6.0603 4.1820 0.4058 UNSAT 0.6662 0.6114 SAT 33 800 0.1885 5.5938 4.1700 0.3795 UNSAT 0.6908 0.6183 SAT 34 815 0.1960 7.2086 4.1587 0.4060 UNSAT 0.7173 0.6378 SAT 35 830 0.1983 6.7261 4.1482 0.3825 UNSAT 0.7383 0.6441 SAT 36 845 0.2057 8.4771 4.1384 0.4102 UNSAT 0.7590 0.6618 SAT 37 900 0.2087 8.8526 4.1291 0.3961 UNSAT 0.7773 0.6693 SAT 38 915 0.2109 8,3947 4.1205 0.3764 UNSAT 0.7935 0.6749 SAT 39 930 0.2124 8.2652 4.1123 0.3532 UNSAT 0.8078 0.6789 SAT 40 945 0.2145 8.8148 4.1046 0.3389 UNSAT 0.8214 0.6840 SAT 41 1000 0.2175 8.9652 4.0973 0.3346 UNSAT 0.8341 0.6907 SAT 42 1015 0.2222 11.2573 4.0905 0.3481 UNSAT 0.8451 0.7006 SAT 43 1030 0.2259 12.7036 4.0839 0.3519 UNSAT 0.8555 0.7083 SAT 44 1045 0.2298 14.0907 4.0778 0.3577 UNSAT 0.8648 0.7161 SAT 45 1100 0.2329 16.1843 4.0719 0.3556 UNSAT 0.8735 0.7221 SAT 46 1115 0.2361 17.9441 4.0663 0.3562 UNSAT 0.8813 0.7282 SAT 47 1130 0.2424 22.7356 4.0609 0.3860 UNSAT 0.8851 0.7391 SAT 48 1145 0.2481 28.3989 4.0559 0.4090 UNSAT 0.8892 0.7486 SAT 49 1200 0.2496 28.0427 4.0510 0.3911 UNSAT 0.8958 0.7514 SAT 50 1215 0.2522 30.5482 4.0464 0.3849 UNSAT 0.9018 0.7558 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

BRUNS181.DAT PAGE 2 DATE 24-1987 TIME - 12:10:26 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2. 1) ( 2. 1 ) ( 2) 51 1230 0.2564 34.5242 4.0419 0.3950 UNSAT 0.9061 0.7623 SAT 52 1245 0.2593 37.7674 4.0377 0.3931 UNSAT 0.9110 0.7668 SAT 53 1300 0.2604 35.6115 4.0336 0.3751 UNSAT 0.9160 0.7689 SAT 54 1315 0.2607 32.7347 4.0297 0.3507 UNSAT 0.9203 0.7697 SAT 55 1330 0.2661 39.9253 4.0259 0.3778 UNSAT 0.9207 0.7774 SAT 56 1345 0.2697 42.7954 4.0223 0.3856 UNSAT 0.9237 0.7824 SAT 57 1400 0.2754 50.1092 4.0189 0.4136 UNSAT 0.9234 0.7899 SAT 58 1415 0.2801 56.3217 4.0155 0.4300 UNSAT 0.9248 0.7957 SAT 59 1430 0.2842 60.2465 4.0123 0.4406 UNSAT 0.9268 0.8008 SAT 60 1445 0.2874 62.0209 4.0092 0.4428 UNSAT 0.9295 0.8047 SAT

-1515 61 1500 1530 1545 0.2914 0.2936 0.2939 0.2965 69.7078 72.8257 64.7215 67.3406 4.0062 4.0034 4.0006 3.9979 0.4530 0.4455 0.4203 0.4199 UNSAT UNSAT UNSAT UNSAT 0.9311 0.9341 0.9371 0.9394 0.8094 0.8120 0.8126 0.8156 SAT SAT SAT SAT 65 1600 0.2979 66.1124 3.9953 0.4080 UNSAT 0.9421 0.8173 SAT 66 1615 0.3011 71. 0530 3.9928 0.4147 UNSAT 0.9435 0.8208 SAT 67 1630 0.3015 64.1407 3.9903 0.3943 UNSAT 0.9459 0.8214 SAT 68 1645 0.3031 63.6405 3.9880 0.3874 UNSAT 0.9481 0.8233 SAT 69 1700 0.3039 59.3222 3.9857 0.3725 UNSAT 0.9503 0.8242 SAT 70 1715 0.3048 56.4579 3.9835 0.3609 UNSAT 0.9524 0.8254 SAT 71 1730 0.3059 54.4443 3.9813 0.3509 UNSAT 0.9544 0.8266 SAT 72 1745 0.3067 52.1008 3.9792 0.3401 UNSAT 0.9562 0.8277 SAT 73 1800 0.3067 46.0353 3.9772 0.3214 UNSAT 0.9579 0.8279 SAT 74 1815 0.3068 41.7145 3.9753 0.3054 UNSAT 0.9596 0.8282 SAT 75 1830 0.3077 42.7523 3.9734 0.2983 UNSAT 0.9611 0.8293 SAT 76 1845 0.3064 33.3216 3.9715 0.2708 UNSAT 0.9619 0.8283 SAT 77 1900 0.3075 34.4710 3.9697 0.2671 UNSAT 0.9633 0.8295 SAT 78 1915 0.3081 34.5333 3.9679 0.2601 UNSAT 0.9647 0.8303 SAT 79 1930 0.3090 34.2423 3.9662 0.2553 UNSAT 0.9659 0.8313 SAT

.1945 0.3093 31. 8853 3.9646 0.2456 SAT 0.9672 0.8317 SAT-2000 0.3105 34.4319 3.9630 0.2459 SAT 0.9682 0.8331 SAT 82 2015 0.3125 39.1025 3.9614 0.2531 UNSAT 0.9687 0.8350 SAT 83 2030 0.3138 40.7022 3.9598 0.2535 UNSAT 0.9696 0.8363 SAT 84 2045 0.3127 33.4285 3.9584 0.2311 SAT 0.9701 0.8356 SAT 85 2100 0.3131 33.2072 3.9569 0.2246 SAT 0.9712 0.8361 SAT 86 2115 0.3128 30.5678 3.9555 0.2116 SAT 0.9721 0.8360 SAT 87 2130 0.3126 28.1116 3.9541 0.2004 SAT 0.9730 0.8361 SAT 88 2145 0.3120 23.5723 3.9527 0.1851 SAT 0.9736 0.8357 SAT 89 2200 0.3129 25.3750 3.9514 0.1862 SAT 0.9744 0.8367 SAT 90 2215 0.3135 25.8699 3.9501 0.1837 SAT 0.9752 0.8373 SAT 91 2230 0.3139 26.1411 3.9488 0.1797 SAT 0.9760 0.8378 SAT 92 2245 0.3141 25.6122 3.9476 0.1735 SAT 0.9768 0.8381 SAT 93 2300 0.3136 22.1836 3.9464 0.1611 SAT 0.9773 0.8378 SAT 94 2315 0.3125 17.3035 3.9452 0.1441 SAT 0.9775 0.8371 SAT

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BRUNS185.DAT PAGE 1 DATE 24-1987 TIME - 12:31:30 REC TIME LAM LEFT < RIGHT EQ (1.2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < . 25 (1) ( 2. 1) ( 2. 1 ) (2 )

1 0 0.0000 0.0000 0.0000 0.0000 SAT 0.0000 0.0000 UNSAT 2 15 0.0000 0.0000 0.0000 0.0000 SAT 0.0000 0.0000 UNSAT 3 30 0.3268 0.0000 5.6294 0.8436 SAT 0.8781 0.6310 SAT 4 45 0.2946 0.0066 161.1086 0.3767 SAT 0.9291 0.6584 SAT 5 100 0.4345 -0.2811 18.4995 0.6560 SAT 0.8919 0.8310 SAT 6 115 0.3624 0.0058 10.1152 0.1425 SAT 0.8678 0.7906 SAT 7 130 0.3613 -0.0136 7.7071 0.0815 SAT 0.9125 0.8008 SAT 8 145 0.3142 -0.9581 6.6086 0.3780 SAT 0.8856 0.7620 SAT 9 200 0.2967 -0.1863 5.9883 0.3625 SAT 0.9014 0.7484 SAT 10 215 0.2505 -0.6789 5.5920 0.5850 SAT 0.8318 0.6868 SAT 11 230 0.2452 -1.4471 5.3179 0.4404 SAT 0.8622 0.6836 SAT 245

~

0.2662 0.1723 5.1173 0.1476 SAT 0.8890 0.7229 SAT 300 0.2708 0.0592 4.9643 0.0707 SAT 0.9125 0.7338 SAT 315 0.2865 0.0345 4.8438 0.0744 SAT 0.9255 0.7587 SAT 15 330 0.2986 0.5942 4.7466 0.1572 SAT 0.9367 0.7765 SAT 16 345 0.2910 -0.2155 4.6664 0.0580 SAT 0.9418 0.7700 SAT 17 400 0.2789 -0.1521 4.5993 0.0565 SAT 0.9385 0.7571 SAT 18 415 0.2737 -0.3296 4.5422 0.0891 SAT 0.9441 0.7525 SAT 19 430 0.2760 -0.4972 4.4931 0.0511 SAT 0.9524 0.7578 SAT 20 445 0.2811 -0.0002 4.4503 0.0024 SAT 0.9585 0.7664 SAT 21 500 0.2862 -0.7051 4.4129 0.0465 SAT 0.9634 0.7745 SAT 22 515 0.2924 -1. 2440 4.3797 0.0923 SAT 0.9666 0.7834 SAT 23 530 0.2957 -0.8289 4.3502 0.1069 SAT 0.9705 0.7888 SAT 24 545 0.2921 -0.1477 4.3238 0.0583 SAT 0.9722 0.7860 SAT 25 600 0.2956 -0.2461 4.2999 0.0808 SAT 0.9749 0.7913 SAT 26 615 0.2983 -0.2774 4.2783 0.0930 SAT 0.9774 0.7955 SAT 27 630 0.3021 -0.4843 4.2587 0.1140 SAT 0.9790 0.8007 SAT 28 645 0.3013 -0.3047 4.2407 0.0909 SAT 0.9809 0.8008 SAT 29 700 0.3009 -0.2440 4.2242 0.0757 SAT 0.9828 0.8014 SAT 715 0.3000 -0.1652 4.2090 0.0584 SAT 0.9842 0.8015 SAT 730 0.3011 -0.1758 4.1950 0.0609 SAT 0.9857 0.8035 SAT 32 745 0.2965 -0.0074 4.1820 0.0114 SAT 0.9842 0.7994 SAT 33 800 0.2930 -0.0382 4.1700 0.0216 SAT 0.9838 0.7965 SAT 34 815 0.2951 -0.0000 4.1587 0.0003 SAT 0.9848 0.7996 SAT 35 830 0.2938 -0.0143 4.1482 0.0115 SAT 0.9858 0.7990 SAT 36 845 0.2889 -0.5001 4.1384 0.0554 SAT 0.9833 0.7943 SAT 37 900 0.2881 -0.7164 4.1291 0.0572 SAT 0.9844 0.7941 SAT 38 915 0.2847 -2.5300 4.1205 0.0829 SAT 0.9836 0.7909 SAT 39 930 0.2848 -1.7136 4.1123 0.0737 SAT 0.9848 0.7917 SAT 40 945 0.2838 -1.4457 4.1046 0.0758 SAT 0.9857 0.7912 SAT 41 1000 0.2843 -1. 3551 4.0973 0.0645 SAT 0.9867 0.7924 SAT 42 1015 0.2840 -1.7832 4.0905 0.0612 SAT 0.9876 0.7927 SAT 43 1030 0.2817 -4.7347 4.0839 0.0773 SAT 0.9873 0.7906 SAT 44 1045 0.2811 -2.6239 4.0778 0.0762 SAT 0.9880 0.7904 SAT 45 1100 0.2802 -2.7091 4.0719 0.0778 SAT 0.9886 0.7900 SAT 46 1115 0.2788 -4.7821 4.0663 0.0840 SAT 0.9889 0.7889 SAT 47 1130 0.2770 -15.5619 4.0609 0.0942 SAT 0.9888 0.7872 SAT 48 1145 0.2772 352.2103 4.0559 0.0851 SAT 0.9895 0.7879 SAT 49 1200 0.2764 -18.2015 4.0510 0.0852 SAT 0.9899 0.7875 SAT 50 1215 0.2753 42.9921 4.0464 0.0895 SAT 0.9901 0.7866 SAT

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BRUNS185.DAT PAGE 2 DATE 24-1987 TIME - 12:31:37 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < . 25 (1) (2.1) (2 . 1) (2 )

51 1230 0.2769 7.1981 4,0419 0.0670 SAT 0.9902 0.7891 SAT 52 1245 0.2781 4.1557 4.0377 0.0514 SAT 0.9906 0.7909 SAT 53 1300 0.2793 4.7433 4.0336 0.0361 SAT 0.9909 0.7928 SAT 54 1315 0.2813 0.4886 4.0297 0.0151 SAT 0.9907 0.7955 SAT

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BRUNS282.DAT PAGE 1 DATE 24-1987 TIME - 12:39:17 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < . 25 (1) (2 . 1) (2. 1) ( 2) 1 0 0.0000 21.1503 3.9441 0.0945 SAT 0.9925 0.8370 SAT 2 15 0.0000 21.1503 3.9441 0.0945 SAT 0.9925 0.8370 SAT 3 30 0.3739 0.0000 5.6294 0.6219 SAT 0.9455 0.6912 SAT 4 45 0.3237 -0.0006 161,1086 0.0840 SAT 0.9537 0.6994 SAT 5 100 0.3863 0.0466 18.4995 0.3257 SAT 0.9585 0.7953 SAT 6 115 0.4292 0.2389 10.1152 0.4205 SAT 0.9681 0.8412 SAT 7 130 0.4151 0.0294 7.7071 0. 134 5 SAT 0.9761 0.8414 SAT 8 145 0.3237 0.4788 6.6086 0.5635 SAT 0.8430 0.7726 SAT 9 200 0.3710 0.0003 5.9883 0.0075 SAT 0.8794 0.8230 SAT 10 215 0.3448 0.3083 5.5920 0.2007 SAT 0.8842 0.8059 SAT 11 230 0.3497 -1. 7763 5.3179 0.0988 SAT 0.9123 0.8147 SAT

~

245 0.3843 0.5837 5.1173 0.2025 SAT 0.9189 0.8447 SAT 300 0.3425 1.0609 4.9643 0.1858 SAT 0.8755 0~8152 SAT 315 0.3216 14.4145 4.8438 0.3078 UNSAT 0.8726 0.7984 SAT 15 330 0.3236 -1.4673 4.7466 0.2173 SAT 0.8950 0.8031 SAT 16 345 0.2958 11.9240 4.6664 0.3995 UNSAT 0.8645 0.7758 SAT 17 400 0.3035 2.7263 4.5993 0.2489 SAT 0.8870 0.7869 SAT 18 415 0.2951 8.0003 4.5422 0.2704 UNSAT 0.8946 0.7795 SAT 19 430 0.2845 -16.2329 4.4931 0.3089 SAT 0.8965 0.7688 SAT 20 445 0.2792 -27.8675 4.4503 0.2982 SAT 0.9049 0.7639 SAT 21 500 0.2838 8.8488 4.4129 0.2049 SAT 0.9178 0.7716 SAT 22 515 0.2899 3.0125 4.3797 0.1172 SAT 0.9280 0.7805 SAT 23 530 0.2830 4.6306 4.3502 0.1591 SAT 0.9299 0.7737 SAT 24 545 0.2943 0.1236 4.3238 0.0342 SAT 0.9327 0.7885 SAT 25 600 0.2999 0.0638 4.2999 0.0210 SAT 0.9396 0.7960 SAT 26 615 0.3032 0.4686 4.2783 0.0479 SAT 0.9462 0.8007 SAT 27 630 0.3044 0.6069 4.2587 0.0514 SAT 0.9520 0.8030 SAT 28 645 0.3074 0.9105 4.2407 0.0718 SAT 0.9568 0.8072 SAT 29 700 0.3125 2.0862 4.2242 0.1081 SAT 0.9600 0.8132 SAT 715 0.3185 2.9064 4.2090 0.1488 SAT 0.9620 0.8198 SAT 730 0.3270 7.8246 4.1950 0.2075 SAT 0.9611 0.8282 SAT 32 745 0.3300 8.4019 4.1820 0.2108 SAT 0.9644 0.8316 SAT 33 800 0.3295 5.7821 4.1700 0.1817 SAT 0.9673 0.8319 SAT 34 815 0.3346 7.2549 4.1587 0.2080 SAT 0.9686 0.8368 SAT 35 830 0.3380 7.2081 4.1482 0.2171 SAT 0.9706 0.8403 SAT 36 845 0.3379 6.4947 4.1384 0.1931 SAT 0.9729 0.8408 SAT 37 900 0.3359 3.6446 4.1291 0.1550 SAT 0.9743 0.8398 SAT 38 915 0.3386 5.3273 4.1205 0.1638 SAT 0.9759 0.8425 SAT 39 930 0.3393 4.9583 4.1123 0.1551 SAT 0.9777 0.8437 SAT 40 945 0.3366 2.9751 4.1046 0.1148 SAT 0.9781 0.8420 SAT 41 1000 0.3374 2.7125 4.0973 0.1114 SAT 0.9797 0.8432 SAT 42 1015 0.3372 2.5654 4.0905 0.0994 SAT 0.9811 0.8435 SAT 43 1030 0.3366 1.8858 4.0839 0.0845 SAT 0.9822 0.8435 SAT 44 1045 0.3369 1.8415 4.0778 0.0799 SAT 0.9834 0.8442 SAT 45 1100 0.3354 1.1388 4.0719 0.0597 SAT 0.9841 0.8435 SAT 46 1115 0.3348 0.7475 4.0663 0.0486 SAT 0.9850 0.8434 SAT 47 1130 0.3320 0.1258 4.0609 0.0186 SAT 0.9847 0.8416 SAT 48 1145 0.3290 0.0455 4.0559 0.0116 SAT 0.9841 0.8396 SAT 49 1200 0.3298 0.0024 4.0510 0.0027 SAT 0.9850 0.8407 SAT 50 1215 0.3319 0.0961 4.0464 0.0165 SAT 0.9855 0,8427 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

BRUNS282.DAT PAGE 2 DATE 24-1987 TIME - 12:39:24 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) ( 2. 1) (2 . 1) ( 2) 51 1230 0.3324 0.1586 4.0419 0.0209 SAT 0.9863 0.8435 SAT 52 1245 0.3351 0.7379 4.0377 0.0444 SAT 0.9862 0.8460 SAT 53 1300 0.3362 1.0564 4.0336 0.0515 SAT 0.9869 0.8472 SAT 54 1315 0.3368 1.1628 4.0297 0.0535 SAT 0.9876 0.8480 SAT 55 1330 0.3364 0.9927 4.0259 0.0461 SAT 0.9882 0.8480 SAT 56 1345 0.3341 0.2171 4.0223 0.0209 SAT 0.9878 0.8466 SAT 57 1400 0.3361 0.8133 4.0189 0.0386 SAT 0.9880 0.8484 SAT 58 1415 0.3352 0.4259 4.0155 0.0273 SAT 0.9884 0.8480 SAT 59 1430 0.3360 0.6105 4.0123 0.0332 SAT 0.9889 0.8489 SAT 60 1445 0.3355 0.3658 4.0092 0.0258 SAT 0.9894 0.8488 SAT 4'1515 61 1500 1530 0.3326 0.3319 0.3297 0.0059 0.0531 0.6115 4.0062 4.0034 4.0006 0.0032 0.0093 0.0303 SAT SAT SAT 0.9882 0.9887 0.9881 0.8469 0.8466 0 .. 8451 SAT SAT SAT 1545 0.3276 1. 4634 3.9979 0.0478 SAT 0.9877 0.8438 SAT 65 1600 0.3264 2.1967 3.9953 0.0572 SAT 0.9879 0.8430 SAT 66 1615 0.3243 3.5998 3.9928 0.0739 SAT 0.9874 0.8415 SAT 67 1630 0.3230 4.6762 3.9903 0.0815 SAT 0.9875 0.8408 SAT 68 1645 0.3242 3.3403 3.9880 0.0660 SAT 0.9879 0.8419 SAT 69 1700 0.3258 1.7517 3.9857 0.0467 SAT 0.9880 0.8435 SAT 70 1715 0.3251 2.1919 3.9835 0.0507 SAT 0.9883 0.8432 SAT 71 1730 0.3245 2.7489 3.9813 0.0535 SAT 0.9887 0.8429 SAT 72 1745 0.3241 3.1022 3.9792 0.0545 SAT 0.9891 0.8428 SAT 73 1800 0.3244 2.6078 3.9772 0.0490 SAT 0.9895 0.8433 SAT 74 1815 0.3235 3.1973 3.9753 0.0548 SAT 0.9897 0.8428 SAT 75 1830 0.3228 3.9641 3.9734 0.0584 SAT 0.9900 0.8424 SAT 76 1845 0.3231 3.1928 3.9715 0.0528 SAT 0.9904 0.8428 SAT 77 1900 0.3219 4.7558 3.9697 0.0614 SAT 0.9903 0.8421 SAT 78 1915 0.3203 6.6230 3.9679 0.0735 SAT 0.9900 0.8410 SAT 79 1930 0.3198 7.4361 3.9662 0.0752 SAT 0.9903 0.8407 SAT

.1945 0.3194 7.4348 3.9646 0.0756 SAT 0.9906 0.8405 SAT 2000 0.3192 7.8713 3.9630 0.0738 SAT 0.9909 0.8406 SAT 82 2015 0.3193 6.9678 3.9614 0.0692 SAT 0.9912 0.8409 SAT 83 2030 0.3192 6.9301 3.9598 0.0672 SAT 0.9915 0.8409 SAT 84 2045 0.3190 7.1092 3.9584 0.0653 SAT 0.9918 0.8410 SAT 85 2100 0.3179 8.7047 3.9569 0.0735 SAT 0.9917 0.8402 SAT 86 2115 0.3172 9.4917 3.9555 0.0770 SAT 0.9918 0.8398 SAT 87 2130 0.3168 10.4502 3.9541 0.0771 SAT 0.9920 0.8396 SAT 88 2145 0.3168 9.7522 3.9527 0.0731 SAT 0.9923 0.8398 SAT 89 2200 0.3169 9.7393 3.9514 0.0697 SAT 0.9925 0.8400 SAT 90 2215 0.3161 11.1576 3.9501 0.0741 SAT 0.9926 0.8395 SAT 91 2230 0.3160 11.2836 3.9488 0.0721 SAT 0.9928 0.8396 SAT 92 2245 0.3152 13.1703 3.9476 0.0763 SAT 0.9928 0.8391 SAT 93 2300 0.3144 14.4516 3.9464 0.0807 SAT 0.9928 0.8386 SAT 94 2315 0.3134 17.6015 3.9452 0.0879 SAT 0.9927 0.8378 SAT 95 2330 0.3123 21.1503 3.9441 0.0945 SAT 0.9925 0.8370 SAT

BYR183F.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 12:40:20 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2 . 1) (2 . 1) ( 2) 1 0 0.0000 21.1503 3.9441 0.0945 SAT 0.9925 0.8370 SAT 2 15 0.0000 21.1503 3.9441 0.0945 SAT 0.9925 0.8370 SAT 3 30 -0.0182 0.0000 5.6294 6.1867 SAT 0.0103 0.1174 UNSAT 4 45 -0.0109 0.0045 161.1086 1.7275 SAT 0.0092 0.0617 UNSAT 5 100 0.0267 0.0755 18.4995 1.7329 SAT 0.0838 0.3176 UNSAT 6 115 0.0562 0.0415 10.1152 1.7378 SAT 0.3599 0.6940 UNSAT 7 130 0.0620 0.0369 7.7071 1. 1194 SAT 0.5186 0.7472 UNSAT 8 145 0.0784 0.0911 6.6086 1.2320 SAT 0.6780 0.8330 UNSAT 9 200 0.0704 0.0179 5.9883 0.4747 SAT 0.6927 0.8071 UNSAT 10 215 0.0181 0.4116 5.5920 1.6606 SAT 0.0356 0.2230 UNSAT 11 230 0.0098 0.6244 5.3179 1.4648 SAT 0.0136 0.0788 UNSAT

~

245 -0.0048 0.6026 5.1173 1.6097 SAT 0.0038 0.0208 UNSAT 300 0.0118 0,0493 4.9643 0.5100 SAT 0.0236 0.1151 UNSAT 315 -0.0149 0.7686 4.8438 1.4640 SAT 0.0291 0.1756 UNSAT 15 330 -0.0270 1.1602 4.7466 1,6119 SAT 0.0987 0.4155 UNSAT 16 345 -0.0313 0.8386 4.6664 1.4250 SAT 0.1495 0.4923 UNSAT 17 400 -0.0275 0.4313 4.5993 0.9580 SAT 0.1378 0.4306 UNSAT 18 415 -0.0183 0.0854 4.5422 0.3742 SAT 0.0707 0.2545 UNSAT 19 430 -0.0084 0.0091 4.4931 0. 1207 SAT 0.0162 0.0679 UNSAT 20 445 -0.0105 0.0001 4.4503 0.0103 SAT 0.0285 0.1019 UNSAT 21 500 -0.0084 0.0083 4.4129 0.1013 SAT 0.0211 0.0681 UNSAT 22 515 -0.0058 0.0450 4.3797 0.1952 SAT 0.0116 0.0344 UNSAT 23 530 -0.0118 0.0121 4.3502 0.1035 SAT 0.0484 0.1303 UNSAT 24 545 -0.0068 0.0236 4.3238 0.1359 SAT 0.0174 0.0475 UNSAT 25 600 -0.0023 0.1704 4.2999 0.3166 SAT 0.0020 0,0055 UNSAT 26 615 -0.0001 0.2305 4.2783 0.3671 SAT 0.0000 0.0000 UNSAT 27 630 0.0004 0.2786 4.2587 0.3348 SAT 0.0001 0.0001 UNSAT 28 645 0.0031 0.5811 4.2407 0.4153 SAT 0.0052 0.0107 UNSAT 29 700 0.0045 0.5484 4.2242 0.4226 SAT 0.0119 0.0222 UNSAT 715 0.0031 0.3952 4.2090 0.3056 SAT 0.0062 0.0107 UNSAT 730 0.0008 0.1548 4.1950 0.1646 SAT 0.0005 0.0008 UNSAT 32 745 0.0027 0.3147 4.1820 0.2297 SAT 0.0053 0.0081 UNSAT 33 800 0.0026 0.3893 4.1700 0.2014 SAT 0.0056 0.0079 UNSAT 34 815 -0.0004 0.0226 4.1587 0.0399 SAT 0.0001 0.0002 UNSAT 35 830 -0.0031 0.1983 4.1482 0.0865 SAT 0.0078 0.0108 UNSAT 36 845 -0.0030 0.0977 4.1384 0.0713 SAT 0.0079 0.0101 UNSAT 37 900 -0.0015 0.0015 4.1291 0.0055 SAT 0.0020 0.0024 UNSAT 38 915 -0.0015 0.0004 4.1205 0.0033 SAT 0.0023 0.0026 UNSAT 39 930 -0.0016 0.0001 4.1123 0.0023 SAT 0.0029 0.0030 UNSAT 40 945 0.0000 0.1973 4.1046 0.0738 SAT 0.0000 0.0000 UNSAT 41 1000 0.0009 0.5004 4.0973 0.1065 SAT 0.0010 0.0009 SAT 42 1015 0.0021 0.8294 4.0905 0.1539 SAT 0.0057 0.0052 SAT 43 1030 0.0032 1.9513 4.0839 0.1907 SAT 0.0137 0.0120 SAT 44 1045 0.0019 1.6104 4.0778 0.1133 SAT 0.0050 0.0043 SAT 45 1100 0.0016 0.5459 4.0719 0.0900 SAT 0.0038 0.0030 SAT 46 1115 0.0037 2.0109 4.0663 0.1808 SAT 0.0194 0.0160 SAT 47 1130 0.0047 1.8738 4.0609 0.2120 SAT 0.0321 0.0256 SAT 48 1145 0.0047 1.4481 4.0559 0. 1965 SAT 0.0344 0.0259 SAT 49 1200 0.0037 0.5670 4.0510 0.1337 SAT 0.0223 0.0162 SAT 50 1215 0.0037 0.6434 4.0464 0,1227 SAT 0.0235 0.0162 SAT

BYR183H.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 12:41:59 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < . 25 (1) (2 . 1) (2. 1) (2 )

1 0 0.0000 0.0869 3.94193508.1655 SAT 0.0077 1.0000 UNSAT 2 15 0.0000 0.0869 3.94193508.1655 SAT

• 0.0077 1.0000 UNSAT 3 30 -0.4466 0.0000 5.6294 6.6993 SAT 0.8421 0.9876 UNSAT 4 45 -0.2512 0.0414 161.1086 3.2101 SAT 0.6096 0.9723 UNSAT 5 100 -0.1693 1.0253 18.4995 3.5624 SAT 0.5159 0.9492 UNSAT 6 115 -0.1191 -0.5932 10.1152 3.2400 SAT 0.4308 0.9106 UNSAT 7 130 -0.0924 -0.4197 7.7071 2.6186 SAT 0.3981 0.8679 UNSAT 8 145 -0.0363 25.1516 6.6086 3.4970 UNSAT 0.0815 0.5170 UNSAT 9 200 0.0047 19.7252 5.9883 3.6703 UNSAT 0.0015 0.0180 UNSAT 10 215 0.0039 -1.2763 5.5920 2.3822 SAT 0.0015 0.0134 UNSAT 11 230 0.0304 -1.3200 5.3179 2.6482 SAT 0.0854 0.4544 UNSAT

~

245 0.0274 -2.2749 5.1173 1.7525 SAT 0.0891 0.4085 UNSAT 300 0.0461 6.2574 4.9643 2.0234 UNSAT 0.2253 0.6665 UNSAT 315 0.0523 -5.2162 4.8438 1.7562 SAT 0.3131 0.7238 UNSAT 15 330 0.0378 -0.5141 4.7466 0.7382 SAT 0.1981 0.5820 UNSAT 16 345 0.0322 -0.4720 4.6664 0.3367 SAT 0.1744 0.5063 UNSAT 17 400 0.0332 -0.3063 4.5993 0.3065 SAT 0.2120 0.5249 UNSAT 18 415 0.0340 -0.1927 4.5422 0.2760 SAT 0.2504 0.5394 UNSAT 19 430 0.0234 -0.1157 4.4931 0.2291 SAT 0.1331 0.3600 UNSAT 20 445 0.0247 -0.0393 4.4503 0.1323 SAT 0.1656 0.3873 UNSAT 21 500 0.0197 -1. 2182 4.4129 0.3236 SAT 0.1220 0.2901 UNSAT 22 515 0.0213 -0.2729 4.3797 0.2007 SAT 0.1562 0.3247 UNSAT 23 530 0.0251 0.0001 4.3502 0.0020 SAT 0.2190 0.4024 UNSAT 24 545 0.0220 0.1393 4.3238 0.1388 SAT 0.1913 0.3429 UNSAT 25 600 0.0163 2.6543 4.2999 0.3716 SAT 0.1143 0.2241 UNSAT 26 615 0.0087 4.5943 4.2783 0.6603 UNSAT 0.0316 0.0759 UNSAT 27 630 0.0052 16.7960 4.2587 0.7243 UNSAT 0.0123 0.0288 UNSAT 28 645 0.0109 2.0561 4.2407 0.3710 SAT 0.0509 0.1161 UNSAT 29 700 0.0118 1. 8528 4.2242 0.2806 SAT 0.0653 0.1348 UNSAT 715 0.0108 1.1871 4.2090 0.2900 SAT 0.0606 0,1161 UNSAT 730 0.0134 0.1650 4.1950 0.1365 SAT 0.0953 0.1690 UNSAT 32 745 0.0117 0.2875 4.1820 0.2000 SAT 0.0794 0.1343 UNSAT 33 800 0.0095 0.9129 4.1700 0.2774 SAT 0.0569 0.0932 UNSAT 34 815 0.0073 2.5731 4. 1587 0.3447 SAT 0.0365 0.0580 UNSAT 35 830 0.0063 1.8026 4.1482 0.3552 SAT 0.0292 0.0434 UNSAT 36 845 0.0068 1.4073 4.1384 0.2936 SAT 0.0367 0.0506 UNSAT 37 900 0.0057 1.2220 4.1291 0.3142 SAT 0.0279 0.0362 UNSAT 38 915 0.0048 1.1035 4.1205 0.3230 SAT 0.0214 0.0261 UNSAT 39 930 0.0023 1.9158 4.1123 0.4066 SAT 0.0050 0.0062 UNSAT 40 945 0.0004 2.7750 4.1046 0.4548 SAT 0.0002 0.0002 UNSAT 41 1000 -0.0025 3.6844 4.0973 0.5475 SAT 0.0058 0.0072 UNSAT 42 1015 -0.0063 6.7540 4.0905 0.6748 UNSAT 0.0325 0.0446 UNSAT 43 1030 -0.0056 4.6926 4.0839 0.5827 UNSAT 0.0278 0.0360 UNSAT 44 1045 -0.0074 5.1506 4.0778 0.6165 UNSAT 0.0488 0.0617 UNSAT 45 1100 -0.0067 3.6522 4.0719 0.5313 SAT 0.0428 0.0513 UNSAT 46 1115 -0.0088 4.1375 4.0663 0.5849 UNSAT 0.0717 0.0856 UNSAT 47 1130 -0.0101 4.3618 4.0609 0.5973 UNSAT 0.0952 0.1097 UNSAT 48 1145 -0.0114 4.5324 4.0559 0.6118 UNSAT 0.1225 0.1368 UNSAT 49 1200 -0.0115 4.3200 4.0510 0.5664 UNSAT 0.1305 0. 1384 UNSAT 50 1215 -0.0100 2.8642 4.0464 0.4537 SAT 0.1045 0.1094 UNSAT

BYR183H.DAT NRC REPORT ***************************

PAGE 2 DATE 24-1987 TIME - 12:42:05 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < . 25 (1) (2 . 1) (2. 1) ( 2) 51 1230 -0.0086 1.8148 4.0419 0.3511 SAT 0.0801 0.0828 UNSAT 52 1245 -0.0086 1.7680 4.0377 0.3242 SAT 0.0843 0.0828 SAT 53 1300 -0.0076 1.0974 4.0336 0.2515 SAT 0.0685 0.0654 SAT 54 1315 -0.0066 0.6413 4.0297 0.1888 SAT 0.0551 0.0510 SAT 55 1330 -0.0058 0.3464 4.0259 0.1364 SAT 0.0444 0.0396 SAT 56 1345 -0.0050 0. 1568 4.0223 0.0898 SAT 0.0349 0.0300 SAT 57 1400 -0.0052 0.1893 4.0189 0.0930 SAT 0.0395 0.0325 SAT 58 1415 -0.0043 0.0419 4.0155 0.0421 SAT 0.0276 0.0221 SAT 59 1430 -0.0043 0.0489 4.0123 0.0423 SAT 0.0298 0,0228 SAT 60 1445 -0.0047 0.0957 4.0092 0.0565 SAT 0.0363 0.0266 SAT 4'1515 61 1500 1530 1545

-0.0052

-0.0050

-0.0050

-0.0040 0.1854 0.1495 0.1508 0.0046 4.0062 4.0034 4.0006 3.9979 0.0763 0.0624 0.0578 SAT SAT SAT 0.0457 0.0445 0.0463 0.0323 0.0301 0.0300 SAT SAT SAT 0.0096 SAT 0.0313 0.0200 SAT 65 1600 -0.0031 0.0629 3.9953 0.0332 SAT 0.0195 0.0123 SAT 66 1615 -0.0030 0.0673 3.9928 0.0359 SAT 0.0191 0.0115 SAT 67 1630 -0.0030 0.0774 3.9903 0.0349 SAT 0.0197 0.0114 SAT 68 1645 -0.0015 0.7164 3.9880 0.1036 SAT 0.0049 0.0030 SAT 69 1700 -0.0012 0.9326 3.9857 0.1162 SAT 0.0029 0.0017 SAT 70 1715 -0.0010 0.9334 3.9835 0.1179 SAT 0.0022 0.0012 SAT 71 1730 -0.0003 1. 6452 3.9813 0.1444 SAT 0.0002 0.0001 SAT 72 1745 0.0005 2.1879 3.9792 0.1736 SAT 0.0005 0.0003 SAT 73 1800 0.0009 2.7005 3.9772 0.1838 SAT 0.0019 0.0010 SAT 74 1815 0.0010 2.4702 3.9753 0.1775 SAT 0.0023 0.0012 SAT 75 1830 0.0020 3.9965 3.9734 0.2176 SAT 0.0094 0.0050 SAT 76 1845 0.0018 3.8440 3.9715 0.1959 SAT 0.0077 0.0040 SAT 77 1900 0.0025 5.0536 3.9697 0.2234 SAT 0.0159 0.0082 SAT 78 1915 0.0030 5.1520 3.9679 0.2353 SAT 0.0230 0.0116 SAT 79 1930 0.0032 5.2582 3.9662 0.2308 SAT 0.0260 0.0127 SAT

• 1945 0.0039 6.6038 3.9646 0.2532 UNSAT 0.0385 0.0189 SAT 2000 0.0045 7.6568 3.9630 0.2696 UNSAT 0.0511 0.0251 SAT 82 2015 0.0043 6.5546 3.9614 0.2516 UNSAT 0.0505 0.0239 SAT 83 2030 0.0045 6.7637 3.9598 0.2453 SAT 0.0550 0.0253 SAT 84 2045 0.0049 6.9493 3.9584 0.2526 UNSAT 0.0658 0.0298 SAT 85 2100 0.0051 7.9498 3.9569 0.2517 UNSAT 0.0736 0.0325 SAT 86 2115 0.0050 7.1634 3.9555 0.2372 SAT 0.0741 0.0317 SAT 87 2130 0.0056 8.7627 3.9541 0.2530 UNSAT 0.0902 0.0388 SAT 88 2145 0.0061 10.3233 3.9527 0.2655 UNSAT 0.1062 0.0456 SAT 89 2200 0.0063 9.7826 3.9514 0.2651 UNSAT 0.1165 0.0491 SAT 90 2215 0.0063 9.8427 3,9501 0.2546 UNSAT 0.1207 0.0495 SAT 91 2230 0.0062 9.0564 3.9488 0.2398 SAT 0.1215 0.0484 SAT 92 2245 0.0066 10.5619 3.9476 0.2498 SAT 0.1376 0.0548 SAT 93 2300 0.0061 8.0292 3.9464 0.2140 SAT 0.1197 0.0470 SAT 94 2315 0.0062 8.7766 3.9452 0.2092 SAT 0.1260 0.0483 SAT 95 2330 0.0062 9.1232 3.9441 0.2019 SAT 0.1304 0.0487 SAT 96 2345 0.0064 8.7626 3,9430 0.2028 SAT 0.1406 0.0516 SAT 97 0 0.0062 6.8464 3.9419 0.1836 SAT 0.1349 0.0482 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

CALCL178.DAT PAGE 1 I

DATE 24-1987 TIME - 12:43:11 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < . 25 (1) ( 2. 1) (2. 1) ( 2) 1 0 0.0000 6.8464 3.9419 0.1836 SAT 0.1349 0.0482 SAT 2 15 0.0000 6.8464 3.9419 0.1836 SAT 0.1349 0.0482 SAT 3 30 0.0147 0.0000 5.6294 0.2933 SAT 0.4286 0.0211 SAT 4 45 0.0117 0.0001 161.1086 0.1100 SAT 0.5333 0.0187 SAT 5 100 0.0264 0.0010 18.4995 0.1676 SAT 0.7168 0.1019 SAT 6 115 0.0184 0.0002 10.1152 0.0458 SAT 0.5843 0.0576 SAT 7 130 0.0529 -1.0739 7.7071 0.5500 SAT 0.5677 0.3501 SAT 8 145 0.0494 0.0246 6.6086 0.2597 SAT 0.6282 0.3311 SAT 9 200 0.0885 0.5366 5.9883 0.8724 SAT 0.6312 0.6231 SAT 10 215 0.0916 -5.6634 5.5920 0.6325 SAT 0.7143 0.6467 SAT 11 230 0.1144 -0.9941 5.3179 0.8718 SAT 0.7624 0.7461 SAT 245 0.1175

~

-8.8491 5.1173 0.6769 SAT 0.8133 0.7607 SAT 300 0.1170 2.3150 4.9643 0.4817 SAT 0.8460 0.7629 SAT 315 0.1146 4.2403 4.8438 0.3097 SAT 0.8668 0.7587 SAT 15 330 0.1208 0.5178 4.7466 0.3620 SAT 0.8899 0.7803 SAT 16 345 0.1271 0.3707 4.6664 0.4113 SAT 0.9061 0.7997 SAT 17 400 0.1287 0.7511 4.5993 0.3563 SAT 0.9217 0.8058 SAT 18 415 0.1314 3.6585 4.5422 0.3411 SAT 0.9338 0.8141 SAT 19 430 0.1400 1.4526 4.4931 0.4607 SAT 0.9305 0.8343 SAT 20 445 0.1383 0.7182 4.4503 0.3374 SAT 0.9375 0.8322 SAT 21 500 0.1316 0.0934 4.4129 0.1318 SAT 0.9258 0.8193 SAT 22 515 0.1258 0.0017 4.3797 0.0163 SAT 0.9174 0.8072 SAT 23 530 0.1199 0.1487 4,3502 0.1426 SAT 0.9061 0.7933 SAT 24 545 0.1165 0.3016 4.3238 0.1953 SAT 0.9068 0.7851 SAT 25 600 0.1203 0.0739 4.2999 0.0831 SAT 0.9151 0.7968 SAT 26 615 0.1210 0.0275 4.2783 0.0541 SAT 0.9244 0.8001 SAT 27 630 0.1206 0.0276 4.2587 0.0569 SAT 0.9314 0.8000 SAT 28 645 0.1220 0.0028 4.2407 0.0164 SAT 0.9383 0.8048 SAT 29 700 0.1225 0.0002 4.2242 0.0042 SAT 0.9444 0.8069 SAT 715 0.1154 0.3719 4.2090 0. 1629 SAT 0.9133 0.7887 SAT 730 0.1139 0.6167 4.1950 0.1776 SAT 0.9174 0.7852 SAT 32 745 0.1091 1.7577 4.1820 0.2664 SAT 0.9020 0.7713 SAT 33 800 0.1059 3.3556 4.1700 0.3079 SAT 0,8974 0.7617 SAT 34 815 0.1032 3.3145 4.1587 0.3356 SAT 0.8948 0.7530 SAT 35 830 0.1017 3.1184 4.1482 0.3337 SAT 0.8982 0.7484 SAT 36 845 0.1001 3.3553 4.1384 0.3334 SAT 0.9008 0.7435 SAT 37 900 0.0982 3.3800 4.1291 0.3445 SAT 0.9006 0.7367 SAT 38 915 0.0973 3,4365 4.1205 0.3292 SAT 0.9054 0.7342 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

CALCL182.DAT PAGE 1 DATE 24-1987 TIME - 12:43:56 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) ( 2. 1) (2. 1) ( 2) 1 0 0.0000 3.4365 4.1205 0.3292 SAT 0.9054 0.7342 SAT 2 15 0.0000 3.4365 4.1205 0.3292 SAT 0.9054 0.7342 SAT 3 30 0.0447 0.0000 5.6294 0.8944 SAT 0.4286 0.1667 SAT 4 45 0.0492 0.0004 161.1086 0.2795 SAT 0.6914 0.2514 SAT 5 100 0.1416 0.0438 18.4995 1.4267 SAT 0.6883 0.7655 UNSAT 6 115 0.1137 0.0028 10.1152 0.2329 SAT 0.6750 0.6990 UNSAT 7 130 0.0740 0.1059 7.7071 0.5377 SAT 0.4565 0.5131 UNSAT 8 145 0.0736 0.0309 6.6086 0.3199 SAT 0.5551 0.5237 SAT 9 200 0.0606 0.9864 5.9883 0.4362 SAT 0.5166 0.4369 SAT 10 215 0.0515 0.9419 5.5920 0.4586 SAT 0.4934 0.3667 SAT 11 230 0.0455 -0.2267 5.3179 0.4282 SAT 0.4910 0.3177 SAT 245 0.0415 -1.4896 5.1173 0.3804 SAT 0.5020 0.2837 SAT 300 0.0372 -0.9328 4.9643 0.3628 SAT 0.4952 0.2452 SAT 315 0.0300 0.4659 4.8438 0.4146 SAT 0.4031 0.1774 SAT 15 330 0.0358 0.7408 4.7466 0.1964 SAT 0.5104 0.2376 SAT 16 345 0.0362 0.1231 4.6664 0.1433 SAT 0.5645 0.2448 SAT 17 400 0.0323 -0.6359 4.5993 0.1951 SAT 0.5314 0.2072 SAT 18 415 0.0332 0.1782 4.5422 0.1377 SAT 0.5855 0.2182 SAT 19 445 0.0304 7.6778 4.4931 0.1646 SAT 0.5787 0.1792 SAT 20 500 0.0299 0.6028 4.4503 0.1381 SAT 0.6119 0.1787 SAT 21 515 0.0287 -0.3756 4.4129 0.1353 SAT 0.6276 0.1711 SAT 22 530 0.0258 1.3352 4.3797 0.1728 SAT 0.5834 0.1454 SAT 23 545 0.0257 0.8453 4.3502 0.1473 SAT 0.6157 0.1470 SAT 24 600 0.0253 -18.8310 4.3238 0.1352 SAT 0.6374 0.1447 SAT 25 615 0.0259 -0.2638 4.2999 0.1033 SAT 0.6746 0.1526 SAT 26 630 0.0249 -3.0969 4.2783 0. 1096 SAT 0.6789 0.1447 SAT 27 645 0.0257 -3.5893 4,2587 0.0794 SAT 0.7123 0.1538 SAT 28 700 0.0252 0.5039 4.2407 0.0810 SAT 0.7240 0.1498 SAT 29 715 0.0224 -2.1555 4.2242 0.1326 SAT 0.6383 0.1238 SAT 730 0.0228 -0.6473 4.2090 0.1084 SAT 0.6674 0.1284 SAT

• --* 745 0.0218

-55.7729

---

--*- 4.1950 0.1188 SAT

• -----~ -

0.6592 0.1193--

SAT

CALCL185.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 12:44:35 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2. 1) (2 . 1) ( 2) 1 0 0.0000 3.3543 4.1820 16.3658 SAT 0.0755 0.9945 UNSAT 2 15 0.0000 3.3543 4.1820 16.3658 SAT 0.0755 0.9945 UNSAT 3 30 0.1249 0.0000 5.6294 0.0735 SAT 0.9988 0.6096 SAT 4 45 0.0573 -0.0016 161.1086 0.8267 SAT 0.5182 0.3132 SAT 5 100 0.0823 -0.0000 18.4995 0,0420 SAT 0,7590 0.5244 SAT 6 115 0.0252 -0.0166 10.1152 0.8727 SAT 0.1022 0.1024 UNSAT 7 130 0.0352 -0.0035 7.7071 0.2992 SAT 0,2530 0.1923 SAT 8 145 0.0339 -0.0030 6.6086 0.1990 SAT 0.3210 0.1893 SAT 9 200 0.0292 -0.0080 5.9883 0.2112 SAT 0.3256 0.1521 SAT 10 215 0.0275 -0.0079 5.5920 0.1716 SAT 0.3705 0.1420 SAT 11 230 0.0194 -0.0366 5,3179 0.2741 SAT 0.2437 0.0778 SAT

~

245 0.0190 -0.0271 5.1173 0.2021 SAT 0.2874 0.0768 SAT 300 0.0143 -0.0559 4.9643 0.2414 SAT 0.2063 O_. 0458 SAT 315 0.0185 -0.0077 4.8438 0.0935 SAT 0.3282 0.0756 SAT 15 330 0.0189 -0.0057 4.7466 0.0614 SAT 0.3858 0.0800 SAT 16 345 0.0194 -0.0025 4.6664 0,0355 SAT 0,4452 0.0852 SAT 17 400 0.0220 -0.0014 4.5993 0,0261 SAT 0,5324 0.1079 SAT 18 415 0.0267 -0.0398 4.5422 0.1222 SAT 0.5992 0.1536 SAT 19 430 0.0283 -0.0508 4.4931 0.1324 SAT 0.6561 0.1709 SAT 20 445 0.0320 -0.1190 4.4503 0.1879 SAT 0.6985 0.2103 SAT 21 500 0.0324 -0.1390 4.4129 0.1638 SAT 0.7330 0.2163 SAT 22 515 0.0360 -0.4571 4.3797 0.2145 SAT 0.7559 0.2557 SAT 23 530 0.0353 -0.3310 4.3502 0.1646 SAT 0.7713 0.2499 SAT 24 545 0.0365 -0.4578 4.3238 0.1648 SAT 0.7987 0.2639 SAT 25 600 0.0352 -0.2523 4.2999 0.1106 SAT 0.7993 0.2512 SAT 26 615 0.0355 -0.4154 4.2783 0.1007 SAT 0.8196 0.2556 SAT 27 630 0.0365 -0.5545 4.2587 0.1093 SAT 0.8388 0.2677 SAT 28 645 0.0368 -2.5486 4.2407 0.1023 SAT 0.8543 0.2723 SAT 29 700 0.0358 -0.1755 4.2242 0.0683 SAT 0.8567 0.2636 SAT 715 0.0342 -0.1295 4.2090 0.0217 SAT 0.8426 0.2471 SAT 730 0.0329 -0.1017 4.1950 0.0104 SAT 0.8352 0.2342 SAT 32 745 0.0333 0.0003 4.1820 0.0020 SAT 0.8501 0.2390 SAT 33 800 0.0330 0.0046 4.1700 0.0083 SAT 0.8588 0.2368 SAT 34 815 0.0322 0.0744 4.1587 0.0256 SAT 0.8595 0.2292 SAT 35 830 0.0338 0.0171 4.1482 0.0133 SAT 0.8620 0.2474 SAT 36 845 0.0331 0.0017 4.1384 0.0040 SAT 0.8637 0.2408 SAT 37 900 0.0340 -2.2311 4.1291 0.0163 SAT 0.8730 0.2511 SAT 38 915 0.0335 0.0423 4.1205 0.0035 SAT 0.8767 0.2465 SAT 39 930 0.0326 1. 5263 4.1123 0.0185 SAT 0.8711 0.2369 SAT 40 945 0.0324 0.4751 4.1046 0.0204 SAT 0.8779 0.2357 SAT 41 1000 0.0320 0.1567 4.0973 0.0269 SAT 0.8820 0.2323 SAT

CALCL285.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 12:45:45 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1} < . 25 (1) (2 . 1) (2 . 1) ( 2) 1 0 0.0000 -3.5804 4.1820 0.1629 SAT 0.1461 0.0478 SAT 2 15 0.0000 -3.5804 4.1820 0.1629 SAT 0.1461 0.0478 SAT 3 30 0 . 0882 0.0000 5.6294 1.1761 SAT 0.6279 0.4377 SAT 4 45 0.0118 -0.0087 161.1086 0.6615 SAT 0.0235 0.0188 SAT 5 100 0.0470 0.0018 18.4995 0.2520 SAT 0.3497 0.2648 SAT 6 115 0.0315 0.0040 10.1152 0.1247 SAT 0.2707 0.1513 SAT 7 130 0.0604 0.0221 7.7071 0.4148 SAT 0.5436 0.4123 SAT 8 145 0.0208 0.1093 6.6086 0.4471 SAT 0.0774 0.0808 UNSAT 9 200 0.0108 0.0690 5.9883 0.4614 SAT 0.0293 0.0240 SAT 10 215 -0.0078 1.0438 5.5920 0.6515 SAT 0.0159 0.0130 SAT 11 230 -0.0021 0.0998 5.3179 0.3375 SAT 0.0016 0.0010 SAT

~

245 -0.0039 0.7595 5.1173 0.2728 SAT 0.0068 0.0035 SAT 300 -0.0048 -0.1113 4.9643 0.2172 SAT 0.0132 0.0055 SAT 315 0.0002 -0.0064 4.8438 0.0587 SAT 0.0000 0,0000 SAT 15 330 -0.0025 -0.0261 4.7466 0.0988 SAT 0.0048 0.0015 SAT 16 345 0.0082 -0.0420 4.6664 0.1444 SAT 0,0409 0.0162 SAT 17 400 0.0072 -0.0160 4.5993 0.0936 SAT 0.0384 0.0128 SAT 18 415 0.0142 -0.1483 4.5422 0.2218 SAT 0.1289 0.0484 SAT 19 430 0.0191 -0.3617 4.4931 0.2853 SAT 0.2209 0.0859 SAT 20 445 0.0298 -1.2819 4.4503 0.4632 SAT 0.3317 0. 1877 SAT 21 500 0.0349 -1.6573 4.4129 0.4915 SAT 0.4157 0.2420 SAT 22 515 0.0339 -0.8491 4,3797 0.3880 SAT 0.4350 0.2334 SAT 23 530 0.0338 -0.5732 4.3502 0.3219 SAT 0.4658 0.2333 SAT 24 545 0.0382 -0.8412 4.3238 0.3693 SAT 0.5298 0.2816 SAT 25 600 0.0423 -1.0233 4.2999 0.4064 SAT 0.5840 0.3269 SAT 26 615 0.0470 -1.2486 4.2783 0.4514 SAT 0.6279 0.3762 SAT 27 630 0,0450 -1.0583 4.2587 0.3428 SAT 0.6269 0.3573 SAT 28 645 0.0475 -1. 5298 4.2407 0.3556 SAT 0.6652 0.3849 SAT 29 700 0.0478 -1.9999 4.2242 0.3149 SAT 0.6904 0,3889 SAT 715 0.0478 -2.5234 4.2090 0.2751 SAT 0.7114 0.3902 SAT 730 0.0477 -1.8913 4.1950 0.2408 SAT 0.7309 0.3912 SAT 32 745 0.0476 -1,0918 4.1820 0.2094 SAT 0.7482 0.3912 SAT 33 800 0.0510 -1.4513 4.1700 0.2615 SAT 0.7621 0.4252 SAT 34 815 0.0523 -1.6257 4.1587 0.2630 SAT 0.7823 0.4391 SAT 35 830 0.0524 -1. 2095 4.1482 0.2364 SAT 0.7974 0.4412 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

CALCL282.DAT PAGE 1 DATE 24-1987 TIME - 12:45:14 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2 . 1) (2. 1) ( 2) 1 0 0.0000 0.1567 4.0973 0.0269 SAT 0.8820 0.2323 SAT 2 15 0.0000 0.1567 4.0973 0.0269 SAT 0.8820 0.2323 SAT 3 30 -0.0290 0.0000 5.6294 1.1614 SAT 0.1579 0.0778 SAT 4 45 0.0595 0.0015 161.1086 0.8166 SAT 0.3352 0.3296 SAT 5 100 -0.0102 0.0039 18.4995 0.6844 SAT 0.0122 0.0165 UNSAT 6 115 0.0004 0.0005 10.1152 0.1555 SAT 0.0000 0.0000 SAT 7 130 -0.0021 0.0008 7.7071 0.1244 SAT 0.0014 0.0008 SAT 8 145 0.0285 0.0202 6.6086 0.4628 SAT 0.1713 0.1415 SAT 9 200 0.0448 0.0377 5.9883 0.5839 SAT 0.3729 0.2973 SAT 10 215 0.0268 0.0005 5.5920 0.0470 SAT 0.1788 0.1359 SAT 11 230 0.0469 0.0901 5.3179 0.4171 SAT 0.3735 0.3302 SAT

~

245 0.0432 0.0389 5.1173 0.2214 SAT 0.3934 0.3004 SAT 300 0.0463 0.0578 4.9643 0.2223 SAT 0.4826 0.3347 SAT 315 0.0523 0.3020 4.8438 0.2881 SAT 0.5797 0.3954 SAT 15 330 0.0512 0.1662 4.7466 0.1976 SAT 0.6193 0.3898 SAT 16 345 0.0609 1.0630 4.6664 0.3551 SAT 0.6774 0.4785 SAT 17 400 0.0584 0.9243 4.5993 0.2264 SAT 0.6940 0.4610 SAT 18 415 0.0483 -0.0137 4.5422 0.0365 SAT 0.5615 0.3714 SAT 19 430 0.0400 -1.3141 4.4931 0.2059 SAT 0.4526 0.2910 SAT 20 445 0.0292 -5.8717 4.4503 0.4001 SAT 0.2668 0.1816 SAT 21 500 0.0283 -4.5147 4.4129 0.3509 SAT 0.2818 0.1731 SAT 22 515 0.0194 _::A .Btt7, 4.3797 0.4852 SAT 0.1418 0.0909 SAT

CLIN86.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 12:49:39 REC TIME LAM LEFT < RIGHT EQ (1.2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) ( 2. 1 ) (2. 1) ' (2 )

1 0 0.0000 1.9418 3.9419 128.5626 SAT 0.0014 0.9991 UNSAT 2 15 0.0000 1.9418 3.9419 128.5626 SAT 0.0014 0.9991 UNSAT 3 30 0.1758 0.0000 5.6294 0.5408 SAT 0.7500 0.2264 SAT 4 45 0.2197 0.0061 161.1086 0.3042 SAT 0.8993 0.3881 SAT 5 100 0.1758 0.0012 18.4995 0.0773 SAT 0.8696 0.3225 SAT 6 115 0.1632 0.0089 10.1152 0.0966 SAT 0.9031 0.3118 SAT 7 130 0.1460 0.0142 7.7071 0.1400 SAT 0.9032 0.2796 SAT 8 145 0.1705 0.0022 6.6086 0.0507 SAT 0.9142 0.3582 SAT 9 200 0.1677 0.0005 5.9883 0.0158 SAT 0.9358 0.3599 SAT 10 230 0.1594 0.0058 5.5920 0.0387 SAT 0.9484 0.3166 SAT 11 245 0.1683 0.0059 5.3179 0.0201 SAT 0.9600 0.3610 SAT

~300 0.1779 0.0724 5.1173 0.0673 SAT 0.9643 0.4019 SAT 315 0.1875 4.2277 4.9643 0.1061 SAT 0.9660 0 .. 4380 SAT 330 0.1964 1.6279 4.8438 0,1368 SAT 0.9671 0.4693 SAT 15 345 0.2057 1. 1740 4.7466 0.1664 SAT 0.9667 0.4988 SAT 16 400 0.2105 1.0540 4.6664 0.1628 SAT 0.9711 0.5153 SAT 17 415 0.2209 2.0731 4.5993 0.2001 SAT 0.9667 0.5436 SAT 18 430 0.2262 1. 681 7 4.5422 0.1972 SAT 0.9699 0.5589 SAT 19 445 0.2312 4.2308 4.4931 0.1946 SAT 0.9725 0.5726 SAT 20 500 0.2341 3.2852 4.4503 0.1801 SAT 0.9758 0.5815 SAT 21 515 0.2352 3.0199 4.4129 0,1558 SAT 0.9789 0.5859 SAT 22 530 0.2358 2.2376 4.3797 0.1338 SAT 0.9815 0,5893 SAT 23 545 0.2352 1. 9098 4.3502 0.1083 SAT 0.9835 0.5900 SAT 24 600 0.2338 2.0534 4.3238 0.0817 SAT 0.9850 0.5889 SAT 25 615 0.2311 0.3957 4.2999 0.0502 SAT 0.9852 0.5849 SAT 26 630 0.2281 0.0672 4.2783 0.0222 SAT 0.9850 0.5802 SAT 27 645 0.2260 0.0031 4.2587 0.0042 SAT 0.9856 0.5771 SAT 28 700 0.2237 0.0437 4.2407 0.0129 SAT 0.9857 0.5734 SAT 29 715 0.2209 0.2969 4.2242 0.0310 SAT 0.9853 0.5685 SAT 730 0.2184 0.4578 4.2090 0.0451 SAT 0.9850 0.5640 SAT 745 0.2163 0.5503 4.1950 0.0545 SAT 0.9852 0.5605 SAT 32 800 0.2143 0.9044 4.1820 0.0619 SAT 0.9854 0.5571 SAT 33 815 0.2129 0.8479 4.1700 0.0647 SAT 0.9860 0.5550 SAT 34 830 0.2110 1.1401 4.1587 0.0715 SAT 0.9859 0.5514 SAT 35 845 0.2095 1. 7174 4.1482 0.0739 SAT 0.9864 0.5491 SAT 36 900 0.2078 2.4807 4.1384 0.0784 SAT 0.9864 0.5460 SAT 37 915 0.2067 2.8157 4.1291 0.0780 SAT 0.9870 0.5444 SAT - - ---- ....!

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

CONN172.DAT PAGE 1 DATE 24-1987 TIME - 12:50:11 REC TIME LAM LEFT < RIGHT EQ (1.2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) ( 2. 1 ) ( 2. 1) ( 2) 1 0 0.0000 3.5912 4.1205 539.3185 SAT 0.0672 1.0000 UNSAT 2 100 0.0000 3.5912 4.1205 539.3185 SAT 0.0672 1.0000 UNSAT 3 200 0.1155 0.0000 5.6294 2.0859 SAT 0.5319 0.6224 UNSAT 4 300 0.2231 -0.2477 161.1086 2.0157 SAT 0.8004 0.8951 UNSAT 5 400 0.2274 -0.1083 18.4995 0.8366 SAT 0.8926 0.9122 UNSAT 6 500 0.1766 -0.1812 10.1152 0.4907 SAT 0.8166 0.8737 UNSAT 7 600 0.1805 -0.0307 7.7071 0.1891 SAT 0.8809 0.8856 UNSAT 8 700 0.2212 -0.7774 6.6086 0.6819 SAT 0.8867 0.9245 UNSAT 9 800 0.2462 -1.5469 5.9883 0.9294 SAT 0.9122 0.9405 UNSAT 10 900 0.2482 -1.4611 5.5920 0.6530 SAT 0.9354 0.9432 UNSAT

-1100 11 1000 1200 1300 0.2486 0.2392 0.2326 0.2186

-0.7580

-0.0611

-0.0379

-5.2232 5.3179 5.1173 4.9643 4.8438 0.4535 0.1165 0.0630 0.3612 SAT SAT SAT SAT 0.9509 0.9542 0.9589 0.9478 0.9448 0.9420 o_.9401 0.9339 SAT SAT SAT SAT 15 1400 0.2052 -20.6216 4.7466 0.5817 SAT 0.9352 0.9268 SAT 16 1500 0.1906 61.7512 4.6664 0.7887 UNSAT 0.9144 0.9172 UNSAT 17 1600 0.1755 182.4065 4.5993 0.9719 UNSAT 0.8859 0.9051 UNSAT 18 1700 0.1572 134.6744 4.5422 1.2073 UNSAT 0.8280 0.8856 UNSAT 19 1800 0.1453 90.1316 4.4931 1. 2585 UNSAT 0.8031 0.8699 UNSAT 20 1900 0.1334 199.5845 4.4503 1.3123 UNSAT 0.7708 0.8507 UNSAT 21 2000 0.1169 145.0037 4.4129 1.4786 UNSAT 0.6850 0.8155 UNSAT 22 2100 0.0995 146.9330 4.3797 1.6526 UNSAT 0.5691 0.7637 UNSAT 23 2200 0.0809 236.5785 4.3502 1.8390 UNSAT 0.4217 0.6831 UNSAT 24 2300 0.0600 300.7953 4.3238 2.0661 UNSAT 0.2449 0.5445 UNSAT 25 0 0.0368 301.9544 4.2999 2.3281 UNSAT 0.0888 0.3124 UNSAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

COOP85.DAT PAGE 1 DATE 24-1987 TIME - 13:35:50 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM (1.1) ( 1. 1) < . 25 (1) (2. 1) (2 . 1) ( 2) 1 0 0.0000 0.0000 0.0000 0.0000 SAT 0.0000 0.0000 UNSAT 2 20 0.0000 0.0000 0.0000 0.0000 SAT 0.0000 0.0000 UNSAT 3 40 0.0737 0.0000 5.6294 0.1733 SAT 0.8471 0. 0511 SAT 4 100 0.2228 -0.0544 161.1086 0.6304 SAT 0.7654 0.4060 SAT 5 120 0.2330 -0.0505 18.4995 0.2862 SAT 0.8757 0.4670 SAT 6 140 0.2166 0.0391 10.1152 0.0536 SAT 0.9080 0.4553 SAT 7 200 0.1949 0.2748 7.7071 0.0850 SAT 0.9102 0.4204 SAT 8 220 0.2226 0.0745 6.6086 0.1037 SAT 0.9244 0.4990 SAT 9 240 0.2022 0.0419 5.9883 0.0523 SAT 0.9149 0.4614 SAT 10 300 0.1822 -0.5807 5.5920 0.1524 SAT 0.8964 0.4183 SAT 11 320 0.1722 2.3183 5.3179 0.1643 SAT 0.9032 0.3980 SAT

~

340 0.1642 -1.2713 5.1173 0.1661 SAT 0.9105 0.3811 SAT 400 0.1657 -1.3699 4.9643 0.1115 SAT 0.9292 0.3903 SAT 420 0.1603 1.1037 4.8438 0.1179 SAT 0.9350 0.3790 SAT 15 440 0.1528 0.7996 4.7466 0.1384 SAT 0.9321 0.3604 SAT 16 500 0.1431 1.0723 4.6664 0.1705 SAT 0.9179 0.3343 SAT 17 520 0.1407 1.1994 4.5993 0.1505 SAT 0.9269 0.3297 SAT 18 540 0.1359 2.5032 4.5422 0.1512 SAT 0.9280 0.3175 SAT 19 600 0.1396 0.8906 4.4931 0.0974 SAT 0.9377 0.3317 SAT 20 620 0.1361 1.0389 4.4503 0.1027 SAT 0.9400 0.3230 SAT 21 640 0.1371 0.4756 4.4129 0.0780 SAT 0.9481 0.3282 SAT 22 700 0.1330 1.0152 4.3797 0.0933 SAT 0.9461 0.3169 SAT 23 720 0.1344 0.5950 4.3502 0.0683 SAT 0.9528 0.3236 SAT 24 740 0.1297 1.0009 4.3238 0.0907 SAT 0.9463 0.3098 SAT 25 800 0.1315 0.7059 4.2999 0.0642 SAT 0.9521 0.3175 SAT

DICN185.DAT NRC REPORT .

PAGE 1 DATE 24-1987 TIME - 13:36:56 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2 . 1) ( 2. 1) (2 )

1 0 0.0000 4.9999 4.24073838.6860 UNSAT 0.1034 1.0000 UNSAT 2 15 0.0000 4.9999 4.24073838.6860 UNSAT 0.1034 1.0000 UNSAT 3 30 0.1757 0.0000 5.6294 0.3634 SAT 0.9964 0.9251 SAT 4 45 0.1139 0.0036 161.1086 1.4538 SAT 0.8336 0.8780 UNSAT 5 100 0.0691 0.0244 18.4995 1.8345 SAT 0.5907 0.7564 UNSAT 6 115 0.0845 0.0026 10.1152 0.3624 SAT 0.7639 0.8367 UNSAT 7 130 0.0731 0.0246 7.7071 0.5711 SAT 0.7706 0.8045 UNSAT 8 145 0.0704 0,0071 6.6086 0.4341 SAT 0.8215 0.8007 SAT 9 200 0.0515 0.0302 5.9883 0.9576 SAT 0.6256 0.6913 UNSAT 10 215 0.0490 0.0230 5.5920 0.7228 SAT 0.6720 0.6769 UNSAT 11 230 0.0448 0.0283 5.3179 0.6481 SAT 0.6837 0.6435 SAT

• 245 0.0468 _0~010~ 5 .1173___,Q_ .3~21 ~L. 0.7504 0.6681 SAT-

GG185.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 13:37:46 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2 . 1) (2. 1) ( 2) 1 0 0.0000 0.5129 3.9419 7.7368 SAT 0.0123 0.9919 UNSAT 2 15 0.0000 0.5129 3.9419 7.7368 SAT 0.0123 0.9919 UNSAT 3 30 0.2615 0.0000 5.6294 0.0000 SAT 1.0000 0.5891 SAT 4 45 0.1700 -0.0218 161.1086 0.5237 SAT 0.8380 0.4566 SAT 5 100 0.1526 -0.0078 18.4995 0.3135 SAT 0.8826 0.4424 SAT 6 115 0.1382 -0.0076 10.1152 0.2494 SAT 0.9034 0.4183 SAT 7 130 0.1277 -0.0088 7.7071 0.2137 SAT 0.9176 0.3965 SAT 8 145 0.1308 -0.0050 6.6086 0.0997 SAT 0.9450 0.4207 SAT 9 200 0.1293 -0.0086 5.9883 0.0743 SAT 0.9597 0.4252 SAT 10 215 0.1334 -0.0004 5,5920 0.0119 SAT 0.9698 0.4488 SAT 11 230 0.1375 -0.0037 5.3179 0.0279 SAT 0.9759 0.4708 SAT 245 0.1430 -0.0171 5.1173 0.0688 SAT 0.9781 0.4962 SAT 300 0.1473 -0.0297 4.9643 0,0897 SAT 0.9806 0.5164 SAT 315 0.1483 -0.0230 4.8438 0.0753 SAT 0.9845 0.5245 SAT 15 330 0.1507 -0.0496 4,7466 0.0798 SAT 0.9867 0,5366 SAT 16 345 0.1480 -0.0114 4,6664 0.0367 SAT 0.9871 0.5314 SAT 17 400 0.1510 -0.0647 4.5993 0.0572 SAT 0.9878 0.5446 SAT 18 415 0.1511 -0.0503 4.5422 0.0474 SAT 0.9897 0.5484 SAT 19 430 0.1510 -0.1732 4.4931 0.0369 SAT 0.9912 0.5506 SAT 20 445 0.1530 -0.3730 4,4503 0.0503 SAT 0.9916 0.5600 SAT 21 500 0,1503 -0.0330 4.4129 0.0143 SAT 0.9904 0.5536 SAT 22 515 0.1480 0.0106 4.3797 0.0109 SAT 0.9898 0.5483 SAT 23 530 0.1466 0.0247 4.3502 0.0240 SAT 0.9903 0.5456 SAT 24 545 0.1462 0.0304 4.3238 0.0244 SAT 0.9913 0.5463 SAT 25 600 0,1457 0.0244 4.2999 0.0254 SAT 0.9922 0.5467 SAT 26 615 0.1452 0.0327 4.2783 0.0269 SAT 0.9929 0.5469 SAT 27 630 0.1461 0.0077 4.2587 0.0140 SAT 0.9934 0.5516 SAT 28 645 0.1454 0.0172 4.2407 0.0192 SAT 0.9939 0.5509 SAT 29 700 0.1433 0.0834 4.2242 0.0391 SAT 0.9923 0.5450 SAT 715 0.1428 0.0998 4.2090 0.0387 SAT 0.9929 0.5450 SAT 730 0.1411 0.2184 4.1950 0.0523 SAT 0.9919 0.5403 SAT 32 745 0.1406 0.1940 4.1820 0.0513 SAT 0.9925 0.5399 SAT 33 800 0.1396 0.2794 4,1700 0.0552 SAT 0.9926 0.5379 SAT 34 815 0.1377 0.5373 4.1587 0.0691 SAT 0.9910 0.5322 SAT 35 830 0.1369 0.5315 4.1482 0.0701 SAT 0.9912 0.5304 SAT

GINN82.DAT NRC REPORT *********~*****************

PAGE 1 DATE 24-1987 TIME - 13:38:23 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1 ) < .25 (1) ( 2. 1 ) (2 . 1) ( 2) 1 0 0.0000 0.5315 4.1482 0.0701 SAT 0.9912 0.5304 SAT 2 15 0.0000 0.5315 4.1482 0.0701 SAT 0.9912 0.5304 SAT 3 30 0.2431 0.0000 5.6294 5.6308 SAT 0.4894 0.9102 UNSAT 4 45 0.2357 -0.0049 161.1086 1.2853 SAT 0.6921 0.9296 UNSAT 5 100 0.0673 -0.0641 18.4995 2.6580 SAT 0.1002 0.5583 UNSAT 6 115 0.0898 -0.0280 10.1152 0.7869 SAT 0.2520 0.7127 UNSAT 7 130 0.0120 -0.2035 7.7071 2.1159 SAT 0.0057 0.0455 UNSAT 8 145 0.0004 -0.1416 6.6086 1.4995 SAT 0.0000 0.0001 UNSAT 9 200 -0.0100 -0.1643 5.9883 1.1827 SAT 0.0081 0.0348 UNSAT 10 215 0.0016 -0.0315 5.5920 0.4924 SAT 0.0003 0.0009 UNSAT 11 230 -0.0143 -0.0810 5.3179 0.7362 SAT 0.0260 0.0728 UNSAT

~

245 0.0145 -0.0150 5.1173 0.2220 SAT 0.0238 0.0767 UNSAT 300 0.0031 -0.0130 4.9643 0.1379 SAT 0.0013 0~0038 UNSAT 315 0.0108 -0.0078 4.8438 0.1038 SAT 0.0188 0.0454 UNSAT 15 330 0.0230 -0.1920 4.7466 0.4079 SAT 0.0867 0.1805 UNSAT 16 345 0.0356 -0.6190 4.6664 0.6596 SAT 0.1923 0.3491 UNSAT 17 400 0.0443 -1. 3864 4.5993 0.7580 SAT 0.2895 0.4571 UNSAT 18 415 0.0503 -1.0893 4.5422 0.7711 SAT 0.3732 0.5234 UNSAT 19 430 0.0384 -0.1720 4.4931 0.2891 SAT 0.2507 0.3933 UNSAT 20 445 0.0345 -0.0353 4.4503 0.1274 SAT 0.2358 0.3465 UNSAT 21 500 0.0376 -0.0785 4.4129 0. 1908 SAT 0.2934 0.3877 UNSAT 22 515 0.0296 -0.0128 4.3797 0.0682 SAT 0.2063 0.2844 UNSAT 23 530 0.0261 -0.0906 4,3502 0.1584 SAT 0.1831 0.2374 UNSAT 24 545 0.0280 -0.0278 4.3238 0.0791 SAT 0.2249 0.2653 UNSAT 25 600 0.0258 -0.0957 4.2999 0.1323 SAT 0.2147 0.2355 UNSAT 26 615 0.0276 -0.0183 4.2783 0.0592 SAT 0.2587 0.2630 UNSAT 27 630 0.0283 -0.0064 4.2587 0.0319 SAT 0.2903 0.2736 SAT 28 645 0.0311 -0.0193 4.2407 0.0555 SAT 0.3467 0.3142 SAT 29 700 0.0321 -0.0363 4.2242 0.0784 SAT 0.3848 0.3297 SAT 715 0.0296 -0.0002 4.2090 0.0061 SAT 0.3613 0.2959 SAT 730 0.0280 -0.0161 4.1950 0.0518 SAT 0.3552 0.2750 SAT 32 745 0.0257 -0.0995 4.1820 0.1137 SAT 0.3293 0.2433 SAT 33 800 0.0229 -0.3190 4.1700 0.1856 SAT 0.2853 0.2037 SAT 34 815 0.0238 -0.1699 4.1587 0.1376 SAT 0.3191 0.2175 SAT 35 830 0.0230 -0.2247 4.1482 0.1457 SAT 0.3223 0.2073 SAT 36 845 0.0231 -0.1728 4.1384 0.1275 SAT 0.3428 0.2093 SAT 37 900 0.0239 -0.1019 4.1291 0.0909 SAT 0.3751 0.2212 SAT 38 915 0.0243 -0.0633 4.1205 0.0697 SAT 0.4016 0.2278 SAT 39 930 0.0271 -0.0082 4.1123 0.0234 SAT 0.4465 0.2699 SAT 40 945 0.0252 -0.0221 4.1046 0.0366 SAT 0.4165 0.2430 SAT 41 1000 0.0248 -0.0379 4.0973 0.0460 SAT 0.4257 0.2376 SAT 42 1015 0.0224 -0.2831 4.0905 0.1158 SAT 0.3703 0.2028 SAT 43 1030 0.0240 -0.0665 4.0839 0.0564 SAT 0.4098 0.2269 SAT 44 1045 0.0220 -0.2929 4.0778 0.1113 SAT 0.3699 0.1990 SAT 45 1100 0.0201 -0.8006 4.0719 0.1628 SAT 0.3263 0.1711 SAT 46 1115 0.0186 -1. 4290 4.0663 0.1946 SAT 0.2988 0.1508 SAT 47 1130 0.0173 -1.7165 4.0609 0.2168 SAT 0.2771 0.1342 SAT 48 1145 0.0149 -2.7510 4.0559 0.2729 SAT 0.2135 0.1036 SAT 49 1200 0.0125 -4.0683 4.0510 0.3258 SAT 0.1535 0.0753 SAT 50 1215 0.0113 -4.9711 4.0464 0.3378 SAT 0.1328 0,0626 SAT

GINN82.DAT NRC REPORT **********-*****************

PAGE 2 DATE 24-1987 TIME - 13:38:30 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1 ) < .25 (1) ( 2. 1 ) (2. 1) (2 )

51 1230 0.0089 -7.8371 4.0419 0.3877 SAT 0.0817 0.0395 SAT 52 1245 0.0077 -8.6725 4.0377 0.3964 SAT 0.0639 0.0298 SAT 53 1300 0.0073 -7.7463 4.0336 0.3797 SAT 0.0609 0.0270 SAT 54 1315 0.0060 -8.9498 4.0297 0.3917 SAT 0.0431 0.0186 SAT 55 1330 0.0076 -7.5870 4.0259 0.3138 SAT 0.0674 0.0297 SAT 56 1345 0.0084 -5.5224 4.0223 0.2671 SAT 0.0842 0.0362 SAT 57 1400 0.0061 -9.1840 4.0189 0.3218 SAT 0.0424 0.0192 SAT 58 1415 0.0051 -11.9375 4.0155 0.3316 SAT 0.0307 0.0135 SAT 59 1430 0.0050 -9.5571 4.0123 0.3106 SAT 0.0319 0.0133 SAT 60 1445 0.0051 -8.5722 4.0092 0.2898 SAT 0.0338 0.0135 SAT

-1515 61 1500 1530 1545 0.0054 0.0059 0.0047 0.0038

-6.6787

-6.1834

-7.4380

-8.0105 4.0062 4.0034 4.0006 3.9979 0.2597 0.2296 0.2517 0.2647 SAT SAT SAT SAT 0.0405 0.0491 0.0323 0.0217 0.0156 0.0182 o _.0118 0.0077 SAT SAT SAT SAT 65 1600 0.0025 -10.0988 3.9953 0.2894 SAT 0.0095 0.0034 SAT 66 1615 0.0020 -10.5060 3.9928 0.2889 SAT 0.0061 0.0021 SAT 67 1630 0.0013 -11.4739 3.9903 0.2920 SAT 0.0029 0.0010 SAT 68 1645 0.0001 -14.0935 3.9880 0.3129 SAT 0.0000 0.0000 SAT 69 1700 0.0008 -13.2235 3.9857 0.2757 SAT 0.0010 0.0003 SAT 70 1715 0.0006 -11.9451 3.9835 0.2639 SAT 0.0007 0.0002 SAT 71 1730 0.0021 -8.9447 3.9813 0,2044 SAT 0.0072 0.0024 SAT 72 1745 0.0037 -5.0711 3.9792 0,1439 SAT 0.0207 0.0072 SAT 73 1800 0.0066 -0.8943 3.9772 0.0426 SAT 0.0511 0.0235 SAT 74 1815 0.0071 -0.3842 3.9753 0.0270 SAT 0.0595 0.0267 SAT 75 1830 0.0086 -0.3301 3.9734 0,0213 SAT 0.0827 0.0387 SAT 76 1845 0.0099 -2.7328 3.9715 0.0621 SAT 0.1061 0.0511 SAT 77 1900 0.0106 -4.0562 3.9697 0.0809 SAT 0.1223 0.0582 SAT 78 1915 0.0095 -1.2509 3.9679 0.0430 SAT 0.1011 0.0475 SAT 79 1930 0.0076 -0.8834 3.9662 0.0177 SAT 0.0636 0.0313 SAT

.1945 0.0067 6.0930 3.9646 0.0463 SAT 0.0502 0.0244 SAT 2000 0.0090 0.5787 3.9630 0.0265 SAT 0.0776 0.0425 SAT 82 2015 0.0091 0.8459 3.9614 0. 0311 SAT 0.0833 0.0443 SAT 83 2030 0.0084 0.0488 3.9598 0.0065 SAT 0.0727 0.0378 SAT 84 2045 0.0076 0.4929 3.9584 0.0185 SAT 0.0616 0.0313 SAT 85 2100 0.0068 1.6510 3.9569 0.0448 SAT 0.0497 0.0249 SAT 86 2115 0.0057 4.2705 3.9555 0.0758 SAT 0.0360 0.0179 SAT 87 2130 0.0052 5.1279 3.9541 0.0876 SAT 0.0312 0.0151 SAT 88 2145 0.0055 4.5881 3.9527 0.0754 SAT 0.0354 0.0167 SAT 89 2200 0.0049 8.0923 3.9514 0.0910 SAT 0.0289 0.0133 SAT 90 2215 0.0046 11. 3473 3.9501 0.0962 SAT 0.0264 0.0118 SAT 91 2230 0.0043 15.4862 3.9488 0.1033 SAT 0.0233 0.0101 SAT 92 2245 0.0051 4.8239 3.9476 0.0713 SAT 0.0335 0.0146 SAT 93 2300 0.0061 1.0563 3.9464 0.0393 SAT 0.0458 0.0202 SAT 94 2315 0.0066 0.2720 3.9452 0.0201 SAT 0.0551 0.0240 SAT 95 2330 0.0073 0.0063 3.9441 0.0033 SAT 0.0674 0.0293 SAT 96 2345 0.0079 0.2520 3.9430 0.0211 SAT 0.0787 0.0339 SAT 97 0 0.0080 0.4222 3.9419 0.0250 SAT 0.0838 0.0352 SAT

GINNA82.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 13:39:14 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < . 25 (1) (2 . 1) ( 2. 1) ( 2) 1 0 0.0000 0.4222 3.9419 0.0250 SAT 0.0838 0.0352 SAT 2 15 0.0000 0.4222 3.9419 0.0250 SAT 0.0838 0.0352 SAT 3 30 0.2431 0.0000 5.6294 5.6308 SAT 0.4894 0.9102 UNSAT 4 45 0.2357 -0.0049 161.1086 1.2853 SAT 0.6921 0.9296 UNSAT 5 100 0.0673 -0.0641 18.4995 2.6580 SAT 0.1002 0.5583 UNSAT 6 115 0.0898 -0.0280 10.1152 0.7869 SAT 0.2520 0.7127 UNSAT 7 130 0.0120 -0.2035 7.7071 2.1159 SAT 0.0057 0.0455 UNSAT 8 145 0.0004 -0.1416 6.6086 1.4995 SAT 0.0000 0.0001 UNSAT 9 200 -0.0100 -0.1643 5.9883 1.1827 SAT 0.0081 0.0348 UNSAT 10 215 0.0016 -0.0315 5.5920 0.4924 SAT 0.0003 0.0009 UNSAT 11 230 -0.0143 -0.0810 5.3179 0.7362 SAT 0.0260 0.0728 UNSAT 245 0.0145 -0.0150 5.1173 0.2220 SAT 0.0238 0.0767 UNSAT 300 0.0031 -0.0130 4.9643 0.1379 SAT 0.0013 0~0038 UNSAT 315 0.0108 -0.0078 4.8438 0.1038 SAT 0.0188 0.0454 UNSAT 15 330 0.0230 -0.1920 4.7466 0.4079 SAT 0.0867 0.1805 UNSAT 16 345 0.0356 -0.6190 4.6664 0.6596 SAT 0.1923 0.3491 UNSAT 17 400 0.0443 -1.3864 4.5993 0.7580 SAT 0.2895 0.4571 UNSAT 18 415 0.0503 -1.0893 4.5422 0.7711 SAT 0.3732 0.5234 UNSAT 19 430 0.0384 -0.1720 4.4931 0.2891 SAT 0.2507 0.3933 UNSAT 20 445 0.0345 -0.0353 4.4503 0.1274 SAT 0.2358 0.3465 UNSAT 21 500 0.0376 -0.0785 4.4129 0.1908 SAT 0.2934 0.3877 UNSAT 22 515 0.0296 -0.0128 4.3797 0.0682 SAT 0.2063 0.2844 UNSAT 23 530 0.0261 -0.0906 4.3502 0.1584 SAT 0.1831 0.2374 UNSAT 24 545 0.0280 -0.0278 4.3238 0.0791 SAT 0.2249 0.2653 UNSAT 25 600 0.0258 -0.0957 4.2999 0.1323 SAT 0.2147 0.2355 UNSAT 26 615 0.0276 -0.0183 4.2783 0.0592 SAT 0.2587 0.2630 UNSAT 27 630 0.0309 -0.0113 4.2587 0.0462 SAT 0.3191 0.3109 SAT 28 645 0.0323 -0.0313 4,2407 0.0788 SAT 0.3606 0.3308 SAT 29 700 0.0298 -0.0001 4.2242 0.0053 SAT 0.3403 0.2974 SAT 715 0.0283 -0.0124 4.2090 0.0489 SAT 0.3370 0.2775 SAT 730 0.0260 -0.0827 4.1950 0.1115 SAT 0.3135 0,2458 SAT 32 745 0.0231 -0.2745 4.1820 0.1848 SAT 0.2718 0.2055 SAT 33 800 0.0242 -0.1351 4.1700 0.1313 SAT 0.3077 0,2217 SAT 34 815 0.0234 -0.1780 4.1587 0.1385 SAT 0.3126 0.2121 SAT 35 830 0.0236 -0.1322 4.1482 0.1188 SAT 0.3347 0.2152 SAT 36 845 0.0245 -0.0697 4.1384 0.0801 SAT 0.3686 0.2286 SAT 37 900 0.0249 -0.0375 4.1291 0.0570 SAT 0.3965 0.2363 SAT 38 915 0.0280 -0.0220 4.1205 0.0407 SAT 0.4429 0.2810 SAT 39 930 0.0260 -0.0081 4.1123 0.0235 SAT 0.4133 0.2531 SAT

GINNA86.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 13:39:53 REC TIME LAM LEFT < RIGHT EQ (1.2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) (2. 1) (2. 1) ( 2) 1 0 0.0000 -0.0081 4.1123 0.0235 SAT 0.4133 0.2531 SAT 2 15 0.0000 -0.0081 4.1123 0.0235 SAT 0.4133 0.2531 SAT 3 30 0.7785 0.0000 5.6294 12.0950 SAT 0.6805 0.9905 UNSAT 4 45 0.5038 0.0045 161.1086 1.4672 SAT 0.6071 0.9837 UNSAT 5 100 0.2669 11.1242 18.4995 4.9900 SAT 0.3399 0.9521 UNSAT 6 115 -0.0400 -1.5438 10.1152 8.6336 SAT 0.0078 0.3301 UNSAT 7 130 -0.0246 -2.5803 7.7071 4.2644 SAT 0.0047 0.1664 UNSAT 8 145 0.0227 -0.2447 6.6086 1.3991 SAT 0.0057 0.1519 UNSAT 9 200 0.0445 -0.0253 5.9883 0.3540 SAT 0.0299 0.4172 UNSAT 10 215 0.0492 -0.0066 5.5920 0.1172 SAT 0.0492 0.4749 UNSAT 11 230 0.0657 0.1150 5.3179 0.3419 SAT 0.1074 0.6240 UNSAT e15 16 245 300 315 330 345 0.0790 0.0791 0.0867 0.0978 0.0882 0.1650 0.0680 0.0890 0.1662 0.0271 5.1173 4.9643 4.8438 4.7466 4.6664 0.5834 0.4241 0.5181 0.6918 0.2753 SAT SAT SAT SAT SAT 0.1814 0.2202 0.2952 0.3876 0.3766 0.7111 0.7156 0.7551 0.7995 0.7670 UNSAT UNSAT UNSAT UNSAT UNSAT 17 400 0.0943 0.0653 4.5993 0.3859 SAT 0.4491 0.7925 UNSAT 18 415 0.0928 0.0341 4.5422 0.2660 SAT 0.4835 0.7893 UNSAT 19 430 0.0899 0.0103 4.4931 0.1309 SAT 0.5063 0.7803 UNSAT 20 445 0.0845 0.0013 4.4503 0.0443 SAT 0.5076 0.7603 UNSAT 21 500 0.0855 0.0001 4.4129 0.0081 SAT 0.5501 0.7667 UNSAT 22 515 0.0808 0.0173 4.3797 0.1441 SAT 0.5490 0.7472 UNSAT 23 530 0.0798 0.0196 4.3502 0.1466 SAT 0.5758 0.7444 UNSAT 24 545 0.0798 0.0170 4.3238 0.1255 SAT 0.6065 0.7458 UNSAT 25 600 0.0799 0.0133 4.2999 0.1042 SAT 0.6359 0.7477 UNSAT 26 615 0.0790 0.0214 4.2783 0.1168 SAT 0.6571 0.7448 UNSAT 27 630 0.0787 0.0198 4.2587 0.1089 SAT 0.6807 0.7448 UNSAT 28 645 0.0772 0.0365 4,2407 0.1396 SAT 0.6940 0.7385 UNSAT 29 700 0.0753 0.0671 4.2242 0.1762 SAT 0.7033 0.7303 UNSAT 715 0.0743 0.0905 4.2090 0.1841 SAT 0.7175 0.7260 UNSAT 730 0.0723 0.1273 4.1950 0.2186 SAT 0.7230 0.7165 SAT 32 745 0.0725 0.1116 4.1820 0.1888 SAT 0.7424 0.7184 SAT 33 800 0.0713 0.1535 4.1700 0.2034 SAT 0.7517 0.7125 SAT 34 815 0.0689 0.2960 4.1587 0.2509 SAT 0.7488 0.6997 SAT 35 830 0.0696 0.2399 4.1482 0.2047 SAT 0.7677 0.7046 SAT 36 845 0.0703 0.1582 4.1384 0.1603 SAT 0.7853 0.7100 SAT 37 900 0.0711 0.0921 4.1291 0.1205 SAT 0.8014 0.7154 SAT 38 915 0.0695 0.1820 4.1205 0.1555 SAT 0.8033 0.7072 SAT 39 930 0.0691 0.1750 4.1123 0.1528 SAT 0.8133 0.7057 SAT 40 945 0.0686 0.2124 4.1046 0.1530 SAT 0.8220 0.7035 SAT 41 1000 0.0681 0.2304 4.0973 0.1552 SAT 0.8300 0.7011 SAT 42 1015 0.0678 0.2133 4.0905 0.1506 SAT 0.8384 0.6999 SAT 43 1030 0.0679 0.1973 4.0839 0.1330 SAT 0.8483 0.7016 SAT 44 1045 0.0680 0.1609 4.0778 0.1194 SAT 0.8573 0.7028 SAT 45 1100 0.0680 0.1532 4.0719 0.1092 SAT 0.8654 0.7035 SAT 46 1115 0.0678 0.1892 4.0663 0.1082 SAT 0.8718 0.7026 SAT 47 1130 0.0672 0.2616 4.0609 0.1174 SAT 0.8761 0.6996 SAT 48 1145 0.0668 0.2729 4.0559 0.1192 SAT 0.8813 0. 6980 . SAT 49 1200 0.0668 0.2238 4.0510 0.1102 SAT 0.8875 0.6985 SAT 50 1215 0.0661 0.3028 4.0464 0.1225 SAT 0.8901 0.6948 SAT

GINNA86.DAT NRC REPORT ***************************

PAGE 2 DATE 24-1987 TIME - 13:40:00 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1) < . 25 (1) ( 2. 1) ( 2. 1) ( 2) 51 1230 0.0652 0.3908 4.0419 0.1400 SAT 0.8910 0.6898 SAT 52 1245 0.0639 0.6544 4.0377 0.1720 SAT 0.8863 0. 6811 SAT 53 1300 0.0639 0.6471 4.0336 0.1575 SAT 0.8921 0.6821 SAT 54 1315 0.0640 0.5248 4.0297 0.1445 SAT 0.8975 0.6831 SAT 55 1330 0.0645 0.3772 4.0259 0.1178 SAT 0.9030 0.6872 SAT 56 1345 0.0639 0.4354 4.0223 0.1274 SAT 0.9049 0.6839 SAT 57 1400 0.0634 0.5050 4.0189 0.1343 SAT 0.9071 0.6810 SAT 58 1415 0.0642 0.3504 4.0155 0.1025 SAT 0.9112 0.6865 SAT 59 1430 0.0649 0.1820 4.0123 0.0747 SAT 0.9151 0.6915 SAT 60 1445 0.0649 0.1425 4.0092 0.0671 SAT 0.9191 0.6925 SAT

-1515 61 1500 1530 1545 0.0649 0.0638 0.0630 0.0628 0.1420 0.3466 0.5753 0.6782 4.0062 4.0034 4.0006 3.9979 0.0626 0.0943 0.1128 0.1114 SAT SAT SAT SAT 0.9227 0.9182 0.9173 0.9203 0.6931 0.6859 0.6810 0.6802 SAT SAT SAT SAT 65 1600 0.0628 0.7321 3.9953 0.1048 SAT 0.9236 0.6807 SAT 66 1615 0.0635 0.4619 3.9928 0.0777 SAT 0.9262 0.6857 SAT 67 1630 0.0635 0.5042 3.9903 0.0723 SAT 0.9293 0.6863 SAT 68 1645 0.0637 0.4295 3.9880 0.0619 SAT 0.9324 0.6880 SAT 69 1700 0.0642 0.2739 3.9857 0.0449 SAT 0.9350 0.6913 SAT 70 1715 0.0640 0.3367 3.9835 0.0482 SAT 0.9370 0.6904 SAT 71 1730 0.0640 0.2853 3.9813 0.0459 SAT 0.9395 0.6907 SAT 72 1745 0.0636 0.4142 3.9792 0.0559 SAT 0.9404 0.6884 SAT 73 1800 0.0637 0.2811 3.9772 0.0476 SAT 0.9428 0.6899 SAT 74 1815 0.0641 0.1465 3.9753 0.0339 SAT 0.9448 0.6926 SAT 75 1830 0.0641 0.1375 3.9734 0.0308 SAT 0.9470 0.6933 SAT 76 1845 0.0638 0.2056 3.9715 0.0396 SAT 0.9478 0.6914 SAT 77 1900 0.0638 0.1916 3.9697 0.0385 SAT 0.9497 0.6915 SAT 78 1915 0.0637 0.2153 3.9679 0.0400 SAT 0.9513 0.6911 SAT 79 1930 0.0632 0.3518 3.9662 0.0529 SAT 0.9511 0.6883 SAT

.1945 0.0635 0.2667 3.9646 0.0419 SAT 0.9528 0.6904 SAT 2000 0.0639 0.1179 3.9630 0.0273 SAT 0.9540 0.6933 SAT 82 2015 0.0638 0.1391 3.9614 0.0289 SAT 0.9554 0.6930 SAT 83 2030 0.0635 0.2779 3.9598 0.0376 SAT 0.9559 0.6912 SAT 84 2045 0.0632 0.4550 3.9584 0.0444 SAT 0.9566 0.6896 SAT 85 2100 0.0631 0.4402 3.9569 0.0439 SAT 0.9580 0.6896 SAT 86 2115 0.0631 0.3634 3.9555 0.0421 SAT 0.9594 0.6898 SAT 87 2130 0.0631 0.3411 3.9541 0.0403 SAT 0.9607 0.6900 SAT 88 2145 0.0632 0.3391 3.9527 0.0368 SAT 0.9620 0.6907 SAT 89 2200 0.0632 0.2658 3.9514 0.0336 SAT 0.9632 0.6913 SAT 90 2215 0.0634 0.2108 3.9501 0.0273 SAT 0.9644 0.6925 SAT 91 2230 0.0631 0.3607 3.9488 0.0363 SAT 0.9645 0.6906 SAT 92 2245 0.0629 0.4781 3.9476 0.0386 SAT 0.9654 0.6901 SAT 93 2300 0.0628 0.5209 3.9464 0.0409 SAT 0.9662 0.6895 SAT 94 2315 0.0627 0.6138 3.9452 0.0428 SAT 0.9670 0.6889 SAT 95 2330 0.0626 0.5585 3.9441 0.0430 SAT 0.9679 0.6887 SAT 96 2345 0.0624 0.8643 3.9430 0.0494 SAT 0.9681 0.6872 SAT 97 0 0.0621 1.3347 3.9419 0.0548 SAT 0.9684 0.6858 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

HATCH278.DAT PAGE 1 DATE 24-1987 TIME - 13:40:41 REC TIME LAM LEFT < RIGHT EQ (1.2) COND LEFT > RIGHT COND NUM ( 1. 1) ( 1. 1 ) < .25 (1) ( 2. 1) (2 . 1) ( 2) 1 0 0.0000 1.3347 3.9419 0.0548 SAT 0.9684 0.6858 SAT 2 15 0.0000 1.3347 3.9419 0.0548 SAT 0.9684 0.6858 SAT 3 30 0.2612 0.0000 5.6294 0.6095 SAT 0.6048 0.1594 SAT 4 45 0.2194 0.0031 161.1086 0.0653 SAT 0.7171 0.1566 SAT 5 100 0.2090 0.0000 18.4995 0.0000 SAT 0.8197 0.1649 SAT 6 115 0.2358 0.0090 10.1152 0.0700 SAT 0.8961 0.2172 SAT 7 130 0.2314 0.0016 7.7071 0.0249 SAT 0.9294 0.2225 SAT 8 145 0.2363 0.0045 6.6086 0.0290 SAT 0.9529 0.2393 SAT 9 200 0.2438 0.0101 5.9883 0.0407 SAT 0.9665 0.2585 SAT 10 215 0.2400 0.0018 5.5920 0.0148 SAT 0.9740 0.2589 SAT 11 230 0.2175 0.0668 5.3179 0.0619 SAT 0.9466 0.2279 SAT 245 0.2123 0.1079 5.1173 0.0610 SAT 0.9545 0.2236 SAT 300 0.2055 0.2815 4.9643 0.0668 SAT 0.9580 o_.2161 SAT 315 0.2044 0.2041 4.8438 0.0536 SAT 0.9656 0.2174 SAT 15 330 0.1933 2.0811 4.7466 0.0788 SAT 0.9555 0.2017 SAT 16 345 0.1908 -4.9295 4.6664 0.0695 SAT 0.9614 0.2000 SAT 17 400 0.1875 -0.8496 4.5993 0.0665 SAT 0.9650 0.1965 SAT 18 415 0.1855 -1.0480 4.5422 0.0599 SAT 0.9692 0.1951 SAT 19 430 0.1811 -1.8464 4.4931 0.0639 SAT 0.9693 0.1895 SAT 20 445 0. 1783 -1.1345 4.4503 0.0622 SAT 0.9714 0. 186 5 SAT 21 500 0.1753 -3.3953 4.4129 0.0622 SAT 0.9726 0.1828 SAT 22 515 0.1710 10.7490 4.3797 0.0676 SAT 0.9708 0.1768 SAT 23 530 0.1692 -11.6201 4.3502 0.0631 SAT 0.9731 0.1751 SAT 24 545 0.1672 4.4990 4.3238 0.0606 SAT 0.9747 0.1729 SAT 25 600 0.1680 1.4263 4.2999 0.0487 SAT 0.9776 0.1753 SAT 26 615 0.1680 0.9491 4.2783 0.0414 SAT 0.9801 0.1764 SAT 27 630 0.1676 0.9226 4.2587 0.0374 SAT 0.9820 0.1766 SAT 28 645 0.1714 0.2323 4.2407 0.0181 SAT 0.9804 0.1842 SAT 29 700 0.1725 0.0834 4.2242 0.0114 SAT 0.9822 0.1872 SAT 715 0.1730 0.0479 4.2090 0.0081 SAT 0,9839 0.1890 SAT 730 0.1743 0.0041 4.1950 0.0023 SAT 0.9851 0.1922 SAT 32 745 0.1749 0.0002 4.1820 0.0004 SAT 0.9864 0.1942 SAT 33 800 0.1762 0.0336 4.1700 0.0052 SAT 0.9872 0.1973 SAT 34 815 0.1774 0.1023 4.1587 0.0093 SAT 0.9880 0.2003 SAT 35 830 0.1776 0.0942 4.1482 0.0090 SAT 0.9890 0.2014 SAT 36 845 0.1779 0.1474 4.1384 0.0092 SAT 0.9899 0.2027 SAT 37 900 0.1774 0.1151 4.1291 0.0063 SAT 0.9905 0.2025 SAT

• • • • • • • • • • • • • • • • • • • • • • • • • • • NRC REPORT ***************************

HATCH82.DAT PAGE 1 DATE 24-1987 TIME - 13:41:25 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > *RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) ( 2. 1) ( 2. 1 ) (2) 1 0 0.0000 0.1151 4.1291 0.0063 SAT 0.9905 0.2025 SAT 2 15 0.0000 0.1151 4.1291 0.0063 SAT 0.9905 0.2025 SAT 3 30 1.1187 0.0000 5.6294 0.4906 SAT 0.9774 0.7767 SAT 4 45 1. 0951 -0.0009 161.1086 0.0736 SAT 0.9902 0.8222 SAT 5 100 1.1304 -0.0042 18.4995 0.1121 SAT 0.9944 0.8524 SAT 6 115 1.0800 -0.0075 10.1152 0.0789 SAT 0.9936 0.8534 SAT 7 130 1.0472 -0.1281 7.7071 0.1332 SAT 0.9941 0.8543 SAT 8 145 1.0149 -1. 6884 6.6086 0.1717 SAT 0.9938 0.8529 SAT 9 200 1.0107 0.3275 5.9883 0.1198 SAT 0.9956 0.8570 SAT 10 215 0.9984 -0.6746 5.5920 0.1171 SAT 0.9963 0.8581 SAT 11 230 0.9891 -0.3774 5.3179 0.1098 SAT 0.9969 0.8592 SAT 245 0.9684 -5.0299 5.1173 0.1456 SAT 0.9960 0.8570 SAT 300 0.9550 11.7926 4.9643 0. 1506 SAT 0.9960 0~8562 SAT 315 0.9294 3.5263 4.8438 0.1989 SAT 0.9936 0.8517 SAT 15 330 0.9189 5.7118 4.7466 0.1870 SAT 0.9942 0.8510 SAT 16 345 0.8969 13.1541 4.6664 0.2214 SAT 0.9922 0.8467 SAT 17 400 0.8896 15.3554 4.5993 0.1997 SAT 0.9930 0.8463 SAT 18 415', 0.8812%-6588.5667 4.5422 0.1886 SAT 0.9935 0.8455

'SAT 19 430 0.8725 10.3270 4.4931 0.1833 SAT 0.9938 0.8444 SAT 20 445 0.8621 11. 7699 4.4503 0.1870 SAT 0.9937 0.8427 SAT 21 500 0.8539 8.0160 4.4129 0.1838 SAT 0.9939 0.8414 SAT 22 515 0.8474 5.7357 4.3797 0.1765 SAT 0.9942 0.8407 SAT 23 530 0.8396 8.6645 4.3502 0.1764 SAT 0.9942 0.8394 SAT 24 545 0.8323 14.4199 4.3238 0.1758 SAT 0.9943 0.8381 SAT 25 600 0.8244 27.9411 4.2999 0.1789 SAT 0.9941 0.8366 SAT 26 615 0.8151 48.7605 4.2783 0.1875 SAT 0.9936 0.8345 SAT 27 630 0.8088 53.6620 4.2587 0.1851 SAT 0.9937 0.8333 SAT 28 645 0.8003 40.7399 4.2407 0.1918 SAT 0.9933 0.8313 SAT 700 0.7921 63.2735 4.2242 0.1979 SAT 0.9929 0.8292 SAT 715 0.7856 116.7302 4.2090 0.1975 SAT 0.9928 0.8277 SAT 31 730 0.7783-252.6368 4.1950 0.2007 SAT 0.9925 0.8259 SAT 32 745 0.7713-167.5660 4.1820 0.2036 SAT 0.9923 0.8241 SAT 33 800 0.7651-101.0860 4.1700 0.2037 SAT 0.9922 0.8225 SAT 34 815 0.7591 -91.4445 4.1587 0.2040 SAT 0.9921 0.8209 SAT 35 830 0.7527-185,0394 4.1482 0.2064 SAT 0.9918 0.8191 SAT 36 845 0.7455-256,2531 4.1384 0.2122 SAT 0.9913 0.8169 SAT 37 900 0.7397-373,2257 4.1291 0.2125 SAT 0.9911 0.8153 SAT 38 915 0.7347 818.3661 4.1205 0.2105 SAT 0.9911 0.8139 SAT 39 930 0.7293 188.6489 4.1123 0.2103 SAT 0.9910 0.8123 SAT 40 945 0.7243 200.8796 4.1046 0.2098 SAT 0.9910 0.8108 SAT 41 1000 0.7194 123.9235 4.0973 0.2089 SAT 0.9909 0.8093 SAT 42 1015 0.7144 102.9307 4.0905 0.2092 SAT 0.9908 0.8077 SAT 43 1030 0.7093 101.7543 4.0839 0.2104 SAT 0.9906 0.8060 SAT 44 1045 0.7049 123.6796 4.0778 0.2093 SAT 0.9905 0.8046 SAT

INDI382.DAT NRC REPORT ***************************

PAGE 1 DATE 24-1987 TIME - 13:42:29 REC TIME LAM LEFT < RIGHT EQ ( 1. 2) COND LEFT > .RIGHT COND NUM ( 1. 1) ( 1. 1) < .25 (1) ( 2. 1) (2. 1) ( 2) 1 0 0.0000 123.6796 4.0778 2.5112 UNSAT 0.9905 0.9983 UNSAT 2 15 0.0000 123.6796 4.0778 2.5112 UNSAT 0.9905 0.9983 UNSAT 3 30 0.2355 0.0000 5.6294 2.9283 SAT 0.8859 0.9569 UNSAT 4 45 0.2063 0.0000 161.1086 0.0000 SAT 0.9254 0.9594 UNSAT 5 100 0.1999 -0.0005 18.4995 0.1819 SAT 0.9579 0.9630 UNSAT 6 115 0.1750 -0.0076 10.1152 0.8639 SAT 0.9436 0.9565 UNSAT 7 130 0.1405 -0.0299 7.7071 1.6096 SAT 0.8634 0.9383 UNSAT 8 145 0.1431 -0.0137 6.6086 0.8594 SAT 0.9071 0.9432 UNSAT 9 200 0.1432 -0.0085 5.9883 0.5302 SAT 0.9332 0.9454 UNSAT 10 215 0.1424 -0.0070 5.5920 0.3733 SAT 0.9500 0.9466 SAT 11 230 0.1367 -0.0185 5.3179 0.4763 SAT 0.9540 0.9438 SAT 245 0.1315 -0.0398 5.1173 0.5380 SAT 0.9568 0.9409 SAT 300 0.1363 -0.0148 4.9643 0.2022 SAT 0.9639 o_.9458 SAT 315 0.1368 -0.1402 4.8438 0.1290 SAT 0.9711 0.9472 SAT 15 330 0.1353 0.0176 4.7466 0.1609 SAT 0.9754 0.9469 SAT 16 345 0.1370 0.0011 4.6664 0.0538 SAT 0.9795 0.9488 SAT 17 400 0.1366 0.0034 4.5993 0.0554 SAT 0.9827 0.9493 SAT 18 415 0.1347 -0.0739 4.5422 0.1271 SAT 0.9839 0.9485 SAT 19 430 0.1360 -0.0031 4.4931 0.0473 SAT 0.9860 0.9500 SAT

~ f ,; DOCKET NUMBER FliOPOSED RULE

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~ DOC ET [Q INTERNATIONAL ATOMIC ENERGY AGENCY uc; RC AGENCE INTERNATIONALE DE L'ENERGIE ATOMIQUE ME)l{llYHAPOllHOE AfEHTCTBO no ATOMHO'A 3HEPfl111 -#87 HAY 12 All :05 ORGANISMO INTERNACIONAL DE ENERGIA ATOMICA WAGRAMERSTRASSES, P.O.BOXl00, A*l400VIENNA, AUSTRIA _Qff! *~ J.  ;.

TELEX: 1-1264S, CABLE: INATOMVIENNA, FACSIMILE: 43 222230184, TELEPHONE: (222) .tfW}C K[r'ING *1:

BR A I IN REPLY PLEASE REFER TO: DIAL DIRECTLY TO EXTENSION:

PRIERE DE RAPPELER LA

REFERENCE:

COMPOSER DIRECfEMENT LE NUMERO DE POSTE:

30 April, 1987

• Commissioner J ames Asselstine U.S. Nuclear Regulatory Commision 1717 H Street NW Washington DC 20555, USA

~cfmmissione r, Recently, I learned that the staff is preparing an ammendment to the regulations governing containment leakage testing (10CFR50 Appendix J). Unfortunately, the comment period on the draft rule expired on April 24th-- about a day before I heard about it here in Austria. I would still like to offer my personal comments on the Appendix since it contains

• a shortcoming which takes on particular importance in the wake of Chernobyl and TMI-2 . Although the comment pe r iod is expired, I know that you have other avenues available for raising this particular issue, if you agree with it.

Therefore, I am offering the attached comments to you directly.

I look forward to seeing you again upon my return to the NRG on June 1st. I wish you the bes t for your future plans.

~r.

U ~~~ision oosten of Nuclear Safety I nternational Atomic Energy Agency bee

HAR REGULATORY c..vMPN KEl\NG & SERVICE SECTO' OfFICE OF lHE SECRET ARY OF THE COMMISS~

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COMMENTS ON 10CFR50 APPENDIX J The rule contains a flawed definition of the "Primary reactor containment" in 10CFR50 Appendix J.II.A which in turn, controls the scope of all subsequent leakage testing provisions in the rule.

Specifically it states:

"Primary reactor containment" means the structure or vessel that encloses the components of the reactor coolant pressure boundary, as defined in section 50.2(v) and serves as an essentially leaktight barrier against the uncontrolled release of radioactivity to the environmenl .

• Up until now, the staff and the utilities have literally interpreted this to mean only the single hermetically structure surrounding the reactor coolant components during normal operation.

reactor coolant pressure boundary defined by 50.2 However, the is enclosed by not one but by several structures or vessels during normal operation. Additional structures may also come into play during accident conditions. Consider the following two examples:

Steam Generators In a Pressurized Water Reactor (PWR), the majority of the reactor coolant pressure boundary surface is located in the interior of the steam generator vessel and is composed of very thin wall tubing.

There are 2 to 4 steam generators per reactor and each may contain about 5000 such tubes and have a bundle surface area of about 51,000 ft 2 .

Since the steam generator vessel lies within the primary containment structure, as well as the other reactor coolant system components, we typically think of the entire reactor coolant pressure boundary as being protected by the containment structure for which we have established leakage requirements. In actuality, however, the walls of the steam generator shell and the associated steam piping form a steel vessel which enclose the steam generator tubes and isolate them from the cuntaimuent atmosphere. Strictly speaking, the tube bundle has no containment since this steel vessel is equipped with with non-leaktight main steam isolation valves and is also equipped with atmospheric relief and safety valves which communicate directly with the outside environment.

Decay Heat Removal Components There are a number of piping systems which penetrate the primary containment structure and which are required to remain in service during an accident. The decay heat removal system, for example, becomes an extension of the reactor coolant system pressure boundary in an accident*. This piping system is not leaktight, as was seen at TMI-2. However, the structures which house the decay heat removal system components and intersystem isolation valves are not included in the current interpretation of Appendix J even though their containment isolation function is assumed in the FSAR.

Thus we have an interesting situation where in the first example the containment has been defined so narrowly that the majority of the reactor coolant pressure boundary is excluded from the rule's l eakage requirements: and in the second example the containment boundary has been defined in terms of the normal power alignment of systems and not according to the accident alignment.

In short, the rule is too narrowly scoped. The containment definition should be clarified and expanded to include all structures which enclose th primary coolant pressure boundary and/or which are relied upon to perfoLrn a containment function. The staff should consider incorp0rating a similiar definition as was recently proposed by the OECD containment task force (see attached article) .

• It would appear more appropriate to consider the decay heat removal system under 10CFRS0.2.(v).1 as opposed to 10CFRS0.2.(v).2 since its complete isolation from the containment cannot be relied upon in an accident (see Appendix J.I I .B).

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TENNESSEE VALLEY AUTHORITY { ff/ /=,,.e. ..J'(~

cHATTANooGA. TENNESSEE 37401 ooc.:KnE USNHC r

SN 157B Lookout Place MAY 061987 ~ rfAY 12 P4 :55

.s. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

In accordance with the prov1s1ons for public review and comment indicated in the Federal Register on January 17, 1979, the Tennessee Valley Authority (TVA) is pleased to provide the following comments on the methods acceptable to the NRC staff for complying with the proposed amendments to Appendix J, if they

• are promulgated as published. We are providing comments on our review of the following:

Task MS 021-5 Division l October 1986 "Containment System Leakage Testing" If there are any questions please telephone K. P. Parr at (615) 751-8082.

Very truly yours, AUTHORITY Enclosure cc <Enclosure):

Office of Administration Division of Rules and Records Attention: Rules and Procedures Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 by An Equal Opportunity Employer

Co J/4_*-----

.I

Enclosure Methods Acceptable for Compliance with Proposed Amendments to Appendix J to 10 CFR Part 50 .

Hith regard to the subject regulatory guide, we have the following comments, referenced by page and item number:

l. Page 4, item 8 - The design of the airlock doors at Sequoyah and Hatts Bar Nuclear Plants precludes testing the door seals at Pac*

2. Pages 8 and 9, item 6.1 - In some cases, the time duration from the end of the Type A test to the start of the verification test can be several hours. This data should not be included in the Type A test data. During this time, stable conditions are being established for the start of the verification test. Data taken during this time period does not reflect either the Type A test conditions, since a leak has been superimposed, or

• 3.

stable conditions for the verification test.

Page 10, item 11.l - Instrumentation used for Type Band C tests should not be required to have a semiannual calibration. If an instrument is used within its calibration cycle and is not found out of tolerance on its subsequent calibration, its use should not be restricted to a six-month period. Some instruments are currently on a one-year calibration cycle.

4. Page 10, item 11.3 - It is not practical, nor possible in some instances, to perform daily calibration on all pieces of equipment used for Type B and C tests. If an instrument is found to be out of tolerance or calibration, there are existing measures that can be taken to ensure an accurate leakage rate (i.e., retests, statistical analysis).

5. Page 10, item 12.l - The word 11 leakage in the second sentence should be 11 11 pressure. 11

• 6. Page 10, item 12.2 and page 11, item 12.3 - The criterion for temperature stabilization in paragraph 12.2 is a good definition of stabilization; however, it is too restrictive in respect to the supplemental requirements of paragraph 12.3. Deviations to this during the Type A test should be evaluated. They should not be the basis for satisfactory Type A test completion especially since the requirements for determining the location, quantity, and weighting values are already specified by Regulatory Positions, 7, 11, 13.2, 13.3, 14.l, 14.2, 14.3, and 15. These positions will result in pressures, humidities, and temperatures being representative of the test volume which are necessary for the use of the ideal gas laws to determine the leakage. It will also be noted that the temperature, function ( 9 t/T) 2 in equation 2.1 has the least impact on the accuracy of the calculated leakage.

7. Page 12, item 14 - He would like further clarification regarding the suitability of existing temperature surveys for similar plants.

8. Page 13, item 15 - We believe that the equation is in error and should read as follows:

m j=l

9. Page 13, item 17.1 - We believe that the makeup fluid should be the same as or less viscous than the system fluid not the test fluid .

10. Page 15, Appendix, Condition 1 - The source of the stat i stical equations and literature used to develop equations 1.1, 1.5, and 1.6 shou l d be referenced.

11. Page 16, Appendix, Condition 2 - As in all types of testing, "obviousli' bad data is occasionally encountered. This data occurs when pressure, temperature, or humidity extrusions (such as when fans are tripped, pressure relief panels cycle, and when water level changes occur) have not had time to dissipate or stabilize before data is obtained. In addition, the ability of the Type A instrument system to accurately detect extremely low leakage (less than what the system was designed to detect) will result in a large scatter in data and result in a low correlation coefficient. This penalizes tight primary containments by the fact that this scatter causes a large error in the confidence level of the measured leakage rate and the ability to get agreement during the verification test.

The ISG 2 (equation 2.11) also does not consider all variables encountered during testing that could have an effect on the measurement of leakage. This equation is used only to size the instrument system prior to purchase, installation and use. When installed, the data obtained by it is evaluated to determine if it behaves in accordance with parameters used to design or size it . The use of the equation 2.11 in developing equation 2.1 is invalid, and we recommend that it not be used as a basis for test acceptance.

DOCKl:"TEO

JSNllC GPU Nuc lear Nuclear ~7 MAY -8 AlO :59 100 Interpace Pa rkway Parsippany , New Jersey 07054 201 263-6500 TELEX 136-482 6FF !CE v* ~ Wri ter' s Direct Dial Number:

DOC KET Ill" Bn ... NC, April 30, 1987 5200-87--0031 Mr. Samuel J. Chilk Secretary of the Commission u: s: Nuclear Regulatory Commission Washington ; DC 20555

Dear Mr:

Chilk:

Subject:

Request for Comments on Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Pl ants Proposed Rule.

The staff of GPU Nuclear Corporation herewith submits comments on the subject proposed rule. Comments were requested in a October 29; 1986 Federal Register notice and subsequently the corrment per iod was extended on January 22~ 1987.

As a general comment, we believe that the Commission and its staff should be commended for the improvements proposed within this rule. Th is proposed revision to Appendix J will help make the current technical specifications easier to use by eliminating inconsistencies presently encountered :

There are; however, a number of items in both the proposed rule and the draft Reg. Guide that we feel need modification/clarification. Our specific comments/suggestions are contained in the enclosures :

Sincerely, yR)(f.~

J. R. Thorpe Director, Licensing &Reg: Affairs Enc l osures 4647g JRT:RPJ:ls

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Enclosure l GPU NUCLEAR COMMENTS ON PROPOSED CHANGE TO APPENDIX J

1) General Referencing the testing standard, i.e., ANSI/ANS 56.8, in addition to the proposed regulatory guide, i.e., MS-021-5, in the text of the proposed rule is advisable since the proposed regulatory guide only supplements the requirements of the testing standards.

On the question of whether Appendix J revision should be accomplished at this time we feel that it should. It is not clear that this revision should be considered interim, however.

2)Section III A(3) gives the interval between Type A tests as 4 years while ANSI/ANS 56.8-1981, section 3.2.3, gives it as 5

• 3) years. Recommend that both documents designate 5 years.

Section (15)c Invitation to Comment.

Previous Type A test results should remain valid until superceded by a new Type A test. The 0.6 La requirement is sufficient control over local leakage without the complication of a running total for the type A test.

4)Section III B(4)(d)

Individual Tech Spec. leakage criteria for air lock tests is unnecessary. The 0.6 La limit on total is sufficient control. There should be no other basis for reportability for Type B or C results. Meanlngless reports would result.

5)Section III ASA Should clarify to assure that it is understood that all corrective action need not be implemented prior to restart.

Recommend the following wording for end of the first sentence.

• *

• a Corrective Action Plan that focuses attention on the 11 cause of the problem and indicates what is to be accomplished before and after restart must be developed ******* "

6)Section IV ("Report") of the proposed rule requires licensees to submit a corrective action plan to the NRC for any Type A test failure and Type Band C failures included as a part of the Type A test sequence. This requirement appears to be inconsistent with the requirements of Section 10 CFR 50.73(a)(2)(i)(B),

"Licensee Event Report System." The latter requires written NRC notification only when there exists a condition prohibited by the Plant's Technical Specification.

4647g For examples if a Type A test failure occurred during the performance of the required Technical Specification surveillance and the licensee complied with the applicable action statements the proposed rule would require written NRC notification even though such notification is not required by 10 CFR 50.73.

7.) Section 12 Major Changes We definitely recolTITlend that the commission continue to apply the Backfit Rule along with its "substantial increase" provision

• 4647g Enclosure 2 GPU NUCLEAR COMMENTS ON APPENDIX J DRAFT REGULATORY GUIDE

1) Position 2- Type A Test Requirements States that the instrumentation system error shall be included in the leakages, but does not define how this is to be done.

Equation 2.13 of the appendix seems to be a way to do this. How is this instrumentation error to be applied to the leakage?

Presumably this will cause a change in the calculation of the reportable leakage. It is assumed that the change will not be major as the ISG calculation is already performed in the ILRT code.

2) Section 3.2.4 of the ANSI 56.3 standard indicates that the confidence limit calculation adequately accounts for instrument

• errors in the leakage measurement system. Does Position 2 change this?

Position 6 - Verification Test Position 6. l indicates that a plot is able to be generated of the masses and/or the leakage rates in which the verification results are a direct extension of the Type A test line. Also, the Type A test period should not be ended a significant period of time before the Verification test begins.

This position indicates that it may be desired for the calculation of the leakage rate during the first five sets of the Verification test to be calculated using Type A test data and data from the induced leak setup period, rather than have the leakage set to zero until five sets of Verification data have been collected and statistics can be calculated. This

• would allow a continuous plot to be generated including the Type A and Verification test periods.

The position imposes requirements on those running the test, but there should be only small changes to the code to calculate leakage rates as defined in the pervious paragraph. Once calculated in this manner, plots can be generated using existing functions as desired.

3) Position 12 - Containment Atmosphere Stabilization Position 12. l indicates that the 95% UCL of the leakage shall be zero or positive before starting the Type A test. Currently we do not calculate 95% UCL on the leakage, but only on the leakage rate. Does this position relate to leakage rate or is there now a requirement to calculate 95% UCL for leakage? Will a positive or zero leakage rate or 95% UCL leakage rate be sufficient to meet this requirement? Not clear at all how these calculations would be done. Recommend an additional statement as follows:

4647g "Each interval between temperature readings has a point-to-point change in average temperature and rate of change in average temperature associated with it. The total of these divided by the number of points gives the average change or rate of change."

The Position 12.3 requirement for meeting stabilization criteria throughout the Type A test and Verification appears to be an unnecessary and burdensome requirement. The two additional conditions on the Mass Point curve slope and data scatter should suffice to assure quality data.

4.) Position 13 - Data Recording and Analysis In position 13.l, some clarification is need as to "start time"

• vs. "restart time." Also a definition should be provided for "time forward." For example, does this mean time forward from the "start time" or time forward from the time when the decision to restart the test is made?

The minimum duration of the test being lowered to eight hours will require some changes to the code as will limits on the ability to restart the test.

Position 13.3 requires additional statistics to be calculated on the air mass data for non-linearity and data scatter. This will be a significant change in code, as these statistics will be used in other places besides the statistics subroutine. The statistics to be calculated involve some complex equations, however they are all defined in the literature. This position requires a parabolic curve fit of the air mass data to be done.

Space must be allocated for the new statistics and the parabolic constants in the AIRMASSDATAFILE so the results can be used in criteria checks. Another implementations is to have these statistics, and the appropriate checks, be calculated only on user demand.

5.) Position 15 - Absolute Test Method This position indicates a change in the calculation of the spatially-averaged containment temperature. The new calculation is not difficult to program but will take some time.

6.) Position 20 - Recording of Leakage Rates The statement on packing would meet the probable intent better if reworded as follows:

"Packing leakage which would provide a leak path in parallel with containment isolation valve seats must be accounted for in reported Type C leakage rates. Both valve design and installed orientation can determine if the packing leakage is a significant leak path."

4647g "87 MAY -8 All :11 Telephone (412) 393-6000 Nuclear Group P.O. Box 4 OFFli..£ ~, . ~ - '-'*" 'f April 24, 1987 Shippingport, PA 15077-0004 OOCKE llH l '"r RVICf B. ANC~

u. s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Proposed Rulemaking Federal Register, 51 FR 39538

. Gentlemen:

Published in the Federal Register on October 29, 1986 (51 FR 39538) was a proposed rulemaking and request for comment. The proposed rule is to amend the regulations to update the criteria, and clarify questions of interpretation in regard to leakage rate testing of containments of light-water-cooled nuclear power plants.

We would like to provide comments on two of the fifteen questions posed in the proposed rule.

Question #10 "The value of collecting data from the "As Found" condition of valves and seals and the need for acceptance criteria for this condition."

The As Found condition measured for Type Band C tests is necessary to determine if a component has significantly degraded. Trending of As Found and As Left Type Band C test results is a valuable tool in evaluating subsequent test results.

Acceptance Criteria for the As Found test results could be integrated as described in the comment that follows for Question #15.

Question #15 "How to effectively adjust Type A test results to reflect individual Type B and C test results obtained from inspections, repairs, adjustments, or replacements in years between Type A tests."

During the Type A test, alignment of containment penetrations is such that any leakage through the containment isolation valves, would be the minimum pathway penetration leakage rate (i.e., lowest leakage of two valves in seri es). Therefore, any adjustment to Type A test results during interim periods should use the Type Band C minimum pathway penetration leakage rates.

tm

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Proposed Rulemaking Federal Register 51 FR 39538 Page 2 Presently Type A results are only adjusted for the Type B and C performed prior to the Type A test. If any Type B or C As Found minimum pathway penetration leakage rate is reduced (corrective maintenance, DCP, etc.), then this difference is added to the final Type A result. This method of adjustment is further detailed in IE Information Notice 85-71, "Containment Integrated Leakage Rate Test".

A similar method could also be used to adjust Type A results during interim test periods. Increases or decreases in any As Found minimum pathway penetration leakage rate, over the previous As Left minimum pathway penetration leakage rate,

• would be added to the previous Type A result.

In addition, Section proposed rule states:

III.A.3. Type A Test Frequency "Unless a longer interval is specifically approved by the of the NRC staff, the interval between the preoperational and first periodic Type A test must not exceed three years, and the interval between subsequent period type A tests must not exceed four years."

The Standard Technical Specifications (STS) state that Type A testing be conducted at 40+ 10 month intervals. The STS interval would imply a maximum interval between periodic Type A tests of 50 months; whereas the revised Appendix J requires a maximum of 48 months. The proposed rule creates a conflict with the STS which should be resolved prior to issuance as a Final Rule .

• Very truly yours, ti~

J. D. Sieber Vice President, Nuclear

WASHINGTON PUBLIC POWER SUPPLY SYSTEM 00(.K[ i L'..1 If("'

P .O . Box 968

• 3000 George Washington Way

• Richland, Washington 99352

• 57 MAY -4 P7 :10 April 28, 1987 US NUCLEAR REGULATORY COMMISSION ATTN: DOCKETING AND SERVICE BRANCH WASHINGTON, D.C. 20555

Subject:

PROPOSED RULE, LEAKAGE RATE TESTING OF CONTAINMENTS OF LIGHT ~JATER COOLED NUCLEAR POWER PLANTS

Dear Sir:

The Supply System has completed its review of the subject Proposed Rule.

During our review we had the opportunity to participate in the development of comments by the Atomic Industrial Forum, the law finn of Bishop, Cook, Purcell and Reynolds, and the BWR Owners Group.

These organizations have expended considerable effort on this topic as shown by the detailed nature and significance of their comments. Since the Supply System has participated in the development of these comments and is in substantial agreement with them, we will not reiterate or duplicate them here.

The Supply System feels strongly that the above noted groups have presented reasoned and credible arguments regarding the subject proposed rulemaking,

• they should be listened to. We urge the Commission to defer further action on this proposal until all of the necessary changes are in hand and a better understanding of their impacts exists.

Thank you for this opportunity to participate in the Commissions rulemaking process. Should you have any questions regarding this matter, please feel free to contact me.

Very truly yours,

.~s6.:~

Regulatory Programs cc: E. REVELL - BPA(399)

MAY O8 1987

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WASH INGTON, D.C. 20036 (202) 857-9800 *a7 HAY -1 P4 :Q3 TELEX: 440574 INTLAW UI TELECOPIER: (202) 857-9846 April 24, 19 8 7 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, o.c. 20555 Attn: Docketing and Service Branch Re: Proposed Rule to Amend Appendix J Requirements Regarding Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants (51 Fed. Reg. 39538 (Oct. 29, 1986

Dear Mr. Chilk:

On October 29, 19 86, the Nuclear Regulatory Commission ("NRC" or "Commission") published in the Federal Register a notice inviting pub lic comments on a proposed rule to amend its Appendix J containment leakage rate testing requirements. 51 Fed. Reg. 39538. The stated purpose of the proposed rule is to "aid the NRC licensing and enforcement staffs by eliminating conflicts, ambiguities, and lack of uniformity in the regulation of the inservice inspection program." Id., col. 1. On behalf of the licensees listed below,1/ we respectfully submit the following comments on this proposed rule. I. DISCUSSION The scope of the proposed revision is allegedly limited to corrections and clarifications, and excludes new criteria. Id., col. 3. As discussed more fully below, while some aspects or-the proposed rule may be beneficial, we maintain that major .! / Arkansas Power & Light Company; Consol id ated Edison Compan y of New York, Incorporated; Florida Power Corporation; New York Power Authority; System Ene r gy Resources, Incorporated ; TU Electric; Washington Public Power Supply System; Yankee Atomic Electric Company.

Mr. Samuel J. Chilk April 24, 1987 Page 2 provisions are not mere corrections and clarifications, but are substantial new requirements/criteria. Further, some of these new requirements/criteria are technically unsupported and compliance would require a substantial commitment of industry resources with little, if any, safety benefit. Finally, we maintain that the Staff has failed to perform an acceptable backfitting analysis to support its proposal as required by 10 C.F.R. §50.109. A. Objections to the Proposed Rule While certain of the proposed revisions may be desirable to some licensees, many of the proposed provisions are objectionable in that they (1) go far beyond the stated limited purposes of the proposal; (2) are not supported by safety concerns; and (3) will result in significant additional costs and occupational exposure associated with meeting the new requirements. (The backfit implications of the provisions are separately addressed below). While many of the provisions are objectionable based on the factors noted above, the adverse impacts of the following four objectionable provisions are dominant: (1) III.A(4) and III.A(6) - elimination of the option of testing at reduced pressure; (2) III.A(7)(b)(i) - acceptance criteria for "as found" leakage; (3) III.A(B)(a) - retesting following failure of "as found" Type A test - and filing of Corrective Action Plan; and (4) III.A(8)(b)(ii) - option to do more frequent Type B & C testing rather than more Type A penalty tests. (It should be noted that the Staff in NUREG/CR-4398 also stated that these four provisions are likely to create the greatest impact upon industry.) The impacts of these revisions are noted below. The proposed revision to §§III.A(4) and A(6) would modify current requirements/criteria by eliminating the option to perform Type A tests at reduced pressures. Approximately one-third of the nation's containments are tested at reduced pressure. NUREG/CR-4398 at 26. Many of these facilities are older plants whose owners are concerned about the costs and possible negative safety impacts of cycling containments during tests at full design-basis pressure. In addition, the change will lengthen considerably the downtime (and the outage costs) associated with Type A tests at these plants. The proposed revision to §III.A(7)(b)(i) is a new requirement. Licensees are not currently required to determine the "as found" condition for the Type A test. NUREG/CR-4398 at

30. This proposed revision appears to be derived from I&E Notice 85-71, which the Staff issued to clarify (or, arguably, change) its position on the meaning of the current Appendix J.

This revision is likely to result in increased frequency of failure of Type A tests (with the corresponding need for corrective action and/or increased frequency of Type Band C

Mr. Samuel J. Chilk April 24, 1987 Page 3 testing and associated increase in occupational exposure from local tests).~/ Finally, the proposed revisions to §§III.A(8)(a) and A(8)(b)(ii) will necessitate hardware modifications to support the increased reliance on Type Band C test results as a measure of leak tightness. These changes will tend to result in additional outages due to the increased frequency of Type Band C testing. Further, the preparation of a Corrective Action Plan, which would be subject to Staff review and approval,3/ is a new requirement which will likely result in the significant burden of more frequent servicing and inspection of penetrations (and a corresponding increase in occupational exposure). NUREG/CR-4398 at 35-37. In sum, these proposed provisions reflect a clear attempt by the Staff to impose new and significant criteria under the guise of "clarifications" to the current regulations contained in Appendix J, contrary to the express scope of the rule. Further, these provisions are not technically supported by public health and safety concerns, yet would impose significant burdens on licensees. These burdens alone are enough to warrant serious reconsideration of the merits of the proposed rule. However, as detailed below, the proposed rule is also legally flawed in that it fails to satisfy the Commission's backfit rule, 10 C.F.R.

 §50.109.

B. The Proposed Rule Will Require Backfitting of Many Existing Facilities The Staff, in its backfit analysis for the proposed revision to 10 C.F.R. Part 50, Appendix J, states that: The current Appendix J does not support the Staff positions in IN 85-71 regarding reporting and "back-correction" of Type Band C test results. Appendix J currently requires rerortinf of specific results of Type Band C tests only if (l theocal tests were performed "during a type A test" and resulted in failure to complete the test and or failure to meet the acceptance criteria, or (2) the acceptance criteria for Type Band C tests were not met. Appendix J,

      §§III.A.!, V.B.3. Similarly, Appendix J only requires correction of Type A test results to reflect Type Band C tests 1n cases where leakage was discovered in the conduct of the Type A test and caused termination of the test or unacceptable results. Appendix J, §III.A.!. See also 38 Fed. Reg. 4385 (February 14, 1973)(Statement o-f-Consideration).

The Corrective Action Plan is not currently submitted to the NRC. NUREG/CR-4398 at 36.

Mr. Samuel J. Chilk April 24, 1987 Page 4 [t]he proposed rule is intended to be applied to the entire population of nuclear power reactors and it clearly constitutes a backfit.!/ As noted above many aspects of the proposed rule are simply editorial changes and clarifications, but others are substantive and will require utilities to perform major backfits in order to comply with the regulations.1/ For example, the proposed requirement to determine the "as found" leakage rate condition for Type A tests constitutes a new requirement rather than a clarification as the Staff claims. As the Staff has recognized, the determination of the "as found" condition in Type A testing has not previously been required. NUREG/CR-4398 states that: [R]eporting of the "as found" condition for the Type A test does not appear to be presently done. The NRC has been requesting that the utilities supply sufficient data from the Type Band C tests results to derive an "as found" condition for the containment. However, . . . this requirement or request has not been enforced in all NRC regions. The requirement for reporting the "as found" condition for the Type A test will . . . make the reporting of the "as found" mandatory . . . . The utilities will see some negative im~act from this re uirement. There wille some increase in time nee e or reporting an ana ysis o t e T*pe Band C testing done in conjunction with t e Ty~e A test, so that the "as found" condition of the containment can be determined.6/ (Emphasis added.)

• §50.109 Backfit Analysis for Proposed 10 C.F.R. 50, App. J and Proposed Reg. Guide MS 021-5 (Oct. 16, 1986) at 1.

The Staff represented the proposed rule as being "limited to corrections and clarifications, and {excluding) new criteria." 51 Fed. Reg. 39538, col. 3. This statement did not fully expose the substantive nature of many aspects of the proposed rule.

 §_/ NUREG/CR-4398, Cost Analysis of Revisions to 10 C.F.R. Part 50, Appendix J, Leak Tests for Primary and Secondary Containments of Light-Water-Cooled Nuclear Power Plants (1985) at 30.

Mr. Samuel J. Chilk April 24, 1987 Page 5 In addition, reporting of the "as found" condition for the Type A test requires determination of the minimum pathway leakage characteristics of the containment penetrations and pressurization for each valve. Many plants do not have the necessary equipment, piping and valve configurations to perform these tests. To comply with the new regulations would thus require an extensive and costly backfit. Another significant backfit may arise due to a necessity to test each valve individually. Several aspects of the proposed rule, including the "as found" acceptance criteria for Type B and C tests, the requirement for single active failure analysis to be used for Type Band C testing criteria, the definition of minimum and maximum pathway leakages, and reporting requirements for Type Band C failures, point to a necessity to attain this capability. For many facilities, this will mean the addition of multiple block valves and test connections, as well as vents and drains, on lines penetrating containment. The expense of these backfits and the outage work required to comply could be significant.

c. Key Aspects of the Proposed Rule Fail to Satisfy the Backfitting Rule To pass muster under the backfitting rule, the proposed requirement or modification must be shown to provide a "substantial increase in the overall protection of the public health and safety" as well as to be justified in terms of the "direct and indirect costs of implementation . . . . " 10 C.F.R.

 §50.109(a)(3). If, taking all relevant factors into account, there is no substantial increase in protection of the public, then sound regulation dictates that the requirement not be imposed on licensees.

Unless the proposed revisions to Appendix J meet these standards, the Commission should refrain from making the changes mandatory. It is apparent from examining the record that many of the proposed revisions do not meet these standards. The Staff concluded in its backfitting analysis that: [t]here is no substantial increase in the overall protection of the public health and safety or the common defense and security that can presently be quantified from the proposed backfit.1/ 21 §50.109 Backfit Analysis for Proposed 10 C.F.R. 50, App. J and Proposed Reg. Guide MS 021-5 (Oct. 16, 1986) at 6.

Mr. Samuel J. Chilk April 24, 1987 Page 6 Thus, the Staff concedes that one of the standards is not met by the proposed rule (the conclusion implies that the proposed rule, on the whole, is deficient). When examined from a risk perspective, the current leakage rate criteria in Appendix J are seen to be very conservative and the proposed revisions to Appendix J are thus not supported by any need to further restrict permissible leakage rate limits. Since the containment is designed to withstand a mitigated design basis accident, there is reasonable assurance that (with few exceptions) normal containment leakage is relatively insignificant. The current Appendix J programs for each plant provide even greater assurance of leak tightness. Current allowable leakage rate are much less than 10 wt. %/day, ranging from approximately 0.1 to 2.6 wt. %/day of the contained air mass.8/ Yet NUREG-1150, the NRC's contemporary study of risk, states: A risk-based study . . . using Reactor Safety Study [WASH-1400) data indicated that the contribution to overall reactor risk from containment leaks u~ to 10 wt %/day is small. Using risk-based in ormation and new source terms from NUREG-1150, we have reassessed the contribution of small containment leaks to public risk and to expected radiation doses in the vicinity of the plant given a severe accident. Containment leaka e during normal 6 o!eration produces a negligi le contribution to o £site risk . . . . ~/ (Emphasis added). Thus, there is an enormous margin between the current allowable leakage rates and those found by the authors of NUREG-1150 to be significant to increasing overall reactor risk. Adjustments to the Appendix J requirements may well not be a worthwhile endeavor when the conservatism of the allowable leakage rates is considered._!_Q_/ See NUREG/CR-3549 at 2, where the authors put these values Inperspective by pointing out that a 0.1 wt %/day leakage ra e out of a containment volume of 56,634 m3 (2,000,000 3 ft ) under a pressure of 380 kPa (55 psia) at 339 K (150°F) is equivalent to that represented by a hole with a diameter of approximately 0.152 cm (0.06 in.). NUREG-1150, Reactor Risk Reference Document (1987), at 10-15. NUREG/CR-4330, Review of Light Water Reactor Regulatory Requirements (1986), states (at 2.39) that leakage rate limits are believed to be conservative, and that a factor of 10 to 100 increase in leak rate may not be risk significant.

Mr. Samuel J. Chilk April 24, 1987 Page 7 That the proposed revisions to Appendix J may not be supported can further be seen by examining several pertinent NRC documents. NUREG/CR-3539 concludes that LWR accident risk is relatively insensitive to the containment building leakage rate.11/ Consequently, absent gross containment failures resulting from a - severe accident (which Appendix J was not meant to address and which are addressed by defense-in-depth and other regulatory policies) Appendix J revisions tending to move containment testing programs toward a penetration-by-penetration level of exactitude will not appreciably increase the health and safety of the public. The current Appendix J regulations constitute an adequate containment program when the large margin between current leakage rates and "acceptable" leakage rates is considered. A July 15, 1982 memorandum from the Safety Program Evaluation Branch-Division of Safety Technology reinforces this point.12/ The Memorandum states in the first paragraph: - We find that fine tuning the containment leakage rate can not be justified based on the risk assessment reduction potential of any improvements in leak rate. Nuclear plant risk studies indicate that risk is dominated by core melt events which result in gross failure of the containment . . . The risk from these gross failures overshadows the risk associated with containment leakage for mitigated loss-of-coolant accidents and core damage events which may have a large source term but do not result in a gross containment failure. The Safety Program Evaluation Branch goes on to recommend that resources which would be used to improve leakage testing methods and requirements could be more efficiently used to perform periodic or continuous gross checks of containment integrity. This is precisely our point. Since the proposed revisions have not been shown to result in a substantial increase in the overall protection, they may not, consistent with the Commission's own regulations in 10 C.F.R. §50.109, be imposed as binding requirements. In examining the costs of the proposed rule, the Staff estimates

 !!_I NUREG/CR-3539, Impact of Containment Building Leakage on LWR (Light Water Reactor) Accident Risk (1984), at 11.

July 15, 1982 memorandum from Warren Minners, Acting Chief-Safety Program Evaluation Branch-Division of Safety Technology to George w. Knighton, Chief-Research & Standards Coordination, Division of Safety Technology.

Mr. Samuel J. Chilk April 24, 1987 Page 8 that there is a potential for large financial savings due to the avoidance of penalty replacement energy costs (due to fewer unscheduled outages to perform leakage rate testing). The Staff, however, recognizes that it may not be appropriate to factor these savings into its calculations, and assumes that the benefits which would accrue (from technically sound and unambiguous regulations that minimize the need for exemptions) would equal the costs created. These crucial Staff assumptions however, are untested in practice. Without further substantiation, they are entitled to little or no weight and can be viewed as part of a "bootstrapping" effort by the Staff to reach a pre-determined conclusion in its backfit analysis -- viz., that the rule can be cost-justified, notwithstanding the absence of "substantial increase" in safety. Significantly, the Staff's opinion that the proposed rule would reduce the number of outages necessary for Type A testing should be discounted since the assumption that the impact of more "as found" test failures can be lessened by increased Type Band C testing is speculative.13/ Type B tests currently may be performed, and Type c testsare required to be performed, every refueling outage, but in no case at intervals greater than every two years. For plants on an 18-month refueling cycle, shutdown would be required in order to perform more-frequent Type Band C tests, and these substantial costs were not fully considered in the Staff's cost analysis (NUREG/CR-4398). The real cost of the proposed rule is also apparent when the increase in occupational exposures is examined. The Staff admits that the proposed rule would cause a 10,000 person-rem increase in routine occupational exposure over the operating life of the power reactor population. The more frequent testing of individual containment penetrations requires more time inside containment for test crews, resulting in increased occupational exposures. Ironically, the Staff admits that this additional exposure of employees to radiation is the only significant, quantifiable change to safety, and it is a negative one.14/ Thus, far from producing a substantial increase in the overall protection, the proposed revisions may have a negative overall impact. Such speculation is the sine qua non of the Staff's assertion that the revisions are essentially supported by the expectation of cost savings due to averted Type A tests. For every averted Type A test assumed as a source of cost-saving, the Staff has assumed the "benefit" of $1.2 to 2.5 million (nominal cost of performing one Type A test). NUREG/CR-4398 at 34. _!ii Id. at 6.

Mr. Samuel J. Chilk April 24, 1987 Page 9 As mentioned above, the four specific changes which would have the most significant cost impact are: (1) the revision to Sections III.A(4) and IV.A(6) of Appendix J, eliminating the option to test at reduced pressure; (2) the revision to the Section III.A(7)(b)(i) acceptance criteria for determination of the "as found" leakage rate condition; (3) the revision to Section III.A(8)(a), whereby a Corrective Action Plan must be implemented, following failure of the "as found" leakage rate to satisfy the acceptance criteria; and (4) the revision to Section III.A(8)(b)(ii), whereby licensees would have the option of performing more frequent Type B or Type C testing to correct for unsuccessful Type A leakage tests. The specific impacts of these changes are significant. As noted above, the latter two changes would result in an enormous increase in occupational exposure. Tables 1.3 and 1.4 of NUREG/CR-4398 show that the revision to paragraph III.A(8)(a) would result in an increase of 1411 to 9220 man-rem, and the revision to paragraph III.A(8)(b)(ii) would cause an increase of 353 to 5408 man-rem. Paragraph III.A(8)(a) would require a large number of licensees to develop and implement Corrective Action Plans to better ensure the integrity of their containment systems. These plans usually require increased surveillance and maintenance of containment penetrations, thus resulting in increased costs and occupational exposure. Paragraph III.A(8)(b)(ii) would give utilities the option to do more frequent local leak rate tests in lieu of more frequent penalty Type A tests if the previous Type A test failures were due to leakage through Type Band C penetrations. This type of local testing involves substantially higher occupational exposures than does the integrated leak rate testing. In addition, the Staff concedes that licensees will have to develop procedures and make equipment modifications in order to comply with the regulations: This action will require changes to the technical specifications, test procedures, data analyses, and test reports. In some cases it may entail modifications of some systems to conform to all aspects of the revised leakage testing program, such as test taps to enable testing of some valve(s) not previously tested._!2/ Finally, the major cost created by the revisions disallowing Type A tests at reduced pressure would be financial. Tables 1. 3 and 1.4 of NUREG/CR-4398 show that a cost of between $7.9 to

 $22.8 million would result. This is due to the fact  that approximately 40 plants currently testing at reduced   pressure

_!2/ Id. at 4.

Mr. Samuel J. Chilk April 24, 1987 Page 10 would need to increase their pressurization and depressurization times, leading to more plant downtime. In short, the Staff's conclusion that the proposed revisions are cost justified is not well founded, and falls short of the required analysis and findings mandated by 10 C.F.R. §50.109 for backfits such as this. D. The Current Exemptions Should Remain Intact. Regardless of any revisions which are made to the Appendix J requirements, exemptions to the current Appendix J should not be voided by the new rule unless the new rule would substantially modify the underlying basis for the exemption. Many proposed modifications to Appendix J are not substantive in n a t u r e , ~ , renumbering sections, minor clarifications and general consolidations. In addition, while some clarifications appear substantive, the underlying basis for the new provision is unchanged from the old rule. Many exemptions have been granted to provisions of the old rule which in the new proposal contain such non-substantive changes. Where exemptions to such old provisions have been granted, we maintain that it would be an unwarranted expenditure of industry and Staff resources to file and process new exemption requests where the underlying basis of the exemption has not changed. Accordingly, if there is to be a final rule, we suggest that the Statement of Considerations state that licensees need not file new exemption requests in these instances. Rather, licensees need only provide a letter to the Staff noting the exemptions at issue and provide a brief description of why the exemptions should be retained in force. E. The Commission Should Consider Alternatives to the Proposed Rule In view of the significant and unresolved issues regarding the proposal, as noted above, we suggest that the Commission withdraw the proposed rule, issue a Generic Letter making the provisions of the proposal voluntary,16/ and merge the issues raised by the proposal with the more comprehensive revision of Appendix J which the Commission is planning to initiate within the next year or two.17/ In this way, the Commission would avoid "piecemeal" rulemaking which would only confuse the issues immediately prior to the larger rulemaking .

 .!.§_/ Such a voluntary approach has been utilized in the past, including the proposed rule on Appendix K, and GDC - 4.
 !21    See 51 Fed. Reg. 39539 at 39538, col. 2; see also NUREG/ CR-4330, Review of Light Water Reactor Regulatory Requirements (1986).

Mr. Samuel J. Chilk April 24, 1987 Page 11 The Commission implicitly recognized elements of this suggestion in its "Invitation to Comment," in asking whether licensees should be given the option to continue to follow the existing version of Appendix J even if the proposed revisions are adopted and whether the existing rule or the proposed revisions should be made voluntary.18/ The Staff has raised no significant safety concern which is driving the proposed revisions at this time. In light of this fact, it would be wise to defer this rulemaking in order to avoid an interim set of regulations which would serve little useful purpose, but would instead create confusion and impose implementation costs in the short period before the comprehensive revisions take place. II. CONCLUSION From the foregoing, we maintain that the proposed rule is significantly flawed in that it contains new requirements/criteria beyond the scope of the proposal which are, in addition, unsupported by valid technical considerations and the requisite backfit analysis (10 C.F.R. §50.109). Accordingly, in view of the more comprehensive revisions of Appendix J scheduled for the near term, we recommend that the Commission withdraw the proposed rule, issue a Generic Letter making the provisions of the proposal voluntary as a means of satisfying Appendix J and merging the issues in the proposal with the upcoming comprehensive revisions of Appendix J. It is also unclear whether any of the substantive changes which would result in an intensified Appendix J program and tend to produce a penetration-by-penetration level of scrutiny can be justified from a risk-reduction perspective. The NRC should stand back and view the proposed changes in the light of contemporary perspectives on severe accidents and safety goal policies .

 .!_!!_/ 51 Fed. Reg. 39538 at 39539, cols. 1-2.

Mr. Samuel J. Chilk April 24, 1987 Page 12 Given these problems, the Commission should not go forward with the rule as proposed, but rather should consider the alternative course outlined herein. Respect submitted, BISHOP, COOK, REYNOLDS Suite 800 1200 Seventeenth Street, N.W. Washington, D.C. 20036

JUGKET NUMBER MBARWi6Q PR . .,

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Wisconsin Electr,c POWER coMPAN'f 231 W. MICHIGAN, PO BOX 2046, MILWAUKEE, WI 53201 C51 F~ -E'f§~F)~ OOC:KETEQ USNRC "87 APR 29 PS :18 (414) 221-2345 VPNPD-87-160 NRC-87-44 April 23, 1987 U.S. NUCLEAR REGULATORY COMMISSION Washington, D. c. 20555 Attention: Docketing and Service Branch Gentlemen: COMMENTS ON PROPOSED RULE AND REGULATORY GUIDE LEAKAGE RATE TESTING OF CONTAINMENTS FOR LIGHT-WATER-COOLED NUCLEAR POWER PLANTS 10 CFR 50, APPENDIX J AND TASK MS 021-5 This letter is to transmit our comments on the proposed revisions to 10 CFR 50 Appendix J regulations as published in the Federal Register on October 29, 1986. We have previously provided comments on the Draft Regulatory Guide associated with this Appendix J revision in our letter dated January 5, 1987

• (copy attached). Our comments on the Draft Regulatory Guide addressed specific concerns with the timing of the Types Band C testing relative to the Type A test, treatment of gas pressure sources inside containment, the basic purpose of the verification test, leak rate stabilization criteria guidance, clarification of calibration requirements, data scatter analysis methodology, and justifications for maintaining the option to perform reduced pressure tests. Specific comments on Appendix J revisions follow.

First, in the Definitions, Section II, the proposed rule defines Containment Isolation Valve in terms of General Design Criteria 55, 56, or 57 of Appendix A to 10 CFR 50. This would not be applicable to plants that predate Appendix A. Modifying the current definition as follows would be more appropriate:

    " ... any valve which is relied upon to perform a containment isolation function in the design basis loss-of-coolant accident."

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U. s. Nuclear Regulatory Commission Page 2 April 23, 1987 Second, the term "accident" is used frequently in the proposed rule, but it is not included in the definitions. "Accident" should be defined in Section II as "the design basis loss-of-coolant accident presented in the licensee's Final Safety Analysis Report". This is consistent with the background information published with the rule and would preclude the inclusion of valves such as main steam isolation valves, feedwater check valves, and safety injection check valves for pressurized water reactors in the Type C test program, unless relied upon to perform a containment isolation function in the design basis accident analysis. Finally, we re-emphasize the comments in our January 5 letter regarding the disallowance of reduced pressure tests in Section III.A.4. Although no specific unacceptable degradation mechanism has been associated with the full pressure tests, the higher fatigue usage from performing the full pressure test may reduce rather than improve containment functionality over the plant lifetime. We recognize that none of the justifications for reduced pressure tests are individually compelling, but in total they provide substantial justification for not eliminating that option. As a final general comment on the regulations, we believe that it would be appropriate to defer general revision of Appendix J until the planned overall reviews of containment functional and test requirements are complete. We understand these reviews are scheduled within the next two years. These reviews should also include consideration of life extension impacts .

• We also endorse the comments submitted by Bechtel Power Corporation dated January 13, 1987 concerning this subject.

We trust that both these comments and the remarks contained herein will be beneficial to you in formulating a final regulation. Please feel free to contact us if you desire further discussion or clarification of our comments. Very truly yours, l,'/ { v - _; ""\* l C. W. Fay Vice President Nuclear Power Attachment Copies to NRC Resident Inspector NRC Regional Administrator, Region III NRC Rules and Procedures Branch, Division of Rules and Records

0 Wisconsin Electr,c POWER coMPANY 231 W. MICHIGAN, PO BOX 2046, MILWAUKEE, WI 53201 (414) 277-2345 VPNPD-87-005 NRC-87-002 January 5, 1987 Rules and Procedures Branch Division of Rules and Records Office of Administration U.S. NUCLEAR REGULATORY COMMISSION Washington D. c. 20555 Gentlemen: TASK MS 021-5 COMMENTS ON DRAFT REGULATORY GUIDE CONTAINMENT SYSTEM LEAKAGE TESTING This letter is to transmit our comments on Draft Regulatory Guide dated October 1986 and entitled, "Containment System Leakage Testing," per your request. The comment numbers correspond to the paragraph numbers in Part C of the regulatory guide.

1. We agree and believe that this is an important point to make.

2. We agree with this point but believe that one of the referenced paragraphs, 3.2.1.3 of ANSI/ANS 56.8-1981, requires further change. The first sentence of this paragraph should be replaced with the following:

The containment isolation system functional test should be conducted prior to the Type A test. Those systems whose lineups must be altered to support the Type A test must have their Type Band C tests completed prior to the Type A test. The remainder should be conducted after the Type A test. This method is recommended because it performs the Type A test as close to the "as found" condition as possible. This means that the Type A test must be performed early in the outage, but it is the best way to determine the true "as found" integrated leak rate as required by 10 CFR 50 Appendix J.

Rules and Procedures Branch January 5, 1987 Page 2

3. The second paragraph of 3.2.1.5 of ANSI/ANS 56.8-1981 states, "Systems that are required for proper conduct of the test or to maintain the plant in a safe condition during the test shall be operable in their normal mode and need not be vented or drained." Pargraph 3 of the regulatory guide, which prohibits gas sources in containment, seems to contradict this statement because some of the systems needed to maintain the plant in a safe condition are gas systems. At Point Beach Nuclear Plant, we must have either instrument air or a temporary gas source to the power operated relief valves. Our technical specifications require that they be operable to maintain pressure relief capability of the reactor coolant system .

We also believe that it is better to keep the safety injection accumulators pressurized throughout the test. If they are vented, nitrogen gas that has been dissolved in the boric acid solution will continue to come out of solution for some time. These gas additions to containment could not be measured and may introduce a significant error to the test. For these reasons, we believe that this paragraph of the regulatory guide should state the gas sources that are needed for reactor safety or for proper conduct of the test may be kept in operation if monitored for leakage into containment and factored into the test results.

6. (3) The purpos e s tated here for the verification test is not consistent with the current Appendix J, the proposed Appendix J, or the past interpretation of some regional inspectors. The inspectors interpret the verification test as a quality check on the data and measured containment leakage. The current Appendix J states that the supplemental test is done to verify the accuracy of the Type A test. The proposed Appendix J states the purpose is to confirm the capability of the Type A test method and equipment to measure the maximum allowed leakage rate. We recommend that the definition in the current Appendix J be used in this regulatory guide.

(4) This statement allows for a straight line that does not stabilize within the mass change acceptability band. Inspectors require stabilization of the leakage rate or change in mass within the band. A linear regression fit line may be in the band while the actual data is out. Furthermore, this statement is vague and could cause misunderstanding between inspectors and licensees. A definite period of time or number of data points should be specified rather than just saying "sufficient points". A one-hour time period would be appropriate here.

Rules and Procedures Branch January 5, 1987 Page 3

11. Parts 11.1 and 11.2 are an improvement of ANSI/ANS 56.8-1981; however, it appears that Part 11.3 has overlooked the distinction between a calibration and a calibration check. Instruments used in Type Band C tests should be calibrated as stated in Paragraph 4.2.2 as modified by Part 11.1 of the regulatory guide. Part 11.3 should be deleted, and Paragraph 4.2.4 should stand as written. It is impractical to perform a detailed calibration on a daily basis, but periodic calibration checks both prior to and following a series of tests are practical and worthwhile.

13. Part 13.3 states that additional conditions need to be applied to limit nonlinearity and data scatter during a Type A test; however it fails to prescribe these additional requirements. Instead, it provides a discussion of the parabolic inequality method, which the NRC inspectors use as an alternative. In theory, any system that can adequately control the quality of the least squares fit from the mass point technique should be acceptable.

The parabolic inequalities method presented in the appendix of the regulatory guide would be a significant technical imposition on utilities, requiring substantial statistical analyses with minimal benefit. If there is excessive data scatter or nonlinearity, the 95% UCL will remain high and the test will fail. The value of further constraints on data is questionable. Both the current and proposed versions of Appendix J to 10 CFR 50 state that the purpose of the test is to ensure that the containment does not exceed the leakage rate allowed by technical specifications and to provide surveillance so that proper maintenance and repairs are done. This is adequately provided by conservatively bounding the leak rate, and the proposed mathematical leak rate linearity test and da~a scatter analysis are not needed. This additional criteria will fail or lengthen some tests that have demonstrated that leakage is within required limits. In addition to these comments on the specific points of the proposed regulatory guide, we believe that Paragraph 3.2.2 of ANSI/ANS 56.8-1981 should be modified to specifically allow reduced pressure testing and should be referenced in the regulatory guide. This paragraph specifies that the Type A test pressure should be equal to or greater than accident pressure (P ). The current regulations allow testing at pressures atcone half of P , and we believe that there are several good reasons for c8Rtinuing reduced pressure testing.

Rules and Procedures Branch January 5, 1987 Page 4 First, the density of the containment atmosphere at reduced pressure is very close to that of the steam-air mixture that would be present in an accident. The flow rate of a compressible fluid through a penetration is affected by fluid friction, which is density dependent. Secondly, many penetrations have resilient seals and many valves are installed so that higher containment side pressure seals them tighter. This can make a full pressure test less conservative than a reduced pressure test. In fact, the actual pressure in an accident will reach P for only a second and will be greater than one-half P foraiess than nine minutes at our Point Beach Nuclear Plant. aThis is typical of most nuclear containments. For these reasons, the reduced pressure test may be a better

• model of the post-accident conditions in the containment.

Since the purpose of the test is to ensure that containment leakage will remain below the allowable limit in an accident, the reduced pressure test should be permissible. Please feel free to contact us if you desire further explanation of our comments. Very truly yours,

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NUCLEAR UTILITY BACKFITTING AND REFORM GROUP SUITE 700

                                      *97 APR 29 A11 :SJ,!oo SEVENTEENTH     STREET, N . w.

WASH I NGTON, D. C . 20036 TELEP HONE (2 02) 857 - 9817 April 24, 1987 Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing & Service Branch Subj: Proposed Rule: Leakage Rate Testing of Containments of Light-Water - Cooled Nuclear Power Plants, 10 C.F.R. Part 50, Appendix J (51 Fed. Reg. 39536 (1986))

Dear Mr. Chilk:

On October 29, 1986, the Commission issued for public comment proposed amendments to 10 C.F.R. Part 50, Appendix J, the regulations governing leakage rate testing of containmen t s of light-water-cooled nuclear power plants. 51 Fed. Reg. 39536 (1986). The following comments are submitted by the Nuclear Utility Backfitting and Reform Group ( "NUBARG"). ! /

    !/   NUBARG consists of the Edison Electric Institute and the following nuclear utilities:

Alabama Power Company, Arkansas Power & Light Company, Baltimore Gas & Electric Company, Cleveland Electric Illuminating Company, Commonwealth Edison Company, Detroit Edison Company, Duke Power Company, Florida Power & Light Company, Florida Power Corporation, Georgia Powe r Company, Houston Lighting & Power Company, Long Island Lighting Company, New York Power Authority, Niagara Mohawk Power Corporation, Northeast Utilities, Northern States Power Company, Pac ific Gas and Electric Company, Pennsylvania Power & Light Company, Philadelphia Electric Company, Portland General (Footnote 1 continued on next page)

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NUBARG submits these comments to address the Commission's application of the backfitting rule, 10 C.F.R. S 50.109, to the Appendix J revisions. It is NUBARG's position that because the proposed revisions have not been shown to produce the requisite substantial increase in safety, they may not be mandated by regulation. Instead, the revisions should be made voluntary or deferred until the more comprehensive revisions to Appendix J. I. APPLICATION OF SECTION 50.109 As the Commission has noted, the backfitting analysis prepared for the Appendix J revisions does not conclude that there will be a "substantial increase in the overall protection" as required by§ 50.109 (a)(3). 51 Fed. Reg. at 39541. Nevertheless, the Commission has issued the proposed rule because the revisions are ostensibly designed "for the purpose of updating the existing regulation" (51 Fed. Reg. at 39536) and because the backfitting analysis has shown that the direct and indirect costs of implementation are justified due to better, more uniform tests and test reports, greater confidence in the reliability of the test results, fewer exemption requests, and fewer interpretive debates.£/ Section 50.109(a)(3), however, is clear: both a substantial increase in overall protection and cost justification must be demonstrated before a proposed backfit may be imposed. Because the proposed revisions have not been shown to produce a substantial increase in safety, the Commission is barred by Section 50.109(a)(3) from imposing the revisions as binding requirements. It is axiomatic that an agency is bound by its own regulations. S e e , ~ , Nader v. NRC, 513 F.2d 1045, 1051 (o.c. Cir. 1975). Thus tlieeomm1ss1on may not dispense with the substantial increase standard merely because it believes the proposed revisions will not cost too much. (Footnote 1 continued from previous page) Electric Company, Rochester Gas & Electric Corporation, TU Electric, Toledo Edison Company, Washington Public Power Supply System, and Yankee Atomic Elec t ri c Company (representing also Publ i c Se r vice Company of New Hampshire, New Hampsh i re Yankee Division, Maine Yankee Atomic Power Company, and Vermont Yankee Nuclea r Power Corporation). l/ 51 Fed. Reg. at 39 5 41.

Moreover, the Commission's characterization of these changes as "updating" or "clarifying" Appendix J vastly understates the significance of some of the changes. While some of the changes represent useful clarifications or streamlining of Appendix J, there are several significant backfits in the proposed rule that have not been adequately considered in a backfitting analysis. These are addressed in comments filed by other parties and include the following:

1. "As found" acceptance criteria. The "as found" acceptance criteria of proposed Sections III.A.(7) and II.B.(4) represent new requirements. These changes are likely to have a significant cost impact while not improving safety. With respect to Type A tests, the Staff has recognized that current requirements do not specifically provide "as found" acceptance criteria for Type A tests, but rather provide data to the NRC from which the "as found" condition of the containment can be derived. See NUREG/CR-4398, Cost Analysis of Revisions to 10 CFR Part 50, Appendix J (September 1985), at 30. Moreover, the new "as found" acceptance criteria for Type Band C tests may substantially increase Type Band C testing at many plants. The Staff has recognized this (NUREG/CR-4398 at 54-55) but has underestimated the cost of such additional testing and ignored plant modifications that may be necessary. The "as found" Type B and C test requirements point to a need to test all valves individually, which would necessitate modifications such as the addition of block valves and test connections. Further, an increased frequency of Type Band C testing may significantly extend outage duration. Performing "as found" local leak rate testing extends the critical path for preventive maintenance on valves and can tie up resources, with the result that non-Integrated Leak Rate Test outages could be extended up to several days. This may actually have a negative effect on safety by delaying preventive maintenance.

The current backfitting analysis fails to consider the cost of modifications that will be needed and the cost of extended facility downtime from increased Type Band C testing. See Backfit Analysis at 5; NUREG/CR- 4398 at 54-55. The NCR's cost analysis estimated only the labor cost of the increased frequency of local leak rate tests on the basis of a 1.0 to 1.5 hour test duration. Experience has shown that such tests require substantially more time than this to complete, perhaps as much as 8 to 24 hours.

2. "As found" testin for modifications, re airs and re~lacements. Propose Sect1on IV.A prov1 e s t at any mo ification, repair, or replacement of a component subject to Type B or C testing must . . . be preceded by a Type B or Type C test." Currently such testing is generally required only during refueling outages prior to Type A tests. If prior testing were required during forced outages or other maintenance outages, this would substantially enlarge maintenance activities and increase

worker exposure. Increased facility downtime would also result from this additional testing. This provision has not been identified as a backfit and separately justified by an adequate backfitting analysis. The Staff has treated this change merely as a "clarification." NUREG/CR-4398 at 68.

3. Three- eriod between eriodic tests. Propos tion III.A. 3) interva between the preoperational and first periodic Type A test may not exceed three years and that if initial fuel loading is delayed so that the three-year interval is exceeded, another preoperational test will be required. This is a new requirement which has not been identified as a backfit and separately justified. This requirement will often mean an additional Type A test due to delays between preoperational testing and plant operation. No benefit to safety will be achieved by this additional testing since the plant has not experienced any service life .

• 4. Definition of "containment isolation valve". The definition of "containment isolation valve" refers to General Design Criteria 55, 56 and 57. As a result, pre-GDC plants, whose containment isolation valves were not required to be designed to these criteria, may have to make modifications. No backfitting analysis of this change has been made.

5. Corrective Action Plans. The proposed revisions require the filing of a "corrective Action Plan". See Sections III.A.(8), III.B.(4) and VI.B. This is a new requirement.

Currently, test failures are reported in LERs in accordance with 10 C.F.R. S 50.73. The addition of a new reporting requirement would thus be duplicative. No backfitting analysis to justify such a new requirement has been performed. In view of these significant backfits, the Commission should take care not to adopt the new revisions without a backfitting analysis that conforms to Section 50.109. Unless the proposed revisions meet the standards of Section 50.109, the Commission should refrain from mandatinfi that licensees implement the changes. The better approac may be for the Commission to make the proposed revisions voluntary and grant licensees the option to determine whether to implement the changes. The Commission recognizes this in questions 5 and 6 under the "Invitation to Comment," which solicit comments on whether licensees should be given the option to continue to follow the existing version of Appendix J even if the proposed revisions are adopted, and whether the existing rule or the proposed revisions should be made voluntary. 51 Fed. Reg. at 39539, cols. 1-2. Alternatively, the Commission could propose adoption of those provisions that truly represent updating or streamlining of the current Appendix J and which would therefore not impose backfits. This would in all probability require republication of the proposed rule.

Moreover, we understand that the Commission is planning a more comprehensive updating and streamlining of Appendix J requirements in the next year or two. See 51 Fed. Reg. at 39539, col. 2; see also NUREG/CR-4330, Review ci'"r"Light water Reactor Regulatory RegtiTrements (June 1986). Because there appears to be no safety concern requiring adoption of the proposed revisions at this time, the Commission should consider deferring the proposed revisions until the more comprehensive rulemaking. This would avoid the process of piecemeal revisions to the rule that could create administrative problems for both the staff and licensees. II. RESPONSE TO COMMISSIONER BERNTHAL'S QUESTIONS In his separate views, Commissioner Bernthal requested comments on whether the backfitting rule should be revoked as it applies to rulemaking proceedings. In Commissioner Bernthal's opinion, when rulemaking concerns such matters as "human-factors rules [or] updating antiquated rules," application of Section 50.109 to the rulemaking "exact[s] NRC resources wholly disproportionate to any conceivable benefit to the public." 51 Fed. Reg. at 39540, col. 2. NUBARG respectfully disagrees with Commissioner Bernthal's position. As the Commission correctly observed when it promulgated the backfitting rule, there is no practical difference between backfits imposed by order or staff position in individual dockets and those imposed by rulemaking. In either case the licensee is required to use its resources to implement the backfit, and the Commission, as a matter of sound regulatory practice, should understand the impact of the backfit before imposing it. As the Commission stated in adopting the backfitting rule (50 Fed. Reg. at 38101, cols. 1-2): Since there is no practical difference between a backfit that is imposed pursuant to a rule or a staff position interpreting a rule, the Commission will alter the final rule to require a documented analysis of required backfits regardless of the source * . *

• Because there must be safety reasons for the agency to impose any changes to a regulatory requirement or a staff position applicable to the licensee, because the safe[ty]

consequences are unknown until analyzed, and because the Commission should fully understand the effects of a proposed backfit before its imposition, it is of little consequence how a backfit is imposed. In short, the backfitting rule should be applied regardless of whether the proposed backfit is to be effected by rule, regulation, order or Staff position.

It is also difficult to understand how the application of the backfitting rule would require the NRC to expend "resources wholly disproportionate to any conceivable benefit to the public." 51 Fed. Reg. at 39540, col. 2. The Commission has previously acknowledged that the systematic and documented analysis required by the backfitting rule represents essentially the same type of analysis performed by the NRC in the past in considering proposed requirements. Thus, the Commission has noted that the backfitting analysis has "precedent in existing NRC practices as seen in the Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission, NUREG/BR-0058, the approved CRGR Charter and the Commission's approved plan for the management of plant-specific backfitting . . . . " 50 Fed. Reg. at 38103, col. 3. The continuation of this type of prudent analysis cannot be considered a sudden exaction of NRC resources far in excess of the public benefit. Commissioner Bernthal has also requested comment on whether the Commission should amend the backfitting rule to delete the requirement of S 50.109(a)(3) that the backfit produce "a substantial increase in the overall protection." Commissioner Bernthal apparently believes that the "substantial increase" standard could prevent adoption of new requirements that are otherwise desirable and in the public interest. In our view, retention of the "substantial increase" standard is essential. Licensees must be permitted to manage their plants within a stable regulatory framework, absent the imposition of mandatory requirements that do not substantially enhance the public health and safety. The present backfitting rule ensures this ability by permitting only the imposition of requirements that would produce a "substantial increase in the overall protection." If a proposed requirement does not provide a "substantial increase in the overall protection," taking into account all relevant factors, then sound regulation dictates that such a requirement not be imposed on licensees. It would be tantamount to an abdication of its commitment to restore regulatory stability for the Commission to abandon the backfitting rule simply because a proposed backfit is found not to be justified under the prevailing standards. Finally, Commissioner Bernthal has solicited comment on whether the backfitting rule should be amended to permit the Commission to consider nonmonetary benefits in the analysis. In our view, the backfitting rule already allows consideration of nonmonetary benefits or nonquantitative factors. Section 50.109(c) requires the Commission to "consider information available concerning [as many of the listed] . . . factors as may be appropriate and an~ other information relevant and material to the pro~osed backfit. (Emphasis added.) This language makes clear t a t the Commission is to tailor its backfitting analysis to the proposed change under consideration and that the analysis should consider both qualitative and quantitative factors. In

short, the Commission's authority to consider nonmonetary benefits in the backfitting analysis is clear, and there is no need to amend the backfitting rule to permit it to do so. NUBARG appreciates the opportunity to comment on these matters. Respect s to h Nuclear Utility Back itting and Reform Group

LIO.C.l<fJ NUMBER PR ...,I mmeosrn aw.s -:; u {_~IF~ 9_,g~ N Nebraska Public Power District

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                                                                     *a7 APR 29 PS :1 ~7 APR 29 PS :l NLS8700195 April 24, 1987 U.S. Nuclear Regulatory Commission Washington, DC 20555

• Attention:

Subject:

Gentlemen: Docketing and Service Branch Proposed Revision to 10CFR50 Appendix J and Draft Regulatory Guide MS 021-5 The Nebraska Public Power District ( the District) endorses the BWR Owner's Group comments pertaining to the proposed 10CFR50 Appendix J revision and draft Regulatory Guide MS 021-5. The District further supports the Owner's Group request that a more thorough Backfit Analysis, in accordance with 10CFR50.109, be conducted. Revisions due to comment incorporation should be published again in proposed form to allow further review and comment. Should you have any questions concerning the District's position on this

• issue, please contact me.

Sincerely,

 ~Division Manager Nuclear Support GAT/mtb: jw

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LAWOF"F"ICES BISHOP, COOK, PURCELL & REYNOLDS CKETE UStiC 1200 SEVENTEENTH STREET, N.W. WASHINGTON , D.C. 20036 (202) 857-9800

                                                           *a7 PR 28 P2 :48 TELEX: 440574 INTLAW UI TELECOPIER: {202) 857- 9846 April 24, 1987 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Attn: Docketing and Service Branch Re: Proposed Rule to Amend Appendix J Requirements Regarding Leakage Rate Testing of Containments of Light- Water-Cooled Nuclear Power Plants (51 Fed. Reg. 39538 {Oct. 29, 1986))

Dear Mr. Chilk:

On October 29, 1986, the Nuclear Regulatory Commission ("NRC" or "Commission") published in the Federal Register a notice inviting public comments on a proposed rule to amend its Appendix J containment leakage rate testing requirements. 51 Fed. Reg. 39538. The stated purpose of the proposed rule is to "aid the NRC licensing and enforcement staffs by eliminating conflicts, ambiguities, and lack of uniformity in the regulation of the inservice inspection program." Id., col. 1. On behalf of the licensees listed below,1/ we respectfully submit the following comments on this proposed rule. I. DISCUSSION The scope of the proposed revision is allegedly limited to corrections and clarifications, and excludes new criteria. Id., col. 3. As discussed more fully below, while some aspects o--r-the proposed rule may be beneficial, we maintain that major

 !/   Arkansas Power & Light Company; Consolidated Edison Company; Florida Power Corporation; New York Power Authority; System Energy Resources, Incorporated; TU Electric; Washington Public Power Supply System; Yankee Atomic Electric Company.

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Mr. Samuel J. Chilk April 24, 1987 Page 2 prov1s1ons are not mere corrections and clarifications, but are substantial new requirements/ criteria. Further, some of these new requirements/ criteria are technically unsupported and compliance would require a substantial commitment of industry resources with little, if any, safety benefit. Finally, we maintain that the Staff has failed to perform an acceptable backfitting analysis to support its proposal as required by 10 C.F.R. SS0.109. A. Objections to the Proposed Rule While certain of the proposed revisions may be desirable to some licensees, many of the proposed provisions are objectionable in that they (1) go far beyond the stated lim i ted purposes of the proposal; (2) are not supported by safety concerns; and (3) will result in significant additional costs and occupational exposure associated with meeting the new requirements. (The backfit implications of the provisions are separately addressed below). While many of the provisions are objectionable based on the factors noted above, the adverse impacts of the following four objectionable provisions are dominant: (1) III.A(4) and III.A(6) - elimination of the option of testing at reduced pressure; (2) III.A(7)(b)(i) - acceptance criteria for "as found" leakage; (3) III.A(8)(a) - retesting following failure of "as found" Type A test - and filing of Corrective Action Plan; and (4) III.A(8)(b)(ii) - option to do more frequent Type B & C testing rather than more Type A penalty tests. (It should be noted that the staff in NUREG/ CR- 4398 also stated that these four provisions are likely to create the greatest impact upon industry.) The impacts of these revisions are noted below. The proposed revision to SSIII.A(4) and A(6) would modify current requirements/ criteria by eliminating the option to perform Type A tests at reduced pressures. Approximately one-third of the nation's containments are tested at reduced pressure. NUREG/CR-4398 at 26. Many of these facilities are older plants whose owners are concerned about the costs and possible negative safety impacts of cycling containments during tests at full design-basis pressure. In addition, the change will lengthen considerably the downtime (and the outage costs) associated with Type A tests at these plants. The proposed revision to SIII.A(7)(b)(i) is a new requirement. Licensees are not curren t ly required to determine the "as found" condition for the Type A test. NUREG/ CR- 4398 at

30. This proposed revision appears to be derived from I&E Notice 85 - 71, which the Staff issued to clar i fy (or, arguably, change) its position on the meaning of the current Appendix J.

This revision is likely to result in increased frequency of failure of Type A tests (with the corresponding need for corrective action and/ or increased frequency of Type Band C

Mr. Samuel J. Chilk April 24, 1987 Page 3 testing and associated increase in occupational exposure from local tests).~/ Finally, the proposed revisions to §§III.A(8)(a) and A(8)(b)(ii) will necessitate hardware modifications to support the increased reliance on Type Band C test results as a measure of leak tightness. These changes will tend to result in additional outages due to the increased frequency of Type Band C testing. Further, the preparation of a Corrective Action Plan, which would be subject to Staff review and approval,3/ is a new requirement which will likely result in the significant burden of more frequent servicing and inspection of penetrations (and a corresponding increase in occupational exposure). NUREG/CR- 4398 at 35-37. In sum, these proposed provisions reflect a clear attempt by the Staff to impose new and significant criteria under the guise of "clarifications" to the current regulations contained in Appendix J, contrary to the express scope of the rule. Further, these provisions are not technically supported by public health and safety concerns, yet would impose significant burdens on licensees. These burdens alone are enough to warrant serious reconsideration of the merits of the proposed rule. However, as detailed below, the proposed rule is also legally flawed in that it fails to satisfy the Commission's backfit rule, 10 C.F.R. SS0.109. B. The Proposed Rule Will Require Backfitting of Many Existing Facilities The Staff, in its backfit analysis for the proposed revision to 10 C.F.R. Part 50, Appendix J, states that: The current Appendix J does not support the Staff positions in IN 85- 71 regarding report i ng and "back - correction" of Type Band C test results. Appendix J currently requires re~ortin! of specific results of Type Band C tests only if (l theocal tests were performed "during a type A test" and resulted in failure to complete the test and or failure to meet the acceptance criteria, or (2) the acceptance criteria for Type Band C tests were not met. Appendix J, SSIII.A.1, V.B.3. Similarly, Appendix J only requires correction of Type A test results to reflect Type Band C tests 1n cases where leakage was discovered i n the conduct of the Type A test and caused termination of the test or unacceptable results. App e ndix J, §III.A.1. See also 38 Fed. Reg. 4385 (February 14, 1973)(Statement or-Consideration). 11 The Corrective Act i on Plan is not currently submitted to t he NRC. NUREG/ CR- 4398 at 36.

Mr. Samuel J. Chilk April 24, 1987 Page 4 [t]he proposed rule is intended to be applied to the entire population of nuclear power reactors and it clearly constitutes a backfit. i / As noted above many aspects of the proposed rule are simply editorial changes and clarifications, but others are substantive and will require utilities to perform major backfits in order to comply with the regulations. ~/ For example, the proposed requirement to determine the "as found" leakage rate condition for Type A tests constitutes a new requirement rather than a clarification as the Staff claims. As the Staff has recognized, the determination of the "as found " condition in Type A testing has not previously been required. NUREG/CR-4398 states that: [R]eporting of the "as found" condition for the Type A test does not appear to be presently done. The NRC has been requesting that the utilities supply sufficient data from the Type Band C tests results to derive an "as found" condition for the containment. However, . . . this requirement or request has not been enforced in all NRC regions. The requirement for reporting the "as found" condition for the Type A test will . . . make the reporting of the "as found" mandatory . . . . The utilities will see some negative imSact from this requirement. There wille some increase in time needed for reporting and analysis of the Tfipe Band C testing done in conjunction with t e Tyee A test, so that the "as found" condition of the containment can be determined.6/ (Emphasis added.}

 .!I S50.109 Backfit Analysis for Proposed 10 C.F.R. 50, App. J and Proposed Reg. Guide MS 021-5 (Oct. 16, 1986) at 1.

The Staff represented the proposed rule as being "limited to corrections and clarifications, and [excluding] new criteria." 51 Fed. Reg. 39538, col. 3. This statement did not fully expose the substantive nature of many aspects of the proposed rule.

 §_/ NUREG/CR-4398, Cost Analysis of Revisions to 10 C.F.R. Part 50, Appendix J, Leak Tests for Primary and Secondary Containments of Light-Water - Cooled Nuclear Power Plants (1985) at 30.

Mr. Samuel J. Chilk April 24, 1987 Page 5 In addition, reporting of the "as found" condition for the Type A test requires determination of the minimum pathway leakage characteristics of the containment penetrations and pressurization for each valve. Many plants do not have the necessary equipment, piping and valve configurations to perform these tests. To comply with the new regulations would thus require an extensive and costly backfit. Another significant backfit may arise due to a necessity to test each valve individually. Several aspects of the proposed rule, including the "as found" acceptance criteria for Type B and C tests, the requirement for single active failure analysis to be used for Type Band C testing criteria, the definition of minimum and maximum pathway leakages, and reporting requirements for Type Band C failures, point to a necessity to attain this capability. For many facilities, this will mean the addition of multiple block valves and test connections, as well as vents and

• drains, on lines penetrating containment. The expense of these backfits and the outage work required to comply could be significant.

C. Key Aspects of the Proposed Rule Fail to Satisfy the Backfitting Rule To pass muster under the backfitting rule, the proposed requirement or modification must be shown to provide a "substantial increase in the overall protection of the public health and safety" as well as to be justified in terms of the "direct and indirect costs of implementation . . . . " 10 C.F.R.

 §50.109(a)(3). If, taking all relevant factors into account, there is no substantial increase in protection of the public, then sound regulation dictates that the requirement not be i mposed on licensees.

Unless the proposed revisions to Appendix J meet these standards, the Commission should refrain from making the changes mandatory. It is apparent from examining the record that many of the proposed revisions do not meet these standards. The staff concluded in its backfitt1ng analysis that: [t]here is no substantial increase in the overall protection of the public health and safety or the common defense and security that can presently be quantified from the proposed backfit. l/ ll §50.109 Backfit Analysis for Proposed 10 C.F.R. 50, App. J and Proposed Reg. Guide MS 021 - 5 (Oct. 16, 1986) at 6.

Mr. Samuel J. Chilk April 24, 1987 Page 6 Thus, the Staff concedes that one of the standards is not met by the proposed rule (the conclusion implies that the proposed rule, on the whole, is defic ient). When examined from a risk perspective, the current leakage rate criteria in Appendix J are seen to be very conservative and the proposed revisions to Appendix J are thus not supported by any need to further restrict permissible leakage rate limits. Since the containment is designed to withstand a mitigated design basis accident, there is reasonable assurance that (with few exceptions) normal containment leakage is relatively insignificant. The current Appendix J programs for each plant provide even greater assurance of leak tightness. Current allowable leakage rate are much less than 10 wt. %/day, ranging from approximately 0.1 to 2.6 wt. %/day of the contained air mass.8/ Yet NUREG-1150, the NRC's contemporary study of risk, states:

• A risk-based study . . . using Reactor Safety Study [WASH-1400) data indicated that the contribution to overall reactor risk from containment leaks ut to 10 wt %/day is small.

using risk-based in ormation and new source terms from NUREG-1150, we have reassessed the contribution of small containment leaks to public risk and to expected radiation doses in the vicinity of the plant given a severe accident. Containment leaka e during normal o site r1s 6 o eration reduces a ne I i i le contribution to Emp as1s a Thus, there is an enormous margin between the current allowable leakage rates and those found by the authors of NUREG-1150 to be significant to increasing overall reactor risk. Adjustments to the Appendix J requirements may well not be a worthwhile endeavor when the conservatism of the allowable leakage rates is considered.10/ See NUREG/CR-3549 at 2, where the authors put these values In""perspective by pointing out that a 0.1 wt 3 %/ day leakage ra~e out of a containment volume of 56,634 m (2,000,000 0 ft ) under a pressure of 380 kPa (55 psia) at 339 K (150 F) is equivalent to that represented by a hole with a diameter of approximately 0.152 cm (0.06 in.). NUREG-1150, Reactor Risk Reference Document (1987), at 10-15. 10/ NUREG/CR-4330, Review of Light Water Reactor Regulatory Requirements (1986), states (at 2.39) that leakage rate limits are believed to be conservative, and that a factor of 10 to 100 increase in leak rate may not be risk signif icant.

Mr. Samuel J. Chilk April 24, 1987 Page 7 That the proposed revisions to Appendix J may not be supported can further be seen by examining several pertinent NRC documents. NUREG/CR-3539 concludes that LWR accident risk is relatively insensitive to the containment building leakage rate.11/ Consequently, absent gross containment failures resulting from a - severe accident (which Appendix J was not meant to address and which are addressed by defense-in - depth and other regulatory policies) Appendix J revisions tending to move containment testing programs toward a penetration-by-penetration level of exactitude will not appreciably increase the health and safety of the public. The current Appendix J regulations constitute an adequate containment program when the large margin between current leakage rates and "acceptable" leakage rates is considered. A July 15, 1982 memorandum from the Safety Program Evaluation Branch-Division of Safety Technology reinforces this point.12 / The Memorandum states in the first paragraph: - We find that fine tuning the containment leakage rate can not be justified based on the risk assessment reduction potential of any improvements in leak rate. Nuclear plant risk studies indicate that risk is dominated by core melt events which result in gross failure of the containment . . . The risk from these gross failures overshadows the risk associated with containment leakage for mitigated loss-of-coolant accidents and core damage events which may have a large source term but do not result in a gross containment fa il ure. The Safety Program Evaluation Br anch goes on to recommend that resources which would be used to improve leakage testing methods and requirements could be more efficiently used to perform periodic or continuous gross checks of containment integrity. This is precisely our point. Since the proposed revisions have not been shown to result in a substantial increase in the overall protection, they may not, consistent with the Commission's own regulations in 10 C.F.R. §50.109, be imposed as binding requirements. In examining the costs of the proposed rule, the Staff estimates 11/ NUREG/CR-3539, Impact of Containment Building Leakage on LWR (Light water Reactor) Accident Risk (1984), at 11. g; July 15, 1982 memorandum from Warren Minners, Acting Ch i ef-Safety Program Evaluation Branch- Division of Safety Technology to George w. Knighton, Chief- Research & Standards Coordination, Division of Safety Technology.

Mr. Samuel J. Chilk April 24, 1987 Page 8 that there is a potential for large financial savings due to the avoidance of penalty replacement energy costs (due to fewer unscheduled outages to perform leakage rate testing). The Staff, however, recognizes that it may not be appropriate to factor these savings into its calculations, and assumes that the benefits which would accrue (from technically sound and unambiguous regulations that minimize the need for exemptions) would equal the costs created. These crucial Staff assumptions however, are untested in practice. Without further substantiation, they are entitled to little or no weight and can be viewed as part of a "bootstrapping" effort by the staff to reach a pre-determined conclusion in its backfit analysis -- viz., that the rule can be cost - justified, notwithstanding the absence of "substantial increase" in safety. Significantly, the Staff's opinion that the proposed rule would reduce the number of outages necessary for Type A testing should be discounted since the assumption that the impact of more "as found" test failures can be lessened by increased Type Band C testing is speculative.13/ Type B tests currently may be performed, and Type c testsare required to be performed, every refueling outage, but in no case at intervals greater than every two years. For plants on an 18-month refueling cycle, shutdown would be required in order to perform more-frequent Type Band C tests, and these substantial costs were not fully considered in the staff's cost analysis (NUREG/CR-4398). The real cost of the proposed rule is also apparent when the increase in occupational exposures is examined. The Staff admits that the proposed rule would cause a 10,000 person-rem increase in routine occupational exposure over the operating life of the power reactor population. The more frequent testing of individual containment penetrations requires more time inside containment for test crews, resulting in increased occupational exposures. Ironically, the Staff admits that this additional exposure of employees to radiation is the only significant, quantifiable change to safety, and it is a negative one.14/ Thus, far from producing a substantial increase in the overall protection, the proposed revisions may have a negative overall impact. Such speculation is the sine qua non of the Staff's assertion that the revisTons are essentially supported by the expectation of cost savings due to averted Type A tests. For every averted Type A test assumed as a source of cost-saving, the Staff has assumed the "benefit" of $1.2 to 2.5 million (nominal cost of performing one Type A test). NUREG/CR-4398 at 34.

 !ii   Id. at 6.

Mr. Samuel J. Chilk April 24, 1987 Page 9 As mentioned above, the four specific changes which would have the most significant cost impact are: (1) the revision to Sections III.A(4) and IV.A(6) of Appendix J, eliminating the option to test at reduced pressure; (2) the revision to the Section III.A(7)(b)(i) acceptance criteria for determination of the "as found" leakage rate condition; (3) the revision to Section III.A(8)(a), whereby a Corrective Action Plan must be implemented, following failure of the "as found" leakage rate to satisfy the acceptance criteria; and (4) the revision to Section III.A(8)(b)(ii), whereby licensees would have the option of performing more frequent Type B or Type C testing to correct for unsuccessful Type A leakage tests. The specific impacts of these changes are significant. As noted above, the latter two changes would result in an enormous increase in occupational exposure. Tables 1.3 and 1.4 of NUREG/CR-4398 show that the revision to paragraph III.A(8)(a ) would result in an increase of 1411 to 9220 man-rem, and the revision to paragraph III.A(8)(b)(ii) would cause an increase of 353 to 5408 man-rem. Paragraph III.A(8)(a) would require a large number of licensees to develop and implement Corrective Action Plans to better ensure the integrity of their containment systems. These plans usually require increased surveillance and maintenance of containment penetrations, thus resulting in increased costs and occupational exposure. Paragraph III.A(8)(b)(ii) would give utilities the option to do more frequent local leak rate tests in lieu of more frequent penalty Type A tests if the previous Type A test failures were due to leakage through Type Band C penetrations. This type of local testing involves substantia l ly higher occupational exposures than does the integrated leak rate testing. In addition, the Staff concedes that licensees will have to develop procedures and make equipment modifications in order to comply with the regulations: This action will require changes to the technical specifications, test procedures, data analyses, and test reports. In some cases it may entail modifications of some systems to conform to all aspects of the revised leakage testing program, such as test taps to enable testing of some valve(s) not previously tested.15/ Finally, the major cost created by the revisions disallowing Type A tests at reduced pressure would be financial. Tables 1.3 and 1.4 of NUREG/CR-4398 show that a cost of between $7.9 to $22.8 million would result. This is due to the fact that approximately 40 plants currently testing at reduced pressu r e 15/ Id. at 4.

Mr. Samuel J. Chilk April 24, 1987 Page 10 would need to increase their pressurization and depressurization times, leading to more plant downtime. In shor t , the Staff's conclusion that the proposed revisions are cost justified is not well founded, and falls short of the required analysis and findings mandated by 10 C.F.R. §50.109 for backfits such as this. D. The Current Exemptions Should Remain Intact. Regardless of any revisions which are made to the Appendix J requirements, exemptions to the current Appendix J should not be voided by the new rule unless the new rule would substantially modify the underlying basis for the exemption. Many proposed modifications to Appendix J are not substantive in n a t u r e , ~ , renumbering sections, minor clarifications and general consolidations. In addition, while some clarifications appear substantive, the underlying basis for the new provision is unchanged from the old rule. Many exemptions have been granted to provisions of the old ru l e which in the new proposal contain such non-substantive changes. Where exemptions to such old provisions have been granted, we maintain that it would be an unwarranted expenditure of industry and Staff resources to file and process new exemption requests where the underlying basis of the exemption has not changed. Accordingly, if there is to be a final rule, we suggest that the Statement of Considerations state that licensees need not file new exemption requests in these instances. Rather, licensees need only provide a letter to the Staff noting the exemptions at issue and provide a brief description of why the exemptions should be retained in force. E. The Commission Should Consider Alternatives to the Proposed Rule In view of the significant and unresolved issues regarding the proposal, as noted above, we suggest that the Commission withdraw the proposed rule, i ssue a Generic Letter making the provisions of the proposal voluntary,16/ and merge the issues raised by the proposal with the more comprehensive revision of Appendix J which the Commission is planning to initiate within the next year or two.17/ In this way, the Commission would avoid "piecemeal" rulemaking which would only confuse the issues immediately prior to the larger rulemaking. 16/ Such a voluntary approach has been utilized in the past, including the proposed rule on Appendix K, and GDC-4. 17/ See 51 Fed. Reg. 39539 at 39538, col. 2; see also NUREG/ CR-4ITO, Review of Light water Reactor Regulatory Requirements (1986).

Mr. Samuel J. Chilk April 24, 1987 Page 11 The Commission implicitly recognized elements of this suggestion in its "Invitation to Comment," in asking whether licensees should be given the option to continue to follow the existing version of Appendix J even if the proposed revisions are adopted and whether the existing rule or the proposed revisions should be made voluntary.18/ The Staff has raised no significant safety concern which is driving the proposed revisions at this time. In light of this fact, it would be wise to defer this rulemaking in order to avoid an interim set of regulations which would serve little useful purpose, but would instead create confusion and impose implementation costs in the short period before the comprehensive revisions take place. II. CONCLUSION From the foregoing, we maintain that the proposed rule is significantly flawed in that it contains new requirements/criteria beyond the scope of the proposal which are, in addition, unsupported by valid technical considerations and the requisite backfit analysis (10 C.F.R. §50.109). Accordingly, in view of the more comprehensive revisions of Appendix J scheduled for the near term, we recommend that the Commission withdraw the proposed rule, issue a Generic Letter making the provisions of the proposal voluntary as a means of satisfying Appendix J and merging the issues in the proposal with the upcoming comprehensive revisions of Appendix J. It is also unclear whether any of the substantive changes which would result in an intensified Appendix J program and tend to produce a penetration- by- penetration level of scrutiny can be justified from a risk - reduction perspective. The NRC should stand back and view the proposed changes in the light of contemporary perspectives on severe accidents and safety goal policies. 18/ 51 Fed. Reg. 39538 a t 39539, c ols. 1 - 2.

Mr. Samuel J. Chilk April 24, 1987 Page 12 Given these problems, the Commission should not go forward with the rule as proposed, but rather should consider the alternative course outlined herein. BISHOP, COOK, REYNOLDS Suite 800 1200 Seventeenth Street, N.W. Washington, D.C. 20036

JOCKET NUM8ER iftQPQMD (51 DOCKETED USNRC

                                  *a7 APR 28 Pl2 :45                        -@ED1"soN Docket No . 50-346              {:Ff ,r*r   - ~-                                         D ONALD      C. SHELTON
                                                      - ' 'r                              Vice President-Nuclear fiocit11N > * * ~

I

• I! (419] 249-2399 License No . NPF-3 Serial No . 1349 April 24, 1987 United States Nuclear Regulatory Commission Document Cont rol Desk Washington, D. C. 20555 Gentlemen:

Toledo Edison respectfull y submits the following comments on the proposed revision to Appendix J and the proposed Regulatory Guide MS 021 - 5 . Toledo Edison has reviewed draft Regulatory Guide MS 021 - 5 and has no comments which are not more properly addressed in the review of Appendix J. Specific comments on Appendix J are included as Attachment 1 to this submittal. Responses to the questions pub l ished in the Federal Register (lOFR 39538) are included as Attachment 2. Additionally, Toledo Edison has reviewed the recommendations to the proposed revision of Appendix J submitted by the B&W Owner ' s Group Technical Specific-a t i on Subcommittee and fully endorse those recommendations . cc: DB-1 NRC Resident I nspector A. B. Davis, Acting Regional Administrator (2 copies) THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652

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Docket No. 50-346 License No. NPF-3 Serial No. 1349 Attachment 1 Page 1 TOLEDO EDISON COMMENTS ON PROPOSED APPENDIX J Section 1 Introduction Footnote 111 Specific guidance concerning acceptable leakage test method, procedures and analyses that may be used to imp - lement these requirements and criteria will be provided in a regulatory guide that is being issued in draft form for public comment with the designation MS 021-5. Copies of the regulatory guide may be obtained from the Nuclear Regulatory Commission, Document Management Branch, Washington , D. C. 20555." Toledo Edison Comment The footnote should be deleted. Reason Test methods, procedures and analyses are described in Section V of the proposed Appendix J. Specific guidanc e concerning these test methods and analyses at present a re contained in the Technical Specifications. Thus, the f ootnote is redundant. Section II Definitions

1. Containment Isolation System Functional Test "A test to verify the proper performance of the isolation system by normal operation of the valves .

For automatic containment isolation systems, a tes t of the automatic isolation system performed by actuation of the containment isolation signals." Toledo Edison Comment This definition should be deleted. Reason Containment Isolation System functional test does no t relate to Appendix J.

Docket No. 50-346 License No. NPF-3 Serial No. 1349 Attachment 1 Page 2

2. 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."

Toledo Edison Comment The following should be added to the definition of the containment isolation valve: Exemptions to GDC will be indicated in the plant Safety Analysis Report *

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

Toledo Edison Comment This paragraph should be revised as follows:

                    "The maximum leakage rate that can be attributed to a penetration leakage path (e.g., the larger, not total leakage of two valves in a series, or if the valves are installed in series and tested in parallel, the larger leakage of the two valves and if the valves are installed parallel, the total leakage). This generally assumes a single active failure of the better of two leakage barriers in a series or parallel when performing Type B or C tests."

Reason Valves tested in parallel are not defined. This could result in a leakage savings as analyzed in Section III.C.(3)(a) if repair or adjustment has been made on only one valve.

Docket No. 50-346 License No. NPF-3 Serial No. 1349 Attachment 1 Page 3

4. 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). * ** under these test conditions."

Toledo Edison Comment The definition should be revised as follows:

                    "The minimum leakage rate that can be attributed to a penetration leakage path (e.g., the smaller leakage of two val ves in series, or for valves installed in series and tested in parallel, the as found minimum pathway leak rate for the valve not repaired can be deter-mined after repairs are completed on the other valve)."

Reason Valves tested in parallel are not defined. This could result in a leakage savings as analyzed in Section I II .A.(7)(c)(iii).

5. Type C Test "A pneumatic test to measure containment isolation valve leakage rates."

• Toledo Edison Comment "as described in the Technical Specifications" should be added in continuation of the definition, Reason See reason for Item II-1.

Docket No. 50-346 License No. NPF-3 Serial No. 1349 Pa ge 4 Section III General Leak Test Requirements A.(b)(3) Test Frequency "Unless a longer interval is specifical ly approved by the NRC staff, the interval between the pre-operational and first periodic Type A tests must not exceed three years and the i nterval between subsequent periodic Type A tests must not exceed four yeirs *** " Toledo Edison Comment The revised test frequency (Periodic Type A tests must not exceed four years) will require Technical Specifications changes since the existing Technical Specifications identify the frequency of 40 months+/- 10 months. Deletion of Type A tests during a 10-year plant in-service inspection will also require Technical Specification changes, however, it will eliminate the scheduling problems associated with a 10-year ISI. A.(b)(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 ac containment design pressure *** " Toledo Edison Comment The word "maximum" should be added before "containment design pressure *** " Reason The Davis-Besse Appendix J test pressure (38.0 psig) was established using the peak pressure of 36.95 psig pl us maxi-mum containment pressure of 1 psig at the beginning of the accident. B.( 1) Frequency (a) "Type B tests, except tests for air locks must be per f ormed on containment penetrations during shutdown for refuel i ng or at other convenient intervals but in no case at intervals greater then 2 years. If opened *** contain-ment integrity."

Docket No. 50-346 License No. NPF-3 Serial No. 1349 Attachment 1 Page 5 Toledo Edison Comment The first sentence should be revised as follows:

                 "Type B tests, except tests for air locks shall be performed prior to initial criticality and periodically thereafter during shutdown periods or normal plant operations, but in no case shall any individual test be conducted at intervals greater than two years. If the two-year interval ends while primary containment integrity is not required, the test interval may be extended provided all deferred testing is successfully completed before containment integrity is required in the plant."

Reason Regulatory Guide MS 021-5 and Appendix J have conflicting statements in reference to the frequency of Type B test. B. (3) (b) (ii)

                 "Whenever maintenance other than on door seals *** , if that maintenance involved the pressure retaining boundary."

Toledo Edison Comment Revise this section as follows:

                 "Whenever maintenance other than on door seals *** , if that maintenance affected the leakage rate of the pressure retaining boundary."

Reason Maintenance not affecting the leakage rate should not require a leakage test. C.(4)(a) A containment isolation valve need not be Type C tested .** a single active failure of a system component. Toledo Edison Comment Add the following in continuation of this paragraph. (e.g., PWR secondary side systems valves.)

Docket No. 50-346 License No. NPF-3 Serial No. 1349 Attachment 1 Page 6 Reason PWR secondary side systems do not fail considering single active failure due to the closed loop inside containment. Pipe rupture is considered passive failure

• Docket No. 50-346 License No. NPF-3 Serial No. 1349 Attachment 2 Page 1 RESPONSE TO QUESTIONS IN FEDERAL REGISTER Question 1: The extent to which these positions in the proposed rule are already in use ..

Answer 1: Per our comments on the proposed Appendix J (Attachment 1), if all of these comments are incorporated, the existing program at Davis-Besse may meet the intent of the proposed rule, however, a more detailed evaluation of the new rule must still be performed. Question 2: The extent to which those (positions) in use and those not in use but proposed are desirable. Answer 2: Revision to Appendix J, to clarify and simplify the text is desirable. Revising the requirements of a rule, which has not been shown to be ineffective, for the purpose of updating, is not desirable. Question 3: Whether there continues to be a further need for this regulation. Answer 3: Toledo Edison believes that 10CFR50, Appendix J, is still needed, but it should contain program requirements and acceptance criteria for a "Containment Leak Rate Testing Program". This will allow each licensee to develop their own plant-specific program and will eliminate the submittal of exemptions to the Appendix J .

• Question 4:

Answer 4: Estimates of the costs and benefits of this proposed revision as a whole and of its separate provisions. Costs to Toledo Edison from this revision include a) Eng-ineering and Licensing time and manpower for detailed review and analysis b) potential increased testing time and manpower, c) procedure revision time and manpower, and d) a Technical Specification Amendment. There is no observable gain from this revision. Question 5: Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule (reflecting consideration of public comments) becomes effective. Answer 5: Yes. Until there is an agreement between the NRC and the licensees either to develop a new program as recommended in our answer to Question No. 3 or exemption(s) (if required) are granted by the NRC to the proposed rule.

Docket No. 50-346 License No. NPF-3 Serial No. 1349 Attachment 2 Page 2 Question 6: If the existing rule or its proposed revision were completely voluntary, how many licensees would adopt either version in its entirety and why? Answer 6: Toledo Edison would continue to use the existing program which is in compliance with current Appendix J. The new revision does not provide any increase in safety. Question 7: Whether a) all or part of the proposed Appendix J revisions would constitute a "backfit" under the definition of that term in the Commission's Backfit Rule, and b) there are parts of the rule which do not constitute backfits, but which would aid the staff, licensees or both. Answer 7: This proposed revision clearly falls under the definition of backfit contained in 50.109(a)(l). Clarification of wording or other changes which will not cause licensees to revise their procedures or Technical Specifications do not constitute a "backfit". Question 8: Since the NRC is planning a broader, more comprehensive review of containment functional and testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation. Answer 8: No. It is not worthwhile to go forward with this proposed revision as an interim updating of the existing regulation since one to two years would not provide adequate time to the

• Question 9:

licensees to revise their program, submit exemptions or the Technical Specification changes (if any) to the NRC and get approval. The advisibility of referencing the testing standard (ANSI/ ANS 56.8) in the regulatory guide (MS 021-5) instead of in the text of Appendix J. Answer 9: Toledo Edison believes that neither the Regulatory Guide nor the testing standard should be referenced in Appendix J. Appendix J should contain program requirements and acceptance criteria. The Regulatory Guide can reference the standard.

Docke t No. 50-346 License No. NPF-3 Serial No. 1349 Attachment 2 Page 3 Question 10: The value of collecting data from the "as-found" condit ion of valves and seals and the need for acceptance criteria for this condition. Answer 10: As-found data is a valuable tool for the utilities, however, it should not be regulated, Question 11: Whether the Technical Specification limits on allowable containment leakage should be relaxed and if so, to wha t extend and why, or if not, why not? Answer 11: The current approach to leakage calculations is very conservative and should be relaxed. Type A testing should be performed with valves in the normal lineup. The effect of leak-before-break should also be considered and incorporated into the new requirements. Question 12: What risk-important factors influence containment performance under severe accident conditions? To what degree these factors are considered in the current containment testing requirements, and what approaches should be considered in addressing factors not presently covered? Answer 12: Toledo Edison is unaware of additional risk factors which have not been considered in defining the containment testing requirements. Question 13: What other approaches to validating containment integri t y could be used that might provide detection of leakage paths as soon as they occur, whether they would result in any adjustments to the Appendix J test program and why? Answer 13: No response is provided at the present time due to the lack of investigation of other types of leakage testing . Question 14: What effect "leak-before-break" assumption could have on the leakage rate test program. Current accident assumptions use instantaneous complete breaks in piping systems, resulting in a test program based on pneumatic testing of vented, drained lines. "Leak-before-break" assumptions presume that pipes will fail more gradually , leaking rather than instantly emptying. Answer 14: The use of "leak-before-break" assumptions will result in the termination of accidents before maximum containment pressure is reached. Since containment would not be sub-jected to as a high design pressure, the existing testing requirements could be reduced.

Docket No. 50-346 License No. NPF-3 Serial No. 1349 Attachment 2 Page 4 Question 15: How to effectively adjust Type A test results to reflect individual Type Band C test results obtained from inspections, repairs, adjustments, or replacements of penetrations and valves in the years in between Type A tests. Answer 15: Type A tests and Type Band C tests are based on different test criteria and should not be correlated,

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             '-10A1M[A$T Ulfll'T tf.5 SE~IC( C()trlP,.NY frliOAT"( ,t,ST "11.JCl.(AA (t.ERG'r COMPANY P.O. BOX 270         USNRC HARTFORD, CONNECTICUT 06141-0270 (203) 665-5000 "87 APR 28 P12 :37 April 24, 1987 Docket Nos. 50-213 50-245 50-336 50-423 Bl 2420 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3 Proposed Revision to 10 CFR 50, Appendix J Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants Proposed Rule (51 FR 39538) On October 29, 1986, the Nuclear Regulatory Commission (NRC) published for public comment in the Federal Register (51 FR 39538) a major revision of its regulations in Title 10, Code of Federal Regulations, Part 50, Appendix J (10 CFR 50, Appendix J). The intent of the proposed revision and associated regulatory guide (Task MS 021-5) is to clarify questions of interpretation in regard to leakage rate testing of containments of light-water-cooled nuclear power plants. The proposed rule is intended to aid the NRC licensing and enforcement staff by eliminating conflicts, ambiguities, and lack of uniformity in the regulation of the in-service inspection program. As licensees of the Haddam Neck Plant and the Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3, respectively, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company {NNECO) hereby submit our comments in response to the Federal Register notice (51 FR 39538). CYAPCO and NNECO believe that the proposed revision to 10 CFR 50, Appendix J should not be promulgated as a final rule as stipulated in 10 CFR 50.109. The Commission's own backfit analysis did not conclude that a substantial increase in the overall protection of the public health and safety or the common defense and security *would be derived from the backfit. We believe that there is a need for stability and control in the regulatory process. The backfit rule establishes a two-part test that must be met before the Commission can impose new requirements. First, there must be a substantial increase in the overall protection of the public health and safety or the common defense and security and, second, the direct and indirect costs of implementation must be justified in view of the increased protection. It is not sufficient to MAYO 6 1987 Acknowledged by card . ..............,..,... *-

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U.S. Nuclear Regulatory Commission B12420/Page 2 April 24, 1987 assert that only one of these two is met by a proposed rule. We believe it is inappropriate for the Commission to be considering modification or suspension of the backfit rule when the threshold criteria of that rule are not met, and we urge the Commission reconsider its position. More information pertaining to the applicability of 10 CFR 50.109 to the proposed rule is included in Attachment No. 1. Although we believe that the proposed rule should not be promulgated in the first instance in accordance with 10 CFR 50.109, two alternatives do exist. First, Appendix J could be revised to give licensees the option of complying with either the existing Appendix J requirements or the proposed ones (i.e., the proposed requirements are voluntary). Another option would be to defer the promulgation of these proposed changes until the subsequent, more comprehensive revisions to Appendix J. Notwithstanding the above comments, our general comments on the proposed revision are included in Attachment No. 2. Additional comments related to specific sections of the proposed rule are included in Attachment No. 3. Attachment No. 4 lists our responses to 15 supplemental questions found under the heading "Invitation to Comment" (51 FR 39539). Comments on the associated Regulatory Guide issued in draft form with the designation Task MS 021-5 are found in Attachment No. 5. We trust that the Staff finds the attached information useful. Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY

• E. J. Mroczka Senior Vice President By: C. F. Sears Vice President cc: J. M. Allan, Acting Region I Administrator J. J. Shea, NRC Project Manager, Millstone Unit No. 1 D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 R. L. Ferguson, NRC Project Manager, Millstone Unit No. 3 F. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant T. Rebelowski, Resident Inspector, Millstone Unit Nos. 1 and 2 J. T. Shedlosky, Resident Inspector, Millstone Unit No. 3 P. D. Swetland, Resident Inspector, Haddam Neck Plant

 \-

• ATTACHMENT 1 COMMENTS ON THE APPLICABILITY OF THE BACKFIT RULE TO THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J

Attachment 1 B 12420/Page 1 COMMENTS ON THE APPLICABILITY OF THE BACKFIT RULE TO THE PROPOSED REVISION OF 10 CFR .50, APPENDIX J CYAPCO and NNECO believe that the Commission should not promulgate the revision to 10 CFR 50, Appendix J as a final rule, because the Commission's backfit analysis did not conclude that there is a substantial increase in the overall protection of the public health and safety or the common defense and security to be derived from the backfit. We believe that there is a need for stability and control in the regulatory process *

• The backfit rule was promulgated after extensive deliberation by Commission, which included a significant amount of interaction with utilities, industry groups, and other interested parties. We believe it is inappropriate for the Commission to be considering modification or suspension of the backfit rule the when the threshold criteria of that rule are not met, and we urge the Commission reconsider its position.

The backfit rule establishes a two-part test that must be met before the Commission can impose new requirements. First, there must be a substantial increase in the overall protection of the public health and safety or the common defense and security and, second, the direct and indirect costs of implementation must be justified in view of the increased protection. It is not sufficient to assert that only one of these two is met by a proposed rule. The Commission's analysis concluded that "* ** the direct and indirect costs of implementation are justified due to better, more uniform tests and test reports, greater confidence in the reliability of the test results, fewer exemption requests, and fewer interpretive debates." Although this conclusion may be debatable, the Commission's backfit analysis also concluded that the first of these two tests (the substantial increase criterion) had not been met. The Commission explicitly included the substantial increase criterion in 10 CFR 50.109 because it did not believe that safety improvements should be

Attachment 1 B 12420/Page 2 required as backfits if those improvements resulted in insignificant or small benefits to the public health and safety. Since one part of the two-part backfit test was not met, the Appendix J revision should not be promulgated. Since the substantial increase criterion was not met, a discussion of the cost-benefit criterion is superfluous with respect to conclusions on the appropriateness of promulgating the Appendix J revisions. However, the Commission may wish to consider the following comments on that criterion. CYAPCO and NNECO believe that the cost-benefit criterion would also not be satisfied when applied specifically to older facilities rather than to a generic facility. We also do not concur with the NRC Staff's assertion in the Background section of the proposed rule that the scope of the proposed revision "* *

• is limited to corrections and clarifications, and excludes new criteria." The NRC Staff itself noted that the "* ** option of performing periodic reduced pressure testing in lieu of testing at full calculated accident pressure has been dropped."

In addition, the new definitions of maximum and minimum pathway leakage imply the need for extensive backfitting at older plants in order to measure the leakage at every isolation valve. In summary, although we concur that the proposed revision of Appendix J does come a long way in eliminating ambiguity and simplifying text, the proposed rule change should not be promulgated. The purpose of the backfit rule was to prevent unjustified changes in regulatory requirements. The NRC Staff's analysis concluded that the 10 CFR 50, Appendix J revision is an unjusti fied change in that it will not provide a substantial increase in the overall protection of the public health and safety. Furthermore, there is no compelling reason why the Appendix J revisions deserve special treatment under the backfit rule and, therefore,-the revised 10 CFR 50, Appendix J should not be promulgated.

le ATTACHMENT 2

GENERAL COMMENT

S ON THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J

Attachment 2 B12420/Page 1

GENERAL COMMENT

S ON THE PROPOSED REVISION OF 10 CFR .50, APPENDIX J

1. The proposed revision of Appendix J does come a long way in eliminating ambiguity and in simplification of text. The most encouraging improvement is Section VII.A entitled, "Applicability." This section specifically states that technically justifiable alternatives to Appendix J will be considered by the NRC *

• 2. The emphasis of Appendix J appears to have been changed. Originally, it was interpreted as a means of assuring that containments were leak tight prior to resumption of operations (following refueling). It provided the basis for a test program aimed at identifying and repairing containment leakage paths. It also accounted for anticipated .. deterioration in containment leakage barriers by making test acceptance criteria .75 La (for Type A} and .6 La (for Types B and C tests) *
• The proposed version of Appendix J appears now to be attempting to provide assurance that leakage never exceeded La during a completed operating cycle.

3. The proposed Appendix J, ANSI/ANS-.56.8, and the draft regulatory guide on containment Type A, B, and C testing impose measures which require specific precision and error analysis. Adjusting very accurate Type A test

Attachment 2 B 12420/Page 2 measurements with LLRT test results of lesser required accuracy, poses several technical problems: a) the combination of leakage results do not follow established significant figure rules for addition, and, b) the local leak rate error analysis uses a simple root-mean-square technique versus the Student t-distribution method for ILRT calculations. The validity of simply adding the results and associated errors together is questionable.

4. CYAPCO and NNECO take the position that present operating plants should be given the opportunity to continue to meet the current Appendix J provisions or previously approved alternative leak test r~quirements if the proposed rule becomes effective

• ATTACHMENT 3 SPECIFIC COMMENTS ON THE PROPOSED REVISION OF 10 CFR .50, APPENDIX J

Attachment 3 B 12420/Page 1 SPECIFIC COMMENTS ON THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J Appendix J Section Comments II. Definitions The application of Maximum Pathway Leakage Rate, as defined, results in the reporting of leakage rates that are 1) higher than reasonably expected, and

2) not representative of containment performance.

This approach generally assumes the active failure of one valve in each penetration, or over 50 individual failures in the typical containment system. Furthermore, barriers which are passive, including closed valves that are not subject to spurious action, should not be viewed as components subject to active failure. While this approach is effective in improving the performance of some individual barriers, it does not give credit for the redundancy that exists. A more realistic basis and failure criterion are needed. As noted in the "Major Changes" section of the proposed revision, the option of performing reduced pressure testing in lieu of testing at full calculated accident pressure has been dropped from the definition of a "Type A Test". CYAPCO conducts such tests, as do a number of other operating nuclear power reactors. A review of CYAPCO ILRT test results over the last 20 years indicates that consistent leakage measurements have been achieved. It is recommended that the reduced pressure test option be retained.

Attachment 3 Bl 2420/Page 2 SPECIFIC COMMENTS ON THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J Appendix J Section Comments II. Definitions (con't.) The definition of a "Type A Test" requires DBA-LOCA system alignments, but does not address operation of plant shutdown cooling systems, e.g., residual heat removal, which are necessary to maintain plants in a safe condition. The definition should be revised to clarify that system alignm ents should be representative of DBA-LOCA align ments unless needed for operational safety. Specifying Type "B" tests as pneumatic, im pacts plants that by design, utilize alternative methods and test fluid mediums. It is recommended that the definition be revised to allow testing to be conducted using other methods of e quivalent sensitivity *

• Specifying Type "C" tests as pneumatic inconsistent with Section III.C.(2) of the proposed revision of Appendix J.

using other test mediums. That section allows testing It is recommended that is the definition be revised to allow testing to be conducted using other methods of equivalent sensitivity.

Attachment 3 B12420/Page 3 SPECIFIC COMMENTS ON THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J Appendix J Section Comments III. General Test Requirements 111.A.(4} Conducting Type "A" tests "* ** at or greater than Pac* **", does not address existing plant technical

• specifications or Appendix J exemptions allowing for reduced pressure ILRTs.

seven reduced twenty years. pressure CYAPCO has conducted tests over the past A review of CYAPCO reduced pressure testing concluded: (a} testing at this reduced pressure provides adequate assurance of containment integrity, and (b) test results are valid and consistent. It is recommended that the reduced pressure test option be retained. If reduced pressure testing ls eliminated, the requirement that Pt must not exceed containment design pressure at the start of the test may not be possible for those plants in which Pac equals P design, e.g., the Haddam Neck Plant or Millstone Unit No. 2. Normally, the test pressure is equal to Pt plus the

       .,                   measurement      uncertainty of the ILR T precision pressure measuring system to ensure that the requirements of the test are met. For some plants, this would make the test pressure greater than

Attachment 3

• B 12420/Page 4 SPECIFIC COMMENTS ON THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J

 . Appendix J Section                                Comments Ill. General Test          Pac= Pd*    It is recommended that some amount of Requirements (con't.) tolerance around Pt be allowed.

III.A(5) It is recommended that the "Pretest Requirements" section be revised to account for plant shutdown

• operations realignments.

and refueling mode system The requirement that CIVs undergo valve

                               "* ** no preliminary exercising or adjustments for the purpose of improving performance ***" is confusing terminology,     especially    for    those     Type "C" penetrations that require draining and venting prior to an LLR T. After draining and v~nting operations, it is necessary to open and         close containment isolation valves (CIV) to ensure CIV closure " *** by normal operation ***".

It is recommended that CIV closure verification operations be added to this section. III.A.(7)(a),(b) The requirement of " a properly justified statistical analysis ***" is too vague and would be subject to a wide range of interpretations. CYAPCO and NNECO recommend referencing the draft NUREG and its associated ANS 56.8-1981 statistical analysis as methods to satisfy this requirement.

Attachment 3 B 12420/Page 5 SPECIFIC COMMENTS ON THE PROPOSED REVISION OF 10 CFR .50, APPENDIX J

    \-_______________________________

Appendix J Section Comments III. General Test Requirements {con't.) III.A.(7)(d) No known or acceptable "analytical" techniques exist today to adjust Type "A" test results due to effects of valve stem leakage or packing adjustments, e.g., X number of turns on a packing nut equates to Y decrease in valve total leakage. It is possible, however, to perform LLR T tests on valves exhibiting evidence of stem leakage or after packing adjustments, and to use these test results to adjust the Type "A" tests. It is recommended that this requirement be reworded to reflect these facts. III.A.(8)(b)(i) We concur with the approach outlined in this section which allows the Type A retest schedule to be reviewed and approved by the NRC Staff. A Corrective Action Plan (CAP) focuses plant maintenance, modification, and testing resources on those penetrations and valves performing poorly. Enhanced rework and retesting efforts can reduce leakage significantly, and it is appropriate to consider these efforts when determining the necessity of repeated Type A testing.

Attachment 3 Bl 2420/Page 6 SPECIFIC COMMENTS ON THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J Appendix J Section Comments III. General Test Requirements (con't.) III.C(2)(a) The requirement that Type "C" pressurization test medium be air or nitrogen will impact those plants which have penetrations that can only be tested by

• other methods.

It is recommended that the requirement be revised to allow testing by methods of equivalent sensitivity. III.C(3)(b)(ii) It appears to be overly conservative to require a demonstration of sealing function for 30 days at 1.1 Pa when accident analyses show plant pressures will return to normal in a much shorter period of time. It is recommended that this requirement be revised to reflect more realistic accident conditions *

• III.C(4)(b) This paragraph should be clarified to exclude from Type C testing those valves for which alternative leak test requirements have previously been approved by the NRC Staff.

V.A. CY APCO and NNECO recommend that test procedures and methods be referenced or described in a utility ILRT /LLRT program report and not in technical specifications.

ATTACHMENT 4

• RESPONSE TO SPECIFIC QUESTIONS RAISED ON THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J

Attachment 4

  . Bl 2420/Page 1 RESPONSE TO SPECIFIC QUESTIONS RAISED ON THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J
 \*

Question No. CYAPCO AND NNECO RESPONSE

1. Our nuclear plants use most of the approaches to containment testing presented in the proposed revision of Appendix J. Some exceptions are:

• 0 Reduced pressure Type A testing with extrapolation is still used at the Haddam Neck Plant.

data o Current Type B and C test programs do not include an error analysis.

2. Our plants comply with the present version of Appendix J to the maximum extent possible. In areas where verbatim compliance is not possible, we have requested exemptions based on alternative means of assuring containment integrity.

Alternatives to Appendix J are generally limited to our two older plants (both pre-date Appendix J). These plants have been evaluated for containment integrity by the NRC in the SEP and ISAP programs. For these reasons, we believe its plants are utilizing every measure presently available to assure containment integrity. With these thoughts in mind, it is not desirable to contemplate major changes in Appendix J.

3. There is a continuing need for Appendix J as a means of assuring a uniform approach to demonstrating containment integrity.

Attachment 4 B12420/Page 2 RESPONSE TO SPECIFIC QUESTIONS RAISED ON THE PROPOSED REVISION OF 10 CFR .50, APPENDIX J Question No. CYAPCO AND NNECO RESPONSE

4. Cost impacts are difficult to estimate without specific designs in mind. Individual penetration modifications, to add test vents and drains, could cost as little as $50,000/penetration. Modifications to accomplish water seal testing in BWR emergency core cooling penetrations could cost millions of dollars (with questionable benefits in terms of safety). Both types of modifications would likely result in a substantial increase in occupational radiation exposure.

Improvements in Types B and C testing are probably more cost effective than those made to enhance Type A testing. However, mid-cycle shutdowns to accomplish additional Type B or C tests are not cost effective and would result in a considerable increase in occupational radiation exposure. Enhanced penetration maintenance based on test results, with improvements substantiated by test results, would be more productive than increased testing *

     .5.       Older plants have exemptions to the existing version of Appendix J. Compliance to the       current Appendix J    with
               ~ontinuance of existing exemptions and final exemption requests should be permitted in lieu of across the board enforcement of the proposed Appendix J.

6. Although we comply with the current version of Appendix J to the maximum extent possible, we would probably not voluntarily adopt either version of Appendix J in its entirety at this point.

Attachment 4

• B 12420/Page 3 RESPONSE TO SPECIFIC QUESTIONS RAISED ON THE PROPOSED REVISION OF 10 CFR .50, APPENDIX J Question No. CYAPCO AND NNECO RESPONSE In our older plants, exemptions and modifications were necessary to comply with the existing version of Appendix J. It is difficult for older plants to adopt either version of Appendix J in its entirety and, therefore, we would not anticipate making major changes to our current leakage testing programs, even if the existing rule or its proposed revision were completely voluntary.

7. We believe that some of the proposed Appendix J revisions do constitute a "backfit." For example, the new definitions of maximum and minimum pathway leakage (as opposed to those in I&E Information Notice 8.5-71) imply the ne.e d for extensive backfitting at older plants. This backfitting would be required to measure the leakage of every isolation valve. It would entail the addition of many test connections and main line valves utilized as test boundaries. In addition, individual valve leakage testing would increase occupational radiation exposure. A more detailed discussion of the applicability of the 10 CFR .50.109 to the proposed revisions is contained in Attachment No. 1.

8. If the NRC is planning further revisions to Appendix J in the near future, it is probably not worthwhile to go forward with this proposed revision as an interim updating of the existing

          ,,       regulation. This position is reinforced by the NRC Staff's finding that this proposed revision does not provide a substantial increase in the overall protection of the public health and safety.

Attachment 4 B12420/Page 4 RESPONSE TO SPECIFIC QUESTIONS RAISED ON THE PROPOSED REVISION OF 10 CFR .50, APPENDIX J \-- - - - - - - - - - - - - - - Question No. CY APCO AND NNECO RESPONSE

9. The purpose of Appendix J should be to define general containment system leakage test requirements. As such, we believe it is appropriate to reference the testing standard

{ANSI/ANS 56.8 - 1981) in the regulatory guide {MS 021-5) instead of in the text of Appendix J.

10. Collection and interpretation of "as-found" data as a basis for determining containment test acceptability raises questions that are frequently difficult to answer. If "as-found" results exceed acceptance criteria, it is necessary to (1) explain how this situation occurred, (2) explain how long this condition existed, and (3} explain any impacts on public health and safety. It is generally difficult to precisely answer the first two of these questions. It is understandable that the NRC wants to establish that containment integrity has been maintained throughout completed plant operating cycles. However, collection of "as-tound" data does not identify or quantify leakage when it occurs between tests. It provides only historical documentation of the containment condition.

11. Safety technical specification limits on containment should be relaxed as follows:

o Relax La to refl~ct recently gained knowledge of source terms.

• Attachment 4 B 12420/Page 5 RESPONSE TO SPECIFIC QUESTIONS RAISED ON THE PROPOSED REVISION OF 10 CFR 50, APPENDIX J

 ,-,-  Question No.                        CYAPCO AND NNECO RESPONSE 0     Individual penetration leakage limits (e.g., 5% La) should be deleted. Maintaining total Types B and C leakage less than .6 La is sufficient *

• 0 Listings of containment isolation valves could be deleted from technical specifications. A reference to a complete tabulation of all containment isolation valves in the FSAR could be added to technical specifications to replace the deleted listing.

12. Performance of containment penetrations cou~d be affected by pressure, temperature, humidity, radiation,

• and other post-accident environmental factors. Appendix J can only measure leakage and valve actuation at ambient conditions (and test pressure in the case of leakage testing). It is not practical to try
• 13.

to duplicate other containment post-accident conditions during Appendix J testing. Continuous containment leakage monitoring systems may help assure that operational leakage is limited. However, the sensitivity of such monitoring must first be determined. Also, continuous monitoring could not replace Types B and C testing. Other methods, such as ultrasonic flow noise signature analysis downstream of a closed CIV or infrared thermography of closed CIVs may be used to detect bypass leakage through valves. However, practical cost-benefit considerations would prohibit the use of such methods at this time.

Attachment 4 B 12420/Page 6 RESPONSE TO SPECIFIC QUESTIONS RAISED ON THE PROPOSED REVISION OF 10 CFR .50, APPENDIX J Question No. CY APCO AND NNECO RESPONSE

14. "Leak-before-break" criteria may result in less Appendix J testing, as indicated by the question.

15

• If it is necessary to adjust Type A results between Type A tests,
• it should be done as prescribed in Option C of Question No. 15 (i.e., differences between "as-found" and "as-left" results are added or subtracted from the previous Type A leakage) *
• ATTACHMENT 5 RESPONSE TO PROPOSED REGULATORY GUIDE (TASK MS 021-5)

Attachment 5 B12420/Page 1 RESPONSE TO PROPOSED REGULATORY GUIDE MS 021-5 MS-021-5 Section Comments

6. Verification Test Items (5) and (6) should not be added, as the Items (5) and (6) period between the Type A test and the verification test is needed to prepare for the verification test. In addition, RCS adjustments may be done during this time period *

• 11. Calibration Items 11.1 and 11.3 Instrumentation for B and C tests, particularly items such as stop watches or thermometers, may remain in calibration for greater than six months. Some flexibility should be allowed.

CYAPCO and NNECO recommend deletion of 11.3 because a calibration check (as opposed to a calibration) is sufficient to routinely assure instrumentation accuracy.

13. Data Recording and The period of valid data collection should be Analysis, Item 13.1 determined by careful engineering evaluation, justifying the non-inclusion of any data. The proposed use of a declared restart to determine valid data does not permit reconsideration of the test conditions, and should be deleted.

14. Temperature Measure- Psychrometric readings should not be required, ment Item 14.3 as variations of humidity over time and varied plant conditions would result in initial surveys being non-representative.

Attachment 5 B 12420/Page 2 RESPONSE TO PROPOSED REGULATORY GUIDE MS 021-.5 MS-021-5 Section Comments

15. Absolute Test Method The proposal of redefining containment air temperature (Ti) is not recommended or needed.

The current method of weighting sensor readings should be retained. The new "Ti" attempts to correct for spatial oscillations of containment dry bulb temperatures, a phenomena which has never been observed in over 12 ILRTs conducted by CYAPCO and NNECO. CY APCO and NNECO recommend the following methodology be utilized to ensure achievement of valid and consistent "Ti" and ILRT test results: (a) Determine R TD and dewcell sensor locations utilizing methods outlined in EPRI Report NP-2726, Appendix M. Verify sensor volume weight fractions are less than or equal to 10%. (b) Model RTD and dewcell sensor temperature responses over an expected containment temperature range such that the ANS 56.8 RTD accuracy requirement of + 0.5°F is met.

Attachment 5 Bl2420/Page 3 RESPONSE TO PROPOSED REGULATORY GUIDE MS 021-.5 MS-021-5 Section Comments

15. Absolute Test Method (c) Locate RTD and dewcell sensors within (con't.)

                                 .5 ft. of theoretical center of imaginary sensor sub-volumes. Do not place near heat sinks or sources.

(d) Calculate single failure RTD and dewcell

• sensor volume fractions, and ensure revised sensor fractions meet ANS .56.8 requirement of less than or equal to 10%.

(e) Control average containment air temperature change during ILRT Ltm measurement period . to less than 0.35°F/hr. This will ensure non-linear temperature effects (thermal masking of real leakage rate} are

• minimized and a linear regression analysis of mass point versus time would yield valid values for Ltm*

Containment air temperature control can be achieved by following guidance contained in EPRI Report NP-2726, Appendices G and T. CY APCO utilized these techniques during the 1986 ILRT and achieved excellent results.

Attachment 5 B 12420/Page 4 RESPONSE TO PROPOSED REGULA TORY GUIDE MS 021-.5

  \-       MS-021-5 Section                      Comments Extended ANSI Method  The   proposed changes are not required or (Condition 1 and 2) necessary.      The   extended   ANSI   method attempts to verify: (a) that Ltm is represented by a linear mass point versus time plot, and (b) that mass point data scatter is minimized.

Both of these considerations are reflected in the calculated confidence limit, and the use of the UCL is sufficient to prevent significant variation in either case. Use of measurement equipment that meets ANS 56.8 requirements and tight control of temperature as previously mentioned, eliminates these problems and the need for these requirements

• oornuto

                                                                                                             '..,: Jf 'C
                                                                                                  *a7    APR 28 A9 :25 AMERICAN NUCLEAR SOCIETY STANDARDS COMMITTEE                                                 OFFt              -

OOCKf:. ~*w t rl f c ~rRVtr.f April 24, 1987  :.H. JCH '. Headquarters: Reply to: Ted M. Brown

55

0.onh Kensington Avenue LaGrange Park, 111inois 60525 USA Wiss, Janney , Elstner Assoc ., Inc .

Telephone 312/352-66 11 330 Pfingsten Road Telccopy 31 2/352-0499 Telex 254635 Northbrook, IL 60062 (312) 272- 7400 Nuclear Regulatory Commission Attention: Docketing and Service Branch Room 1121 1717 H Street NW Washington D.C. Gentlemen:

• The ANS 56.8 working group appreciates and supports your effort to improve and clarify the existing Appendix J. The following specific comments apply to the proposed Appendix J .

II. Definition: Containment Isolation System Functional Test is separate from the type A test and should not be defined in Appendix J. II. Definition: Suggest using the definition contained in ANS 56 .8-8 7 for containment isolation valve. II. Definition: The definitions of maximum and minimum pathway leakages should provide for simultaneous testing of the isolati on valves. II . Definit ion: Correct the format of Verification Test *

• III. A(l)(a): Should be changed to read "to the extent practical ,

type Band type C tests ". III. A(3): Test frequency should be omitted from Appendix J and incorporated in the regulatory guide . III . A(4): Add statement "If the design pressure is less than Pac, the test pressure shall be reviewed by NRC staff" . III. A(7)(c): Provide guidanc e for the case where as found leakage is found during the type A test and cannot be quantified. III. A(8)(b): Increased test frequency does not in itself improve the performance of the containment. This requirement could result in an owner electi ng to perform the type A test on a 24 month basis instead of replacing a troublesome component. Acknowle<fgecr by card. -

  ,t- *     .Jl
         *'OC 0

ostmtr ... p, dd'I

III. B(l)[Instead of lower case i] and(3): Move test frequency requirements into the regulatory guide. III. B( 3) ( b) (ii): Suggest inserting "or testable penetrations" after the words "door seals" and before "has". III. B(4): Suggest that B and C as found criteria should not exceed La using minimum pathway leakage and as left less and .6 La using maximum pathway leakage. Also, should C test be discussed in this item. III. C: The comments on III B regarding test frequency and as found as left limits apply here also *

• III. C(2)(a): What is the definition of a qualified water seal system. Is the definition of III C(3)(b)(ii) sufficient to define the seal system.

The following general comments pertain to the draft regulatory guide MS 021-5. 0 The regulatory guide should reference ANSI/ANS 56.8-1987. 0 Required test interval should be identified in the regulatory guide. 0 ANSI 56.8 contains requirements for conducting a type A test in 8 hours including twenty data sets at approximately equal intervals. The consensus of the working group is that the ANS 56.8 criteria is sufficiently conservative. It is recognized by accepting a 95 percent upper confidence limit that there may be 5 percent of the reported results above the reported upper limit. And if the 95 percent UCL is equivalent to 0.75 La then we also accept the fact that 5 percent of the tests may statistically exceed the 0.75 La criteria. The additional conditions required by the regulatory guide appear to be complicated, not practically defined and unnecessary. The working group members have reviewed about fifty ILRT's utilizing the additional conditions from the Appendix of the Draft Regulatory Guide. The assumed basis of these conditions is to further evaluate the test data quality and provide a mathematical minimum to that quality. The fifty ILRT's do not demonstrate the adequacy or consistency of these additional conditions in actual test situations. Certainly a larger sample of ILRT's is needed in verifying any additional conditions.

In a paper entitled "Methods for Determining Integrated Leakage Rate Test Duration - Case Studies" Larry Young examines 16 test results. Of the 16 tests one (Case 3) satisfied the 56.8 criteria but did not satisfy the other criteria contained in this paper, Case 3 only marginally exceeded the test criteria (0.078 vs 0.075) as the test continued for more than 24 hours. The working group feels the additional criteria is not required, however, we also feel that if the NRC insists on additional criteria there are better approaches than that contained in the Appendix to this Draft Regulatory Guide. Very truly yours,

• TMB/jh cc: Marilyn Weber

                              /4/111~

Ted M. Brown Chairman, 56.8 Working Committee

DOCKETED USNf C COMBUSTION~ ENGINEERING 0 87 APR 27 P3 :16 April 24, 1987 LD-87-022 U.S. Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, D. C. 20555

Dear Sir:

Comments on Proposed 10CFR50, Appendix J, Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants (51FR39538, October 29, 1986) On October 29, 1986 the NRC published in the Federal Register a proposed revision to the requirements for leakage rate testing of containments for light-water-cooled nuclear power plants as set forth in Appendix J to 10CFR50. Combustion Engineering has reviewed the proposed rule and appreciates the opportunity to provide comments. Combustion Engineering's comments on this proposed rule will be limited to the aspect of the proposal with which we have had greatest involvement. As such, only specific comments on the proposal's implications to the plant's technical specifications will be provided. The Commission has recognized in the Supplementary Information section of the proposed rule the existence of the Technical Specification Improvement Project. This program and the Commission's recently issued Interim Policy Statement on Technical Specification Improvements (52FR3788), we believe, support the complete removal of any reference to the plant's technical specifications from the proposed rule. The Interim Policy Statement defines a set of selection criteria to be used in determining the appropriate set of technical specifications. The Appendix J proposed rule, which specifies that certain items be included in a plant's technical specifications, essentially undermines the Interim Policy Statement by not allowing the selection criteria to set the appropriate set of technical specifications. It is, therefore, suggested that, before the proposed rule is issued, all references to technical specifications be removed. For your information, sections which refer to technical specifications in the proposed rule are listed in the Enclosure to this letter. Power Systems 1000 Prospect Hill Road (203) 688-1911 Combustion Engineering, Inc. Post Office Box 500 Telex: 99297 Windsor, Connecticut 06095-0500

har' itople dd' I "9c; I

U. S. Nuclear Regulatory Commission LD-87-022 April 24, 1987 Page 2 Should you have any questions concerning these comments, please feel free to contact me or Mr. J.B. Kingseed of my staff at (203) 285-5213. Very truly yours, COMBUSTION ENGINEERING, INC.

                                ~t ~cbr~

Director

                                                               ~ /f$S Nuclear Licensing

• AES:ss Enclosure

Enclosure to LD-87-022 Sections of Proposed Rule Which Reference Technical Specifications I. Introduction Subpart (a) II. Definitions La (weight percent/24hr.) Pac (psig) Preoperational Leak Test

• III. General Leak Test Requirements B(l)(b)

B(2) B ( 3 )(b) (i) - three places B(4)(d) C(3)(b)(i) IV. Special Leak Test Requirements B V. Test Methods, Procedures, and Analyses A VII. Application A B - two places

                                                    ,JOCKET
                                                                        .P7J.

(51 Fl .JC/~ 5't} DuKE PowER GoMPANY OOCKETEO P.O. BOX 33189 USHRC CHARLOTTE, N,C, 28242 TELEPHONE HAL B. TUGKER VIOE PRESIDENT NUCLEAR PRODUCTION

                                                                          *a1 APR 27 P<3~,              7 3-4331 April 23, 1987 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION:          Docketing and Service Branch

Subject:

10CFR Part 50 - Proposed Rule Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants and Related Draft Regulatory Guide Duke Power Company Comments Gentlemen: The NRC published for comment in the Federal Register, SlFR 39538, Octo-ber 29, 1986 the proposed rule, 10CFRSO, Appendix J. Also, notice of a draft related regulatory guide was also published. This letter contains Duke Power Company comments on both of these initiatives. Detailed comments emphasizing the effect of these items, from a utility's perspective, are provided as an attach-ment. In our consideration of the proposed rule and the draft regulatory guide we participated in industry efforts associated with these items, namely the Atomic Industrial Forum's Subcommittee on Operations and Maintenance and the B&W Owners Group. These two groups' comments were submitted to the NRC in letters dated April 8, 1987 and January 23, 1987 respectively. Duke Power Company supports and endorses each of these groups' comments. In general, Duke Power feels there is a definite need to update the current 10CFRSO, Appendix J regulations and finds the October 29, 1986 proposal ac-ceptable. However, we do not feel that the additional requirements of the draft regulatory guide are warranted and should be deleted prior to final issuance of these two documents. Please see our detailed comments on the draft regulatory guide contained in the attachment. Duke Power appreciates the opportunity to comment on these items. Very truly yours, Hal B. Tucker JSW/114/jgm

                                                                                    - MAYO 6 1987 Acknowledged by cartf. * ::. Aw * *'* ****, I * - -

JO A 0

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 ~ ~      .~J ,~

ATTACHMENT TO H.B. TUCKER LETTER DATED APRIL 23, 1987 Review of 10CFRSO Appendix J Proposed Rule Changes Major Changes Affecting Current Test Practices 1.) Type A Test Pressure at Pa - does not allow for a reduced pressure test ILRT. IMPACT: Increases critical path time for all units that perform reduced pressure test. (Both pump up and blow down time is increased). 2.) Type A Test Duration - Type A test duration has been dropped from the test criteria in Appendix J. The existing Appendix J requires the licensee to conduct the test in accordance with ANSI 45.4-1972 which specifies a 24 hour test duration. Proposed rule change refers to a regulatory guide, which references ANSI-56.8-1981 and is deemed acceptable by the NRC staff. ANSI 56.8-1981 allows for a shorter duration test based on the ISG criteria. IMPACT: Most of the critical path time lost by performing full pressure (Pa) test as described in item (1) can be recovered by shorter duration test described in ANSI 56.8-1981. 3.) Type A test "as found" condition - Type A test "as is" as originally described in III.A.l(a), that the containment was to be " *** tested in as close to the 'as is' condition as practical" has been reemphasized and clarified by explicit requirements that have been added to measure, record and report "as found" and as left leakage rates. The minimum pathway leakage method for adjusting Type A test results for all changes in leakage rates from isolation repair or adjustment of leakage barriers subject to Type B or Type C testing is explicitly emphasized. As Found Acceptance Criteria less than or equal to 1.00 La As Left Acceptance Criteria less than or equal to 0.75 La IMPACT: The NRC is currently requiring all stations to perform as found leakage rate calculations. The proposed rule change clearly emphasizes the requirement for performing as found leakage rate calculation. The As Found Acceptance Criteria has been increased to 1.0 La from 0.75 La. The increase in the as found requirement will benefit all stations. 4.) Type A Retest Requirements - If two consecutive periodic as found Type A tests exceed the as found acceptance criterion of 1.0 La, a Type A test must be performed at least every 24 months unless an alternative leakage test program acceptable to the NRC staff is performed. The licensee may submit a Corrective Action Plan and an alternative leakage test program proposal to the NRC staff for approval. IMPACT: This proposed rule change provides provisions for increased local leak rate testing on the affected penetrations in lieu of an increased Type A leakage test frequency. Revision applies the adjustment of test frequency directly to identified problem areas. The proposed Appendix J provides an alternative to Type A penalty tests by allowing Type B or C penalty tests and the submittal of a Corrective Action Plan. S.) Test Frequency - (a) Type A - Interval between preop and 1st periodic Type A test must not exceed 3 years (affects Unit 1 and 2 at CNS) and the interval between subsequent Type A tests must not exceed 4 years. IMPACT: Type A test no longer coupled with 10 year inservice inspection period. Test frequency decreased slightly from approximately 3 times/10 yr. period to 3 times/12 year period. Overall effect will be small. (b) Type Band C - Must be performed during shutdown for refueling or at

• other convenient intervals but in no case at intervals exceeding 2 years.

IMPACT: The existing Appendix J states that all Type C tests must be performed at each refueling, but in no case at intervals exceeding 2 years. Proposed rule change will allow for testing of penetrations during forced outages other than refueling to be included in the 2 year test cycle. 6.) Air Locks (a) Proposed rule change states that opening the air lock for the purpose of removing air lock test equipment does not require further testing of the air lock. (b) Additionally, if there has been no air lock opening within 6 months of the last successful test at Pa, the 6-Month interval may be extended up to the next refueling not to exceed 2 years. (c) The current Appendix J requires that air locks opened during periods when containment integrity is not required by the plants technical specifications be retested at the end of such periods at a test pressure= Pa. The proposed revision gives greater flexibility in that it allows testing of the seals instead of testing the entire air lock at Pa. (MNS and CNS currently have exceptions to this requirement in Tech. Specs.) IMPACT: When performing manual seal LRT at MNS and CNS, the aux. bldg. door must be opened following the completion of the LRT to remove test equipment, resulting in the need to reperform the LRT every 3 days. The proposed change eliminates the need to retest following the air lock door opening for test equipment removal purposes. Item (b) will have little effect on stations, since it is unlikely that air locks will remain closed for extended per-iods. Item (c) will have little effect on MNS and CNS since these stations currently have exceptions to the existing rule in Technical Specifications. 0NS currently performs full hatch leak test following periods when containment integrity is not required in accordance with Tech. Specs. Change will allow seal leak test to be performed in lieu of full hatch leak test. 7.) Type Band C Leak Rate Test Acceptance Criteria Proposed change states that "the sum of the as found or as left Type B and C test results must not exceed 0.60 La using maximum pathway leakage and including leakage rate readings from continuous leakage monitoring systems." IMPACT: The requirement for determining the "as found" or "as left" values for Type Band C testing will result in additional testing. All penetrations which are repaired, modified, replaced or adjusted must be tested twice, once before the change to determine the "as found" and once after to determine the "as left". All three Duke Nuclear stations currently do not report the "as found" values for Type Band C leakage summations. This requirement will be difficult to meet since several penetra-tions during each test cycle are unable to be pressurized to full test pressure. Using the maximum leakage criteria, one must assume that the leakage is greater than 0.6 La, thereby resulting in the failure to meet the "as found" acceptance criteria. 8.) General Comments For the most part, the proposed rule changes will prove beneficial to all the Duke nuclear stations with the exception of the following:

• The requirement for performing a full pressure ILRT at Pa will increase the pump up time and depressurization time for those units currently performing a reduced pressure ILRT. Some of this critical path time will be recovered by performing the shorter duration test as referenced in ANSI 56.8-1981, therefore its overall effect is not significant.

The other area of major concern is the requirement for reporting the "as found" Type B & C leakage summation using the maximum leakage criteria. Meeting the 0.60 La "as found" requirement will be difficult to meet, since invariably, at least one penetration will not be able to be pres-surized to test pressure during each test cycle. 10CFR50, Appendix J, Section IV.A. states, in part, "Any modification, repair, or replacement of a component subject to Type B or Type C testing must also be preceded by a Type B or Type C test." For example, the above noted provision, as stated, does not appear to allow an "emergency" repair on a valve which has broken or otherwise is known to be leaking during a time when containment integrity is required. Some provision or statement should be added to allow an emergency repair without having to perform an "as-found" Type B or C test. Another area requiring further investigation and clarification is the "as found" Type A leakage determination. In Section VB of the revised rule, it clearly specifies how Type A, B, and C tests are to be treated when performed in conjunction with each other. The licensee is required to perform "as found" tests on all Type Band C penetrations performed in conjunction with the ILRT refueling outage for determination of the "as found" Type A adjustment. However, no reference is made to determination of "as found" Type A test adjustment for Type Band C tests performed in the years between ILRT tests. The proposed Appendix J revisions will require technical specification changes at all Duke nuclear stations, since the current technical spec-ifications dealing with Type A, B, and C leak rate testing are based on the existing Appendix J. References to ANSI N45.4-1972 will also need to be deleted from all station technical specifications. However, it is our general feeling that 10CFRSO, Appendix J should be implemented by program or plan - not by technical specifications. At most, inclusion of the new requirements into a station's technical specifications should be limited to La and Pa within the Design Features section. This position would also be consistent with past practice such as Appendix B for QA, Appendix R for Fire Protection, Security plans, and Emergency Planning. Also, the new Appendix J does not appear to meet the criteria for inclusion in technical specifications developed by the Technical Specification Improvement Program effort. The allowable containment leakage rate is determined on a plant-specific basis to meet the dose criteria in 10CFRlOO, assuming a hypothetical major accident. In practice, a value lower than that required to meet the 10CFRlOO values is written into the plant's technical specifications. Allowable leakage rates are 0.2% per day for Catawba, 0.25% per day for Oconee, and 0.3% per day for McGuire. Probabilistic risk assessments, beginning with the Reactor Safety Study, WASH-1400 (NRC 1975), have consistently shown that containment leakage is a relatively minor contributor to overall plant risk. The dominant containment-related contributions to risk stem from accidents in which the containment ruptures (due to steam explosions, overpressure, hydrogen combustion, etc.) or the containment isolation function fails or is bypassed (e.g., an interfacing systems LOCA with resulting direct release outside containment). In these dominant scenarios, containment leakage plays no significant role. While the risk contribution due to containment leakage may be small, the cost impact of containment leakage rate testing is substantial. The primary reason for this is that integrated leak rate tests (ILRTs) or the entire containment (called Type A tests in Appendix J) are generally on the reactor outage critical path. These tests typically cause three to five days of incremental plant downtime at an estimated cost of $1.3 to

 $2.6 million. If this downtime could be reduced by modifying the exist-ing regulatory requirements without compromising public health and safety, the cost savings would be substantial.

The NRC has initiated a program to review current light water reactor regulatory requirements to see if some could be replaced or eliminated to reduce regulatory burdens without compromising public health and safety (Federal Register, October 3, 1984). Pacific Northwest Laboratory (PNL) is conducting a series of studies in support of this NRC program. NUREG/CR-4330 covers a portion of PNL's work. This report presents information on the risks, costs and benefits of streamlining regulatory requirements such as reactor containment leakage rates. The option under consideration in the analysis was to increase the allowable leakage rate for a PWR. to 10% per day. Sensitivity studies to show the effect of varying this numerical value are included in the report. NUREG/CR-4330 concluded that judiciously streamlining the existing regulatory requirements is estimated to have marginal effect on public health and safety. If the effects of increasing the allowable leakage rate are expressed on a dollars per person-rem basis, the ratio is on the order of several thousand dollars saved per person-rem of public expo-sure. For a complete study of risk impact, benefits, and benefit-risk comparisons on increasing the allowable containment leakage rate to 10% per day, refer to NUREG/CR-4330

• DRAFT REG GUIDE MS-O21-5 COMMENTS CONTAINMENT SYSTEM LEAKAGE TESTING Position 5 - The test frequency in ANSI/ANS-56.8-1981 is in direct conflict with the proposed Appendix J revision. These types of problems should be corrected prior to approval of either document. Test frequency change will require a tech spec change.

Position 6 - This position requires the verification test to be coupled to the Type A test without allowing a period of time to set up the verification. This is unreasonable and should be reconsidered by NRC. Position 7 - There is no justification to continue recording data from a sensor that has undoubtedly failed. However, this position requires this to be done. Position 11 - In-situ calibrations of instrumentation should not be required. The only requirement should be to verify there is no installa-tion error. This can be done by attaching dummy loads to the data acquisition system to verify there is no error introduced in the system. This can be done in-situ with no impact of test duration. Position 13 - Position 13.l says that after a start time is selected it is not subject to change. Then the next sentence tells how the time may be changed. This paragraph is contradictory and should be changed. The start time should be subject to change in any direction and any rule to the contrary without further

• justification is unreasonable
• Two statistical tests of the airmass vs. time data are intro-duced in the proposed regulatory guide MS-O21-5. The first test is intended to set an upper limit on curvature of the data, and the second an upper limit on the scatter of the data.

These tests are presented as equations 1.1, 1.2, and 2.1 in the proposed regulatory guide. To facilitate evaluation condition ratios al, a2, and b were derived from the above equations using: left hand side of equation 1.1 al=------------------------------- right hand side of equation 1.1 left hand side of equation 1.2 a2 = ------------------------------- right hand side of equation 1.2 left hand side of equation 2.1 b = ------------------------------- right hand side of equation 2.1 The acceptance criteria for the statistical tests in terms of al, a2, and bare:

1. al and/or a2 less than 1

2. b greater than 1 These ratios were then generated and plotted for each data reading of three actual Type A tests using an inhouse generated Lotus 123 macro routine. The resulting plots (attached) show the pass-fail condition of these previous tests through the 24 hours in which they were conducted.

Upon examination of these plots one notes that equations 1.1 and 1.2 yield erratic results with little or no trending. Equation 2.1 on the other hand trends toward passing in a reasonably smooth fashion after an initial setting period. In all three cases equation 2.1 yielded a unique passing point. In addition it should be noted that the sharp upturn in the al and a2 plots on the McGuire Unit 2 graph, starting at about 19 hours into the test, is probably due to the leak rate reduction that occurs during the transition from maximum pathway leakage to minimum pathway leakage (see attached McGuire Unit 2 ILRT Data). This upturn suggests that a test may have to be extended significantly simply to accommodate this otherwise acceptable transition. Based on the erratic behavior of ratios al, and a2 and the effects that the transition between maximum and minimum pathway leakage has on al, and a2 the proposed limit on curvature is an unreasonable condition to place on the Type A test. The same criteria when applied to the verification tests corresponding to the Type A tests above yields failing results in every case. The indica-

• tion is that if the criteria is applied to the verification tests as well as the Type A tests as paragraph 13.3 of section C in the proposed regulatory guide states, the verification tests will have to be conducted for approximately the same length of time as the Type A tests. For this reason the new extended ANSI criteria should be relaxed or eliminated from the verification tests requirements.

                               ~   GUIRE NUCLEAR STATION - UNIT * .
                               -     INTEGRATED LEAK RATE TEST MAY 20-26, 1986 NORMALIZED MASS VS. TIME 1.0010-------------------------------------,

1.0008 1.0006

1. 0004 rn rn

  <(

1.0002

E I

'l°D w 1.0000 N H _J

      .999B
  <(

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([ 0 z 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TIME (HOURS) 5 /25/ 86 2: 1: 31 TO 5 /26/86 2: 11: 57

McGuire Nuclear Station, Unit 2 ILRT - May 20-26, 1986 2 -----..--.-.- . - . ~ ~ ~ ~ - - ~ - -- - - - - - - - - - - - - - . - - - - - - - - - - - . 1.9 1.8 1.7 1.6 1.5

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                 '            I                                         \ \

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McGuire Nuclear Station, Unit 1 ILRT- August 14-17, 1986 2 1.9 1.8 1.7 1.6

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Catawba Nuclear Station, Unit 1 .

                                                               *                              ~

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• 24 Time (hours)

PAGE 1 OF 2 STATUS OF RULEMAKING RECORD 1 OF 1 PROPOSED RULE: PR-050 RULE NAME: LEAKAGE RATE TESTING OF CONTAINMENTS OF LIGHT WATE R COOLED NUCLEAR POWER PLANTS (GENERAL REVISION OF APPENDIX J) PROPOSED RULE FED REG CITE: 51FR39538 PROPOSED RULE PUBLICATION DATE: 10/29/86 NUMBER OF COMMENTS: 45 ORIGINAL DATE FOR COMMENTS: 01/26/87 EXTENSION DATE: 04/24/87 FINAL RULE FED. REG. CITE: FINAL RULE PUBLICATION DATE: I I NOTES ON: FILE LOCATED ON Pl. TATUS. OF RULE PRESS PAGE DOWN OR ENTER TO SEE RULE HISTORY OR STAFF CONTACT PRESS ESC TO SEE ADDITIONAL RULES, (E) TO EDIT OR (S) TO STOP DISPLAY PAGE 2 OF 2 HISTORY OF THE RULE PART AFFECTED: PR-050 RULE TITLE: LEAKAGE RATE TESTING OF CONTAINMENTS OF LIGHT WATE R COOLED NUCLEAR POWER PLANTS (GENERAL REVISION OF APPENDIX J) PROPOSED RULE PROPOSED RULE DATE PROPOSED RULE SECY PAPER: 86-167 SRM DATE: 09/18/86 SIGNED BY SECRETARY: 10/22/86 FINAL RULE FINAL RULE DATE FINAL RULE SECY PAPER: 91-348 SRM DATE: I I SIGNED BY SECRETARY: I I STAFF CONTACTS ON THE RULE CONTACTl: E. GUNTER ARNDT MAIL STOP: NL-007 PHONE: 443-7893 CONTACT2: MAIL STOP: PHONE: PRESS PAGEUP TO SEE STATUS OF RULEMAKING PRESS ESC TO SEE ADDITIONAL RULES, (E) TO EDIT OR (S) TO STOP DISPLAY

DOCKET NO. PR-050 (51FR39538) In the Matter of LEAKAGE RATE TESTING OF CONTAINMENTS OF LIGHT WATE R COOLED NUCLEAR POWER PLANTS (GENERAL REVISION OF APPENDIX J) DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT - 10/23/86 10/21/86 FEDERAL REGISTER NOTICE - PROPOSED RULE 11/20/86 11/20/86 COMMENT OF AMERICAN NUCLEAR INSURERS (RONALD SANACORE) ( 1) 12/10/86 12/04/86 LTR NORTHEAST UTILITIES (MROCZKA) REQUESTING EXTENSION OF TIME TO FILE COMMENTS 01/13/87 01/06/87 LTR BWR OWNERS' GROUP (PICKENS) REQUESTING COMMENT PERIOD EXT ENS ION 01/13/87 01/06/87 COMMENT OF LYNNE GOODMAN ( 2) 01/13/87 01/09/87 COMMENT OF BECHTEL POWER CORPORATION (R.P. SCHMITZ) ( 3) 01/20/87 01/16/87 FEDERAL REGISTER NOTICE - PROPOSED RULE; EXTENSION OF COMMENT PERIOD 01/20/87 01/16/87 EXTENSION OF COMMENT PERIOOD FOR PROPOSED RULE TO APRIL 24, 1987. 01/27/87 01/23/87 COMMENT OF FLORIDA POWER CORPORATION (E.C. SIMPSON) ( 4) 01/27/87 01/15/87 COMMENT OF COMMONWEALTH EDISON (DENNIS L. FARRAR) ( 5) 01/27/87 01/14/87 COMMENT OF CONSEJO DE SEGURIDAD NUCLEAR (FERNANDO ROBLEDO) ( 6) 01/29/87 01/24/87 COMMENT OF OHIO CITIZENS FOR RESPONSIBLE ENERGY (SUSAN L. HIATT) ( 7) 01/29/87 01/23/87 COMMENT OF BOSTON EDISON (JAMES M. LYDON) ( 8) 02/02/87 01/23/87 COMMENT OF TJE B&W OWNERS GROUP (R.L. GILL, JR.) ( 9) 02/04/87 01/24/87 COMMENT OF MARVIN I. LEWIS ( 10) 02/09/87 02/09/87 NOTE TO RECIPIENTS - NOTING THAT COMMENT #10 WAS DUPLICATE OF COMMENT #7. #10 WILL BE USED AGAIN

DOCKET NO. PR-050 (51FR39538) DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 02/09/87 01/29/87 COMMENT OF MAINE YANKEE ATOMIC POWER COMPANY (G.D. WHITTIER) ( 11) 02/11/87 02/06/87 COMMENT OF NEW YORK POWER AUTHORITY (JOHN C. BRONS) ( 12) 02/13/87 02/12/87 LTR NRC (ARNDT) TO CAROLYN COMER TRANSMITTING INFORMATION REQUESTED IN LTR OF 2/6/87 02/17/87 02/10/87 COMMENT OF STONE &WEBSTER ENGINEERING CORPORATION (R.B. BRADBURY) ( 13) - 03/11/87 01/26/87 COMMENT OF ROCHESTER GAS & ELECTRIC CORPORATION (ROGER W. KOBER) ( 14) 03/23/87 03/20/87 COMMENT OF SOUTH CAROLINA ELECTRIC & GAS CO. (D. A. NAUMAN) ( 15) 03/27/87 03/23/87 COMMENT OF PHILADEPHIA ELECTRIC CO. (J.W. GALLAGHER) ( 16) 03/30/87 03/25/87 COMMENT OF WOLF CREEK NUCLEAR OPERATING CORPORATION (BART D. WITHERS) ( 17) 04/10/87 04/08/87 COMMENT OF ATOMIC INDUSTRIAL FORUM, INC. (J. W. WILLIAMS, JR.) ( 18) 04/23/87 04/22/87 COMMENT OF PENNSYLVANIA POWER & LIGHT COMPANY (HAROLD W. KEISER) ( 19) 04/24/87 04/22/87 COMMENT OF BALTIMORE GAS AND ELECTRIC (JOSEPH A. TIERNAN) ( 20) 04/24/87 04/22/87 COMMENT OF BWR OWNERS' GROUP (T.A. PICKENS) ( 21) 04/27/87 04/23/87 COMMENT OF YANKEE ATOMIC ELECTRIC COMPANY (D.W. EDWARDS) ( 22) 04/27/87 04/24/87 COMMENT OF ALABAMA POWER COMPANY (R.P. MCDONALD) ( 23) 04/27/87 04/22/87 COMMENT OF GEORGIA POWER COMPANY (L.T. GUCWA) ( 24) 04/27/87 04/24/87 COMMENT OF SYSTEM ENERGY RESOURCES, INC. (OLIVER D. KINGSLEY, JR.) ( 25) 04/27/87 04/22/87 COMMENT OF FLORIDA POWER & LIGHT COMPANY (C.O. WOODY) ( 26) 04/27/87 04/24/87 COMMENT OF TU ELECTRIC (WILLIAMS. COUNSIL) ( 27) 04/27/87 04/24/87 COMMENT OF WISCONSIN PUBLIC SERVICE CORP. (D.C. HINTZ) ( 28)

DOCKET NO. PR-050 {51FR39538) DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 04/27/87 04/23/87 COMMENT OF DUKE POWER COMPANY {HAL B. TUCKER) ( 29) 04/27/87 04/24/87 COMMENT OF COMBUSTION ENGINEERING (A.E. SCHERER) 30) 04/28/87 04/24/87 COMMENT OF AMERICAN NUCLEAR SOCIETY STANDARDS COMM. {TED M. BROWN) { 31) 04/28/87 04/24/87 COMMENT OF NORTHEAST UTILITIES {E.J. MROCZKA) ( 32) 04/28/87 04/24/87 COMMENT OF TOLEDO EDISON COMPANY (D.C. SHELTON) ( 33) - 04/28/87 04/24/87 COMMENT OF AP&L AND 7 OTHER LICENSEES {NICHOLAS S. REYNOLDS) ( 34) 04/29/87 04/24/87 COMMENT OF NEBRASKA PUBLIC POWER DISTRICT {G.A. TREVORS) ( 35) 04/29/87 04/24/87 COMMENT OF NUBARG {NICHOLAS S. REYNOLDS) ( 36) 04/29/87 04/23/87 COMMENT OF WISCONSIN ELECTRIC POWER COMPANY {C.W. FAY) { 37) 05/01/87 04/24/87 LTR BISHOP, COOK, PURCELL & REYNOLDS (REYNOLDS) TO NRC (CHILK) CORRECTING FOOTNOTE ON COMMENT #34 PREVIOUSLY SUBMITTED 05/08/87 04/24/87 COMMENT OF WASHINGTON PUBLIC POWER SUPPLY SYSTEM - {G.C. SORENSEN) ( 38) 05/08/87 04/24/87 COMMENT OF DUQUESNE LIGHT (J.D. SIEBER) ( 39) 05/08/87 04/30/87 COMMENT OF GPU NUCLEAR (J. R. THORPE) ( 40) 05/12/87 05/06/87 COMMENT OF TENNESSEE VALLEY AUTHORITY {R. L. GRIDLEY) ( 41) 05/12/87 04/30/87 COMMENT OF INTERNATIONAL ATOMIC ENERGY AGENCY {JAMES K. JOOSTEN) ( 42) 05/12/87 04/20/87 COMMENT OF TESTSING, ENGINEERING & RESEARCH, {TERRENCY E. RENTON) ( 43) 05/13/87 05/04/87 COMMENT OF LONG ISLAND LIGHTING COMPANY (J. D. LEONARD, JR.) ( 44) 08/25/89 08/21/89 COMMENT OF BWR OWNERS' GROUP (STEPHEN FLOYD, CHAIRMAN) ( 45)

OOCKET NUMBER PR F2) ~

                                                            . -:J           ~-       t:J') NRC-87-63 A\ {.51 F£ ~qs-aJ;, TELEX51 1012698WPSCGRB 4

WPSC(414)433-1234 TELECOPIER (414) 433-1297

• EASYLINK 62891993

                                                -                                                      DOCKETED WISCONSIN PUBLIC SERVICE CORPORATION                                  USMRC 600 North Adams* P.O. Box 19002

• Green Bay, WI 54307-9002

                                                                                                 -S7 APR 27 P3 :13 OFFICE o~* ' l, DOCKETING & S

• t *ir:r- ..

BRANCH April 24, 1987 U.S. Nuclear Regulatory Commission

• ATTN: Docketing and Service Branch Washington, D.C. 20555 Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Comments on Proposed 10 CFR 50, Appendix J Wisconsin Public Service Corporation takes this opportunity to provide comments on the proposed revision to 10 CFR 50 Appendix J - Leakage Tests for Containments of Light-Water-Cooled Nuclear Power Plants. Our comments address the 15 questions that the Commission published along with the proposed rule in FR/Vol. 51, No. 209/10-29-86, page 39538, which were the questions the Commission especially requested interested persons to comment on. Attachment 1 to this letter provides these comments. In general WPSC supports the concepts proposed for the rev1s1on to Appendix J, e.g., the "Corrective Action Plan, the significant. clarification of terms, and the new as-found criterion for Type A tests. Also, the Commission is moving in the right direction by removing some engineering specifics from the rule, and including them in a regulatory guide. WPSC encourages this and suggests the rule be revised to completely remove engineering type test specifics and simply state the need for a program consistent with published NRC guidance. WPSC is concerned that the Commission not adopt an interim rule on leakage testing. If subsequent revision is indeed planned the Commission should postpone rulemaking until it can be assured such rulemaking is final. An interim rule would be unnecessarily burdensome on both the licensee and the Commission. Also in the invitation for comment on the proposed Appendix J, Commissioner Bernthal requested comments as to: "Whether the Corrmission should continue its attempts to apply the Backfit Rule to all rulemaking, or whether the Backfit Rule should be revoked as it applies to rulemaking activity~ se. 11 WPSC feels wholeheartedly that the Backfit Rule is in everyone's best interest and should continue to be applied to all rulemaking. MAY O6 1987

                                                                          ~ledged by card,. w;,, el-, Mi iii I I Ii lit

r., n "O 1DStrnark r ., r, r II Copits R Add'I *r r ,.. 0 Spacial 0 r.

Docketing and Service Branch Apri 1 24, 1987 Page 2 Commissioner Bernthal points out that, 11 * *

• the Commission has been forced to sidestep a strict reading of the cost-benefit requirements and the " ... substantial increase in overall protection **. " threshold of the Backfit Rule, when it nevertheless finds broad agreement that a rulemaking is in the public interest."

To this WPSC offers that a substantial cost savings to a Utility, and therefore to the public, is within the intent of the Backfit Rule even if no substantial increase in safety is evident. i.e., As long as safety is not decreased, rule changes that save money are acceptable within the Backfit Rule. Changes that cost money without increasing safety are not in the best interest of industry or the public and, as given by the Backfit Rule, should not be required. Sincerely,

 ~ a .1;kJA

• D. C. Hintz Vice President - Nuclear Power GWH/jms Attach.

cc - Mr. Robert Nelson, US NRC US NRC, Region III

N218.2 Attachment 1 Letter from D. C. Hintz to US NRC, Docketing and Service Branch April 24, 1987 Corrments on Proposed 10 CFR 50, Appendix J

Docketing and Service Branch 2GWH3.1 April 24, 1987 Page 1 Conments on Proposed Appendix J

1) The extent to which these positions in the proposed rule are already in use.

In the proposed rule the type A test definition has been revised to indicate that "the containment system overall integrated leakage rate will be measured under conditions representing design basis LOCA con-tainment pressure and system alignment." The specific reference to "design basis LOCA conditions" has been assumed in the past for Type A

• testing; however, mentioning it in the rule is helpful and should be applied to Type B&C testing as well. In proposed Section III.C.4 "Valves that need not be Type C tested", it states "A containment isola-tion 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 accident, considering a single active failure of a system component." That accident should be specified as a loss of coolant accident.

There are several terms that have been added to the definitions section that WPS has used in the past. a) "As Found" Leakage Rate b) "As Left" Leakage Rate c) Containment Integrated Leak Rate Test d) Containment Isolation System Functional Test e) Containment System f) Leak

Docketing and Service Branch Apri 1 24, 1987 Page 2 g) Leakage h) Maximum Pathway Leakage i) Minimum Pathway Leakage j) Periodic Leak Test k) Pre-operational Leak Test

1) Structural Integrity Test It is helpful to have these terms defined.

• The proposed rule indicates the permissible periods for Type A testing are when the plant is secured and fully shutdown. Although this con-dition may be interpreted differently at different plants, Kewaunee interprets them as the 'refueling shutdown mode', and has always per-formed Type A tests at refueling shutdown mode in the past. It would clarify the proposed rule to identify the refueling shutdown mode as the acceptable time to perform Type A tests.

The proposed rule does not allow reduced pressure Type A tests. The past practice at Kewaunee has been to perform all Type A tests at Pa; however, there are some advantages to performing reduced pressure tests. These advantages lie in modeling containment pressure as close as possible to the post LOCA profile; i.e., containment is greater than1/2 design pressure for only the first five minutes of a design basis LOCA. Testing the containment at pressures in excess of that expected post LOCA may introduce non-conservatisms, as higher pressures will tend to seal some resilient seals and seat some types of isolation valves. For

Docketing and Service Branch April 24, 1987 Page 3 these reasons, the opportunity to perform partial pressure Type A tests should be maintained. Regarding air lock testing, the proposed rule includes:

              "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."

• Presently, after the full air lock pressurization test at Kewaunee, the air lock is entered from outside containment to remove equipment, and then exited from the same door. This door's double seal arrangement is then tested to assure it has remained intact. The above clause in the proposed rule would eliminate our unnecessary test.

Also, it is clarified in the proposed rule, and is the practice at Kewaunee, that "air locks opened during periods when containment integrity is not required by the plants technical specifications need

• not be repeatedly tested during such periods."

In addition, the requirement is proposed that if any maintenance is per-formed on the pressure retaining boundary of the air lock, other than the seals, a full pressure test at Pac must be performed. This is a statement of good engineering practice which is followed at Kewaunee.

Docketing and Service Branch April 24, 1987 Page 4 It is somewhat redundant to other testing requirements and common sense, i.e., testing the airlock after an outage before requiring containment integrity, and not working on the pressure retaining boundary (other than seals) while at power. This testing requirement could be deleted from the proposed rule. The Type B test acceptance criteria was clarified to indicate that it is the MAXIMUM PATHWAY LEAKAGE that must be used when comparing the Type B and C test leakage to the acceptance criterion of 0.6 La. This approach is followed at Kewaunee; however, it is too conservative for regulatory purposes, as it assumes a single active failure at each penetration. Noting the conservatism involved, La would be a more appropriate accep-tance criteria, with a Leakage ALARA" concept followed for each indivi-dual penetration. The Commission should include the Leakage ALARA concept in the proposed rule to remove any ambiguities on acceptance criteria for individual penetrations. In Section V.B of the proposed rule it states that, "Type Band 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 in such a manner that the containment system leak tight status is determined on both an

Docketing and Service Branch April 24, 1987 Page 5 as found and an as left basis." Although arbitrary in choosing the proximity of Type A, Band C tests in defining which Type Band C tests are performed in conjunction with a Type A test, this section is con-sistent with practices at the Kewaunee Nuclear Power Plant. The appropriateness of this manipulation is addressed in response to Question 15. Also, in regard to Type A testing the proposed r~le states, " *** the leakage rate, as determined by a properly justified statistical analy-sis, must not exceed *** ". The present rule states, "The leakage rate shall be less than 0.75 La (and endorses ANSI N45.4-1972)." Notwithstanding the present rule, the NRC presently requires determining leakage rates at the 95% upper confidence limit, as stated in ANSI N56.8-1981. The current NRC practice of selectively applying criteria from ANSI N56.8-1981 creates chaos when evaluating Appendix J regula-tions and interpretations for inclusion in a leakage testing program. The proposed rule states that, "All changes in (Type A) leakage rates resulting from isolation, repair, or adjustment of leakage barriers sub-ject to Type B or Type C testing are determined using the minimum path-way leakage method and added to the Type A test result to obtain the "as found" and "as left" containment leakage rate." The minimum pathway leakage method is not in the present rule; however, if the Type A test results must be manipulated to include the effects of Type Band C tests, this is the favored method.

Docketing and Service Branch April 24, 1987 Page 6 The acceptance criterion for Type Band C testing was revised to read, "The sum of the as found or as left Type Band C test results must not exceed 0.60 La using maximum pathway leakage and including leakage rate readings from continuous leakage monitoring systems." This acceptance criterion removes any ambiguities that it is the maximum pathway leakage that is required when totaling each penetration's Type Band C leakage.

• KNPP does use the maximum pathway leakage for evaluating each penetra-tion's Type Band C leakage; however, as noted earlier, this assumes a
• single active failure at each penetration and is too conservative. La would be more appropriate as the grand total, with a Leakage ALARA con-cept for individual penetrations.

The proposed rule states, "An air lock, penetration, or set of penetra-tions that fails to pass a Type B test must be retested following deter-mination of cause and completion of corrective action. Corrective action to correct the leak and to prevent its future recurrence must be developed and implemented." This statement is a repetition of good engi-neering practice which would better be implemented through a Leakage ALARA policy stated in the proposed rule. There are several revisions from the present rule to the proposed rule that affect Type A and Type C test boundaries: Regarding Type A testing; the proposed rule states, through ANSI 56.8-1981, that "Systems that are not vented or drained which could become exposed to the containment atmosphere during a LDBA shall be

Docketing and Service Branch April 24, 1987 Page 7 Type C tested and the Type C test leakage rate for the penetration path shall be added to UCL." Whereas the present rule states, "However, the containment isolation valves in the systems *defined in III.A.l(d) (i.e., those necessary to maintain safe test conditions, and systems normally water filled and operating post accident) shall be tested in accordance with III.C (i.e., Type C tested). The measured leakage rate from these tests shall be reported to the commission."

• It appears that the proposed rule clarifies the licensee's authority to determine which lines are not vented and drained for the Type A test, and do not require their isolation valve's leakage rates added to the Type A test results. In the present rule, it is evident that lines such as containment heat removal lines need not be vented and their isolation valve's leakages need not be included in the Type A test results. This interpretation is based on paragraphs III.C.3(a) and (b) in the present rule. Adding the words, " *** could become exposed *** during a LDBA" in
• the proposed rule clarifies this point. For further clarification the commission should consider adding a statement identifying (proposed)

III.C.4(a) and USAR considerations, as criteria to aid in determining whether "could become exposed" is appropriate. Regarding Type C Testing: The present rule states, "Type C tests means tests intended to measure containment isolation valve leakage rates." The containment isolation valves included are those that:

Docketing and Service Branch April 24 1987 9 Page 8

a. Provide a direct connection between the inside and outside atmosphere of the primary reactor containment under normal operations such as purge and ventilations vacuum reliefs and instrument valves;

b. Are requ i red to close automatically upon receipt of a contain-ment isolation signal in response to controls designed to effect containment isolation;

• c.

d. Are required to operate intermittently under post acc i dent con-ditions; and {Applies to BWR's.) The proposed rule states Type C tests pneumatically test and measure

                    )

containment isolation valve leakage rates. Containment isolation valves are defined as any valve defined in GDC 55 9 56 9 or 57. The present and proposed rules have the same provisions for excluding leakage from the combined Band C leakage rates to compare to 0.6 Las for containment isolation valves with fluid seals. The proposed rule goes on to define those valves that need not be Type C tested at alls i.e. 9

Docketing and Service Branch April 24, 1987 Page 9 11 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 accident, considering a single active failure of a system component. 11 The Type C testing criteria from the proposed rule would not be appli-cable to Kewaunee since Kewaunee's containment isolation system was designed and approved prior to issuance of GDC 55, 56, and 57. Instead, the containment isolation valves that require Type C testing at Kewaunee meet the criteria discussed above from the present rule, and are described in Kewaunee's USAR. It would, therefore, be appropriate to

         grandfather" Kewaunee in regard to defining containment isolation valves.

The proposed criterion for not Type C testing a valve is appropriate and probably is one criterion for determining whether a line should be vented for a Type A test (see earlier Type A discussion). Also, the

• proposed criterion for not Type C testing a valve should specifically reference a LOCA as the accident.

The proposed rule includes a new section, IV "Special Leak Test Requirements." This section states that modifications made to contain-ment affecting Type B or Type C boundaries must be preceded and followed by the respective local leak rate test. Although not specifi-cally required by the present rule, the practice of pre- and post-modification leakage determination is practiced at Kewaunee and appears to already be required by the NRC.

Docketing and Service Branch April 24, 1987 Page 10 The proposed treatment given to minor containment modifications that can only b~ pneumatically pressure tested by a Type A test is reasonable, i.e., nondestructive examination and deferral of the Type A test until the next one is scheduled. Section V of the proposed Rule, "Test Methods, Procedures, and Analyses" requires a licensee to put their leak test methods, procedures, and ana-lyt i c methods in the plant Technical Specification. Presently Kewaunee's Technical Specifications include at least reference to the methods, procedures, and analyses. It appears, however, in light of the current reform of Technical Specifications (i.e., .WOG MERITS program, and the NRC's Policy Statement in FR/Vol. 52, No. 25/2-6-87/pp. 3788) that leakage testing specifications do not belong in the Technical Specifications, nor do they belong in the plant USAR. It would be appropriate to include the surveillance frequency, acceptance criteria, and limiting conditions for operation in the Technical Specifications. However, the engineering considerations such as sensor layout, instru-mentation selection criteria, calibration specifics, procedural outli-nes, computational and analytical methods would better be placed in a document identified and committed to, in the Technical Specifications, as the plant Leakage Testing Program.

Docketing and Service Branch April 24, 1987 Page 11

2) The extent to which those in use, and those not in use but proposed, are desirable.

It is desirable that the Type A test definition include that the intent is to measure containment leakage in a condition representing the post-L0CA system alignment. It would additionally be desirable to include the post-L0CA clarification to the accident that Type Band C barriers are supposed to protect against *

• The proposed idea of developing a Corrective Action Plan {CAP) if the "as-found" Type A leakage exceeds La is a good one. This will allow the licensee to focus corrective action where it is required rather than force the licensee to expend resources on setting up and performing a supplemental Type A test when the effort would better be spent on defining, analyzing, and correcting a leakage problem.

It is also desirable to raise the allowable as-found containment leakage to La and the as-left leakage to 0.75 La. However, it should be clarified that the containment need not necessarily be pressurized twice if the as-found leakage exceeds La. This would be a consideration when leakage paths are isolated during the Type A test, and calculation shows the as-found results greater than La, but the test data confirm the as left containment condition as leakage less than 0.75 La. The commission has made a move in the right direction by relocating some of the requirements from Appendix Jin draft -Regulatory Guide MS 021-5 and ANSI 56.8-1981. Some of the requirements moved include: contain-

Docketing and Service Branch April 24, 1987 Page 12 ment inspection, Type A test stabilization criteria, vented line cri-teria for Type A tests, and Type Band Type C test methods section. When comparing the proposed rule to ANSI 56.8-1981, it is evident that there is repetition of the rule in the ANSI guide. As there are many engineering specifics in the proposed rule, it would be beneficial to place all the testing and engineering specifics in a regulatory guide and only state in the rule the necessity of a licensee to implement a leakage monitoring program at least equivalent to the published guidance. The rule would also place regulatory requirements on the licensee's administration of changes to the leakage program. This would result in an initial burden on the licensee to develop such a program specific to their plant, following the regulatory guide as guidance, with burden on the NRC to review and approve the plant specific program (note: this is similar to the burden of the proposed rule). Once this program is in place the licensee would have the advantage of a self con-tained program that they were intimately familiar with for leakage testing, and regulators would have the advantage of a plant-specific document containing everything they would need regarding inspection cri-teria.

Docketing and Service Branch April 24, 1987 Page 13

3) Whether there continues to be a further need for this regulation.

As discussed above, there continues to be a need for regulation requiring licensees to monitor containment leakage; however, the regula-tion should be limited to stating the need and goals for a program. The licensee would be required to develop a program, with technical justifi-cation and subsequent NRC approval, for containment leakage monitoring. The surveillance frequency, acceptance criteria, bases, and commitment to a program should be included in the Technical Specifications *

4) Est imates of the costs and benefits of this proposed revision, as a whole and of its separate provisions.

The largest impact the proposed rule would have on the Kewaunee leakage testing program would be requiring Type C testing of the containment isolation valves described in General Design Criteria 55, 56 and 57. As stated earlier, Kewaunee's containment isolation system was designed prior to issuance of GDC 55, 56 and 57, and the isolation prov i sions are generally consistent with the requirements for a Type C test boundary in the present rule and are specifically discussed in the Kewaunee USAR. There are other revisions to the rule that separately would reduce unnecessary leakage testing burdens on Kewaunee, including the Corrective Action Plan concept, deferral of Type A testing of minor modifications pending acceptable NOE, and allowing as found Type A test results of La and as left leakage of 0.75 La.

Docketing and Service Branch April 24, 1987 Page 14 As a whole it appears most beneficial for Kewaunee to develop its own, technically correct, self-contained, leakage testing program and commit to this program by reference in Technical Specifications.

5) Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule (reflecting consideration of public conments) becomes effec-tive *

• Again it would appear to be in everyone's best interest for licensee's to adopt a plant specific leakage testing program based on NRC approved guidance, to subsequently be approved by NRC and referenced in plant Technical Specifications.

6) If the existing rule or its proposed revision were completely voluntary, how many licensees would adopt either version in its entirety and why.

Generally, WPSC finds the proposed rule more desireable than the pre-

• sent rule. Rather than adopt the proposed rule in its entirety, WPS would request exemption to certain parts (e.g., Type C testing those valves defined in GDC 55, 56, and 57), and request that exempt i ons granted to the present Appendix J remain in effect. WPSC would also consider taking exception to the proposed guidance that requires further restrictions on nonlinearity and data scatter during a Type A test, as we feel the least squares analysis at the 95% UCL is sufficiently con-servative. Upon specific application of the proposed rule to Kewaunee's leakage testing program, more areas of conflict may be identified.

Docketing and Service Branch Apri 1 24, 1987 Page 15

7) Whether (a) all or part of the proposed Appendix J revisions would consti-tute a "backfit" under the definition of that term in the Conmission's Backfit Rule, and (b) there are parts of the rule which do not constitute backfits, but which would aid the staff, licensees, or both.

For the Kewaunee plant, the most significant backfit issue arising from the proposed rule would be to require Type C testing of containment iso-lation valves meeting General Design Criteria 55, 56 and 57. This has possible implications of applying the GDC criteria to Kewaunee's con-tainment isolation system. Another potential backfit issue in the proposed rule is the new engi-neering type requirements placed on the leakage tests through draft Regulatory Guide MS-021-5. Without a doubt, some of the requirements in MS-021-5 and ANSI 56.8-1981 are technically more correct than ANSI N45.4-1972 and reflect advances made through gained experience; however, consideration of a backfit analysis is still warranted. This is cer-tainly the case considering the present guidance is adequate to accura-tely determine containment leakages. Additionally, there is a backfit consideration with the Corrective Action Plan concept, although this particular proposal is probably the single most beneficial change from the licensee's standpoint. Disallowing partial pressure Type A tests is also a backfit.

Docketing and Service Branch April 24, 1987 Page 16

8) Since the NRC is planning a broader, more comprehensive review of contain-ment functional testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation.

Considering the time this revision to Appendix J has taken to get to the proposed rule status, it would be reasonable to assume that another con-siderable period of time (3 to 4 years at least) would be required for *

• licensees to respond and the NRC to approve their compliance with this proposed rule. It would be more efficient to issue the "FINAL" rule on Appendix Jin 2 or 3 years, than to update all plants to a proposed rule only to revise it again. Another factor strongly in favor of waiting to revise the rule until in its "FINAL" form is that utili-ties have expended significant resources in complying with the current Appendix J, and, as a result, have technically adequate leakage testing programs. Expending more resources to be just as adequate, especially when another, just as adequate, rule is in the works appears unne-cessary.

9) The advisability of referencing the testing standard (ANSI/ANS 56.8) in the draft regulatory guide (MS-021-5) instead of in the text of Appendix J.

It is apparent that the NRC chose the Rule-Regulat~ry Guide-ANSI Guide format for ease in future revision. WPSC is in favor of this revision and suggests that it be carried further, removing all technical require-ments from the rule, and only stating the need for licensees to imple-

Docketing and Service Branch April 24, 1987 Page 17 ment a leakage testing program and the administrative requirements of

• that p.rogram. All technical requirements of the leakage testing program should be in a Regulatory Guide-ANSI Guide format. Guidance published in the Regulatory and ANSI guides would then be subject to Backfit Rule considerations.

10) The value of collecting data from the "as found" condition of valves and seals and the need for acceptance criteria for this condition *

• Type Band C testing as-found data is valuable as it provides an indica-tion of the amount of degradation that occurred since the previous B &C tests. This information allows one to identify the reliability of the valves or seals that provide containment integrity. Determinations can be made, based on the reliability, whether engineering changes are indi-cated or the required frequency for maintenance is sufficient.

Acceptance criteria for as found Type Band C leakage is valuable as it

• provides a periodic assessment of containment integrity. 0.6 La, on a maximum pathway basis for each penetration is too conservative for regu-latory purposes, as it assumes a single active failure at each penetra-tion. To be rigorous, one would have to take all the as found data and evaluate which single active failure {e.g., failure of one train of con-tainment isolation) would result in the greatest leakage--this would be the reported leakage.

Docketing and Service Branch April 24, 1987 Page 18 Rather than requiring single failure analyses for each set of local leak rate t~s_ts, it is more appropriate to adopt a "Leakage" ALARA (leakage as low as reasonably achievable} outlook on each individual penetration, and set a grand total that is not to be exceeded {i.e., La}, much like the rule presently treats local leakages. The difference would be to formally state the policy in the rule, which would remove ambiguity on individual penetration acceptance criteria. 11} Whether the technical specification limits on allowable containment leakage should be relaxed and if so, to what extent and why, or if not why not. A technical specification limit is placed on containment leakage in order to assure offsite doses remain below the limits set in 10 CFR 100 following a design basis LOCA. A tight containment will also provide protection from radionuclide transport for any other event which results in breach of fuel and RCS pressure boundaries, although the "other" events are unlikely to result in pressurizing containment to the levels a design basis LOCA would. If the NRC were considering relaxing limits on allowable containment leakage, then the basis for the allowable leakage would also have to be changed, i.e., the assumptions used in the offsite dose analysis to determine the activity available for transport out of containment post LOCA. Considering the conservative nature of these assumptions, e.g., (as listed in Kewaunee's USAR}.

Docketing and Service Branch April 24, 1987 Page 19

a. instantaneous double ended rupture of a 29 inch inside diameter reactor coolant loop;

b. 100% of the noble gases and 25% of the Halogens in the cores fission product boundary, of which a homogeneous mixture is r

assumed to occur instantaneously and be available for transport;

c. a containment vessel leak rate of 2.5% for the first day and 1.25% for the remainder of the 30 day period;

• and present knowledge of the relative likelihood of their occurrence, it appears there is a considerable margin between what is postulated for analytic purposes and what could actually happen. For example, the instantaneous guillotine break of a RCS loop as the limiting design basis has been virtually ruled out. If it were to occur, containment pressure would be decreasing before core damage resulted and the fission product inventory would be available for release. Source term research by IDCOR, NRC, and others has shown the consequences of design basis LOCA's to be considerably overestimated.

Revisions to allowable containment leakage should be consistent with revisions to design basis accident analytic assumptions.

Docketing and Service Branch April 24, 1987 Page 20

12) What risk important factors influence containment performance under severe accident conditions, to what degree these factors are considered in the current containment testing requirements, and what approaches should be con-sidered in addressing factors not presently covered.

The factors influencing containment performance under accident con-ditions were considered in the design and construction of the contain-ment, and its associated penetrations *

• The present testing methods adequately determine the ability of the con-tainment to perform its function, any questions as to the adequacy of the containment design can only be addressed through design reviews.

13) What other approaches to validating containment integrity could be used that might provide detection of leakage paths as soon as they occur, whether they would result in any adjustment to the Appendix J test program and why.

Validating containment integrity through Appendix J testing is a multi-

• phase program with a single goal. All three types of testing (A, Band C) are necessary along with containment isolation system testing, proper operational lineups, equipment operability, supporting system operabi-lity, and adherence to proper administrative controls. Any short cuts to provide a "quick check" of containment integrity would only result in partial, and redundant, information on the containment status.

Docketing and Service Branch April 24, 1987 Page 21 During the course of an operating cycle, however, attentive operators may b~ ~le to identify valves in lines penetrating containment with less than complete isolation capability. This information can then be acted upon by the plant technical staff to assure proper resolution, and continued containment integrity.

14) What effect 11 leak-before-break 11 assumption could have on the leakage rate test program. Current accident assumptions use instantaneous complete

• breaks in piping systems, resulting in a test program based on pneumatic testing of vented, drained lines. "Leak-before-break" assumptions presume that pipes will fail more gradually, leaking rather than instantly emptying.

The added conservatism to Type A testing considering the leak-before-break concept in regards to venting and draining of lines, is not too unreasonable; however, the leak-before-break consideration of the design basis accident scenario itself, the double-ended guillotine rupture of a RCS leg, should be reconsidered as discussed in question 11 *

• 15) How to effectively adjust Type A test results to reflect individual Type B and C test results obtained from inspections, repairs, adjustments, or replacements of penetrations and valves in the years in between Type A tests. Such an additional criterion, currently outside the scope of this proposed revision, would provide a more meaningful tracking of overall con-tainment leaktightness on a more continuous basis than once every several

Docketing and Service Branch April 24, 1987 Page 22 years. The only existing or proposed criterion for Type Band C tests per-formed outside the outage in which a Type A test is performed is that the sum of Type B and . C tests must not exceed 60% of the allowable containment leakage. Currently being discussed by the NRC staff are:

a. All Type Band C tests performed during the same outage as a Type A test, or performed during a specified time period (nominally 12 months) prior to a Type A test, be factored into the determination of a Type A test "as found" condition *

b. If a particular penetration or valve fails two consecutive Type B or C tests, the frequency of testing that penetration must be increased until two satisfactory B or C tests are obtained at the nominal test fre-quency. Concurrently, existing requirements to increase the frequency of Type A tests due to consecutive "as found" failures are already being relaxed in the proposed revision of Appendix J. Instead, attention would be focused on correcting component degradation, no matter when tested, and the "as found" Type A test would reflect the actual con-dition of the overall containment boundary.

c. Increases or decreases in Type B or C "as found" test results (over the previous "as left" Type B or C test results) shall be added to or subtracted from the previous "as left" Type A test result.

Docketing and Service Branch April 24, 1987 Page 23 If this sum exceeds 0.75 La but is less than 1.0 La, measures shall be taken to reduce the sum to no more than 0.75 La. This will not be con-sidered a reportable condition. If this sum exceeds 1.0 La, measures shall be taken to reduce the sum to no more than 0.75 La. This will be considered a reportable condition. The existing requirements that the sum of all Type Band C tests be no greater than 0.60 La shall also remain in effect .

• The above discussion illustrates an important point; that Type A and Type Band C tests are separate tests intended to determine dif-ferent intelligence about the leak tightness of containment; however, when their individual results are looked at together, they provide information necessary to evaluate the condition of contain-ment integrity.

Any reasonable combination of Type Band C test results with Type A test results is arbitrary and probably as adequate as the next. The present rule is ambiguous; however, NRC enforceable policy is to include Type Band C leakage reductions, on a minimum pathway basis, to the Type A test results when performed during the same refueling outage. As long as the policy is applied equally throughout the industry a Type A test can be interpreted to yield information on the overall integrity of containment after a period of 3 years, with a maintenance program on individual testable barriers for two years, and a mathematical correction to eliminate the effect of maintenance from the third year.

Docketing and Service Branch April 24, 1987 Page 24 WPSC favors the method proposed by the Conmission in point b above fo! _r_elating Type Band C testing to Type A testing. This quite closely resembles a Leakage ALARA concept for local leak rate testing (referred to in the response to Question 10), and i t main-tains the Type A test as an independent test of the overall contain-ment boundary

• JOCKEl: NUM8ER iBQfQS~D ---~--..~:"."i

(:5/FA Log # TXX-6255 File# 10186 Ref: 10CFR50 App . J ffJELECTRIC April 24, 1987 c:,C> William G. Counsil c.,"'Tl

                                                                                                <,"Tl Executive Vice President                                                                           :;,::c=;

f"it1

                                                                                                   -l
                                                                                                '        *l 1

U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Docketing and Service Branch

SUBJECT:

PROPOSED RULE: LEAKAGE RATE TESTING OF CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS, 51 FED. REG. 209 (1986); DRAFT REG. GUIDE MS 021 - 5 "CONTAINMENT SYSTEM LEAKAGE TESTING," 51 FED. REG . 208 (1986) . Gentlemen: On October 29 , 1986, the Commission published for comment the proposed rule, Leakage Rate Testing of Containments of Light -Water-Cooled Nuclear Power Plants, 10 CFR 50 Appendix J. The purpose for the rule change is to update the criteria and eliminate conflicts, ambiguities and lack of uniformity in the regulation . In addition to the proposed rule, the Commission issued for comment on October 28, 1986, draft Regulatory Guide MS 021-5 , "Containment System Leakage Testing," which was developed to provide guidance on procedures acceptable to the NRC staff for conducting containment leakage tests . The proposed rule contains major changes and clarifications to the Type A test ing requirements used to measure the containment system overall integrated l eakage rate . Expansion and revision to the Type Band C testing requ i rements used to measure leakage through individual containment penetrations and i sol at i on valves are also provided. The proposed Appendix J changes will delete the reference to ANSI N45.4-1972. In its place, draft Regulatory Guide MS 021 -5 endorsing ANS I/ANS 56 .8-1981 with 20 except i ons has been proposed as a means of providing test methods, procedures and analysis acceptable to the NRC staff for leakage testing of containment systems . 400 Nonh Olive Street LB 81 Dallas, Texas 75201 _ MAY Q 6 !£! AeknOWledged by card ****,;;:,,,,,. , iifiilr

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TXX - 6255 April 24, 1987 Page 2 of 2 TU Electric endorses the way in which the NRC staff is developing the final rule by seeking technical input from representative groups and individuals who ultimately would be affected by the rule. TU Electric concurs that the proposed changes to Appendix J will have a positive impact and provide the much needed clarity and revision. The detailed comments that are attached include our endorsements and recommendations indicating those areas where we feel that additional attention is required. Very truly yours, a!.>f/.~

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G. S. Keeley Manager, Nuclear"-t-'l~ff-5,111-fflJ RSB/ml h Attachment

Attachment to TXX-6255 April 24, 1987 Page 1 of 11 I. COMMENTS ON THE PROPOSED 10CFR50 APPENDIX J CHANGES TYPE A TEST The following changes to 10CFR50 Appendix J Type A testing will have a positive impact on current test methods and procedures in place at TU Electric's Comanche Peak Steam Electric Station (CPSES) Units 1 and 2. As a minimum, proposed changes below will streamline testing, provide additional clarity and allow conduct/analysis of testing using current technology: Elimination of the twenty four hour test duration requirement in lieu of test duration that accurately establishes a leak rate trend (minimum eight hours). Allowances for a leakage rate deterioration with an "As Found" leakage criterion of 1.0 La .

• Use of a corrective action plan (subject to NRC staff approval) that focuses on the cause and nature of the Type A failure instead of increased Type A test frequency.

Operation, draining, venting and preparation of penetrations now left to ANSI/ANS 56.8. Repair and adjustments prior to and/or during the Type A test are now explicitly allowed provided Type A test results are adjusted using minimum pathway leakage results. Deferral of minor modifications, repairs or replacements until the next Type A test. Requirement to perform the preoperational test at peak pressure only rather than peak and reduced pressure.

• Other changes to Type A testing requirements require additional evaluation relative to overall benefit. Type A test frequency is no longer tied to the ten year inservice inspection period used by the ASME Boiler and Pressure Vessel (B&PV) Code. Should ANSI/ANS-56.8 be endorsed, Staff comment should be provided to ensure consistency between the four year periodic test frequency of Appendix J [Section II.A.(3)]

and the five year interval of ANSI/ANS-56.8 (Section 3.2.3). A five year test interval is preferred and would allow for anomalies/extensions in plant operating cycles and refueling/unplanned outages. Type A preoperational tests are now required to be preceded by Type Band Type C testing and a structural integrity test (SIT). ANSI/ANS-56.8 requires the SIT and recommends Type Band C be done with all Type Band Type C leakage not accounted for in the Type A test added to the upper confidence limit (UCL) based on minimum pathway leakage. It is assumed that allowances as discussed in ANSI/ANS-56.8 will be applied to the Appendix J requirements for preoperational Type A test procedures.

Attachment to TXX-6255 April 24, 1987 Page 2 of 11 Due to construction schedule restraints at NTOL plants, it may not be reasonable to complete all Type Band C tests prior to the Type A test. Clearly adjustment of preoperational Type A results based on post test repair/rework of Type Band C leakage paths is reasonable and within the intent of the regulation. Also for clarity and consistency the second sentence of Section III.A(3) should state 11

                                                      *** another preoperational Type A test will be necessary."

Type A test pressure requirements of Section 111.A.(4) and ANSI/ANS-56.8 do not permit test pressure to fall more than one psi below Pac. As this appears to be an arbitrary number, a percent pressure drop is recommended. Using this criteria in relation to a Pa of fifty psi, a two percent drop is allowed, but for a Pa of fifteen psi a 6.5% drop is allowed. A four percent pressure drop below Pa is representative of a middle ground between various containment designs. TYPE BAND C TESTING

• Similar to changes proposed to Type A testing, many of the new Appendix J Type Band C requirements streamline Appendix J requirements as well as provide much needed enhancement and clarity. The following changes will have a beneficial impact on Type Band C testing programs and should be retained in the final rule. Briefly these changes include but are not limited to:

Implementation of various test methods, procedures and analyses left to ANSI/ANS-56.8 or other appropriate basis. Definition of minimum and maximum pathway leakage rates and requirements for their use. Allowance for Type C testing at other convenient intervals (during plant operation). Clarification and guidance for exempting valves from Type C testing and use of alternate test methods. Greater airlock testing flexibility provided and airlock test frequency extension for periods of airlock inactivity or relaxed containment integrity requirements. New definition of containment isolation valve consistent with other regulatory bases. New requirements are now proposed for Type Band C As Found" test 11 acceptance criteria and reportability. Additional requirements relative to individual "As Found" acceptance criteria for Type Band C tests, increased test frequency penalties, and additional Type A test adjustments as a result of Type Band C test were also considered by the NRC staff but not incorporated in the proposed regulation. Proposed Appendix J requirements for "As Found" Type B &C leakage and individual valve leakage criteria are not recommended for incorporation in the Appendix J revision. Several other regulatory requirements and bases already exist that adequately deal with this proposed requirement.

Attachment to TXX-6255 April 24, 1987 Page 3 of 11 Recent NRC staff review of the CPSES Inservice Testing Program (SER Supplement 12 Appendix R) has recognized the importance of control over individual valve leak rates. As a result of the Inservice Testing Program (1ST) review, reference leak rates for each Type C tested containment penetration were calculated based on containment isolation valve size and penetration configuration such that the total allowable containment leakage for Type Band C tests of 0.60 La will not be exceeded. Unless justified and approved by evaluation, every attempt is made to maintain each penetration below its referen~e leakage value. This method of setting, maintaining and evaluating penetration reference leakage values ensures flexibility for prudent system operation and provides reasonable assurance of valve leak tight integrity intended by Section XI Subsection IWV of the ASME B&PV code. In as much as, Section XI valve testing is required by 10CFR50.55a(g), additional emphasis by Appendix J would be redundant. Based on requirements of Section XI and Type A test adjustments using minimum pathway calculations, the proposed Appendix J requirements for Type Band C "As Found" acceptance criteria and reporting are not endorsed or recommended . Additionally, staff comments to correct Type A test results using increases or decreases in "As Found" Type Band C results are not recommended. This method would employ a correction of Type A results based on a change in maximum pathway leakage. This is inconsistent with Type Band C minimum pathway corrections to Type A test results already proposed in Section III.A (Type A test). Although not explicitly stated, these minimum pathway corrections proposed by Section III A(7)(c) should encompass a six month operating period prior to the Type A test and conclude with completion of the Verification Test. If desired, correction of Type A test using Type Band C data must be made using minimum path leakage. This would provide a meaningful and consistent comparison of containment system leaktight integrity using the Type A acceptance criteria of 1.0 La (As Found minimum pathway) and 0.75 La* (As Left minimum pathway). "As Left" Type Band C (maximum pathway) acceptance criteria of 0.60 La should be retained. Use of the Inservice Testing Program for valves, and the Appendix J 0.60 La "As Left" requirement, would be more than adequate to maintain overall containment leakage below proposed/commented values. Although not endorsed, correction of the "As Left" Type A test results using "As Found" Type Band C minimum pathway calculations would provide a representative containment leakage which will allow direct correlation with accident analysis. Any realistic "As Found" criterion should require a total allowable Type A leakage of 1.0 La based on minimum pathway leakage. I I. APPLICATION OF BACKFITTING RULE In his separate views, Commissioner Bernthal requested comments on whether the backfitting rule should be revoked as it applies to rulemaking proceedings. TU Electric respectfully disagrees with Commissioner Bernthal's position. As the Commission correctly observed when it promulgated the backfitting rule, there is no practical

Attachment to TXX-6255 April 24, 1987 Page 4 of 11 difference between backfits imposed by order or Staff position in individual dockets and those imposed by rulemaking. In either case the licensee is required to use its resources to implement the backfit, and the Commission, as a matter of sound regulatory practice, should understand the impact of the backfit before imposing it. Commissioner Bernthal has also requested public comment on whether the Commission should amend the backfitting rule to delete the requirement that the backfit result in a "substantial increase in the overall protection." 10CFR 50.109(a)(3). In our view, the backfitting rule represents a proper balancing of competing regulatory concerns. If a proposed requirement does not provide a "substantial increase in the overall protection," taking into account all relevant factors, then as a matter of sound regulation it should not be imposed on licensees. Moreover, the backfitting rule represents the culmination of Commission efforts to reassert management control over the imposition of new

• requirements. If these efforts are to be meaningful, the Commission must apply the standards set forth in the rule, in particular the "substantial increase" standard, to all proposed modifications or regulations. In our view, it would be tantamount to an abdication of its commitment to restore regulatory stability for the Commission to abandon the backfitting rule simply because a proposed backfit is found not to be justified under the prevailing standards.

Commissioner Bernthal has also solicited comment on whether the backfitting rule should be amended to permit the Commission to consider nonmonetary benefits in the cost-benefit analysis. In our view, the backfitting rule already allows consideration of nonmonetary benefits or nonquantitative factors in the backfitting analysis. Section 50.109(c) requires the Commission to "consider information available concerning [as many of the listed] . . . factors as may be appropriate and any other information relevant and material to the proposed backfit." (Emphasis added.) This gives the Commission discretion to consider nonmonetary benefits. TU Electric is also a member of the Nuclear Utility and Backfitting and Reform Group (NUBARG) which is submitting comments separately on the proposed rule. TU Electric endorses the comments of NUBARG. III. COMMENTS ON DRAFT REGULATORY GUIDE MS 021-5, "CONTAINMENT SYSTEM LEAKAGE TESTING" With exception of the recommendations noted below, incorporation of ANSI/ANS-56.8 and associated Regulatory Guide positions into the existing Appendix J program at TU Electric should have minimal program impact. Portions of ANSI/ANS-56.8 are already in use at TU Electric. It is anticipated and recommended that the draft Regulatory Guide be revised to endorse the recently approved 1987 edition of ANSI/ANS 56.8 so as to minimize the number of exceptions taken and incorporate current industry and TU Electric comments. TU Electric comments on a revised Regulatory

Attachment to TXX-6255 April 24, 1987 Page 5 of 11 Guide would then be based on the recently initiated assessment of ANSI/ANS 56.8-1987. Because of this in-progress review, all references throughout this response are benchmarked to ANSI/ANS-56.8-1981 unless otherwise noted. The following discussion will assess each of the twenty regulatory positions contained in the draft Regulatory Guide MS 021-5.

1. Con fl i ct:

Three areas of direct conflict are noted between the proposed Appendix J and ANSI/ANS-56.8. The areas are Type A test frequency, the acceptance criterion for Type Band C tests, and the pressure for hydraulic tests. As noted earlier, the proposed revision to Appendix J specifies a four year Type A test interval, whereas ANSI/ANS-56.8 allows five years. Obviously the five year interval is preferred. Recent emphasis on Type Band C testing, corrective action plans, and increased Type A test frequency for failures would substantiate the five year interval .

• Another item of conflict concerns the acceptance criterion for Type Band C results. To be acceptable, ANSI-56.8 requires the combined leakage rate Jtl.Y.i standard deviation of the leakage rate to be less than 75% of the maximum allowed leakage La. The proposed Appendix J requires the combined leakage rate to be less than 0.60 La at all times. As noted in the Appendix J discussion, the current TU Electric Type C valve programs are structured around an "As Left" leakage limit of 0.60 La. The implicit impact on Type A test results and related changes proposed for Appendix J dictates the use of the conservative criterion of 0.60 La until such time that sufficient justification is available for an increase to the ANSI/ANS-56.8 criteria.

The final area of conflict concerns the test pressure and requirements for water testing. Appendix J requires a test pressure of I.I Pa whereas ANSI/ANS-56.8 specifies a pressure of Pa. Independent of the test pressure used for water testing, leak test requirements and their associated basis must be made part of Technical Specifications and approved by NRC staff. Obviously, test pressure requirement will be established and justified as part of the Technical Specification revision process. Substitution of water testing for pneumatic testing is somewhat nebulous because neither the proposed revision to Appendix J nor the draft Regulatory Guide state the requirements of a "qualified water seal system".

2. Type A Test Requirement:

Although not expressly stated, it is assumed that this requires the Type Band C leakages that are added to the Type A test results be based on minimum pathway and include instrument error. Although rewording is required for explicit clarity, the requirement is consistent with proposed Appendix J changes and Type A testing at TU Electric.

Attachment to TXX-6255 April 24, 1987 Page 6 of 11

3. Pressurizing Consideration:

TU Electric is in agreement with this Regulatory Position. However, in-leakage if properly accounted for should be allowed.

4. Liquid Level Monitoring:

The proposed deletion in paragraph 3.2.1.8 is endorsed, however, it should be realized that only the last paragraph provides guidance for containment free volume corrections. In those cases where an initial and a final level reading are used, current guidance in ANSI/ANS-56.8 is not specific and would allow a post test data adjustment based on a variety of methods and assumptions. For levels lacking adequate instrumentation, determination of when the level change occurred is not possible. Changes that occurred only during test pressurization, depressurization, instantaneously or progressively, would all have a different impact on the test results. TU Electric has interpreted paragraph 3.2.1.8 to allow an analysis of level change with analytical results incorporated into test data. This analysis and possible test result adjustment for all level changes that impact containment free volume will probably be done in a post test situation.

5. Type A Test Frequency:

TU Electric is in total agreement with this exception proposed by the Regulatory Position.

6. Verification Test:

TU Electric uses a superimposed leak method for the Type A verification test. Proposed Regulatory Positions are endorsed subject to the following clarifications. The purpose of the verification test is to verify the ability of the Type A test to

• accurately measure/determine leakage rates approaching La. It is interpreted that prerequisites such as establishment of a stable verification test leakage and containment atmospheric sampling requirements for discharge are acceptable justifications for data acquisition interruptions.

7. Data Rejection:

All data obtained from test sensors including data rejected by faulty sensors will be recorded and evaluated as required during post-test data analysis. Specific sensor rejection criteria, and statistical data rejection techniques will be addressed or referenced in the summary test report submitted pursuant to the requirements of 10CFR50 Appendix J Section VI.

8. Tvpe Band C Test Pressures:

TU Electric is in agreement with this exception proposed by the Regulatory Guide.

Attachment to TXX-6255 April 24, 1987 Page 7 of 11

9. Type Band C Test Schedule:

This Regulatory Guide position provides clarification of regulatory requirements and is endorsed by TU Electric.

10. Test Medium and Water Filled Systems:

TU Electric agrees with this assumption.

11. Calibration:

11.1 The intended pretest instrumentation calibration

           &      philosophy of the Regulatory Positions is to perform a 11.2 calibration within six months of the test in addition to an in-situ check one month prior to the test. To provide additional clarity, TU Electric recommends that Regulatory Position 11.2 explicitly state performance of an in-situ check .

11.3 Calibration of Type Band C instrumentation shall be performed within established calibration intervals. It may be prudent in certain situations to perform frequent or daily calibration checks. With instrumentation technology available today, devices with longer calibration intervals are readily available. Also many onsite calibration facilities lack adequate flow standards and rely on outside assistance. The Regulatory Position should be modified by requiring calibrations to be performed within owner specified periodic intervals. Trying to force this concept by a simple work substitution is not appropriate and lacks the clarity noted in other Regulatory Positions. Regulatory Position 11.3 is not endorsed by TU Electric.

12. Containment Atmospheric Stabilization:

12.1 Stabilization Determination: ANSI/ANS 56.8 section 5.2.1 currently requires a m1n1mum four hour stabilization period and satisfactory temperature stabilization criterion before proceeding with the integrated leakage rate period. In addition, this Regulatory Position recommends that computation of the 95% upper confidence limit (UCL) of containment leakage be performed during the stabilization period to verify an UCL equal to or greater than zero prior to declaring the start of the test. This recommendation is not endorsed by TU Electric and should be deleted. ANSI/ANS 56.8 formulations for the air mass calculation assume uniform temperature. Calculation of the UCL during the stabilization period would use data subjected to atmospheric instabilities. Most tests which initially exhibit a negative value for UCL eventually increase to a positive value and yield satisfactory results. Indication of a negative leakage rate could result from air in-leakage or

Attachment to TXX-6255 April 24, 1987 Page 8 of 11 transient temperature variations caused by operational changes to systems. Independent of the cause, TU Electric recommends a case by case approach to evaluate the most effective approach and analysis of negative UCL's. Obviously if the UCL remains negative despite corrective measures the test should be restarted. If the containment is adequately instrumented, volume fractions properly assigned, and stabilization criteria of Regulatory Position 12.2 met then temperature variations will be adequately accounted for in the calculation of containment mass. 12.2 Temperature Stabilization Criteria: These criteria are endorsed by TU Electric. With exception of the temperature limit in criteria (a) these stabilization criteria are based on the short duration test criterion of BN-TOP-1. Stabilization criteria of ANSI/ANS 56.8 and BN-TOP-1 are based on empirical observation and experience rather than scientific principles. Their usefulness is dependent on proper instrumentation, weighting fraction assignment, and analysis of containment test data. Regulatory Position 12.2 will replace ANSI/ANS 56.8 requirements, therefore for additional clarity, the Regulatory Position should contain an Appendix similar to Appendix Fin ANSI/ANS 56.8. 12.3 Temperature Stabilization Duration: This Position is endorsed by TU Electric and provides allowances for unstable temperature condition identification and correction without impacting test continuation/leakage rate data collection. Instabilities are anticipated at the start of the verification test.

13. Data Recording and Analysis:

13.1 Test Duration: This Regulatory Position is endorsed by TU Electric provided the minimum periodic test duration of eight hours remains . It is assumed that the requirements of Regulatory Position 12.2 and 12.3 for containment atmospheric considerations will be coordinated with this position relative to test restart. Restart would then be predicated on the previous two hours of containment atmospheric stabilization data subject to appropriate problem identification and allowances of Regulatory Position 12.3 13.2 Recording of Data: TU Electric is in agreement with this Regulatory Position.

Attachment to TXX-6255 April 24, 1987 Page 9 of 11 13.3 Type A Test Data Analysis: The Extended ANSI Method The Extended ANSI Method proposed by Regulatory Position 13 .3 is not endorsed by TU Electric. The two conditions of the Extended ANSI Method are intended to control the quality of the Least Squares Fit (LSF} results obtained from the mass point technique. Use of the Extended ANSI Method is unnecessary with judicious use and execution of the ANSI/ANS 56.8 requirements as well as application of additional, easier to use qualitative guidelines. Abnormal or erratic data can be caused by cyclical diurnal effects, instrument noise/surges, unexpected operational heating/cooling occurrences, temperature instability or inaccurate containment volume modeling. A conscientious use and knowledgeable execution of current ANSI/ANS 56 .8 requirements could mitigate data scatter and unacceptable LSF results. Expanded containment modeling/analysis, instrumentation enhancements and upgrades, application of data rejection criteria, increased attention analysis to stabilization trends, stringent control of containment integrity, and detailed operational requirements for system isothermal conditions would all optimize test conditions and thus enhance data quality. Reasonable application of ANSI/ANS 56.8 and its regulatory guide endorsements provide minimum criteria for the following fundamentals of acceptable Type A and verification test results: stable containment environment, good instrumentation, representative containment atmospheric modeling and uniform data sets. Properly justified and expanded test performance requ i rements would improve data quality and are favored in lieu of the superfluous statistical analysis of the Expanded ANSI Method . Rather than generically impose the rigorous statistical tests of the Extended ANSI Method, additional test prerequisites and/or performance gu idelines should be used that achieve equivalent results. Upper Confidence Limit (UCL) values obtained using the ANSI 56.8 mass point method already measure the confidence placed in the accuracy of the LSF of the actual leakage rate. Obviously, a time dependent decrease in the difference between the UCL and the LSF indicates the scatter in data is constant or decreasing. Once this correlation is established, then each additional data set should increase the confidence in the LSF leakage rate.

Attachment to TXX-6255 April 24, 1987 Page 10 of 11 Several other less complex and easier to use approaches have been suggested that analyze the trends between the UCL and the LSF as well as their associated slopes. EPRI Report No. NP-3400 and a paper by Ted Brown published in the Proceedings of the 1982 ANS Containment Leakage Rate Testing Workshop are examples of proposed alternate methods. Although these methods were proposed to establish test duration, their application to control the quality of Type A test data is readily apparent. It is doubtful if the statistical tests of the Extended ANSI Method could be easily applied to the Type A test or the verification test with any meaningful and consistent results. A paper by Larry Young in NUREG/CP-0076 (Aug. 86) concluded that an iteration of inequality 1.2 used as a statistical test was too complex, would complicate the analysis of ILRT data, and exhibited erratic behavior in various test cases. Application of the two conditions of the Extended ANSI Method to the verification test is similarly not sufficiently justified nor demonstrated, especially considering that the verification is less than half the duration of the Type A test. Use of Condition 2 (Limit on Data Scatter) as a statistical criterion of the Type A test data is the more statistically acceptable and the easier to use of the two conditions of the Extended ANSI Methods. Despite this, use of UCL-LSF trend/slope analysis and better test execution are still favored over the statistical tests of the Extended ANSI Method.

14. Temperature Measurement:

14.1 Volume Fractions: Initial assignment and confirmation of sensors based on pretest surveys and volume fraction calculations is within the original intent of ANSI/ANS-56.8. It should be recognized that reassignment of a sensor's volume fraction based on pretest atmospheric survey results represents a conjectured engineering judgement of containment atmospheric conditions without explicit acceptance criteria. Primary concerns for a failed sensor must continue to be the satisfaction of ISG calculations and minimum sensor quantities. The Regulatory Position for review of volume fractions after the initial periodic test to determine their continued validity is a requirement lacking explicit basis or acceptance criteria and therefore not recommended. Acceptable compliance with this requirement could either require repeating a complete temperature survey or a simple evaluation of displayed sensor data with approximate ranges from previous tests. Unless a

Attachment to TXX-6255 April 24, 1987 Page 11 of 11 substantial containment design modification or system operation procedure is modified, significant deviations are not anticipated from initial survey results. The preoperational and initial periodic surveys are intended to establish and validate the positioning of the sensors within assigned volume fractions. Radical temperature differences should be discovered and measures taken to minimize their effects during these initial surveys. Until a definitive basis or clarification for periodic volume fraction review is established, it is recommended that the portion of this regulatory position requiring this review be deleted. 14.2 Drybulb and Dewpoint Temperature Surveys: 14.3 This requirement is acceptable; however, it will require performance of several temperature surveys. Several surveys will be required to validate various air circulation modes required due to seasonal, diurnal or operational variances .

15. Absolute Test Method:

This Position is endorsed and provides a mathematically correct equation for mean temperature to account for spatial temperature variations.

16. Reporting of Results:

This is an acceptable recommendation for report format and content.

           "As Found" and "As Left" test data will be provided consistent with Appendix J requirements.

17. Flow Rate:

Regulatory Positions regarding test fluid and air discharge method are endorsed by TU Electric.

18. Water Collection:

Use of the water makeup test method is an acceptable and extremely conservative technique. It should be recognized that this technique will also be employed on systems without adequate provisions for water collection (i.e., no drain point or multiple valve leakages at a common drain point).

19. Vacuum Retention:

This Regulatory Position is endorsed by TU Electric.

20. Recording of Leakage Rates:

This Regulatory Position is endorsed by TU Electric.

P. 0. BOX 14000, JUNO BEACH, FL 33408 FLORIDA POWER & LIGHT COMPANY

                                                 '87 APR 27 P12 :18 APRIL       ~ c H87 L-87-165 U. S. Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, D. C. 20555

• Gentlemen:

Re: IO CFR 50 Appendix J Proposed Rule Change The Nuclear Regulatory Commission (NRC) presented a proposed rule change to IO CFR 50 Appendix J, Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants in the Federal Register, Vol. 51, No. 209 on Wednesday October 29, 1986. The NRC requested comments from interested parties prior to adoption of the final rules. Attached are Florida Power & Light Company's (FPL) comments on the proposed rule changes, the necessity of the rule change, the benefits of the rule changes and the Commission's back fit analysis (IO CFR SO. I09) which concluded there was not a substantial increase in the overall protection of the public health or safety for the cost of implementing these rule changes. Should there be any further questions, please contact us. Very truly yours, sident Nuclear Energy COW/RG/gp Attachment MAYO 6 1987 Acknowledged by card ** ,,, , ;; , *** , ,,, , , ,w RG3/023/I PEOPLE . . . SERVING PEOPLE

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ATTACHMENT I COMMENTS ON LEAK RATE TESTING CONCERNS The Commission requested comments to 15 concerns that have been identified in the development and processing of the subject rule changes. FPL comments to those "especially requested" questions are provided below. I. The extent to which these positions in the proposed rule are already in use: FPL complies with the existing rules and methodology presented in Appendix J. Changes in methodology will mandate that FPL change the computer programs which calculate, verify and report the result of Appendix J testing.

2. The extent to which those in use, and those not in use but proposed, are desirable:

FPL utilizes the Bechtel Topical Report (BN-TOP-1) for instrument selection and test duration of Type A test. FPL sees no advantage in changing the accepted and proven (BN-TOP-1) methodology. Therefore the proposed new methodology is non-desirable and will be costly to implement (modify existing computer software and verify).

3. Whether there continues to be a further need for this regulation:

Yes, FPL utilizes the regulations found in Appendix J to meet Technical Specification and insurance requirements.

4. Estimates of the costs and benefits of this proposed revision, as a whole and of its separate provisions:

FPL will incur two types of cost, fixed one-time cost and on-going cost. The fixed one-time cost will occur from modifying computer software, verifying the code changes meet QA requirements and retraining test personnel. FPL operates Westinghouse and Combustion Engineering reactor designs. Therefore, two sets of computer codes will require modifying. This cost could approach one-half million dollars. The on-going costs are associated with the removal of reduced pressure testing. All four reactor containment building designs utilize large volume as opposed to negative pressure or ice condensers to meet accident requirements. The cost of a 24 hour - full pressure test will accumulate at approximately $300,000 per year for FPL. FPL will incur these costs with no increase to safety.

5. Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule (reflecting consideration of public comments) becomes effective:

FPL does not believe that the Commission should allow two sets of testing criteria. The Commission's reason for the proposed rule change was to unify and codify existing testing practices. RG3/023/2

6. If the existing rule or its proposed revision were completely voluntary, how many licensees would adopt either version in its entirety and why?

FPL would not adopt the proposed rule changes since the benefits do not overcome the economic impact and there is no increase in safety.

7. Whether (a) all or part of the proposed Appendix J revisions would constitute a "backfit" under the definition of that term in the Commission's Backfit Rule, and (b) there are parts of the rule which do not constitute backfits, but which would aid the staff, licensees, or both:

a) FPL would be required to backfit three of the older plants to meet changes in the definition of "containment isolation valve". FPL would also be required to modify the computer software that calculates the leakage rate in Type A test with no increase in safety or confidence that the calculated leak rate is correct. b) The rule change will aid those associated with leak rate testing by providing more definitions and a reworded acceptance criteria *

• 8. Since the NRC is planning a broader, more comprehensive review of containment functional and testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation:

If the Commission's review results in a rule change, FPL may be required to modify the new computer codes with the possibility of never having used the new codes. The cost of these modifications from the proposed rule changes would be incurred with no benefit.

9. The advisability of referencing the testing standard (ANSI/ANS 56.8) in the regulatory guide (MS 021-5) instead of in the text of Appendix J:

We strongly disagree with referencing a Reg Guide rather than the appropriate revision of the desired ANS/ANSI standard in Appendix J. We feel that Appendix J is so important that all changes must be in accordance with the rule-making procedures. If a Reg Guide is referenced, the prov1s1ons, evaluations and protections provided in the rule-making regulations are essentially eliminated. I 0. The value of collecting data from the "as found" condition of valves and seals and the need for acceptance criteria for this condition: FPL has been and will continue to collect the "as found" leak rate data because: a) it provides the information necessary to determine if preventive or corrective maintenance is required; b) allows containment leak rates to be calculated for Technical Specification compliance; c) current Appendix J rule requirements require the reporting of Type 1'8 11 and "C" test results; d) the "as found" trending of leak rates, is required by ASME Section XI, which requires a corrective action plan to be developed. RG3/023/3

11. Whether the technical specification limits on allowable containment leakage should be relaxed and if so, to what extent and why, or if not why not:

New source term criteria may allow for the relaxing of containment leak rates, however, FPL has not performed enough in-depth evaluations at this time to justify any changes to Technical Specification leak rates.

12. FPL has no comment.

13. What other approaches to validating containment integrity could be used that might provide detection of leakage paths as soon as they occur, whether they would result in any adjustments to the Appendix J test program and why:

FPL has reviewed proposals that would utilize tracer gases added to the contaiment atmosphere for routine monitoring at the containment surface during operation. These proposals were basic and provided for information

• 14.

purposes without validation testing. What effect "leak-before-break" assumption could have on the leakage rate test program. Current accident assumptions use instantaneous complete breaks in piping systems, resulting in a test program based on pneumatic testing of vented, drained lines. "Leak-before-break" assumptions presume that pipes will fail more gradually, leaking rather than instantly emptying. FPL notes that the leak-before-break assumption would allow for reactor shutdown thereby reducing the source term and containment pressures. Reduced pressure testing will measure a more realistic accident leak rate and still allow accurate peak pressure leak rates to be calculated.

15. How to effectively adjust Type A test results to reflect individual Type B and C test results obtained from inspections, repairs, adjustments, or replacements of penetrations and valves in the years in between Type A

• tests
• FPL's position concerning Type A test results, Type A test failures and containment integrity reporting requirements is as follows:

a) Type A test results, i.e. leak rate, should not be adjusted by prior modifications, repairs or adjustments. The Type A test result is the base line leak rate already measuring the minimum leakage pathway for each penetration. A Type A test should only be called a failure if the calculated or measured leak rate does not meet the Technical Specification criteria. b) The acceptance criteria for Type A test is .75 La. Type B and C test criteria is .6 La. There is no adjustment from one to another. c) The Type B and C tests identify which valves degrade with operation. Trending of this data, in accordance with ASME Section XI codes, would identify those valves which need a corrective action plan to prevent continued degradation. Increasing the frequency of the Type A test does not resolve the root cause of Type B" or "C" test failures. RG3/023/4

General Rule Comments I. One stated purpose of the rule change is to remove inconsistencies in the rule and therefore reduce exemptions requiring NRC and Utility attention. However, the proposed rule totally redefines "containment isolation valve" for the purposes of Appendix J testing and requires they be Type C tested every two years unless certain conditions are met. Every licensed plant will have to reevaluate their entire containment penetration system against the new definition and prove they meet the conditions of Ill C (4) (a) or request anexemption per Ill c (4) (b), or start more Type C testing. There is a fairly high probability that many of these plants will require design changes to meet the new criteria and allow testing to be done. This will add a tremendous utility and NRC work load to reevaluate, change technical specifications and process a potentially large number of exemption requests and likely a large number of rule challenges under the provisions of the bockfit rule.

• 2.

This alone probably invalidates the cost benefits for a rule the NRC admits shows "no substantial increase in the overall protection of the public health and safety". The cost benefit analysis (NUREG/CR-4398) hos a major misconception which, for PWRs, eliminates t h e ~ significant cost savings to utililties. The analysis assumes that utilities will save plant critical path outage time since the new rule will allow more frequent Type B and C testing rather than more frequent Type A testing in the event of failures of Type A test. This is not a valid assumption. For PWRs (and possibly some BWRs) a full set of Type B and C tests requires a plant shutdown and cooldown. A "partial" set of Type B and C tests on those penetrations which contributed to the Type A failure frequently will require a shutdown and cooldown depending on which penetrations are involved. All plants on a refueling cycle longer than 12 months already hove

• to do Type B and C tests each refueling. Thus the time "saved" by not having to do more Type A tests will be used, probably exceeded for PWRs, due to mid cycle shutdowns to do more frequent Type B and C testing.

Proper reevaluation of this (only major) positive cost benefit of the proposed rule will almost certainly show negative cost benefit. At best it shows that the existing NUREG/CR-4398 is seriously flowed.

3. The use of both minimum and maximum pathway leakage for calculations showing success or failure of Types A, B, and C testing has already been mandated by an l&E Information Notice.

It is our understanding that this portion of the rule change is of special importance to the NRC Staff. Because this aspect of testing is addressed under existing programs, it appears a rule change is unnecessary. RG3/023/5

4. On an individual penetration with 2 valves, use of the maximum pathway concept is a single failure as asserted in the discussion. However, the maximum pathway definition is actually to be applied to the entire containment isolation system. These systems are set up in independent trains. That is most penetrations have one "A" train valve and one independent 1'8 11 train valve. When maximum pathway leakage is used, assuming the "best" valve in each penetration fails, the rule would impose the requirement to assume multiple independent failures in Appendix J. This appears to conflict with previous uses of the single failure concept.

5. The proposed rule, the proposed Reg Guide and the ANS standard of leak testing all contain a near-requirement to calibrate test instruments used for Type B and C testing daily. The requirement should be to perform an instrument check daily on test equipment. This is because most utilities do not have the ability to calibrate flow instruments on site. This is probably the most restrictive calibration criteria in the nuclear industry, being applied (typically) to highly reliable pressure gauges and rotometers

• RG3/023/6

ATTACHMENT II COMMENTS ON PROPOSED RULE Florida Power & Light Company (FPL) comments on the proposed rule change to IO CFR 50 Appendix J. SECTION II Definitions Containment Isolation Valve: As stated in the proposed rules each penetration with a valve would become subject to a type B or C test. This would be impossible to do in the case of main steam and for those penetrations which are in operation. This would also cause FPL Plants to re-analyze each penetration into the containment and to request relief for those penetrations which do not need to be in the

• local leak rate program.

FPL's comment is to maintain the current definition of containment isolation valve dropping the reference to General Design Criteria 55, 56, and 57. Add the definition of: Pt (reduce pressure test) I. the term is utilized in Section B.i.b.3.a

2. the reduced pressure test should be maintained in the proposed rule since:

• Bases:

a) Test Duration: The duration of a full pressure test is longer and also more costly, this will increase the critical path time required to complete a Type A test and the cost of the rental equipment. b) Safety: The full pressure test increases the risk of fire due to increased oxygen content and the difficulty in fighting a fire. It will also increase the risk of damaging equipment in the containment. c) Representativeness: The full pressure test is not representative of the real pressure in the containment after an accident, because of conservative assumptions taken in calculating accident pressure and the real amount of time the pressure in the containment will be at ace ident pressure. RG3/023/7

SECTION Ill GENERAL LEAK TEST REQUIREMENTS FPL comment: Add the reduced pressure test as allowed in the current rule. A (I) a preoperational Type A test must be conducted on the containment system and must be preceded by *** Change must to "should" Current constructions schedules do not allow testing of containment systems with all penetration valves in place. Most pre-operational CILRTs required temporary flanges which were later replaced when qualified valves arrived on site. The proposed rule should recognize the actual construction schedule *

• A (3)

             ... Type A test must not exceed four years.

Change four years to "three refuelings". Some current Technical Specifications and outage schedules are based on refuelings, not years. This change would eliminate the need for the discussion that was added to the Regulatory Guide MS 021-5, Section 5. A.7.C FPL comments that this section has clarified the existing rule and is beneficial to both the leak rate test team and the regulator. A.8 *

• FPL comments that the incorporation of a corrective action plan for Type A, B and C test is beneficial. This plan will resolve the root cause of the failure and eliminate the need for increasing the test frequency without fixing the underlying root case of the failure.

Section 111.B.3.a Airlocks The statement "Reduced pressure tests must continue to be performed on the air lock or its door seals at 6-month intervals." Ths statement is not consistent with the first sentence which states "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 Pac." FPL requests rewording of this section for clarity. The term "Reduced pressure test" needs to be defined. RG3/023/8

D CKETEO US~IRC

                                                !iY!iTEM ENERGY RE!iDURCE!i, INC.                            '87 APR 27 P2 :23 0.M:R D. KINGSLEY, JR Vice President                                                     April 24, 1987 Nuclear Operations                                                                    Off!Cc vF SELr.~. -,., ;:

OOCKHl ~iG & ',tRVIC r: BRANCH U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk Gentlemen:

SUBJECT:

Grand Gulf Nuclear Station Unit 1 Docket No. 50-416

• License No. NPF-29 Proposed Revision to Appendix J AECM-87/0088 The purpose of this letter is to provide System Energy Resources, Inc.

(SERI) comments on the proposed revision to Appendix J of 10CFR50. The proposed revision to Appendix J was published in the Federal Register on October 29, 1986. Additional ly SERI endorses the comments made by the Boiling Water Reactor Owners Group on the proposed revision to Appendix J. Attachment I contains comments on the proposed revision to Appendix J of 10CFR50. Attachment II contains comments on the Draft Regulatory Guide, Task 021-5 and Attachment III provides the SERI response to the "Invitation to Comment" questions from the Federal Register, October 29, 1986. If additional information is required, please contact this office. ODK:mbl Attachment cc: Mr. T. H. Cloninger (w/a) Mr. R. B. McGehee (w/a) Mr. N. s. Reynolds (w/a) Mr. H. L. Thomas (w/o) Mr. R. C. Butcher (w/a) Dr. J. Nelson Grace, Regional Administrator (w/a) U.S. Nuclear Regulatory Commission Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 P O BOX 2YJ70 I JACKSON. MISSISSIPPI 39225-3070 I (601) 960-Wf:X) A Middle South Ut1l1t1es Company J18AECM87042001 - 1 _MAY O6 1987

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ATTACHMENT I to AECM-87/0088 SYSTEM ENERGY RESOURCES, INCORPORATED (SERI) COMMENTS ON PROPOSED REVISION OF IOCFR50, APPENDIX J Note: The proposed revision to Appendix J of IOCFR50 as published in the Federal Register on October 29, 1986 (Vol. 51, No. 209, pp. 39538-39544) will be referred to as the 11 Revision 11 and Appendix J which is currently in effect and published in IOCFR50 will be referred to as the 11 Rule 11

• Section II: Definitions

1. The term "Containment Integrated Leak Rate Test (CILRT)" is not used in the Revision except in the last sentence of the definition of Type A test as a reference ( 11 * * * - see CILRT. 11 ) The definition of CILRT and the reference under "Type A Test" should be deleted.

The terms "Containment Isolation System Functional Test" and Containment Leak Test Program" are not used in the Revision. Definitions of these terms should be deleted.

3. The definitions of Maximum Pathway Leakage and Minimum Pathway Leakage are somewhat simplistic. They assume all containment penetrations consist of a single inboard isolation valve and a single outboard valve in series.

Many containment penetrations have two or more inboard and/or outboard isolation valves in parallel. These definitions should be flexible enough to accommodate any containment penetration design. SERI suggests that the definition of Maximum Pathway Leakage be expanded to include the concepts in ANSI/ANS Standard 56.8-1981, Section 6.6 and that the definition of Minimum Pathway Leakage be expanded to include the guidance in Discussion Section 3 of IE Information Notice 85-71.

4. The terms "Periodic Leak Test" and "Preoperational Leak Test" are defined but not used in the Revision. The following terms are actually used:

• TERM Preoperational Test Preoperational Type A Test Periodic Test WHERE USED III.A. (1)

III.A.(!) III.A.(2) Periodic Type A Test III.A.(2) Initial and Periodic Tests III.B.(3).(a) Initial or Periodic Full-Pressure Test III.B.(3).(b).(iii) Regularly Scheduled Type A Test IV.A Preoperational and Periodic Type A Tests VI.A.I Periodic Type Band C Tests VI.A.2 The terms "Periodic Leak Test" and "Preoperational Leak Test" should be changed to terms consistent with the content and intent of Appendix J. Definitions as well as corresponding terms used throughout the Revision should be revised as necessary to provide consistency. The preferred revision would be to delete the word leak" in both definitions since no other changes would be necessary. Jl6ATTC87042201 - I

ATTACHMENT I to AECM-87/OO88 SERI COMMENTS ON PROPOSED REVISION OF 10CFR5O, APPENDIX J

5. The words "Verification Test" should be removed from the end of the Type C Test definition and formatted as a separate definition.

(typographical correction) Section III: General Leak Test Requirements A. Type A Test Paragraph III.A.(7).(a) and (b) - Acceptance Criteria The phrase, 11 * *

• as determined by a properly justified statistical analysis, ... 11 in both of these paragraphs should be deleted or clarified.

The meaning of this phrase is not clear and could be interpreted to mean

• only analyses or analysis techniques which are specifically approved by the NRC prior to the Type A Test. It should be noted that in SERI's experience Type A Testing results are routinely reviewed by NRC inspectors and the analytical methods scrutinized.

Paragraph III.A.(8).(a) - Retesting

1. This paragraph addresses a new requirement, the Corrective Action Plan (CAP). The CAP described in the Revision is considerably more formal than corrective actions in the Rule and will require a significant effort by the utility to compile and report.

2. SERI questions the need for the NRC to review and approve a subsequent test schedule following a single Type A Test failure. The schedule for periodic Type A Tests is clearly specified in the Revision and in the Rule. Therefore the second sentence of this paragraph should be deleted .

• Paragraph III.A.(8).(b).(i) and (ii)

1. The Revision by allowing alternatives to increasing the frequency of Type A tests after two consecutive Type A test failures is a significant improvement over the Rule's requirements by recognizing that increased Type A testing may not be in the best interest of the public or the utility. However additional improvements can be made. Type A test failures are often caused by leakage through locally-testable barriers.

In this case increased frequency of Type B or C testing is required for the failed penetration(s). The formality of requiring the utility to prepare and submit an alternate leakage test program and requiring the NRC to review and approve the program is costly and time-consuming. These two paragraphs should be rewritten to require increased frequency Type Band C testing when that is clearly the appropriate action, without requiring NRC approval.

2. See Comment 1 to Paragraph III.A.(8).(a) regarding Corrective Action Plan, which is also applicable to Paragraph III.A.(8).(b).(ii).

Jl6ATTC87O422O1 - 2

ATTACHMENT I to AECM-87/OO88 SERI COMMENTS ON PROPOSED REVISION OF 10CFR5O, APPENDIX J B. Type B Test Paragraph III.B.(1).(b)

1. The second, third, and fourth sentences of this paragraph are new requirements which were not addressed in the NRC's Backfit Analysis. The third and fourth sentences are Type A test requirements and should be included in Section III.A.

2. Grand Gulf Nuclear Station (GGNS) does not have containment penetrations that employ a continuous leakage monitoring system. The Revision by use of a 11

                       *** such as ... " statement in the fourth sentence would include inflatable air lock door seals in a continuous leakage monitoring category. The Revision would require the leakage from these door seals be

• * *
• accounted for and the Type A test results corrected accordingly."

11 "Accounted for" is an ambiguous term and subject to interpretation. The inflatable door seal systems on the containment air locks at GGNS were not designed for continuous leakage monitoring. Currently there are no means to account for the leakage without modifications to the airlocks, other than examining the door seal system tubing and components visually for leakage with leak detection fluid. GGNS Technical Specifications require periodic surveillances of the air lock door seal system for leakage which provides adequate assurance that any leakage from the system will be insignificant. The fourth sentence should be revised to exclude inflatable air lock door seals or the requirement to account for leakage should be clarified regarding the airlock door seal air systems installed at many nuclear plants. Paragraph 111.B.(3) - Air Locks

1. Paragraphs III.B.(3).(a) and III.B.(3).(b).(iii) discuss "reduced pressure tests" on air locks. Paragraph III.B.(3).(b) uses the term "intermediate pressure tests. 11 These terms are not defined in the Revision. If the concept of reduced-pressure or intermediate-pressure testing of air locks or their components is to be included in the Revision the terms should be defined with detailed requirements and instructions included.

2. GGNS conducts all Type B testing of air locks and their components at or above Pa. How GGNS would comply with reduced pressure and or intermediate pressure testing requirements is not clearly defined in the Revision.

J16ATTC87O422O1 - 3

ATTACHMENT I to AECM-87/OO88 SERI COMMENTS ON PROPOSED REVISION OF 10CFR5O, APPENDIX J Paragraph III.B.(4).(a) - Acceptance Criteria This paragraph specifies a new acceptance criterion requirement for 11 as found" Type Band C leakage. Due to increased Type B testing alone a substantial cost increase would be incurred since all Type B penetrations which are routinely opened at the beginning of each outage would require "as found" testing before they could be opened. At GGNS this includes the containment equipment hatch, the fuel transfer tube door, and two containment air locks. If welds in process piping protected by guard pipes are to be inspected to ASME Code Section XI requirements during the outage up to 22 guard pipe closure seals must also be tested. These tests could have a direct impact on critical path time since the outage could not proceed until "as found 11 testing was complete. The fuel transfer tube door test requires that the fuel transfer canal inside containment be

• drained. Draining the fuel transfer canal is prohibited during reactor operation. Therefore this test could impact refueling operations for a full day or more. Few 11 as found 11 Type B tests could be performed during operation prior to a scheduled outage. These 11 as found" tests could also be required at the beginning of unscheduled outages, often without adequate time to prepare and could directly impact critical path outage time. Replaced power costs alone make "as found 11 acceptance criterion a significant increase in costs. The 11 as found" acceptance criterion should be deleted until the Backfit Analysis addresses the above concerns.

2. This paragraph specifies that both 11 as found" and "as left" combined Type Band C leakage be calculated using the maximum pathway leakage concept. As noted in the definition in Section II of the Revision, this concept assumes a single active failure of the lowest leak rate of two leakage barriers in series. The maximum pathway leakage concept may be appropriate for 11 as left" leakage calculations since that calculation is used to determine if the plant is ready for service. It is not appropriate for "as found" leakage calculations since that calculation documents leakage after the service period is complete. When GGNS shuts down for Type Band C testing the condition of each leakage barrier including any failures is known. The combined Type Band C leakage should be calculated (subject to Comment 1 on this paragraph) to sum leakage across each overall containment penetration which is a minimum pathway leakage concept and should be used in calculating "as found" combined Type Band C leakage.

3. The requirement to include leakage from continuous leakage monitoring systems in the combined Type Band C leakage totals is a new requirement.

Due to including inflatable air lock door seal systems in the definition (in Paragraph III.B.(1).(b), last sentence) it may be difficult or impossible for GGNS to meet this requirement without modifications. This is a significant increase in the requirements of Appendix J that was not addressed in the NRC's Backfit Analysis and should be deleted from the Revision.

4. These comments, with appropriate corrections for Type C versus Type B, are also applicable to Paragraph III.C.(3).(a).

J16ATTC87O422O1 - 4

ATTACHMENT I to AECM-87/OO88 SERI COMMENTS ON PROPOSED REVISION OF 10CFR5O, APPENDIX J Paragraph III.C.(2).(a) - Pressure/Medium

1. The phrase 11 * *

• unless pressurized with a qualified water seal system ... 11 implies that the seal system must be pressurized above atmospheric pressure. Numerous valves at GGNS are open to the suppression pool which provides the water seal; however, the suppression pool is at atmospheric pressure. If the suppression pool does not qualify as a pressurized water seal it would be difficult to perform pneumatic Type C testing on these valves without extensive modifications. Paragraph III.C.(2).(b) uses the word 11 sealed 11 instead of 11 pressurized. 11 In the interest of clarity and consistency the word 11 pressurized 11 in paragraph III.c.(2).(a) should be changed to 11 sealed 11 *

2. The meaning of the word 11 qualified 11 in describing the water seal system is

• unclear. 11 Qualified water seal system 11 should be defined or the word 11 qualified 11 should be deleted.

Paragraph III.C.(3) - Acceptance Criteria The comments on Paragraph III.B.(4).(a), with appropriate corrections for Type C versus Type B, are also applicable to this paragraph. Section IV: Special Leak Test Requirements Paragraph A. - Containment Modification or Maintenance

1. Deletion of the word 11 major 11 and addition of the word 11 repair 11 to the first sentence is an increase in the scope of this paragraph and constitutes new requirements. This new requirement should be subjected to a Backfit Analysis.

• 2. The fourth sentence should be deleted regarding structural repairs. The method and details of demonstrating the structural integrity of the pressure boundary is not discussed in the Revision. As this is a new requirement the demonstration of structural integrity should be subject to a Backfit analysis.

3. The last two sentences, beginning with 11 * *

• Type A testing of certain minor modifications ... 11 are of value in clarifying certain retest requirements. Some additional clarification is needed. If the intent of the revision is met the last three lines of the paragraph should be replaced with the following:

11 Non-isolable piping welds attaching to pressure retaining boundary penetrations, the nominal pipe diameters of which do not exceed one inch." J16ATTC87O422O1 - 5

ATTACHMENT I to AECM-87/0088 SERI COMMENTS ON PROPOSED REVISION OF 10CFR50, APPENDIX J Section V: Test Methods, Procedures, and Analyses Paragraph B - Combination of Periodic Type A, B, and C Tests

1. See Comment 1 to Paragraph III.B.(4).(a) regarding "as found" leakage acceptance criteria as a new requirement. Reporting "as found" leakage is also a new requirement which has no benefit to the utilities or to the safety and health of the general public. "As found" should be deleted as a requirement.

2. The concept of determining Type A, Band C leakage on an 11 as-found 11 basis is of no use in predicting the incipient failure of containment or penetration integrity. Type Band C test results at GGNS have not shown any pattern of leakage trends. The Type A, B, and C test results are

• useful only to determine the integrity of the containment boundary and penetration at a given point in time. Determining and reporting "as found" leakage should not be required.

SECTION VI: REPORTS Paragraph A. 2 - Submittal

1. Submittal of all periodic Band C test results is a new requirement and subject to the Backfit Analysis required by 10CFR50.109. The extra cost to the utility to compile and report the additional test results does not increase the safety and health of the public. If there are concerns, the NRC has access to a plant's Type Band C test results through the Resident Inspectors. The first sentence should be deleted.

• 2. The second sentence should also be deleted for the following reasons .

a. Neither the Rule nor the Revision contains acceptance criteria for individual penetrations or tests. The only acceptance criteria for Type Band C testing are for combined leakage rates. The only reporting that could be made per this paragraph would be when the combined Type Band C leakage exceeded the acceptance criteria. The individual test result that caused the acceptance criteria to be exceeded might not be the significant contributor to the excessive leakage. Therefore attention could be focused on the wrong penetration.

J16ATTC87042201 - 6

ATTACHMENT I to AECM-87/0088 SERI COMMENTS ON PROPOSED REVISION OF 10CFR50, APPENDIX J

b. In accordance with GGNS Technical Specification 3.6.1.2.b (Applicability) the combined Type Band C leakage acceptance criteria are applicable only in Modes 1, 2 and 3. Since the majority of Type Band C tests are performed in Modes 4 and 5 there is no Technical Specification requirement violated if combined Type Band C leakage exceeds the acceptance criteria during modes 4 and 5. It is not valid to assume that the plant has been operated without adequate containment integrity during Modes 1, 2 and 3, based solely on results of tests performed some time after the plant has been shut down.

Paragraph B - Content Comment 1 on Paragraph III.A.(8).(a), regarding the CAP being a new

• requirement, is also applicable to this paragraph .

J16ATTC87042201 - 7

ft:

ATTACHMENT II to AECM-87/0088 SERI COMMENTS ON DRAFT REGULATORY GUIDE, TASK MS 021-5, DATED OCTOBER, 1986 C. Regulatory Position 3: Pressurizing Considerations The regulatory position and Paragraph 3.2.1.7 of ANSI/ANS 56.8 - 1981 do not consider potential sources of gas leakage which cannot be isolated or vented because they are essential to containment sealing. The inflatable door seals on the containment air locks at Grand Gulf Nuclear Station (GGNS) and at some other plants are required to be pressurized above Pa for sealing the doors. Portions of the seal system are located inside the containment boundary. These systems are not designed as continuous leakage monitoring systems (see Comment 2 on Paragraph III.B.(1).b of the proposed Appendix J Rule Revision in Attachment I). This regulatory position

• 6.1:

should address non-isolable pressure sources. Verification Test The supplemental Paragraphs (5) and (6) should be changed to the following: 11 (5) The start time for the verification test should be as soon as the new test conditions have stabilized for the verification test following each Type A test. 11 (6) Data acquisition should not be interrupted without justification from the end of the successful Type A test to the start of the verification test. In some cases, this period of time could be several hours and should not be considered to be part of either the Type A test or the verification test. Data acquisition should also not be interrupted without justification from the start to the finish of the verification test. 11 11.3: Calibration To require calibration (not just calibration check) of all Type Band C test instruments on a daily basis would place undue hardship on utilities. This requirement would require each utility to purchase large numbers of additional pressure gauges, rotometers, thermometers, etc., to replace those that were being calibrated and to expend additional manpower to calibrate the instruments. For many plants the instruments (rotometers) cannot be calibrated onsite and must be sent to outside laboratories for calibration. Due to scheduling policies of these labs there may be a turn-around time of several weeks during which the instruments are off site and unavailable for use. As these instruments are generally needed for testing everyday in an outage there could be a significant impact on an outage schedule. J16ATTC87042202 - 1

ATTACHMENT II to AECM-87/0088 SERI COMMENTS ON DRAFT REGULATORY GUIDE, TASK MS 021-5, DATED OCTOBER, 1986 In view of the fact that utilities are required to maintain acceptable calibration programs and evaluate the effects on the plant of any instrument that fails calibration, daily calibration is not justified. This regulatory position should be deleted. 13.1: Data Recording And Analysis This regulatory position should be deleted. It does not improve the data of the Type A test and could cost the utility additional plant controlling time. As long as the recorded data indicates that the Type A test has satisfied all validity requirements, the start time should not be of concern, even if it was not declared until all data collection was completed .

• 16: Reporting Of Results Reporting of "as found" Type Band C leakage results should not be required. See comments on the Proposed Appendix J Revision in Attachment I .

Jl6ATTC87042202 - 2

ATTACHMENT III to AECM-87/OO88 SERI RESPONSES TO INVITATION-TO-COMMENT QUESTIONS

1. THE EXTENT TO WHICH THESE POSITIONS IN THE PROPOSED RULE ARE ALREADY IN USE.

Response: Grand Gulf Nuclear Station (GGNS) has adopted a number of the positions in the proposed rule, but not all of them. SERI conducts Type A tests in accordance with Bechtel Topical Report BN-Top-1 and reports the leakage rate by both mass point and total time calculational methods. SERI corrects leakage for the Type A test by minimum pathway leakage but SERI sums the leakage of all tested valves and penetrations to determine combined Type Band C leakage. SERI could not implement those portions of ANSI/ANS 56.8 which conflict with the existing Appendix J and ANSI N45.4 standard. The NRC Region II Inspector required SERI to maintain containment pressure above Pa

• 2.

throughout the last Type A test and verification test. THE EXTENT TO WHICH THOSE IN USE, AND THOSE NOT IN USE BUT PROPOSED, ARE DESIRABLE. Response: Desirable proposed positions include the following:

a. Endorsing an updated standard.

b. Clarification of calculation of leakage by minimum pathway leakage (Type A test) and maximum pathway leakage {Type Band C tests).

c. Possibility of alternatives to increased frequency Type A testing.

d. Uncoupling the Type A test schedule from the 1O-year Inservice Inspection Outage.

e. Clarification of when and how much the Type A test pressure may

• f.

drop below Pa . Attempt to clarify that some minor modifications to non-isolable penetrations do not require a Type A test immediately. Conversely a number of the proposed positions are new requirements and are not desirable. It is desirable that the current rules on these positions be maintained. The proposed positions include the following:

a. Requirement to sum "as found" Type Band C leakage which requires pre-maintenance testing.

b. Requirement to report individual Type Band C test results in the Type A test reports.

c. Corrective Action Plans.

d. Acceptance criteria for "as found" Type A test.

e. Extending the containment boundary through the definition of Containment System.

f. Possibility of a second pre-operational Type A test.

g. Including inflatable air lock door seals within the meaning of continuous leakage monitoring systems.

J16ATTC87O422O3 - 1

ATTACHMENT III to AECM-87/OO88 SERI RESPONSES TO INVITATION-TO-COMMENT QUESTIONS

3. WHETHER THERE CONTINUES TO BE A FURTHER NEED FOR THIS REGULATION.

Response: Numerous studies indicate that the regulatory requirements regarding containment leakage rate are orders of magnitude more restrictive than they need to be to safeguard the health and safety of the public. Timely application of the results of these studies should be made to lessen the considerable expense and time required to perform the testing required by this regulation.

4. ESTIMATES OF THE COSTS AND BENEFITS OF THIS PROPOSED REVISION, AS A WHOLE AND OF ITS SEPARATE PROVISIONS.

Response: If the scope of the revision is limited to corrections and clarifications the additional costs of complying with the proposed

• requirements should be essentially zero and the benefits should be mostly intangible.

Unfortunately, the proposed revision contains several new requirements which will increase the costs of complying with this revision:

a. Performing "as-found" Type Band C testing is estimated to average approximately twelve additional Type B/C tests per refueling outage.

Each of these tests requires approximately six man-hours direct labor for a total of 72 man-hours per outage. Radiation exposure is dependent on which components must be tested and could range from near zero to several man-rem of added exposure. Tests are assumed to take place during scheduled outages. During such outages there is sufficient other work and adequate planning to keep any "as-found" testing off the critical path. Therefore, replaced power cost is ignored. If "as-found" testing is required before critical corrective maintenance during an unscheduled outage, replaced power cost (at approximately $1 million per day) for the time needed to prepare for, set up, perform, and recover from the test must be included. This time and cost could range from as little as 4 hours ($170,000) for the containment equipment hatch removal to several days if the test boundary involves several systems.

b. The possibility of requiring a second preoperational Type A test is a significant additional expense. It is most likely to occur just when the plant is ready for initial criticality or initial power ascension. It would require about a week for set up, performance, and recovery. It is unlikely that any critical maintenance or construction could be in progress at this time.

The whole seven days would be critical path time and the replaced power cost of $7 million would be the most important cost. J16ATTC87O422O3 - 2

ATTACHMENT III to AECM-87/0088 SERI RESPONSES TO INVITATION-TO-COMMENT QUESTIONS

c. The remaining new requirements are more difficult to quantify in terms of cost and man hour increases. They involve knowing the leak tightness condition of plant components in the future. It is likely that some additional cost would be incurred if the proposed revision were issued in its present form.

5. WHETHER PRESENT OPERATING PLANTS OR PLANTS UNDER REVIEW SHOULD BE GIVEN THE OPPORTUNITY TO CONTINUE TO MEET THE CURRENT APPENDIX J PROVISION IF THE PROPOSED RULE BECOMES EFFECTIVE.

Response: Due to the new requirements in the proposed rule and the need for backfit analyses, some plants may not be able to meet the new requirements of the proposed rule without extensive and expensive modifications. These plants should be allowed to continue using their present programs. IF THE EXISTING RULE OR ITS PROPOSED REVISION WERE COMPLETELY VOLUNTARILY, HOW MANY LICENSEES WOULD ADOPT EITHER VERSION IN ITS ENTIRETY AND WHY. Response: GGNS would not adopt either version in its entirety and SERI expects that no other licensee would do so. While the proposed regulation resolves some of the problem areas that are present in the current rule, it creates others. For example, there continues to be confusion regarding the scope of the Type C test program and what does and does not require testing. New requirements in the proposed revision would increase the cost of complying with the proposed revision and could require extensive backfitting. GGNS would probably have a containment integrity testing program, possibly in accordance with ASME Section XI, but the exact scope of that program is beyond this discussion.

• 7. WHETHER (A) ALL OR PART OF THE PROPOSED APPENDIX J REVISIONS WOULD CONSTITUTE A 11 BACKFIT 11 UNDER THE DEFINITION OF THAT TERM IN THE COMMISSION'S BACKFIT RULE, AND (B) THERE ARE PARTS OF THE RULE WHICH DO NOT CONSTITUTE BACKFITS, BUT WOULD AID THE STAFF, LICENSEES, OR BOTH.

Response: There are a number of changes in the proposed revision that are either clarifications or enhancements and would not require analysis under the NRC's backfit rule. However certain items such as "as found" testing and acceptance criteria, a second preoperational Type A test, and extension of the containment boundary, do constitute backfits and should be subjected to an adequate backfit analysis.

8. SINCE THE NRC IS PLANNING A BROADER, MORE COMPREHENSIVE REVIEW OF CONTAINMENT FUNCTIONAL AND TESTING REQUIREMENTS IN THE NEXT YEAR OR TWO, WHETHER IT IS THEN STILL WORTHWHILE TO GO FORWARD WITH THIS PROPOSED REVISION AS AN INTERIM UPDATING OF THE EXISTING REGULATION.

Response: Judging by SERI comments and those of other utilities and industry groups, it is apparent that the proposed revision in its present form is not a desirable alternate to the existing rule. It will take J16ATTC87042203 - 3

ATTACHMENT III to AECM-87/0088 SERI RESPONSES TO INVITATION-TO-COMMENT QUESTIONS considerable revision plus at least one more interim draft for public comments before the revision should become law. NRC resources could be better utilized by incorporating this proposed revision (with public comments) into the more comprehensive review.

9. THE ADVISABILITY OF REFERENCING THE TESTING STANDARD (ANSI/ANS 56.8) IN THE REGULATORY GUIDE (MS 021-5) INSTEAD OF IN THE TEXT OF APPENDIX J.

Response: ANSI/ANS 56.8 should be referenced in the proposed rule. This will ensure public notice and review plus appropriate application of the Backfit Rule prior to issue.

10. THE VALUE OF COLLECTING DATA FROM THE "AS FOUND" CONDITION OF VALVES AND SEALS AND THE NEED FOR ACCEPTANCE CRITERIA FOR THIS CONDITION .

• Response: Collecting data from the "as found" condition of valves and seals has no obvious value. It would require extra time and manpower to perform. GGNS has not seen any evidence that Type Band C leakage rates can be trended which would be the only obvious benefit of "as found" testing. Requiring "as found testing would increase personnel needs, could increase personnel radiation exposure, and could impact operational scheduling. "As found" testing should not be required.

11. WHETHER THE TECHNICAL SPECIFICATION LIMITS ON ALLOWABLE CONTAINMENT LEAKAGE SHOULD BE RELAXED AND IF SO, TO WHAT EXTENT AND WHY, OR IF NOT, WHY NOT.

Response: It is evident from published reports (WASH-1400, the final report of the ANS Committee on the Source Term, NUREG/CR-4330) that there is already sufficient justification to relax the limits on containment

• 12.

leakage. The evidence indicates that current technical specification limits on allowable containment leakage are more conservative by at least one order of magnitude than the limits needed to adequately protect the health and safety of the public. WHAT RISK-IMPORTANT FACTORS INFLUENCE CONTAINMENT PERFORMANCE UNDER SEVERE ACCIDENT CONDITIONS, TO WHAT DEGREE THESE FACTORS ARE CONSIDERED IN THE CURRENT TESTING REQUIREMENTS, AND WHAT APPROACHES SHOULD BE CONSIDERED IN ADDRESSING FACTORS NOT PRESENTLY COVERED. Response: The Appendix J testing requirements were formulated to insure containment integrity during design basis accident conditions. The Appendix J testing requirements are not intended to insure containment integrity during the severe accident conditions. Sufficient evaluation of severe accident conditions has not been performed to determine what the significant parameters are or what type of testing would be required to verify containment integrity during such an accident. The present J16ATTC87042203 - 4

ATTACHMENT III to AECM-87/0088 SERI RESPONSES TO INVITATION-TO-COMMENT QUESTIONS Appendix J testing requirements are orders of magnitude more conservative than required to verify containment integrity during design basis accidents and may also be conservative for severe accident conditions. No additional testing requirements should be specified unless future evaluations of severe accidents indicate such additional testing is needed.

13. WHAT OTHER APPROACHES TO VALIDATING CONTAINMENT INTEGRITY COULD BE USED THAT MIGHT PROVIDE DETECTION OF LEAKAGE PATHS AS SOON AS THEY OCCUR, WHETHER THEY WOULD RESULT IN ANY ADJUSTMENTS TO THE APPENDIX J TEST PROGRAM AND WHY.

Response: The majority of Type A test failures with the exception of when work has actually been done on the containment boundary are due to leakage through locally testable penetrations. It may be preferable to allow a

• continuous containment leakage monitoring system in conjunction with Type Band C testing program to substitute for periodic Type A testing. The preoperational Type A test could still be required as would Type A tests after major repairs, replacements, and modifications to non-isolable portions of the containment pressure boundary. The cost of the continuous leakage monitoring system (assuming one could be developed) could partially be offset by deleting the periodic Type A test requirement.

14. WHAT EFFECT LEAK-BEFORE-BREAK" ASSUMPTIONS COULD HAVE ON THE LEAKAGE TEST PROGRAM. CURRENT ACCIDENT ASSUMPTIONS USE INSTANTANEOUS COMPLETE BREAKS IN PIPING SYSTEMS RESULTING IN A TEST PROGRAM BASED ON PNEUMATIC TESTING OF VENTED, DRAINED LINES. "LEAK-BEFORE-BREAK" ASSUMPTIONS PRESUME THAT PIPES WILL FAIL MORE GRADUALLY, LEAKING RATHER THAN INSTANTLY EMPTYING.

Response: It is possible that many penetrations which are currently Type C tested with air could be water tested, thereby eliminating the need to

• drain and refill the lines. Some penetrations which are currently tested with water might be eliminated from the testing program altogether. It is probable that all test connection valves within the penetration boundaries could be eliminated from the testing program by substituting a valve and cap control program. A number of penetrations which are currently vented and drained for the Type A test could remain water filled. It may even be shown that the allowable leakage rates for Type A, Band C tests could be raised. Specific details would have to be determined by new accident analyses.

15. HOW TO EFFECTIVELY ADJUST TYPE A TEST RESULTS TO REFLECT INDIVIDUAL TYPE B AND C TEST RESULTS OBTAINED FROM INSPECTIONS, REPAIRS, ADJUSTMENTS, OR REPLACEMENTS OF PENETRATIONS AND VALVES IN THE YEARS IN BETWEEN TYPE A TESTS . . . . CURRENTLY BEING DISCUSSED BY THE NRC STAFF ARE:

A. ALL TYPE BAND C TESTS PERFORMED DURING THE SAME OUTAGE AS A TYPE A TEST, OR PERFORMED DURING A SPECIFIED TIME PERIOD (NOMINALLY 12 MONTHS) PRIOR TO A TYPE A TEST, BE FACTORED INTO THE DETERMINATION OF A TYPE A TEST "AS FOUND" CONDITION. Jl6ATTC87042203 - 5

ATTACHMENT III to AECM-87/0088 SERI RESPONSES TO INVITATION-TO-COMMENT QUESTIONS B. IF A PARTICULAR PENETRATION OR VALVE FAILS TWO CONSECUTIVE TYPE B OR C TESTS, THE FREQUENCY OF TESTING THAT PENETRATION MUST BE INCREASED UNTIL TWO SATISFACTORY B OR C TESTS ARE OBTAINED AT THE NOMINAL TEST FREQUENCY .... C. I NC REAS ES OR DECREASES IN TYPE B OR C II AS FOUND" TEST RE SUL TS (OVER THE PREVIOUS "AS LEFT" TYPE B OR C TEST RESULTS) SHALL BE ADDED TO OR SUBTRACTED FROM THE PREVIOUS "AS LEFT" TYPE A TEST RESULT. I. IF THIS SUM EXCEEDS 0.75 LA BUT IS LESS THAN 1.0 LA, MEASURES SHALL BE TAKEN TO REDUCE THE SUM TO NO MORE THAN 0.75 LA. THIS WILL NOT BE CONSIDERED A REPORTABLE CONDITION .

• II. IF THIS SUM EXCEEDS 1.0 LA, MEASURES SHALL BE TAKEN TO REDUCE THE SUM TO NO MORE THAN 0.75 LA. THIS WILL BE CONSIDERED A REPORTABLE CONDITION.

III. THE EXISTING REQUIREMENTS THAT THE SUM OF ALL TYPE BAND C TESTS BE NO GREATER THAN 0.6 LA SHALL ALSO REMAIN IN EFFECT. Response: Adjusting Type A test results for Type Band C tests performed between Type A tests should not be required. The Type A test determines the leak tightness of the containment in one configuration only and at one point in time. Due to the requirement to drain and vent all penetrations that might be exposed to containment atmosphere and to perform the test for 8 to 24 hours at or above peak accident pressure, the test results must be considered conservative. The design basis accident assumes a single active

• • failure in addition to the initiating event. Therefore not all the penetrations that are drained and vented for the Type A test would be exposed to containment atmosphere during an accident. In addition containment pressure is at peak accident pressure for only a short time during the accident scenario and rapidly drops to a much lower pressure which is maintained for the duration of the accident. If leak-before-break assumptions were used for the design basis accident it is probable that peak accident pressure would be considerably reduced.

There is no evidence to indicate that Type A test results can be trended to provide interpolation of results from one test to the next. There is evidence to indicate that the major contributor to the Type A test leakage rate is the leakage through the vented and drained penetrations. Since Type Band C combined leakage is already required to be compared to 0.60 La (which provides a substantial buffer for degradation between tests) and the "as left" acceptance criterion of 0.75 La for the Type A test provides a separate buffer for degradation, none of the methods being considered by the NRC should be implemented. J16ATTC87042203 - 6

Georgia Power Company O.DtKET NUM&ERP ~ 333 Piedmont Avenue Atlanta, Georgia 30308

                                                ~_sfll (llJllj     -.fJ . rd.::µ Telephone 404 526-6526

( j7 FR, jcf,-5tf Mailing Address: DOC EiEO A_ Post Office Box 4545 USN. C ~ Atlanta, Georgia 30302

                                                    -S7 APR 27 p 2 :22 Georgia Power L. T. Gucwa                                                             the southern electric system Manager Nuclear Safety and Licensing SL-1877 0016U April 22, 1987 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C.         20555 Attn: Docketing and Service Branch GEORGIA POWER COMPANY COMMENTS ON PROPOSED RULEMAKING REGARDING LEAKAGE RATE TESTING OF CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS

Dear Mr. Chilk:

On October 29, 1986, the Nuclear Regulatory Commission (NRC) published in the Federal Register and solicited public comments on a proposed rule which would make changes to the existing leakage rate testing requirements (for containments of light-water-cooled nuclear power plants) contained in Appendix J to 10 CFR 50. Draft Regulatory Guide MS 021-5 was referenced in the notice with an indication that it may be used by the NRC to implement the requirements of this proposed revision to Appendix J. The Federal Register notice al so presented a set of fifteen questions for which responses were requested. In addition, Commissioner Frederic M. Bernthal invited comments on the question of whether the Commission should continue i ts attempts to apply the Backfit Rule to all rulemaking or whether the rule should be revoked as it applies to ru lemaking activity ~ .s.e_. Georgia Power Company (GPC) appreciates the opportunity to comment on the proposed rule, as well as the draft regulatory guide, the fifteen specific questions, and Commissioner Bernthal 's question. Comments on the proposed changes to Appendix J to 10 CFR 50 and draft Regulatory Gui de MS 02 1-5 are contained in Enclosure l to this 1etter. Responses to the fifteen questions are provided in Enclosure 2. GPC is participating in a Boiling Water Reactors Owners Group (BWROG) Committee which proposes to provide separate comments on the proposed rul emaki ng and draft Regulatory Guide MS 021-5 and respond to the fifteen related questions by April 24, 1987. GPC endorses those separate BWROG comments and responses. With respect to the question posed by Commissioner Bernthal, GPC understands the difficulty and frustration NRC may occasionally experience in strictly complying with established regulations. Members of the nu clear industry face such regulatory burdens daily. However, like other NRC regulations, the Backfit Ru l e received careful consideration prior to approval and represents good regulatory practice. Extensive public comments were provided and the rule was determined to be desirable. While the fu ll practical worth of the rule wi 11 not be known without extensive application, ~ ,e . es e p:.owledged by card ** ! * ,,, * ***

Ci

   *.ottmar'c opies
 '<<Id' I c

. --- iel r

Georgia Power Secretary of the Commission U. S. Nuclear Regulatory Commission April 22, 1987 Page Two that the Backfit Rule will contribute positively to the safe operation and fair regulation of the nuclear industry. The Rule has been a long overdue betterment to the regulatory process by assuring a di sci pl i ned. comprehensive review of NRC backfit activities. Should questions or a need for additional information arise. please do not hesitate to contact me. Sincerely,

• K. Whitt/jhu

                                                       ~   r L. T.

6J, re Cu.A( Gucwa Enc l osures:

l. Comments on Proposed Appendix J and Draft Regulatory Guide MS 021-5

2. Response to Questions on the Proposed Revision to Appendix J to 10 CFR 50 c: Georgia Power Company Mr. R. E. Conway Mr. J. P. O'Reilly Mr. J. T. Beckham, Jr.

Mr. G. Bockhold, Jr.

u. s. Nuclear Regulatory Commission Regional Administrator, Region II Senior Resident Inspector-Construction, Vogtle Senior Resident Inspector-Operations, Vogtle Senior Resident Inspector-Hatch State of Georgia Mr. J. Leonard Ledbetter, Commissioner Department of Natural Resources 700775

ENCLOSURE l COMMENTS ON PROPOSED APPENDIX J AND DRAFT REGULATORY GUIDE MS 021-5 General Comments

1. A number of improvements have been included in the proposed rulemaking to change Appendix J to 10CFR50. GPC supports these modifications.

a. The proposed rule clarifies some of the terms that have caused con-fusion in the past such as minimum and maximum pathway leakage.

b. The 11 as found 11 leakage limit criteria has been increased from 0.75 La to l .0 La .

c. The proposed rule formalizes the requirements of IE Information Notice 85-71 by incorporating them into a regulation.

d. The proposed rule uncouples the Type A test frequency from the 10 year ISI interval and provides a means for increasing the interval between Type A tests.

2. Notwi ths tandi ng the above mentioned advantages, on ba 1ance the proposed rule creates more disadvantages for containment leakage rate testing.

Consequently, Georgi a Power Company (GPC) believes the proposed rule, as set forth in the October 29, 1986 Federal Register, should not be adopted at this time. Some general examples of disadvantages are:

a. Major costly retrofits at some plants to comply with the proposed rulemaking will be required, without offsetting increases in safety

• b.

or operability . The upgraded definition of minimum and maximum pathway leakage, while easier to understand, appear to require isolation valves to be tested individually. This interpretation would require expensive addition of block valves, test connections, vents, and drains on lines that penetrate the containment. More clearly stated and easily understood definitions of minimum and maximum pathway leakage are needed.

c. The assumption that Type A test failure frequency can be reduced by increased Type B and C testing is unproven and may be over s i m-pl i fi ed. Gaining NRC approval of an alternate leakage rate program could be expensive and time-consuming, without offsetting safety or operability benefits.

d. Regulatory Guide MS021-5, referenced by the proposed rulemaking, requires the use of the extended ANSI method. This method is com-pl ex, ambiguous, and may be difficult to apply. The limits that it imposes on the verification tests are unrealistic and the predict-ability of the results has been questioned.

l E-1

General Comments - Cont'd.

e. The draft Regulatory Guide only permits "time forward" for the restart of a type A test. This limitation could excessively delay test conclusions when using present day test equipment and expe-rienced test personnel, possibly resulting in an adverse impact to outage durations.

Specific Comments - Appendix J Section Comments II Definition The revised regulation should use the definition of the present Appendix J for containment isolation valves. If the proposed Appendix J definition is used then PWRs may have to start testing their MSIVs and feedwater check va 1ves. These va 1ves are not intended to be within the Appendix J scope. III.A (3) Provisions should be made for the interval between Type A tests to be extended during ti mes when containment i nte-gri ty is not needed (e.g., extended refueling outages). III.A (4) Some form of reduced pressure testing should be considered in this section because of the risks associated with pneu-matic testing and because lower pressure testing may be more representative of containment function during the design basis loss-of-coolant-accident. Si nee containments have been designed with a peak accident pressure ranging from approximately 11 psig (Mark III BWR Containment) to approximately 57 psig (Mark I BWR Containment), the allowable pressure drop during the test should be some percentage of Pac rather than an arbitrary l psig as required by this proposed sec ti on. Further some existing containments cannot be tested at Pac because the design pressure is so close to the peak accident pressure that there is no margin for assuring design pressure would not be exceeded. III.A (5) The requirement "Information on valve leakage that requires corrective action ... must be included in the report. .. " implies that valves have to be tested individually. Typical leakage testing programs have many procedures which test valves simultaneously and in the aggregate. A re-quirement to test them individually would require extensive retrofit. l E-2

Specific Comments - Appendix J Cont'd. III.A.(7)(c)(i) Retrofit will be required by this section. III.A.(7)(c)(ii) Measuring the leakage rate before isolation, re pair, or adjustment will require the containment to be depr essurized to measure the 1eak and then repressuri zed to fi nish the test because some isolation barriers can only be tested from the inside of Containment. III.A.(7)(c)(iii) This is a new and unreasonable requirement. The re is no correlation between type Band type C tests delta leakage rates before and after component adjustment or r epair and

• III.B.(3)(b)(ii) the previous type A test. It represents a bac kfit and should be handled accordingly. GPC believes that no safety benefits would be gained and no useful information would be obtained by implementation of this requirement.

Provision should be made for acceptance of loca l leakage rate tests after maintenance is performed on testable penetrations of an air lock in lieu of a complete air lock test. III.B.(4)(a) The sum of the "as found" Type B and C tests shoul d be able to exceed 0. 6 La during outages when a Type A test is performed as long as the 11 as found" Type A results are 1ess than or equal to La, During outages when a Type A test is not req uired, no benefit is derived when taking single failure into account, to require the licensee to report under Section VI .A . 2 when the as found leakage exceeds 0.6 La using maximu m pathway leakage. This sec ti on should read: "the sum of th e B and C types as found test results should not exceed 0.6 La using a minimum pathway leakage. III.C. (2) (a) An express definition of "qualified water seal system" should be provided. III.C. (2)(b) For internal consistency, the phrase "qualified seal system" should be changed to a qualified wa te r seal system. III.C.(3)(a) Same comments as III.B.(4)(a) apply. III.C. (3)(b) Is this the same seal system as in III.C.(2)(a)? l E-3

Specific Comments - Appendix J Cont'd. III.C.(3)(b)(ii) Same comment as III.C.(3)(b) applies. IV.A This section requires that an as found Type B or C test is to be performed prior to any modification, repair, or replacement of a component subject to a Type B or C test. Current practice and understanding is that as found testing is required only during refueling outages and not during forced or other maintenance outages. Data collection should not be the prime reason for conducting surveillance testing activities .

• Specific Comments - Proposed Regulatory Guide MS021-5 Section 3

Comment Inleakage should be allowed if leakage rates can properly be accounted for. For example, the inboard MS IVs may have pneumatic accumulators which aid in their closure. The inleakage could easily be accounted for, but under this Section they would have to be vented and drained. 6.1.(6) The period of ti me between the end of the type A test and the verification test should be considered part of the Type A test. In the past, this time has been used to take reactor water samples, air samples, and make up water to the reactor vessel. These activities could significantly disturb the containment atmosphere and to include this as part of the Type A test adds an unwarranted regulatory penalty. 6.1.(7) This sec ti on appears appropriate if a data point between the end of the Type A test and the beginning of the verification test is not required as specified in 6.1.(6).

11. 3 Substituting the word 11 calibration 11 for "calibration checks II in 4. 2. 4 of ANSI/ ANS-56. 8-1981 may require LLRT instrumentation to be calibrated to NBS standards every day or at a frequency that would require retests if the instruments fail to "calibrate out 11

13. l If the data supports a restart of as "time backward" then it should be allowed. For example, the temperature stabilization criteria during a Type A test was no t met because malfunctioning temperature sensor time goes on ,

eventually the malfunctioning sensor is found and its f ound that when the erroneous data is purged from the data base, the temperature stabilization criteria was met many hour s earlier. Moving the start time back in this case wou ld be justifiable. lE - 4

Specific Comments - Proposed Regulatory Guide MS 021-5 Cont'd. 13.3 During the Third Workshop on Containment Integrity held on May 21 thru 23, 1986 at the Washington Marriott in Washington, D. C., Mr. Larry R. Young of the Bechtel Power Corpora ti on presented his paper titled "Methods for Determining Integrated Leakage Rate Test Dura ti on - Case Studies". In the study he found that the proposed 11 Extended ANSI Method" would have incorrectly i denti fi ed two successful tests as failures and concluded that the proposed criteria is too conservative. In the paper he made the following recommendation:

                    "Based on a consensus of Bechtel ILRT engineers and this study the following recommendation is made. After a valid start time is determined, the Predictor, Mass Point on ANSI

56. 8 combined criteria method is preferred and sufficient to determine the success or failure and duration of an ILRT 11

• This recommendation should be considered and the proposed rule should be amended accordingly if the recommendation is determined to be desirable .

lE - 5

ENCLOSURE 2 RESPONSES TO QUESTIONS ON THE PROPOSED REVISION TO APPENDIX J TO 10 CFR 50 Some of the fifteen specific questions relative to the proposed Appendix J rev1s1on are difficult to answer concisely due to ambiguities and vulnerability to different interpretations of the proposed rule. There is a definite need for a uni form approach to demonstrating containment integrity. Appendix J could provide this consistent guidance, but it should be written in a way that would encourage uni form interpretation and enforcement without imposing unnecessary requirements on the nuclear power industry. In order to provide the best available information, questions 1, 2, 3, 4, and 7 have been addressed in a tabulated form to address each functional step of Appendix J based on the estimated impact of the activities associated with the questions. Question Nos. Comments

• 1,2,3,4,& 7 App J See Table TABLE l Section Extent Now Used Desirability Need Cost Backfit III.A (1) All High High No III.A (2) All High High No III.A (3) None High High No III.A (4) Most High High No III A (5) A11 High High No
• III.A (6)

III.A (7) III.A (8) III.A (9) A11 Most Some All Low Med. Med. High Low Med. Med High High High No Yes Yes No III.B Some High High No III.C Some High High No V.A A11 High High No V.B Some Med. Med. No VI.A. l. Some Low Low Yes VI.A. 2 Some Low Low High Yes VI.B Some Med. Med. High No VII N/A Low Low High Yes 2E-1

RESPONSE TO QUESTIONS ON THE PROPOSED REVISION TO APPENDIX J TO 10 CFR 50 Question No. Comment

5. Yes, the plants that have established programs under the current regulation should be allowed to continue to test in accordance with the current Appendix J requirements if the proposed rulemaking is adopted.

6. Most plants would probably not adopt either rule in its entirety. The proposed rule resolves some of the problem areas presently being experienced with the current regulation, but it creates more problems than it resolves.

The extensive retrofit requirements for individual valve testing and additional Type A testing are examples.

8. No, the new rule should not be issued in its present form at this time since the NRC is planning a broader, more comprehensive review of containment testing requirements.

9. The testing standard (ANSI/ ANS 56. 8) should be referenced in the Appendix and not endorsed through the Regulatory Guide. If the Regulatory Guide is referenced in the proposed Appendix J, the specific revision and issue date of the Regulatory Guide should be specified to assure public notice and comment prior to changing the instruc-tions in the Regulatory Guide and licensee commitment.

10. Collection of as found test data should not be required for valves that are to be replaced, as well as double 0-ring seals that have not been disturbed. The value of such data should be compared with the operational impact and person-nel radiation exposure associated with the data collection.

11. Yes, Technical Specification limits on La should be re-laxed to the extent of the conservatism in the source term definition and the off-site dose calculations.

12 Severe accident scenarios should not be considered in Appendix J.

13. Continuous leakage monitoring should be considered and, if conclusively demonstrated to be feasible and cost justified, should replace the Type A test.

2E-2

Response to Questions Cont'd.

14. The 1eak-before-break concept wou 1d give credence to re-duced pressure testing, which would be prohibited under the new Appendix J, because of lower accident pressure.

15. The sum of the "as 1eft" 1eakage for B and C type tests using minimum pathway leakage should be compared only to

0. 6 La during outages when a Type A test is not performed. Correcting back to a previous Type A test would force (out of concern of failing a Type A test) the Plants into a retrofit situation .

2E-3

Alabama Power Company 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291-0400 Telephone 205 250-1835 A. P. McDonald

                                                                                      ,,\,

Senior Vice President Alabama Power the southern electric system 10CFR50 Appendix J April 24, 1987 Docket Nos. 50-348 50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen: Joseph M. Farley Nuclear Plant - Units 1 and 2 Comments on Proposed Revision of 10CFR50, Appendix J and Issuance of Draft Regulatory Guide MS 021-5 Alabama Power Company has reviewed the proposed revision of 10CFR50, Appendix J (Federal Register Vol. 51, No. 209, at 39538) and the draft regulatory guide (MS 021-5) referenced therein. In general, Alabama Power Company believes that 10CFR50, Appendix J should not be revised because, in its current version, the proposed Appendix J is technically flawed. In addition, Appendix J should not be allowed to be interpreted to require actions that are beyond its current scope. An example of this is the current use of IE Information Notice 85-71 by the NRC to 11 supplement 11 Appendix J, thus effectively circumventing the rulemaking process. Alabama Power Company disagrees with the apparent underlying assumption by the NRC that the intent of the original Appendix J was properly interpreted by IE Information Notice 85-71. This Information Notice is considered by Alabama Power Company to be a new position taken by the NRC Staff and thus beyond the scope of Appendix J. Thus, even if the original Appendix J is retained, Alabama Power Company will continue to object to the current enforcement activities by the Regional Staff to the provisions of IE Information Notice 85-71. In addition, there are provisions in both of the proposed documents which, if enacted, would require Alabama Power Company to perform extensive backfit modifications to accommodate application of the regulations to the design of Farley Nuclear Plant. The extent and cost of these required modifications were not noted by the NRC in its backfit analysis, thus the proposed rule's impact is considered to have been underestimated.

                                                      ~ledged by card**

r' ti I " r.,C-. * -

U.S. Nuclear Regulatory Commission April 24, 1987 Page 2 Of particular concern to Alabama Power Company is the NRC intent to adjust the Type A test results with the results of the Type Band C testing. The Type A test allows for testing of containment integrity in a manner which tests the actual design of the plant in a configuration similar to that which would be seen in a postulated accident. The proposed change to Appendix J would negate this actual design configuration by introducing artificialities into the test results by use of adjustments. Any such adjustments are not based on established technical information. To combine the Type Band C test results to the Type A test results will add additional and unnecessary conservatism to an already conservative criteria. This combination is considered to be a redefinition of the Type A test for which the original design of the plant was, in part, based *

• The provision for increased Type Band C testing as a result of Type A failures is also not technically justified. The current Appendix J rule requires Type Band C testing and has established an acceptance criteria of 0.6 La. This acceptance criteria includes an allowance for degradation during operation. Since existing requirements provide sufficient margin to ensure that containment leakage is minimal and the NRC is furnished detailed test reports, no additional requirements are needed. In addition, Farley Nuclear Plant is currently utilizing 18 month fuel cycles. Any additional Type Band C testing required by an overly conservative application of Type A test results could require plant shutdowns for the sole purpose of testing.

For the technical aspects of the regulation, Alabama Power Company concurs with the comments provided by Bechtel Power Corporation in its letter from Mr. R. P. Schmitz to the NRC dated January 9, 1987. As the architect engineer and Integrated Leakage Rate Test contractor for Farley Nuclear Plant, Bechtel Power Corporation's technical position on the potential impact of the regulations is generically applicable to the existing plant design and current test methodologies and capabilities. With regard to the backfittiny aspects of the proposed regulation, Alabama Power Company believes that the proposed changes do not meet the requirements of 10CFR50.109 necessary to justify implementation of the proposed rule. Specifically, no substantial increase in the overall protection of the public health and safety has been demonstrated. This conclusion was also reached by the NRC; however, it is apparently willing to circumvent the intent of the backfitting process in order to promulgate the proposed rule. Alabama Power Company considers this circumvention to be unacceptable. In addition, Alabama Power Company believes the NRC's calculation of direct and indirect costs is low and underestimates the impact on utilities while exaggerating the benefits purported to be gained. As requested, Alabama Power Company's response to the fifteen questions posed in the Invitation to Comment is attached.

U. S. Nuclear Regulatory Commission April 24, 1987 Page 3 In conclusion, Alabama Power Company does not recommend that the proposed revision of Appendix J or the draft regulatory guide be issued. If you have any questions, please advise. Respectfully submitted,

• RPM/STB:dst-D-T.S.7 Attachment R. P. McDonald cc: Mr. L. B. Long Dr . J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford Mr. E.G. Arndt

ATTACHMENT COMMENTS ON PROPOSEU REVISION OF 10CFR50, APPENDIX J AND ISSUANCE OF DRAFT REGULATORY GUIDE MS 021-5

1. NRC Question:

The extent to which these positions in the proposed rule are already in use: APCo Response: Alabama Power Company currently implements the existing Appendix J requirements and is not implementing the additional requirements of the

• 2.

proposed revision or draft regulatory guide. NRC Question: The extent to which those in use, and those not in use but proposed, are desirable: APCo Response: Although confusion exists on the proper interpretation of the existing Appendix J requirements, particularly due to the issuance and attempted enforcement of IE Information Notice 85-71, Alabama Power Company has implemented a technically sound containment leakage rate testing program based on the existing Appendix J and Technical Specification

• requirements. Imposition of the draft rules and regulatory guidance will place undue burden on Alabama Power Company and other utilities due to the backfitting required to meet the new requirements. In addition, this proposed rule may result in the extension of planned outages and the imposition of other outages solely for the purpose of performing additional containment testing.

3. NRC Question:

Whether there continues to be a further need for this regulation: APCo Response: Regulation of containment testing is needed. The existing requirements are preferable to those proposed.

Comments on Proposed Revision of 10CFR50, Page 2 Appendix J and Issuance of Draft Regulatory Guide MS 021-5

4. NRC Question:

Estimates of the costs and benefits of this proposed revision, as a whole and of its separate provisions: APCo l{esponse: Alabama Power Company concurs with that portion of the backfit analysis performed by the NRC which states 11 the analysis does not conclude that there is a substantial increase in the overall protection of the public health and safety or the common defense and security derived from the backfit. 11 A detailed cost impact study has not been performed for Farley Nuclear Plant; however, the cost of backfitting piping penetrations to accommodate the proposed testing requirements would be substantial, possibly as high as several million dollars. In addition, the imposition of 11 as-found 11 leakage rate determination could approximately double the personnel exposure required to perform the Appendix J testing. Should additional local or integrated leakage tests be required on a more frequent schedule, the costs would include weeks of lost generation, mobilization expense, and additional personnel exposure.

5. NRC Question:

Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule (reflecting consideration of public comments) becomes effective. APCo Response: Alabama Power Company concurs with the option that would allow operating plants or plants under review to continue to meet the existing provisions in lieu of the proposed rule.

6. NRC Question:

If the existing rule or its proposed rev1s1on were completely voluntary, how many licensees would adopt either version in its entirety and why:

Comments on Proposed Revision of 10CFR50, Page 3 Appendix J and Issuance of Draft Regulatory Guide MS 021-5 APCo Response: Alabama Power Company would not voluntarily adopt the proposed rev1s1on due to the lack of technical bases for many of the proposed changes and the unwarranted hardship it would impose as described in the cover letter and our response to NRC Question 4.

7. NRC Question:

Whether (a) all or part of the proposed Appendix J rev1s1ons would constitute a 11 backfit 11 under the definition of that term in the Commission's Backfit Rule, and (b) there are parts of the rule which do not constitute backfits, but which would aid the staff, licensees, or both. APCo Response:

a. Significant portions of the proposed rule constitute a backfit as discussed in the cover letter.

b. It is felt that portions of the proposed rule would be mutually beneficial to both the staff and licensees; however, these improvements do not outweigh the significant concerns noted herein.

8. NRC Question:

Since the NRC is planning a broader, more comprehensive review of containment functional and testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation. APCo Response: The ramifications of the proposed rules are such that implementation by most utilities can be expected to require at least four years to accomplish full compliance. Since a broader, more comprehensive review is planned by the NRC which could significantly alter the current test methodologies, it would seem most appropriate to postpone any interim revision of regulations until the study is completed and its effect on the level of future containment testing are fully understood and evaluated by the industry.

Comments on Proposed Revision of 10CFR50, Page 4 Appendix J and Issuance of Draft Regulatory Guide MS 021-5

9. NRC Question:

The advisability of referencing the testing standard (ANSI/ANS 56.8) in the regulatory guide (MS 021-5) instead of in the test of Appendix J. APCo Response: APCo concurs with referencing ANSI/ANS 56.8 in the regulatory guide; however, APCo does not concur with the proposed 11 Extended ANSI Method 11 for the reasons described in the Bechtel letter referenced in the cover letter *

• 10. NRC Question:

The value of collecting data from the 11 as found 11 condition of valves and seals and the need for acceptance criteria for this condition. APCo Response: Alabama Power Company currently performs 11 as found 11 testing of penetrations due to verbal commitments made to the NRC, Region II. However, the value of such testing is questionable and APCo generally disagrees that it should be required, particularly prior to performing needed valve or seal repair, maintenance or adjustment operations.

11. NRC Question:

Whether the technical specification limits on allowable containment leakage should be relaxed and if so, to what extent and why, or if not, why not. APCo Response: The existing Technical Specification limits are acceptable under the existing Appendix J rule. Should the proposed rule be enacted, Technical Specification limits should be revised to the La values as opposed to the .75 La and 0.6 La currently used for integrated and local leakage rate tests, respectively. The existing values were conservatively established to allow for normal degradation of the components between tests. Imposition of the 11 as-found 11 testing provisions will result in adjustments to the Type A test values on an ongoing basis such that the margins currently provided would become redundant.

Comments on Proposed Revision of 10CFR50, Page 5 Appendix J and Issuance of Draft Regulatory Guide MS 021-5

12. NRC Question:

What risk-important factors influence containment performance under severe accident conditions, to what degree these factors are considered in the current containment testing requirements, and what approaches should be considered in addressing factors not presently covered. APCo Response: No comment.

13. NRC Question:

What other approaches to validating containment integrity could be used that might provide detection of leakage paths as soon as they occur, whether they would result in any adjustments to the Appendix J test program and why. APCo Response: No comment.

14. NRC Question:

What effect "leak-before-break" assumption could have on the leakage

• rate test program. Current accident assumptions use instantaneous complete breaks in piping systems, resulting in a test program based on pneumatic testing of vented, drained lines. 11 Leak-before-break 11 assumptions presume that pipes will fail more gradually, leaking rather than instantly emptying.

APCo Response: No comment.

Comments on Proposed Revision of 10CFR50, Page 6 Appendix J and Issuance of Draft Regulatory Guide MS 021-5

15. NRC Question:

How to effectively adjust Type A test results to reflect individual Type Band C test results obtained from inspections, repairs, adjustments, or replacements of penetrations and valves in the years between Type A tests. Such an additional criterion, currently outside the scope of this proposed revision, would provide a more meaningful tracking of overall containment leak tightness on a more continuous basis than once every several years. The only existing or proposed criterion for Type B and C tests performed outside the outage in which a Type A test is performed is that the sum of Type Band C tests must not exceed 60% of the allowable containment leakage *

• APCo Response:

The current use of Type Band C testing is considered to be totally sufficient to establish the status of the leak tightness of the leak barriers. Any necessary corrective actions can be identified from the results of the Type Band C testing. The use of these test results to adjust the previous Type A test results is therefore not justified. While the adjustment of Type A test results utilizing Type Band C test results performed between Type A tests may not be within the scope of the proposed revision, such an adjustment could be enforced as a result of the proposed changes to Appendix J as they could be argued to codify the current interpretation by the NRC Staff of the intent of IE Information Notice 85-71. Specifically, the concern is the provision of the Information Notice that states that containment leak-tight integrity

• is to be monitored between CILRTs through the Type Band C test program. This provision could be interpreted (and enforced) in the future as requiring the above adjustment. Imposition of such an adjustment in the absence of a concise, technically accurate methodology defined in regulatory guidance or industry standards will result in widespread disagreement and confusion and a continuation of the current practice of the NRC Staff in expanding the scope of the regulations while circumventing the rulemaking process. Since the results of such an adjustment v.Quld have a significant impact on future testing and corrective actions, a clearly defined and technically accepted methodology is essential prior to the issuance of the proposed rules and regulations.

- - - ~ - - - - - - - * --- - - uOCKEl NUMBER ED.eO.SfD RUJJi pff >*- ( 5 /F~ ~C/53f' Telephone (61 7) 8 72-8100 TWX 710-380-7619 YANKEE ATOMIC ELECTRIC COMPANY OOCKETED USNRC

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        \..Y~~)                        1671 Worcester Road, Framingham, Massachusetts 017'87 APR 27 AlO:t 1
            -----*                                      April 23, 1987 FYC 012 GLA 87-080 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:       Docketing and Service Branch

Dear Sir:

Comments Pertaining to Proposed Rule (10CFRSO, Appendix J),

                            .. Leakage Rate Testing of Containments of Light- Water- Cooled Nuclear Power Plants," and Draft Regulatory Guide MS 021- 5,
                            .. Containment System Leakage Testing .. (51FR39538 and 51FR39440)

Yankee Atomic Electric Company (YAEC) appreciates this opportunity to comment on the proposed rule regarding 10CFRSO, Appendix J, and Draft Regulatory Guide MS 021-5. YAEC owns and operates the Yankee Nuclear Power Plant in Rowe, Massachusetts. Our Nuclear Services Division also provides engineering and licensing services for other nuclear power plants in the Northeast, including Vermont Yankee, Maine Yankee, and Seabrook. The Nuclear Utility Backfitting and Reform Group (NUBARG) is filing comments resulting from its analysis of the proposed rule and regulatory guide based on its unique perspective. YAEC is an active member of NUBARG and endorses its comments. YAEC is also a member of a group represented by Bishop, Liberman, Cook, Purcell and Reynolds, and we endorse those comments. The attachment to this letter contains our responses to the questions posed under the Invitation to Comment Section of the Federal Register notice. Following are several general remarks which summarize our thoughts on this proposed rule and regulatory guide. -. Since the backfit analysis showed that there is no substantial increase in the public health and safety and that there is no justification in terms of costs, these proposed changes should not be mandated through rulemaking. We recommend that the Commission either wait for the more comprehensive revisions currently underway by the NRC staff or issue these proposed changes as optional. Reporting requirements seem overly restrictive. For example, Paragraph VI.A.2 requires results of Type B or C tests that fail to be submitted within 30 days even though utilities document these and submit them with the next Type A test report. Any of these results which exceed a technical specification limit would be the subject of a Licensee Event Report [10CFR50.73(a)(2)(ii) and (a)(2)(v)(c)J. MAYO 6 1987 Ackn"owtedged by cant.~:, .1, ,,, ,,..., :;..;;;.,e

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United States Nuclear Regulatory Commission April 23, 1987 Page 2 The purpose of any containment testing program is to provide reasonable assurance that the containment is capable of performing its intended function; that is, the leakage rate is never greater than those limits specified in the technical specifications and associated bases. As stated in Sections III.B(4) and III.C(3), "The sum of the as-found or as-left Type B and C test results must not exceed 0.60 La using maximum pathway leakage and including leakage rate readings from continuous leakage monitoring systems." This acceptance criteria adds additional layers of conservatism to an already conservative limit and creates a disincentive for licensees to utilize continuous leakage monitoring systems. No basis is provided either in this proposed regulation or associated draft regulatory guide (MS 021-5) for limiting the summation of all "as-found" leakages to 60% of the limit. One can speculate that the reason is 40% of the leakage limit is not measured by Type Band C testings. This being the case, one would expect the Type A test result to be greater than the summation of Type Band C test results by some substantial fraction of the 40%. Reported test results do not generally support this assumption. The requirement for "maximum pathway leakage," especially for "as-found," is excessive in that it assumes that in every case where there are two barriers (or more) in series, the most leak-tight barrier has failed, even where these are passive barriers such as double seals or 0-rings. An additional penalty is imposed by the requirement to add to the total Band C leakage that leakage measured by a continuous leakage monitoring system which may already be accounted for in the Band C leakage. We suggest the following approach for your consideration: o Acceptance Criteria For "As-Found" Conditions Measure leakage rates for individual barriers in series and report "as-found" leakage based upon "minimum pathway" leakage. o Acceptance Criteria for "As-Left" Conditions Report "as-left" leakage based upon "maximum pathway" leakage and document corrective actions performed between "as-found" and "as-left" conditions. In this manner, credit is allowed, for barriers that are functional at time of testing, documents corrective actions taken to maintain leakage as low as is reasonable and provides assurance that the containment will function as designed, if required, after test completion. For continuous monitoring systems, leakage which is already included (or accounted for) in Type A, B, or C testing, need not be additionally added to the summation of Type Band C test results. The 0.6 La limit is too restrictive. In the case of Type A testing, the "as-left" limit is 0.75 La to allow 0.25 La for deterioration over the next four-year period to the next Type A test. In this case, 0.75 La would allow 0.25 La for deterioration over a two-year period, plus an allowance for leakage not measured by the Type Band C testing program and would conform with the ANS 56.8 Standard.

United States Nuclear Regulatory Commission April 23, 1987 Page 3 If a Type Band C test program were developed to allow testing over the entire cycle, rather than only during refueling outages, the "running total" B and C leakage rates would be relatively constant, with little degradation over time. Since ANSI/ANS 56.8 is a consensus committee composed of a balanced membership (including the NRC), it is inappropriate and undermines the voluntary consensus program for the NRC to propose Regulatory Guide KS-021-5, which takes exceptions to the ANSI/ANS 56.8 Standard. Since the NRC was a major participant in the development of the standard, they should abide by its precepts. However, the approved 1987 version of the standard is currently being printed and will soon be distributed. If the NRC chooses to take exceptions to consensus standards, they should at least address the most current revision .

• The requirement in Section V.A, which specifies that test methods, procedures, and analyses must be referenced or defined in the technical specifications, violates the intent of the Technical Specification Improvement Program. A reference to the Licensee Test Program is all that is needed.

Although this proposed rule was presented as administrative clarifications and corrections, we find substantial new requirements. Further, we believe this proposed rule does not meet the criteria of 10CFR50.109 and would be an unjustified backfit. The Commission should not promulgate this rule. Very;:;;:;* rP.,) 1::-_w. Edwards Director of Industry Affairs DWE/ds Attachments

APPENDIX Invitation to Conunent Questions Question 1: The extent to which positions in the proposed rule are already in use. Answer 1: Many of the specific details such as test pressure, test duration, the maximum/minimum pathway leakage concept, and reporting requirements are not generally in use. A number of positions have been imposed by compliance inspectors and licensing reviewers such as, more frequent testing of repeat leakers, Type Band C acceptance criteria of 0.6 La, and mass point analysis method. Question 2: The extent to which those in use, and those not in use but proposed, are desirable .

• Answer 2: Provisions of the proposed Appendix J which are desirable are as follows:

o The refocusing of corrective action toward the root cause of test failure. o Dropping the Type A test duration requirement from the criteria of Appendix J will allow some licensees to meet the intent of the test program at a greatly reduced cost. o To air lock test extended intervals. Question 3: Whether there continues to be a further need for this regulation. Answer 3: There continues to be a need to be able to demonstrate that the containment structure is capable of functioning as designed under postulated accident conditions. One way to demonstrate this capability is by testing. A testing program which uses industry standards to meet performance objectives specified by NRC regulation is a sound approach. Question 4: Estimates of the costs and benefits of this proposed revision, as a whole and of its separate provisions. Answer 4: As a whole, the rule does not appear to be cost beneficial. (See Answer 5). Probalistic risk assessments have consistently shown that containment leakage is a minor contributer to overall plant risk. NUREG/CR-4330 indicated that changing the regulations would have marginal affect on public health and safety because the Technical Specification limits are so conservative that a factor of 10 to 100 increase in the leak rate may not even be risk significant. However, the cost impact is significant due to increased plant down time of three to five days. Question 5: Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule (reflecting consideration of public comments) becomes effective. Answer 5: The NRC staff backfit analysis in accordance with 10CFRS0.109 showed that the proposed revision to 10CFRS0, Appendix J, does not provide a substantial increase in the overall protection of the public health and safety and that it is not justified in terms of the direct and indirect costs of implementation. Therefore, by definition these proposed changes do not meet the requisite standards of 10CFRS0.109, and the Commission should not mandate the changes through rulemaking. These changes should be deferred pending the more comprehensive revisions underway for Appendix J, and additional backfitting analysis should be performed when these changes are complete. Question 6: If the existing rule or its proposed rev1s1on were completely voluntary, how many licensees would adopt either version in its entirety and why? Answer 6: Licensees have adopted the current rule or have obtained specific exemption to selected parts. The purpose of containment testing is to provide reasonable assurance the containment system will perform within design parameters should it be required to protect the health and safety of the public. Changes to regulation that result in additional cost to licensees and ultimately rate payers, without a corresponding increase in the level of assurance of containment integrity will not be undertaken voluntarily. As an example, the proposed rule will require the performance of Type A tests at the calculated peak accident pressure. Several licensees have performed this test at some reduced pressure. Performing the test at full pressure will require several hours more to pump up to pressure and several hours more to reduce the pressure upon completion of the testing. This represents time when no other work can be performed within the containment and is usually "critical path" on the outage schedule. With outage time as expensive as it is, hundreds of thousands of dollars are added to each outage that requires performance of a test. Containments are designed for full pressure testing, so this is not a problem. The question becomes one of any added assurances of safety in light of the fact that all penetration testing is already done at full pressure. Question 7: Whether (a) all or part of the proposed Appendix J rev1s1ons would constitute a "backfit" under the definition of the term in the Commission's Backfit Rule, or Cb) there are parts of the rule which do not constitute backfits, but which would aid the staff, licensees, or both. Answer 7: Refer to Question 5. Question 8: Since the NRC is planning a broader, more comprehensive review of containment functional and testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation. Answer 8: This proposed interim updating of the regulation does not satisfy the provisions of the backfit rule (10CFR50.109) and should, therefore, not be promulgated through rulemaking. We recommend the proposed rule be handled as described in the response to Question 5 .

• Question 9:

Answer 9: The advisability of referencing the testing standard (ANSI/ANS 56.8) in the regulatory guide (MS 021-5) instead of in the text of Appendix J. The standard is better referenced in the regulatory guide than the regulation. Problems have arisen between licensees and compliance inspectors when guidance presented in the latest revision of a standard was utilized, in apparent conflict with regulation. A regulatory guide can be revised to take advantage of advances in testing technology and corresponding changes to standards more easily than can a regulation. Question 10: The value of collecting data from the "as found" condition of

• Answer 10:

valves and seals and the need for acceptance criteria for this condition. Under actual accident conditions, the most probable leakage path will be through valves and seals. It is not expected that leakage through the structural plates and components of the containment will represent a significant fraction of the total leakage. A realistic "as found" condition will provide a certain measure of how well the containment is performing over time. It should provide a basis for frequency of surveillance testing and definition of those components requiring more attention. "As found" leakages should be based upon minimum pathway leakage to allow credit for those components that actually function under test conditions. An "as found" leakage based upon maximum pathway leakage assumes that the most leak-tight component in each pathway would fail if it were relied upon to function, which is an overconservative and restrictive assumption. Question 11: Whether the technical specification limits on allowable containment leakage should be relaxed and, if so, to what extent and why, or if not, why not? Answer 11: Individual licensees have limits in their technical specifications on allowable containment leakage. These limits are based upon certain site-specific attributes, as well as an NRC directed method of analysis. Guidance on this subject is provided in regulation at 10CFRl00.11 and in Regulatory Guides 1.4 and 1.5 (Safety Guide 5). Several orders of magnitude of conservatism are incorporated within the regulatory position that relates to containment leakage. They include:

1. During CP review guideline exposures of 20 rem whole body and 150 rem thyroid, rather than 10CFRl00.11 limits of 25 rem and 300 rem.

2. Primary containment assumed to leak at technical specification limit for the first 24 hours and 50% of this for the remainder of 30 days. This is in spite of the fact that the pressure peak is reached, within a few seconds and decays rapidly within a few minutes.

Leakage rates specified in technical specifications in most cases, especially PWRs, are approaching the lower limit of measurability and is reflected in the error band of reported results. Leakage limits could be raised by orders of magnitude without a measurable increase in risk to the public and still remain within current regulatory requirements.

• Question 12:

Answer 12: What risk-important factors influence containment performance? The answer to this question is the subject of current studies by industry-sponsored groups. We recormnend that publication of this rule be delayed until these results are available. Question 13: What other approaches to validating containment integrity could be used that might provide detection of leakage paths as soon as they occur, whether they would result in any adjustments to the Appendix J test program and why? Answer 13: Most containment systems operate as a series of subsystems, each of which form closed loops inside and outside of the primary containment boundary. Exceptions to this might be certain ventilation systems designed to function during periods of plant shutdown and systems designed to sample the atmosphere. Containment design conditions assume certain normally closed systems fail because of the accident, in which case, isolation valves are required to close to maintain containment integrity. Operation of the containment atmosphere at a slightly positive (or negative) pressure would permit continuous measurement of containment leakage rate. A seal failure, or other leak in a system having communication with the containment atmosphere, would be quickly detectible, and while measuring a low leak rate, provide assurance that the containment will perform its intended function should the need arise. Leakage through isolation valves in closed systems within the containment, however, would not be detected by this method. Continued operation of a system of this type should permit a decrease in the frequency of Type A testing but should have no effect on the frequency of Type Band C testing . Question 14: What effect .. leak before break" assumptions could have on the leakage rate testing program . Answer 14: .. Leak before break" assumption may have an effect on containment pressure transient, fission product release fraction (source term) and other containment design requirements. Current design is based upon .. worst case" assumptions. Reduced pressure testing, which is prohibited under the proposed rule, is much more realistic under the leakage before a break scenario. Question 15: How to effectively adjust Type A test results to reflect individual Type Band C test results. Answer 15: If there is general agreement that any containment leakage is predominantly through containment penetrations and seals and that leakage through the liner plates and membrane is minimal, then a correlation can be developed between Type Band C leakages and Type A leakage. Currently in Type A testing, credit is allowed for double seals and barriers, when present, under test conditions. Thus, if piping penetrations have two automatic valves in series, and they both close when an isolation signal is received, or if a flanged seal has double 0-ring seals, Type A testing is permitted in that configuration. This leakage measured during the Type A test should be comparable to a summation of all Type Band C test results using minimum pathway leakage. Type Band C testings should be encouraged to be performed on a continuous basis and not emphasize testing during refueling outages. The technical specification limit for the summation of all Band C test results at any pointing time should be a substantial fraction of La (0.75 La, per ANS 56.8) for "as-found" leakage based upon "minimum pathway leakage." Documentation should be provided as part of the test program that each component is tested within its prescribed time intervals.

 "Maximum pathway leakage" should be determined and recorded for each pathway also. Maintenance and repair of components should be performed such that the "as-left" "maximum pathway leakage" is also within technical specification limits. All maintenance and repair should also be documented and included as part of the next Type A test report. This will provide licensees with the necessary incentive and guidance on frequency of preventative maintenance activities to maintain containment leakage within acceptable limits.

A number of penetrations can be tested with the plant operating and others may be tested when the plant is shut down for other than refueling. With a test program spread over an entire operating cycle, the work load is distributed, and it may be possible to detect trends in leakage rate requiring attention. A "running total" of containment leakage can be maintained. Type Band C test results can be a useful tool to estimate the readiness of the containment to perform its intended function. Combining or comparing increases or decreases in Type B or C "as found" over previous "as left" and adjusting previous Type A would not be considered under this "running total" concept . BWR c/o NOATHEAN STATES POWEA CO.

• 414 Nicollet Moll
• Mlnneopollsf!J Sftffll 24 p1 :1 Q T. A. Pickens, Chairman (612) 337-2037 BWROG-8731 April 22, 1987 U.S. Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, D.C. 20555

SUBJECT:

PROPOSED REVISIONS TO 10CFRSO APPENDIX J DRAFT REGULATORY GUIDE MS 021-5 The Boiling Water Reactor Owners' Group (BWROG) Committee on Containment Testing has reviewed the proposed revisions to 10CFRSO Appendix J and the associated draft Regulatory Guide MS 021-5. Specific comments regarding the proposed revisions and NRG questions are included in Attachments 1- 3, while more general comments are embodied in the text of this cover letter. Although we support the NRC ' s initiative to eliminate conflicts and ambiguities, and address issues representing continual misinterpretation of the Appendix J rule, we are concerned that the proposed revision is not limited to the scope identified in the Federal Register notice, which states, "this revision to Appendix J is limited to corrections and clarifications, and excludes new criteria. The revision proposes new requirements which can prove time consuming and costly to the licensees. There are other areas which can be interpreted to require plant modifications to achieve compliance. These requirements are either not adequately addressed, or not addressed at all, in the Backfit analysis. The revision also proposes deletion of the present allowance of reduced pressure testing, Imposing a full pressure test requirement on those plants that have only performed reduced pressure testing since initial startup will extend their critical path outage time. This is tantamount to a new requirement. As a new requirement, this should also be considered in the backfit analysis. There are other changes which, though appearing to be minor in nature, will be costly and difficult to meet. The proposed revision also does not provide the necessary resolution of "misinterpretation problems". This is discussed in detail in our response to Question 2 in Attachment 1. During review of the proposed rule the committee could not reach an agreement on its desirable aspects due to non-uniform interpretations of several areas. The attachments to this letter contain recommendations which clarify the BWROG inter-pretation of the questionable areas. MAYO 6 1987

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Based on the extent and nature of the BWROG comments, we recommend that changes be incorporated and the proposed revisions be re-published to allow further review and comment. The comments/positions provided in this letter have been endorsed by a substantial number of the members of the BWROG, however, it should not be interpreted as a commitment of any individual member to a specific course of action. Each member must formally endorse the BWROG position in order for that position to become the member's position. Very truly yours,

• ~:.::c~rman BWR Owners' Group Attachment 1: Question responses on proposed revision to 10CFRSO Appendix J Attachment 2: Comments on proposed revisions to 10CFRSO Appendix J Attachment 3: Comments on proposed Regulatory Guide MS 021-5 cc: BWROG Containment Testing Committee and Primary Representatives R. F. Janecek, BWROG Vice Chairman D.R. Helwig, RRG Chairman J.M. Fulton, BECO J. W. Power, EPRI W. S. Green, INPO C. L. Tully, AIF S. J. Stark, GE E.G. Arndt, NRC

ATTACHMENT 1 BWR Owners' Group responses are provided below on the 15 NRC questions posed in the 10CFR50 Appendix J rulemaking notice.

1. THE EXTENT TO WHICH THESE POSITIONS IN THE PROPOSED RULE ARE ALREADY IN USE.

The extent to which the positions in the proposed rule are already in use varies widely among BWROG members. Examples include:

a. Some plants use the reduced pressure test.

b. The "as-found" Type A provisions are being used inconsistently, generally on an informal basis.

c. Extensions of containment boundaries are being interpreted and enforced inconsistently.

In addition, some utilities could not implement those portions of ANSI/ANS 56.8 which conflict with the existing Appendix J and ANSI N45.4 standard, such as, performing an 8 hour Type A test. The inconsistency of different NRC Regional Inspectors has caused a reluctance by utilities to implement new test program requirements when they are not required from a licensing standpoint.

2. THE EXTENT TO WHICH THOSE IN USE, AND THOSE NOT IN USE BUT PROPOSED, ARE DESIRABLE.

It was difficult to determine what is desirable due to the inconsistencies with the interpretation and enforcement of the regulation. However, ANSI N45.4 is outdated and a new endorsed

• standard would be beneficial .

The major advantages of the proposed rule are:

1. The possibility of reduced test duration.

2. Use of the mass point analysis method.

3. The potential to not increase the frequency of Type A tests by placing more emphasis on the Type Band C program results.

4. Decreased frequency of air lock testing.

Negative features include:

1. It can be interpreted that all valves must be individually tested. For many plants, this new state of testing would require extensive additions of large block valves and test connections. These modifications may require significant critical path outage time with little apparent benefit to public health or safety.

2. The potential for more frequent testing, resulting in longer and more frequent outages and increased radiation exposure.

3. More frequent reporting requirements for LLRTs.

4. The need to develop revised Technical Specifications to incorporate these changes.

3. WHETHER THERE CONTINUES TO BE A FURTHER NEED FOR THIS REGULATION.

There is a need for a uniform approach to demonstrating containment integrity which Appendix J could provide. However, the appendix needs to be written in a manner that will allow for uniform interpretation and enforcement without imposing unnecessary requirements on the licensees. Probabilistic risk assessments, beginning with WASH-1400 (NRC 1975) and continuing with NUREG/CR-4330, have consistently shown that containment leakage is a relatively minor contributor to overall plant risk. In addition, inherent design features of light water reactors will maintain offsite doses below the guidelines of 10CFRlOO even with containment leakage rates well beyond the presently specified acceptable limits. There is sufficient technical justification to change the emphasis on these tests (i.e. increase allowable leakage rates, concentrate more on local leak rate tests, and concentrate less on integrated leak rate tests).

4. ESTIMATES OF THE COSTS AND BENEFITS OF THIS PROPOSED REVISION, AS A WHOLE AND OF ITS SEPARATE PROVISIONS.

It is difficult to provide utility costs and benefits due to the ambiguities of the rule. However, there would be significant additional costs due to the revision, some of which are: Increased costs for modifications to enable individual testing of valves. Increased costs due to increased number of tests (individual versus group LLRTs). Extension of containment boundaries. Increased downtime between scheduled outages due to required CAPs. Additional radiation exposure for testing performed during mid-cycle outages. For a discussion on benefits see the response to Question 2.

5. WHETHER PRESENT OPERATING PLANTS OR PLANTS UNDER REVIEW SHOULD BE GIVEN THE OPPORTUNITY TO CONTINUE TO MEET THE CURRENT APPENDIX J PROVISIONS IF THE PROPOSED RULE BECOMES EFFECTIVE.

Yes. Due to the new requirements in the proposed rule and need for thorough and complete backfit analyses, utilities should be allowed the option to continue using their present programs.

6. IF THE EXISTING RULE OR ITS PROPOSED REVISION WERE COMPLETELY VOLUNTARILY, HOW MANY LICENSEES WOULD ADOPT EITHER VERSION IN ITS ENTIRETY AND WHY.

Member utilities would not adopt either version in its entirety. The proposed regulation clears up some of the problem areas which are present in the current rule, however, it creates others. For example, there continues to be confusion regarding the scope of the Type C test program and what penetrations do and do not require testing. The proposed revision does not meet the stated objectives of providing clarity and consistency for interpretive purposes. As seen in our comments (Attachment 2), there are many items which are confusing. We have provided (where possible), wording which clarifies the BWROG interpretations. But, there are also areas where the Committee could not agree on an interpretation and we have requested clarification.

7. WHETHER (A) ALL OR PART OF THE PROPOSED APPENDIX J REVISIONS WOULD CONSTITUTE A "BACKFIT" UNDER THE DEFINITION OF THAT TERM IN THE COMMISSION'S BACKFIT RULE, AND (B) THERE ARE PARTS OF THE RULE WHICH DO NOT CONSTITUTE BACKFITS, BUT WOULD AID THE STAFF, LICENSEES, OR BOTH.

It is the BWROG opinion that a thorough and complete backfit analysis should be imposed on this appendix. The backfit rule would not apply to sections of the proposed rule that are only clarifications, such as the proposed definitions for containment leak test program, leak, leakage, and leakage rate. However, certain items, such as the "as-found" acceptance criteria and extension of containment boundary, should be properly classified as new requirements, not as a clarification of an existing position, and are therefore subject to the backfit rule.

8. SINCE THE NRC IS PLANNING A BROADER, MORE COMPREHENSIVE REVIEW OF CONTAINMENT FUNCTIONAL AND TESTING REQUIREMENTS IN THE NEXT YEAR OR TWO, WHETHER IT IS THEN STILL WORTHWHILE TO GO FORWARD WITH THIS PROPOSED REVISION AS AN INTERIM UPDATING OF THE EXISTING REGULATION.

In light of the extensive comments provided on this proposed rule, it would be prudent to resolve the obvious problems in the near future.

9. THE ADVISABILITY OF REFERENCING THE TESTING STANDARD (ANSI/ANS 56.8) IN THE REGULATORY GUIDE (MS 021-5) INSTEAD OF IN THE TEXT OF APPENDIX J.

As with other standards required by the regulation (i.e. 10CFR50.55a referencing ASME code), an ANSI/ANS standard should be referenced in this appendix and not endorsed through the Regulatory Guide. Also, any references in the rule should be subject to a backfit analysis.

10. THE VALUE OF COLLECTING DATA FROM THE "AS FOUND" CONDITION OF VALVES AND SEALS AND THE NEED FOR ACCEPTANCE CRITERIA FOR THIS CONDITION.

The value of "as-found" testing as a general requirement must be weighed against the operational impact and increased personnel radiation exposure. There are times when pre-maintenance testing can severely affect plant availability and may become a factor in decisions to perform elective maintenance. Acceptance criteria associated with as-found Type A, B, and C tests should be maximum allowed by the technical specifications (La), based on minimum pathway leakage. This position is based on components being restored, after rework or adjustment, to within the .75 La (Type A test) or .6 La (Type Band C tests) in the as-left condition and using maximum pathway leakage for Type Band C tests and a minimum pathway leakage for the Type A test .

11. WHETHER THE TECHNICAL SPECIFICATION LIMITS ON ALLOWABLE CONTAINMENT LEAKAGE SHOULD BE RELAXED AND IF SO, TO WHAT EXTENT AND WHY, OR IF NOT, WHY NOT.

Yes, NUREG/CR-4330 indicates that today's technical specification limits on allowable containment leakage are more conservative, by an order of magnitude, than is needed to adequately protect the health and safety of the public. Therefore, technical specifications should be relaxed.

12. WHAT RISK-IMPORTANT FACTORS INFLUENCE CONTAINMENT PERFORMANCE UNDER SEVERE ACCIDENT CONDITIONS, TO WHAT DEGREE THESE FACTORS ARE CONSIDERED IN THE CURRENT TESTING REQUIREMENTS, AND WHAT APPROACHES SHOULD BE CONSIDERED IN ADDRESSING FACTORS NOT PRESENTLY COVERED *

• Appendix J testing requirements assure adequate containment performance for design basis conditions. The design basis accident scenarios were not intended to address severe accident conditions.

The factors which influence containment performance under severe accident conditions are still being investigated. It is not clear that additional testing is either appropriate or necessary to address these factors. The need for additional Appendix J requirements, if necessary, should be addressed only after resolution of the severe accident issues.

13. WHAT OTHER APPROACHES TO VALIDATING CONTAINMENT INTEGRITY COULD BE USED THAT MIGHT PROVIDE DETECTION OF LEAKAGE PATHS AS SOON AS THEY OCCUR, WHETHER THEY WOULD RESULT IN ANY ADJUSTMENTS TO THE APPENDIX J TEST PROGRAM AND WHY.

We are not aware of any other practical approaches to provide detection of all leakage paths as soon as they occur.

14. WHAT EFFECT "LEAK-BEFORE-BREAK" ASSUMPTIONS COULD HAVE ON THE LEAKAGE TEST PROGRAM. CURRENT ACCIDENT ASSUMPTIONS USE INSTANTANEOUS COMPLETE BREAKS IN PIPING SYSTEMS RESULTING IN A TEST

                                                        ~- - -- - - - - ------------ ---

PROGRAM BASED ON PNEUMATIC TESTING OF VENTED, DRAINED LINES.

     "LEAK-BEFORE-BREAK" ASSUMPTIONS PRESUME THAT PIPES WILL FAIL MORE GRADUALLY, LEAKING RATHER THAN INSTANTLY EMPTYING.

Applying leak-before-break criteria could remove some systems from consideration in the leakage test program. This would allow system alignment for leak rate tests to be simplified and more realistic. Venting and draining of some lines during testing also may not be required. A revised accident analysis is needed, in which a more realistic look at the leakage mechanisms, the system boundaries, specification of water rates, etc., is developed.

15. HOW TO EFFECTIVELY ADJUST TYPE A TEST RESULTS TO REFLECT INDIVIDUAL TYPE BAND C TEST RESULTS OBTAINED FROM INSPECTION, REPAIRS, ADJUSTMENTS, OR REPLACEMENTS OF PENETRATIONS AND VALVES FOR THE YEARS IN BETWEEN TYPE A TESTS .

• a.

b. ALL TYPE BAND C TESTS PERFORMED DURING THE SAME OUTAGE AS A TYPE A TEST, OR PERFORMED DURING A SPECIFIED TIME PERIOD (NOMINALLY 12 MONTHS) PRIOR TO TYPE A TEST, BE FACTORED INTO THE DETERMINATION OF A TYPE A TEST "AS FOUND" CONDITION. IF A PARTICULAR PENETRATION OR VALVE FAILS TWO CONSECUTIVE TYPE B OR C TESTS, THE FREQUENCY OF TESTING THAT PENETRATION MUST BE INCREASED UNTIL TWO SATISFACTORY B OR C TESTS ARE OBTAINED AT THE NOMINAL TEST FREQUENCY. CONCURRENTLY, EXISTING REQUIREMENTS TO INCREASE THE FREQUENCY OF TYPE A TESTS DUE TO CONSECUTIVE "AS FOUND" FAILURES ARE ALREADY BEING RELAXED IN THE PROPOSED REVISION OF APPENDIX J. INSTEAD ATTENTION WOULD BE FOCUSED ON CORRECTING COMPONENT DEGRADATION, NO MATTER WHEN TESTED, AND THE "AS FOUND" TYPE A TEST WOULD REFLECT THE ACTUAL CONDITION OF THE OVERALL

• c.

CONTAINMENT BOUNDARY . INCREASES OR DECREASES IN TYPE B OR C "AS FOUND" TEST RESULTS (OVER THE PREVIOUS "AS LEFT" TYPE B OR C TEST RESULTS) SHALL BE ADDED TO OR SUBSTITUTED FROM THE PREVIOUS "AS LEFT" TYPE A TEST RESULT.

i. IF THIS SUM EXCEEDS 0.75 La BUT IS LESS THAN 1.0 La, TAKE MEASURES TO REDUCE SUM TO NO MORE THAN 0.75 La. THIS IS NOT REPORTABLE.

ii. IF THIS SUM EXCEEDS 1.0 La, TAKE MEASURES TO REDUCE SUM TO NO MORE THAN 0.75 La. THIS IS A REPORTABLE CONDITION. iii. THE EXISTING REQUIREMENTS THAT THE SUM OF ALL TYPE BAND C TESTS BE NO GREATER THAN 0.6 La SHALL REMAIN IN EFFECT. Currently, running totals of Type Band C test results are being maintained to insure the technical specification acceptance criteria of 0.6 La is not exceeded. Corrective actions should be addressed as part of these programs (Band C) and not tied to Type A test results.

a. The requirement to adjust Type A test results for any Type B or C tests (as-found) performed in the 12 months preceding the Type A test deviates from the intent of the test to measure the existing leakage rate of the containment.

b. Any additional test requirements should be addressed in the respective corrective action plan for the failure on a case by case basis. A pre-selected increase in test frequency may not be appropriate in all cases.

c. Again, maintaining the "running total" of leak rate is not necessary. Furthermore, degradation in containment leakage rate in the interval between Type A tests is accounted for in the as-left acceptance criteria of 0.75 La for Type A tests and 0.6 La for Types Band C.

ATTACHMENT 2 Comments on Proposed Revisions to 10CFRSO Appendix J SECTION I Introduction - Delete the reference to the Regulatory Guide and include reference to the ANSI Standard in the rule or Impose the Backfit Requirements (10CFRS0.109) and assure that future changes to the Regulatory Guide are in accordance with the proposed/final rulemaking process (10CFR2.804) Referencing a Regulatory Guide in the Code of Federal Regulations is not a standard practice. A Regulatory Guide is intended to provide guidance, whereas reference in a rule can be interpreted to mean mandatory compliance. The BWROG is concerned that future changes to the Regulatory Guide could be (i) substantial and costly, (ii) made without a Backfit Analysis, and (iii) not allow for a review in accordance with 10CFR2.804. SECTION I I Acceptance Criteria Remove the word "functional" as it is ambiguous and subject to individual interpretation. As-Found Leakage Rate Reword as follows:

             "The leakage rate prior to needed repairs or adjustments that could affect the leak tightness of the barrier being tested."

This rewording provides more detail to avoid misinterpretations. Also, the BWROG provides the following definition of REPAIR which is also necessary.

      "Repair - A repair to a Type B or C pressure boundary is defined as work which affects a component's accident pressure retention capability."

As-Left Leakage Rate Reword as follows:

            "The leakage rate following needed repairs or adjustments that could affect the leak tightness of the barrier being tested."

This rewording provides more detail to avoid misinterpretation. Closed System A definition for closed system should be provided for clarification. Containment Isolation System Functional Test This definition should be deleted because there is no mention of the test in the proposed rule. Also, this test is required by plant Technical Specifications and other standards such as ASME Section XI. Containment Isolation Valve Reword the definition as follows:

          "Any valve which is intended to provide a barrier between the containment environment and the outside environment, and which must be in a closed condition to effect containment integrity."

The use of the ANSI 56.8 definition provides consistency among all plants - especially those built prior to the implementation of the General Design Criteria (10CFR50 Appendix A). Containment Leak Test Program Delete the words "of the containment system". See discussion under "Containment System". Containment System Delete definition and modify appropriate paragraphs in Section III.A. (2). The definition of "Type A Test" and "Primary Containment", as reworded, adequately define the containment boundary. Including a "Containment System" definition only causes confusion in the regulation. Also, this definition could be misinterpreted to include systems, or portions of systems, that NUREG-0737 identified as requiring testing to better identify leakage outside containment. These systems are tested at normal operating pressure in accordance with ASME XI or other FSAR commitments. Maximum and Minimum Pathway Leakage In these definitions, the examples provided in parentheses should be deleted. A more complete explanation of alternative methods for determining valve penetration leakage (see IE Information Notice 85-71) should be substituted. If more explanation and detail is not provided, many plants may be forced to make modifications to permit leak testing of each containment valve individually, or be in a gray area where the rule is not specific enough to permit practical interpretation. An acceptable alternative (coupled with IE Information Notice 85-71) would be to provide wording for the Minimum Pathway definition such as: (1) the smallest leakage of two valves in series, or (2) the measured leakage from the inboard of the first valve to the outboard of the second valve in a dual valve isolation system with both valves closed, or (3) one-half of the total leakage of the penetration. Similar philosophy should also be used for the Maximum Pathway definition. Periodic Leak Test and Preoperational Leak Test Delete the definitions as they are redundant to the descriptions in Section III, or reword the definitions to be consistent with the text (i.e., periodic test, preoperational test). Primary Containment Reword definition as follows:

                    "The structure or vessel that encloses the major components of the reactor coolant pressure boundary as defined in section 50.2(v) of this part. It is designed to contain design-basis accident pressure and serve as a leakage barrier against an uncontrolled release of radioactivity to the environment. The term "containment", as used in this appendix refers to the primary containment structures and associated leakage barriers.

This definition does not include a Boiling Water Reactor (BWR) Secondary Containment Building or a Pressurized Water Reactor (PWR) Shield Building. Also excluded from the provisions of this appendix are interior barriers such as the BWR Mark II Drywell Floor, the Drywell perimeters of the BWR Mark III, and the PWR Ice Conde* 1ser." See comments under "Containment System". Type A Test Reword the definition as follows:

                    "A test to measure the Primary Containment overall integrated leakage rate, under conditions representing design basis loss-of-coolant accident containment pressure, and system alignments (1) after the primary containment 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."

See comments under "Containment System". Type C Test Delete the word "pnewnatic" so that water tests are also acceptable. Reduced Pressure Tests Add definition. See comments in cover letter. SECTION I I I A. TYPE A TEST

• III.A.(3) - Test Frequency Add the following insert:

       "If the test interval ends while primary containment integrity is not required, the test interval may be extended provided all deferred testing is successfully completed prior to the time containment integrity is required."

Addition of this insert from the draft ANSI Standard 56.8 dated September, 1986 will eliminate unnecessary testing during plant shutdowns (note: this wording is similar to that stated in the proposed Regulatory Guide). This section also would impose a new regulatory requirement on the preoperational testing. The 10 year ISI test interval starts with initial plant operation. The proposed rule will result in additional costs because it will usually require an additional Type A test due to the time interval between the pre-op test and the start of plant operation. This additional test adds little or nothing to plant safety because the plant has not experienced any service life during that time interval and Type Band C test requirements mandate complete local leak rate testing prior to plant operation. In addition, the cost associated with this additional Type A test was not considered in the backfit analysis. Therefore, either the analysis or the proposed revisions should be revised. III.A.(7)(a) and (b) - Acceptance Criteria Delete "properly justified". This is an ambiguous term which is subject to individual interpretation. Item (b) addresses a new requirement, "as-found", and therefore should have a thorough backfit analysis performed in accordance with 10CFRS0.109. III.A.(7)(c)(iii) This paragraph is confusing and needs clarification. For example, "added to Type A test results" needs to be identified as to whether it refers to the previous or present Type A test results. Also, how or whether to incorporate non-ILRT refueling outages and intermittent tests needs to be clarified. Currently different interpretations apply in different NRC Regions (IE Information Notice 85-71). III.A. (7 )(d) Change wording to read " ... made after the start of the Type A test sequence must be accounted for in the final Type A test results and the appropriate analytical corrections made .*. "

• This rewording provides more clarity to avoid misinterpretation.

III.A.(B)(a) - Retesting This addresses a new requirement, "Corrective Action Plan" (CAP). We question the need for the NRG required approval of the test schedule for Type A tests. Requirements for the test schedule are defined in the rule. III .A. (B)(b)( i) See comment from III.A.(3) regarding insert from ANSI Standard 56.8. III.A. (8)(b)( ii) NRC approval is required prior to implementation of the corrective action plan and alternative leakage test program. Due to plant scheduling requirements, it would be beneficial to have required maximum NRG response time (e.g., 90 days). B. TYPE B TEST III.B.(i)(a) - Frequency See comment from III.A.(3) regarding insert from ANSI Standard 56.8. III.B.(4)(a) - Acceptance Criteria Change wording to read "The sum of the as-found Type Band C tests results must not exceed La using the minimum pathway leakage. The sum of the as-left Type Band C test results must not exceed 0.6 La using the maximum pathway leakage and including leakage rate readings from continuous leakage monitoring systems." This provides more clarity to avoid misinterpretation. III.B. (4)(c) This item should be deleted as the Type B tests do not have individual acceptance criteria. C. TYPE C TEST III.C.(l) - Frequency See comment from III.A.(3) regarding insert from ANSI Standard 56.8 .

• III.C.(3)(a) - Acceptance Criteria Reword as follows:

             "The sum of the as-found Type Band C test results must not exceed La, using the minimum pathway leakage. The sum of the as-left Type Band C test results must not exceed 0.6 La, using the maximum pathway leakage and including leakage rate readings from continuous leakage monitoring systems."

This provides more clarity to avoid misinterpretation. SECTION IV IV.A - Containment Modification or Maintenance Adding "repair" to the definition is a new requirement, and therefore, is subject to a backfit analysis in accordance with 10CFRS0.109. The current rule reads "Any major modification, repair, or replacement. ... " The word "major" has been deleted in the proposed revision, however, it should remain in the rule. The "as-found" requirement is new, and therefore, should have a thorough backfit analysis performed in accordance with 10CFRS0.109. SECTION V V.A - Type A, Band C Test Details This requirement should be deleted. Test methods, procedures, and analyses are not normally referenced in the technical specifications and this would impose an undue requirement and restriction. V.B - Combination of Periodic Type A, B, and C Tests The "as-found" requirement is new, and therefore, requires a backfit analysis under 10CFRS0.109. The words "containment system" should be replaced with "primary containment." This will be consistent with our proposed deletion of the containment system definition. SECTION VI VI.A.2 - Report Submittal Submittal of periodic Band C tests is a new requirement and subject to the Backfit Analysis required by 10CFRS0.109. Also, to prepare this report, an "as-found acceptance criteria" must be defined (i.e. do plants use the previous Type A test?) To avoid duplication of efforts, one report should be required for each series of tests, not for each individual test as implied (i.e. one report per shutdown). Also, reports of failed tests to the Regional Administrator is redundant to the LER process (10CFRS0.73). An LER is presently required for a failed test. This requirement should be deleted. VI.B - Report Content See comments under III.A.(8). SECTION VII

• VII.A - Applicability The bases for alternative leak test requirements should not be required to be in the plant technical specifications.

Incorporation in other plant documents, such as the FSAR, should also be acceptable. Present exemptions should also be allowed under this revision. We suggest the following be added to this paragraph: "Exemptions to previous revisions of this rule approved by the NRG are still applicable."

GENERAL COMMENT

S ON COST ANALYSIS The NUREG/CR-4398 cost analysis of rev1s1ons to 10CFRSO Appendix J, claim a reduction in replacement energy costs due to expected reductions in plant outage times. This is due to the proposed use of more frequent Type Band C testing coupled with less frequent Type A testing (see Section 5.1.4). What is not included in the analysis is the additional plant outage time and increased radiation exposure associated with doing the more frequent (mid-cycle) testing. Therefore, mid-cycle testing outage time needs to be included in a cost-benefit analysis. The cost analysis also does not adequately address the potential capital expenditures for modifications to containment penetrations to allow testing in conformance with the proposed rule. In some BWR plants, the number of penetrations which require testing exceeds 100. Valves for some of these penetrations are tested in groups, not individually. Many of those penetrations are not equipped with the requisite block valves and test connections to allow individual valve local leakage rate testing in accordance with the rule. This is especially true for older BWR plants which were designed and constructed prior to the original issuance of Appendix Jin 1973. The capital expenditures required to effect compliance could approach 10 million dollars per plant. Also, NUREG/CR-4398 considered only the labor cost of the increased number of LLRTs, which was based on a 3.0 hour test duration. This is a substantial underestimate of the time needed to perform an LLRT, which, including valve alignment and restoration, pipe draining and refilling, test equipment setup, checkout, and removal, frequently requires 8 to 24 hours (or more) to complete. The NRC Backfit Analysis does not substantiate its conclusion that the proposed Appendix J is both safety and cost neutral . ATTACHMENT 3 COMMENTS ON DRAFT REGULATORY GUIDE MS-021-5 B. Discussion The draft regulatory guide currently endorses ANSI/ANS-56.8-1981. A draft of 56.8 dated September, 1986 is available. The regulatory guide should be updated concurrently with the revision of the standard as appropriate. C.2 Type A Test Requirement The stated position requires that test instrument error be included in the local leakages used to correct Type A test results . Inclusion of this in the calculations and report would have negligible effect on the overall results, i.e. from .00001 to .0001 La. Moreover, including such small effects is not justified when results of the new source term study indicate that our current allowable leak rates are much too conservative. Therefore, because this requirement would not benefit public safety, it should be deleted. If not deleted, this requirement should be subjected to a backfit analysis in accordance with 10CFRS0.109. C.3 Pressurizing Considerations This regulatory position should identify an exception for components (i.e., valves) with inflatable seals using air or nitrogen as the pressure medium. C.6.(5) and (6) Verification Test In some cases the time duration from the end of the Type A test to the start of the verification test can be several hours. During this time, stable conditions are being established for the start of the verification test. Data taken during this time period does not reflect either the Type A test conditions, since a leak has been superimposed, or stable conditions for the verification test. This data should not be included in the Type A test data. C.8 Type Band C Test Pressures In most BWRs, the Main Steam Isolation Valves (MSIVs) are local leak rate tested by pressurizing the volume between them. This results in the inboard valve being tested in the reverse direction. Testing the MSIV at full design basis accident pressure would lift the seat of the inboard valve, and therefore these valves are tested at a reduced pressure. To test the inboard valves in the accident pressure direction, some BWR's must remove the drywell and reactor vessel heads to install plugs. Therefore, a requirement of full pressure testing could be implemented only after backfits. C.11.1 Calibration For instruments related to Type Band C tests, this may result in considerable hardship. Many of the flowmeters cannot be calibrated onsite and must be sent to an outside laboratory for calibration. Due to scheduling policies of these labs, there may be a turn-around time of several weeks during which the instruments are off site and unavailable for use. Since these instruments are generally needed throughout an outage, there could be a significant impact on an outage schedule. C.11.3 Calibration A requirement for the daily calibration of Type Band C test instruments would present a significant impact on testing efforts. This is particularly true for test rigs that use rotometers. Calibration of rotometers is time consuming and in some cases, cannot be accomplished onsite. Calibration intervals should be based on the type of instrument used and the respective manufacturer's recommendation. In addition, there are already frequent and in many cases daily "checks" on instruments and it is not clear that daily "calibration" is necessary or justified. C.12 Containment Atmosphere Stabilization These additional requirements will substantially increase testing time and costs. The effects of transient atmospheric conditions on

• the final test results depends on the speed of the transient, the containment geometry, and the ability of the instrumentation system to respond to transient conditions, i.e., instrument response time.

The magnitude of errors induced by transient effect upon the final results are not known. Therefore, it is premature to specify an exact numerical acceptance criteria in the regulations. Rather, the procedures and criteria for dealing with transients should be left up to the judgement of those performing the tests, as long as temperature stabilization is met. C.13.2 Data Recording and Analysis Increased readings yield less scatter and better resolution. Also, average data is preferable and does not adversely affect Type A results. C.13.3 The BWROG endorses the comments on this section submitted by Bechtel Power Corporation on January 9, 1987. C.14.2 and 14.3 Temperature Measurement For the following reasons, we question the practice of performing temperature surveys using the ventilation configuration for the Type A test and the requirement to re-run a survey for the first periodic Type A test due to different heat sources from preoperational conditions. The failure to ventilate continuously could result in great personal safety hazards to those making temperature surveys. In recent tests, temperatures of 125°F have been measured in BWR containments when the ventilation system was turned off to simulate test conditions. Moreover, when the Type A test is performed at the start of the outage, the failure to continuously ventilate could result in nitrogen (inerting medium) pockets. These potential safety hazards show that survey requirements must be supported by comprehensive technical studies which establish a clear relationship between temperature surveys and leak rate calculations. C.16 Reporting of Results This item is covered by the BWROG Comments on the proposed revisions to 10CFRSO Appendix J (attachment 2). C.17.2 Flowrate The term "air discharge method" is not defined. If this means measuring the outleakage from a test volume instead of the makeup flow, this restriction could present a considerable problem for many BWR's. In order to meet the requirement for testing valves in

• C.20 the accident direction, using the outleakage technique, considerable backfit of Class 1 piping systems may be required.

Affected systems include main steam, HPCI, and RCIC. Recording of Leakage Rates Accounting for packing leaks outside the primary containment is a major backfit, especially in BWR plants. Many containment isolation valve pairs are designed to be tested by pressurizing through a test tap between the two valves. Consequently, the packing on the inboard valves does not experience the test pressure. Therefore, to account for packing leaks, valves would have to be tested in the accident pressure direction. To accomplish this, test taps and/or block valves would need to be installed in containment. The costs of such modifications would not seem to be justified, especially when considering that valve packing is normally tested during the Type A tests. Appendix: The BWROG endorses the comments submitted by Bechtel Power Corporation on January 9, 1987. Regulatory Analysis: A full and complete regulatory analysis must be performed including a backfit analysis in accordance with 10CFRS0.109

• BA LT IMORE GAS AND ELECTRIC

                                                                                *a7 APR 24 P2 :37 CHARLES CENTER* P. 0. BOX 1475

• BALTIMORE, MARYLAND 21203 .*

OFff * '.F ~ .: I JOSEPH A. TIERNAN 00Ch li ' : \. ~: r .' VICE PRESIDENT ..,_. ** I NUCLEAR ENERGY April 22, 1987 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC 20555 ATTENTION: Docketing and Service Branch

SUBJECT:

Comments on Proposed Rule for Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants

REFERENCE:

(a) Letter from Mr. J. A. Tiernan (BG&:E) to NRC (Rules and Procedures Branch), dated January 23, 1987, Comments on Draft Regulatory Guide Task MS 021-5 (October 1986) Gentlemen: The following comments are submitted by the Baltimore Gas and Electric Company in response to Federal Register Notice 51 FR 39538, dated October 29, 1986. This notice provided a proposed change to 10 CFR 50, Appendix J. Comments on the Draft Regulatory Guide referenced in Appendix J are provided in Reference (a). We have reviewed the proposed revision to 10 CFR 50, Appendix J as well as the associated backfit analysis. While the background information states "the scope of this revision to Appendix J is limited to corrections and clarifications, and excludes new criteria," the proposed change does include additional requirements which were shown by the backfit analysis to be significant in cost and to cause an increase in occupational exposure. Although we recognize many of the changes do provide administrative improvements by eliminating conflicts, ambiguities and lack of uniformity in the regulation, we cannot endorse this proposed rule. The backfit analysis clearly shows the proposed rule does not show a substantial increase in the overall protection of the public health and, therefore, does not meet the backfit rule. Therefore, we feel the revision to 10 CFR 50, Appendix J, as proposed, should be withdrawn. Our specific comments on the backfit analysis are provided in Attachment (1). Baltimore Gas and Electric supports the Commission's effort to improve the requirements in 10 CFR 50, Appendix J. However, we recommend the Commission eliminate or modify proposed changes which prevent it from satisfying the requirements of Section 50.109(a)(3). In light of the above, we have provided both general and specific comments on the proposed Appendix J in Attachments (2) and (3). In addition to exceptions to the proposed changes, these comments also refer to its positive aspects as MAYO 61987 Acknowledged by card .*.......--.....-- _..,._..,.,

l l .,

• l l 1

. . lEAR RfGUtA TORY (C>M1'iv f)OcKETING & SERVICE SECTto~- OFFl(E 0 .. ' si:rRETARY 0 ~ -.1N 12/~,,~~ -

Docketing and Service Branch April 22, 1987 Page 2 well as recommendations to further improve the flexibility and clarity of the requirements of Appendix J. Should you have any questions regarding these comments, we would be pleased to discuss them with you. Very truly yours,

                                                   <:)JrtUluUU-

• JA T/LSL/ dlm Attachments cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC S. A. McNeil, NRC J. M. Allen, NRC T. Foley/D. A. Trimble

ATTACHMENT (1) COMMENTS ON THE BACKFIT RULE 10 CFR 50, APPENDIX J - LEAKAGE TESTS FOR CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS Upon review of the Backfit Analysis, we believe that the Backfit Rule has not been adequately implemented for this proposed revision. The backfit analysis states:

         "This revision of 10 CFR 50, Appendix J is not being proposed by the NRC staff on the basis of any substantial increase in safety or decrease in costs."

and; "The proposed rule is intended to be applied to the entire population of nuclear power reactors and it clearly constitutes a backfit." Based on these statements, it is apparent that the Commission cannot conclusively state that the requirements of Section 50.109(a)(3) of the Backfit Rule have been met. The Commission feels that the change is justified " *** based on the need to conform present testing capabilities to the current state of the art, and to use the best available procedures **** " However, no arguments have been provided to demonstrate a link between the additional qualitative factors and the protection of the public health and safety. Based on this information, the Commission has not shown that Section 50.109(a)(3) has been completely satisfied for the proposed revision. Therefore, we are strenuously opposed to suspension of Section 50.109(a)(3) without a finding of "undue risk to public health and safety," per 50.109(a)(4)(ii), which obviously does not exist. The backfit analysis states that the rule as proposed is "cost neutral." Review of the cost analysis shows that the major savings to the industry (80 to 240 million dollars) is from the option to submit a "Corrective Action Plan" proposing more frequent Type B and C testing rather than more Type A penalty tests. (This option appears reasonable since Type B and C penetration leakage is the predominant cause for Type A test failures.) Without the rule change, the other option left open to the utility would be to request an exemption from more frequent Type A testing due to failure of Type B or C items. However, in each of the above cases, the utility would have to perform the same type of analysis to justify the substitution of more frequent Type B and C tests. Since either the exemption or the Corrective Action Plan can provide the same net result, the savings of 80 to 240 million dollars by the industry as a result of the rule change appears to be an artificial savings. Finally, the cost analysis does not adequately address the effects on the industry for changing the definition of a Containment Isolation Valve. The proposed definition references General Design Criteria 55, 56, and 57 of 10 CFR 50, Appendix A. While the intent was to clarify the definition, it instead creates yet another new ambiguity by implying the existence of a new requirement for those utilities whose construction permit was issued prior to the effective date of Appendix A (1971). The number of plants whose permits were issued prior to 1971 is large enough that this should have been evaluated, and constitutes an obvious backfit, in any event, since it could be construed as requiring significant modifications to those plants.

                                             - l -

ATTACHMENT (l) COMMENTS ON THE BACKFIT RULE 10 CFR 50, APPENDIX ]-LEAKAGE TESTS FOR CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS The proposed change has many benefits which are discussed in Attachments 2 and 3. We recommend the Commission reevaluate all aspects of the proposed change which constitute a backfit and provide a change which can satisfy the Backfit Rule. One method of doing this could include making those aspects of the revision, which do not satisfy the Backfit Rule, voluntary. Another would be to allow present operating plants or plants under review the opportunity to continue meeting the current 10 CFR 50, Appendix J provisions. A final, yet more drastic method would be to eliminate all portions of the proposed change which cannot meet the Backfi t Rule. As we have already indicated, the Backfit Rule may not have been adequately implemented in the draft backfit analysis; however, that is not a basis for circumventing the Backfit Rule completely. To "suspend" the Backfit Rule merely provides a mechanism to bypass it in the future and is an obvious contravention of the agency's own requirements. The seeds of the initial proposal to improve 10 CFR 50, Appendix J are good. However, the additional requirements that were added to the proposed change during the rulemaking process have caused the Backfit Rule to perform its intended function, which is to prevent the imposition of additional requirements which provide no substantial increase in the overall protection of the public health or safety. COMMISSIONER BERNTHAL'S CONCERNS

1. With regard to the Backfit Rule, comment was solicited as to "whether the Commission should continue its attempts to apply the Backfit Rule to all rulemaking, or whether the Rule should be revoked as it applies to rulemaking activity."

(fl Any attempts to modify or revoke the Backfit Rule at this point would be both premature and overreactive. The Backfit Rule was developed to apply to all types of rulemaking and should be effectively implemented for all rulemaking. This rule was developed through a joint effort between the industry and the NRC, and is a long overdue test of the overall desirability of new regulatory initiatives.

2. Comment was also solicited as to "whether the Commission should amend the Backfit Rule to waive the "substantial increase" provision, and indicate explicitly that non-monetary benefits may be weighed by the Commission in the cost-benefit balance, when such considerations are found by the Commission to be in the public interest."

The "substantial increase" threshold is an important part of the Backfi t Rule. This threshold is a cornerstone of the combined industry and NRC effort to discipline the backfitting process. We believe that the "substantial increase" threshold should not be suspended for any backfit. ATTACHMENT (1) COMMENTS ON TiiE BACKFIT RULE 10 CFR 50, APPENDIX J - LEAKAGE TESTS FOR CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS The Backfit Rule acknowledges t hat other factors, in addition to those explicitly mentioned in the rule, can be used to determine whether the requirements of 50.109(a)(3) a re met. However, these other factors must provide assurance that real improvement in overall protection will result and that implementation costs are just ified. Circumvent ing the Backfit Rule during the rulemaking process would significantly weaken the balanced controls established to discipline the backfit process* I W, I ATTACHMENT (2)

GENERAL COMMENT

S 10 CFR 50, APPENDIX J - LEAKAGE TESTS FOR CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS

1. The Baltimore Gas and Electric Company (BG&:E) believes that 10 CFR 50, Appendix J should be revised to clarify the appendix, reflect increased experience with applying the existing requirements and simplify the text. Overall, those portions of the proposed change which reflect the above types of changes are an administrative improvement. In addition, by moving the detailed criteria out of Appendix J and into a Regulatory Guide, the basic test requirements will be highlighted in the Appendix and future changes to the Regulatory Guide can be made without affecting the basic rule. Finally, this change formally recognizes the improved methodology and criteria of ANSI/ ANS-56.8 - 1981.

2* The rule change was designed to provide greater flexibility for licensees to apply the requirements of 10 CFR 50, Appendix J. The intent was to minimize the number of exemptions filed by Licensees. In light of this philosophy, we recommend the periodicity of leakage testing should be provided a tolerance to account for scheduling and operational considerations for those plants on a 24-month refueling interval. One method would be to allow a maximum extension not to exceed 25% of the test frequency for the Type A, B, and C tests as well as the Type A retest requirements. The combined time interval for any three consecutive tests could be limited to 3.25 times each of the test's specified frequency. The above extensions could be restricted to only those plants whose previous leakage history justifies the extended period. This would allow much greater flexibility while still meeting the intent of the periodicity of each test.

3. The NRC is presently evaluating a more comprehensive review of containment integrity and testing requirements than what was presented in this proposed change. This is part of an overall program being conducted to identify current NRC regulatory requirements that have marginal importance to safety and to recommend appropriate actions to modify or to eliminate these unnecessary requirements. We recommend that any change to 10 CFR 50, Appendix J include the results of the above studies.

4. The Supplementary Information to the proposed rule's preamble refers to NRC efforts at improving Technical Specifications and alludes to the possibility of changes in the form of implementation of the Appendix J requirements. One of the major efforts of the Technical Specifications Improvement Program has been the development of a selection criteria for those elements that should remain within Technical Specifications. Application of this criteria to the existing Containment Leakage Technical Specification resulted in it not being selected as an element to be included in the improved version of Technical Specifications. Therefore, we recommend that 10 CFR 50 Appendix J not refer to requirements contained in Technical Specifications, with one exception. This one exception is the inclusion of La and Pa in the Design Features of the Technical Specifications.

ATTACHMENT (2)

GENERAL COMMENT

S 10 CFR 50, APPENDIX J - LEAKAGE TESTS FOR CONTAINMENTS OF LIGHT- WATER-COOLED NUCLEAR POWER PLANTS The justification for the above recommendation is that licensees are required by their Operating Licenses to comply wit h federal regulations. As a result of this license condition, there is no need to repeat federal regulations in Technical Specifications to ensure compliance with these requirements. The duplication of requirements only adds to the administrative burden of both the NRC and licensee. ATTACHMENT (3) SPECIFIC COMMENTS 10 CFR 50, APPENDIX J - LEAKAGE TESTS FOR CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS In the following discussion, specific sections of the proposed rule are reproduced. Words, phrases, or ideas we suggest replacing are overstruck (/) with the proposed words, phrase or idea immediately following, underlined and in parenthesis. II. DEFINITIONS 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 (or any valve which is relied u on to erform a containment isolation function in accordance with the rind al design criteria specified in the Licensee's construction permit. COMMENT The definition contained in the proposed rule would require those utilities whose construction permit was issued prior to the effective date of Appendix A (1971) to make significant modifications to their plants. By altering the above definition as shown, the definition could be clarified without requiring modifications to earlier vintage plants. II. DEFINITIONS 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) **.* 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) **** II.A. (7)(c)(i) All potential leakage paths of the isolated, repaired, or adjusted leakage barrier are locally leak testable, and **.* COMMENT The above definitions of minimum and maximum pathway leakage rates, as well as the requirement in the acceptance criteria, for Type A tests, that all potential leakage paths be locally leak testable would require a backfit. By changing or re-defining the test requirements, those plants whose containment isolation systems were designed to be tested in a certain manner, based on existing requirements at the time the plant was constructed, would have to install multiple test connections as well as additional blocking valves. ATTACHMENT (3) SPECIFIC COMMENTS 10 CFR 50, APPENDIX J- LEAKAGE TESTS FOR CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS VI.A.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 in the manner specified in paragraph 50.4 and at the time of the next Type A test submittal. Reports must 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. COMMENT This paragraph may be interpreted to mean that each containment barrier (e.g., valves, flexible seals) has a separate acceptance criterion and, therefore, requires a separate report. The only stated acceptance criteria in the proposed rule are that Type B and C total leakage must not exceed 0.60 La and "as found-as left" Type A results must not exceed 1.0 La and 0.75 La, respectively. Therefore, Type Band C test results should only be reported with Type A tests. III.A.(3) Test Frequency Unless a longer interval is specifically approved by the NRC staff, the interval between the preoperational and first periodic Type A tests must not exceed three years, and the interval between subsequent periodic Type A tests must not exceed 4 years (with a maximum allowable extension not to exceed 25% of the test fre uenc

• The combined time interval for an 3 consecutive tests shall not exceed 3.25 times the specified test frequency.

COMMENT The alteration to the proposed rule would make the required test frequencies more flexible for those plants which will soon be operating with a 24-month refueling interval. Theoretically, a plant on a 24-month refueling outage can just meet the four year requirement. However, the proposed minimal tolerance would provide those plants on a 24-month refueling interval additional flexibility for scheduling and operational considerations. The allowable tolerance would be in accord with both the maximum allowable extension for Surveillance Requirements as well as ANSI/ ANS-56.8 - 1981 which allows a 5-year frequency for Type A tests. 111.B.(l)(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 (with a maximum allowable extension not to exceed 25% of the test frequency. This allowable extension shall be restricted to only those plants whose previous leakage history can justify the extended eriod. The combined time interval for an 3 consecutive tests shall not exceed 3.25 times the specified test frequency. ATTACHMENT (3) SPECIFIC COMMENTS 10 CFR 50, APPENDIX J - LEAKAGE TESTS FOR CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS 111.B.(J)(a) Initial and periodic tests. Air locks must be tested prior to *** airlock opening (but in no case may the interval exceed 2 years (with a maximum allowable extension not to exceed 25% of the test frequency. This allowable extension shall be restricted to only those plants whose previous leakage history can justify the extended eriod. The combined time interval for an 3 consecutive tests shall not exceed 3.25 times the specified test frequency. III.C.(l) Type C Test 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 (with a maximum allowable extension not to exceed 25% of the test frequency. This allowable extension shall be restricted to only those plants whose previous leakage history can justify the extended period. The combined time interval for an 3 consecutive tests shall not exceed 3.25 times the specified test frequency. COMMENT The above alterations to the proposed rule would make the required test frequencies more flexible for those plants which will soon be operating with a 24-month refueling interval. We recommend the NRC work with the industry to develop the specific criteria necessary to justify the above extension. This criteria can then be provided in the Regulatory Guide on Containment Leakage Testing. Theoretically, a plant on a 24-month refueling outage can just meet the two year requirement. However, the proposed minimal tolerances would provide those plants on a 24-month refueling interval additional flexibility for scheduling and operational considerations. This allowable tolerance would be in accord with the maximum allowable extension for Surveillance Requirements. III. B. (4 )(a) The sum of the /J.t lt/,vivi<A. t/,r as left Type B and C test results must not exceed 0.60 La using **** COMMENT The sum of the "as found" Type B and C test results should be able to exceed 0.60 La as long as the "as found" Type A result is less than La. Only the "as left" Type B and C results should be subject to the 0.60 La maximum.

ATTACHMENT (3) SPECIFIC COMMENTS 10 CFR 50, APPENDIX J - LEAKAGE TESTS FOR CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS V.A. Type A, B, C Test Details

    'i U'/. ittt r/lti'M,dtl t,fi>ttdi/Jrttl Mad Mail#tt (The ANSI Standard used to determine 1

the method of leakage testing) for a steel, concrete, or combination steel and concrete containment and its penetrations and isolation valves for light-water-cooled power reactors must be referenced M dttlr/atd in the Technical Specifications. COMMENT Adding any additional requirements or definitions to the Containment Leakage Technical Specifications goes against the philosophy of the ongoing Technical Specification Improvement Program (see Attachment 2, Comment No. 4). If the intent is to reference the applicable ANSI Standard, this requirement could be fulfilled by incorporating the necessary information in the licensee's containment leakage program and procedures.

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              *ARil            Pennsylvania Power & Light Compan Two North Ninth Street

• Allentown, PA 18101
• 215 / 770-5190CKE l [ P.

USNHC 17 APR 23 P4 :09 Harold W. Keiser Vice President-Nuclear Operations 21s1no-1so2 OFF ICE G, ::. .... 1 " ,- I OOCK ETitl 3 -~ -;r v 1cr: 8RANC. APR 2 2 1987 Mr. Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch SUSQUEHANNA STEAM ELECTRIC STATION PP&L COMMENTS ON PROPOSED RULE, REVISION TO 10CFR50 APPENDIX J AND DRAFT REGULATORY GUIDE MS 021-5 Docket Nos. 50-387 PLA-2848 FILES R41-2, Al7-ll and 50-388

Dear Mr. Chilk:

Pennsylvania Power and Light Company is pleased to have this opportunity to provide comments on the October 29, 1986, 51FR39538 proposed revision to 10CFR50 Appendix J, "Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants," and the associated draft Regulatory Guide MS 021-5 . We support the Commission's efforts to revise the existing regulation to provide clarity and reflect advances in leakage testing methods. The proposed ruling has several changes that are desirable, such as endorsement of the updated ANSI/ANS-56 . 8 standard, the as-found Type A (ILRT) test acceptance criterion of l.OL, and the concept of Corrective Action Plans to address a problem components as an alternative to increased Type A test frequencies following two consecutive test failures. The BWR Owners Group has submitted substantial comments to NRC on the proposed ruling. We fully endorse the BWROG comment s . In addition, we would like to emphasize several concerns . The Backfit Analysis for the proposed Appendix J revision and for the draft Regulatory Guide MS 021- 5 concluded that the proposed rule is both safety and cost neutral . NUREG/CR-4398 provided the cost/benefit analysis upon which the Backfit Analysis was based. It is our concern that due to underestimates in work scopes and facility downtime, failure to address hidden costs, and failure to identify new criteria as backfits , the Backfit Analysis does not substantiate its conclusion that the proposed ruling is both safety and cost neutral. Several areas of the proposed Appendix Jin which the backfit r ule, 10CFR50.109, should have been applied or the existing backfit evaluation is inadequate are as follows.

I /JiJ5Jtib~

2 FILES R41-2, A17-11 PLA-2848 Mr. Samuel J. Chilk 0 Section IV A - "Any modification, repair, or replacement of a component subject to Type B or Type C testing must also be preceded by a Type B or Type C test . " This is a new requirement . As-found leakage is specifically quantified at Susquehanna SES only as needed to support a Type A integrated leakage rate test, or to trend problematic components. This new requirement will increase outage durations, tie up critical resources, and effectively penalize preventative maintenance programs. Also, the duration of mid-cycle forced outages for containment boundary component repair will be increased in direct proportion to the duration of the as- found tests. The cost/benefit study, NUREG/CR-4398, incorrectly identifies this new requirement as a clarification. The costs of increased facility downtime and increased manpower have not been addressed in the Backfit Analysis, nor has the additional radiation exposure resulting from the increased testing been considered in determining the safety impact of the proposed rule. An alternative to this requirement is to require utilities to establish as-found testing programs to document leakage for problem valves and components on a case-by-case basis. The existence of sound maintenance programs should eliminate the perceived need to continually determine as-found Type Band Type C test results. 0 The cost/benefit analysis (NUREG/CR-4398) is based on a typical local leakage rate test (LLRT) duration of three hours. This is a substantial underestimate of the actual time needed to perform an LLRT, which, including valve alignment and restoration, pipe draining and refilling, test equipment setup, checkout, and removal, generally requires eight to twenty-four hours to complete . This gross underestimate in LLRT test duration has resulted in a serious underestimate of the labor costs of Corrective Action Plans and as-found testing requirements. Calculations of increased facility downtime are also inaccurate. NUREG/CR-4398 should be revised to determine more realistic labor and facility downtime costs. 1 ..- 1 0 The proposed revision of Appendix J includes a new definition for Type A testing, "Containment System," which is defined to include "those systems or portions of systems that by their functions extend the primary containment boundary to include their system boundary." This new definition will extend the Type A test boundary, and should have been identified as a backfit and evaluated as such in the cost/benefit analysis. o Corrective Action Plans required for any failed periodic Type A test may necessitate mid-cycle outages to perform increased maintenance and testing of problem components. The Backfit Analysis does not address the cost of increased facility downtime for mid-cycle outages, and underestimates the additional radiation exposure resulting from the increased testing, since exposure during leaka~e rate tests will be greater during mid-cycle outages of short duration than during refueling outages.

3 FILES R41-2, Al7-ll PLA-2848 Mr. Samuel J. Chilk Other areas of the proposed Appendix J and draft Regulatory Guide MS 021-5 which are potential unidentified backfits and/or inadequately evaluated backfits are described in detail in the comments provided by the BWR Owners Group. It is evident that the proposed rule has not been adequately reviewed and justified pursuant to 10CFR50.109, Backfitting. Pennsylvania Power and Light Company therefore requests that the proposed ruling be withdrawn until an adequate backfit analysis is performed. Withdrawal of the proposed rule at this time will allow NRC to further revise Appendix J and draft Regulatory Guide MS 021-5 to remove ambiguities and provide clarification where needed, and to ensure compliance with 10CFR50.109. Again, we thank NRC for this opportunity to comment on the proposed rule. Very truly yours, 917~ H. W. Keiser Vice President - Nuclear Operations cc: NRC Document Control Desk (original) NRC Region I Mr. L. R. Plisco, NRC Project Inspector Mr. M. C. Thadani, NRC Project Manager

uOCKET NUMBERPR eeaeaSEo w - ~a 1 Atomic Industrial Forum, Inc. 7101 W isconsin Avenue L5/ F~ 3t:/5 ~t:) Bethesda, MD 20814-4891 Q(; ET E.. Telephone: (301) 654-9260 US RC TWX 7108249602 ATOMIC FOR DC April 8, 1987 '87 APR 10 All :08 OFFICE Or Stt,,r-;t I v DOCKET! G & 3E?V!Cf. BRA CH Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch

Subject:

Proposed Rule: Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants (l 0CFRS0 Appendix J)

Dear Sir:

• The NRC published in the October 29, 19 86, Federal Register, the proposed rule, 10 CFR SO, Appendix J, "Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants "(51 FR 39538) and solicited comments on the proposed rule. The Atomic Industrial Forum's Committee on Power Plant Design, Construction and Operation has reviewed the proposed rule and offers the following comments for your consideration.

The containment leakage test program requirements and criteria should be stated clearly in the regulations. The regulations should be non-prescriptive and the method should be flexible and subject to licensees re-evaluation so long as the criteria are met. Some of the proposed rule changes would be beneficial; however, because the NRC is planning a broader, more comprehen-sive review of requirements in the next year or two we recommend that the Commission not issue the proposed rule until the additional issues mentioned in the background section of the proposed rule are resolved. Some negative features of the proposed rev1s1on include; (1) the need to develop new technical specification sections to incor-porate the changes, (2) the potential for more frequent testing with increased down time and increased radiation exposure, (3) more reporting requirements for local leak rate tests, (4) the potential for NRC re-evaluation of previous exemptions by use of current design criteria and (5) uncertainty in how future revisions to the Regulatory Guide are to be handled. NUREG/CR-4330 , "Review of Light Water Reactor Regulatory Requirements", concluded that streamlining and decreasing the existing Appendix J regulatory requirements would have marginal effect on public health and safety. Since the risk contribution due to containment leakage is small there is no apparent reason APR 15 1987 ckno le

k

Secretary April 8, 1987 i to increase testing. Major areas of concern in the proposed rule are the requirements for reporting the "as found" type B and C leakage summation using the maximum pathway leakage criteria, and the increased testing of type Band C components which fail the i r acceptance criteria for leakage. Also of concern is the adequacy of the backfit analysis, which concluded that the proposed revision to Appendix J is both safety and cost neutral. The basis for this conclusion is NUREG/CR-4398, "Cost Analysis of Revisions to 10 CFR Part 50, Appendix J, Leak Tests for Primary and Secondary Containments of Light-Water-Cooled Nuclear Power Plants." We are concerned that the backfit analysis did not consider many of the costs associated with the proposed rule, and failed to identify certain backfits as such, as is discussed in the attached responses to NRC questions 2, 4, 7, and 10. Since the proposed revision to Appendix J has not been adequately justified pursuant to 10CFR50.109, we recommend that this proposed rule be withdrawn until an adequate cost/benefit analysis and further revision to the proposed rule are performed. Enclosed are (1) our specific comments which address the fifteen questions in the Federal Register Notice and (2) our comments l on the companion Draft Regulatory Guide (Task MS 021-5). Sincere~ e ~ Chairman liams, Jr. Committee on Powe r Plant Design Construction, and Operation JWW:bjr Enclosures

QUESTIONS/COMMENTS ON PROPOSED REVISION TO 10 CFR SO APPENDIX J, "LEAKAGE RATE TESTING OF CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS" Following are questions on page 39539 of Federal Register Notice of October 29, 1986, with AIF comments:

1. The extent to which these positions in the proposed rule are already in use.

Comment Some items already being used are:

a. The full design basis accident pressure (Pac) for type A test. Some utilities still use the partial pressure test.

b. The "as found" Type A provisions which have only been used (generally on an informal basis) since 1982.

Previous to 1982, many plants did not record "as found" local leak rate test (LLRT) information. Today, some plants only determine "as found" Type Band C leakage rates when necessary to support performance of a Type A test during an ILRT outage.

c. The Design Basis Loss-of-Coolant Accident scenario for Pac and system alignment justification.

d. Provisions for isolating excessive leakage paths during the Type A test.

e. More frequent testing of certain repeat offenders (e.g.

the purge and vent valves). Utilities can not implement those portions of ANSI/ANS 56.8 which conflict with the existing Appendix J and ANSI N45.4 standard, such as, performing an 8 hour Type A test. The inconsistency of different NRC Region inspectors has caused a reluctance by utilities to implement new test program require-ments when they are not required from a licensing standpoint. Older plants which were designed prior to the 10CFRSO, Appendix A, General Design Criteria, will not satisfy the containment isolation valve definitions.

2. The extent to which those in use, and those not in use but proposed, are desirable.

Comment ANSI N45.4 is outdated and should be removed from the regulations. An NRC endorsement of the new standard

ANSI/ANS-56.8 would be beneficial. The major pluses of the new standard are the reduced duration test, use of the Mass Point Analysis Method, provisions for isolating excessive leakage during a Type A test, the potential to extend the Type A frequency based upon the Type Band C program validity or an approved corrective action program, and air lock test extensions. Some negative features involve the need to develop new tech-nical specifications sections to incorporate the changes, the potential for more frequent testing with increased down time and increased radiation exposure, more frequent reporting requirements for LLRTs, the potential for NRC reevaluation of previous exemptions by use of current design criteria and models to analyze older plant designs and uncertainty in how future revisions to the Regulatory Guide are to be handled. It can be interpreted that some plants must retrofit to be able to test each isolation valve individually in order to obtain valid minimum and maximum pathway leakages, and that each Type "B" or "C" test must have its own acceptance criteria in addition to the overall 60 percent La requirement. For many plants, reaching this state of testing could require extensive additions of large block valves and test connec-tions, and extend outage work significantly for installation, with little apparent effect on public health or safety.

3. Whether there continues to be a further need for this regulation.

Comment Yes, the containment leakage test program requirements and criteria should be stated clearly in the regulations. Should future source term or other studies show that greater leakage rates could be allowed, then less restrictive leakage limits would be needed since testing for gross overall leakage would be sufficient. The NRC report, NUREG/CR-4330, indicates that the existing allowable leakage rate is much less, by an order of magnitude, than is necessary to protect the public.

4. Estimates of the costs and benefits of this proposed revision as a whole and of its separate provisions.

Comment Probabilistic risk assessments, beginning with the Reactor Safety Study, WASH-1400 (NRC 1975), have consistently shown that containment leakage is a relatively minor contributor to overall plant risk. The dominant containment-related contri-butions to risk stem from accidents in which the containment ruptures (e.g., due to overpressure) or the containment isolation function fails or is bypassed (e.g., an Interfacing systems LOCA with resulting direct release outside containment). In these dominant scenarios, containment leakage plays no significant role. NUREG/CR-4330 indicated that judiciously streamlining the existing regulatory requirements is estimated to have marginal effect on public health and safety. NUREG/CR-4330 stated that technical specification leakage rate limits are conservative, and a factor of 10 to 100 increase in leak rate may not be risk significant. While the risk contribution due to containment leakage may be small, the cost impact of containment leakage rate testing is substantial. The primary reason for this is that integrated leak rate tests (ILRTs) of the entire containment (called Type A tests in Appendix J) are generally on the reactor outage critical path. These tests typically cause three to five days of incremental plant downtime. If this downtime could be reduced by modifying the existing regulatory req~ire-ments without compromising public health and safety, the cost savings would be substantial. The NUREG/CR-4398 cost/benefit analysis of rev1s1ons to 10CFRS0, Appendix J, claim a reduction in replacement energy costs due to expected reductions in plant outage times. This is due to the proposed use of more frequent Type Band C testing coupled with less frequent Type A testing (see Section 5.1.4). What is not included in the analysis is the additional plant outage time associated with doing the more frequent (mid-cycle) testing. To date, the penetrations that have been tested most frequently are generally the purge and vent valves which are used minimally during the cycle. Testing other penetrations that are in use (i.e., main steam isolation valves, feedwater check valves, etc) could result in extended outage time. Therefore, mid-cycle testing outage time needs to be included in a cost-benefit analysis. The additional radiation exposure would be higher for work done during short mid-cycle outages than corresponding work done during long refueling outages. The compliance effort to revise the Appendix J program procedures could be substantial. Also, NUREG/CR-4398 considered only the labor cost of the increased number of LLRTs, which was based on a 3.0 hour test duration. This is a large underestimate of the duration of LLRTs, which frequently run for 8 to 24 hours. The NRC Backfit Analysis does not substantiate its conclusion that the proposed Appendix J is both safety and cost neutral. Another aspect of cost versus benefit are the actions of the various State Public Utility Commissions. Many states are prescribing performance factors for setting rates and if additional outage time is required to perform these tests, then the additional costs associated with this downtime may be excluded from the rate base.

5. Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule becomes effective.

Comment Licensees should have the option to meet the current Appendix J provisions if a new Appendix J is adopted. The present program is generally adequate and understood by licensees and contractors. Also, this issue is dependent upon the dis-position of the backfit analysis as required by 10CFRS0.109. The claim that fewer exemption requests and interpretive debates would result appears to be geared to the newer operating plants.

6. If the existing rule or its proposed revision were completely voluntary, how many licensees would adopt either version in its entirety and why.

Comment Many licensees, especially with older plants, who have worked to get relief in their FSAR and tech specs from the unneces-sary aspects of the current rules would probably opt for complying with the existing Appendix J. Some licensees might opt for the proposed revision because they are already com-plying with many of its provisions. However, many licensees are concerned with some of the more onerous and impractical aspects of type Band C testing.

7. Whether (a) all or part of the proposed Appendix J revisions would constitute a "backfit" under the definition of that term in the Commission's Backfit Rule, and (b) there are parts of the rule which do not constitute backfits, but would aid the staff, licensees, or both.

Comment

a. Part of the rule could constitute a backfit insofar as the new definitions of containment isolation valve and containment system. These concepts were generally not developed during the design of the older plants.

b. The basic concept of rev1s1ng testing would be a backfit.

Although, there are some beneficial aspects of the proposed rule (see Comment 2), the "as-found" and "maximum-leakage-path" provisions and their impact constitute a backfit and should be treated as such. Some plants would require physical changes, others software and procedural changes. (Also, see Comments 4 and 5).

8. Since the NRC is planning a broader, more comprehensive review of containment functional and testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation.

Comment The proposed rule should not be issued in its present form.

9. The advisability of referencing the testing standard (ANSI/ANS 56.8) in the Regulatory Guide (MS 021-5) instead of in the text of Appendix J.

Comment The testing standard (ANSI/ANS 56.8) should be referenced in the Regulatory Guide. The regulation (Appendix J) should identify overall testing requirements and criteria. Methods to achieve these requirements and criteria should be in the Regulatory Guide and ANSI/ANS 56.8. Efforts should be made by the staff and the testing standard committee to minimize the exceptions made in the Regulatory Guide.

10. The value of collecting data from the "as found" condition of valves and seals and the need for acceptance criteria for this condition.

Comment The requirement to perform "as-found" leakage rate tests on Type Band Type C penetrations has strong potential to impact outage durations. Performance of "as-found" local leakage rate tests (LLRTs) will increase the equivalent critical path for valve preventive maintenance, and will tie up critical resources. This new requirement could increase non-ILRT outage durations by 2-3 days, and possibly longer, depending on outage scope. A negative side effect of the proposed "as-found" Type Band Type C testing requirement is that it penalizes preventive maintenance. It will be difficult to schedule preventive maintenance if it means outages will be extended. An alter-native to this requirement is to require utilities to establish "as-found" testing programs to document leakage for problem valves and components on a case-by-case basis. The existence of sound maintenance programs should eliminate the perceived need to determine continually "as-found" Type Band Type C test reiults.

11. Whether the technical specification limits on allowable containment leakage should be relaxed and if so; to what extent and why, or if not, why not.

Comment Yes, technical specifications should be relaxed if valid accident analyses using up to date leak-before-break and source term information justify doing so. It is evident from NUREG/CR-4330 that there already is sufficient justification. This report indicates that current technical specification limits on allowable containment leakage are more conserva-tive, by an order of magnitude, than is needed to adequately protect the health and safety of the public. Also, the AIF and Owners Groups technical specification improvement efforts have been aimed at simplifying the technical specifications by removing such parts that can be implemented by a separate program. Most of the Appendix J requirements are in that category. There is no need to repeat federal regulations in the technical specifications. Therefore, the proposed rule need not refer to requirements contained in technical specifications with the exception of La and Pa in the Design Features of technical specifications.

12. What risk-important factors influence containment performance under severe accident conditions, to what degree these factors are considered in the current testing requirements, and what approaches should be considered in addressing factors not presently covered.

Comment The NRC has initiated a program to review current light-water reactor regulatory requirements to see if some could be relaxed or eliminated to reduce regulatory burdens without compromising public health and safety (Federal Register, October 3, 1984). Pacific Northwest Laboratory (PNL) is conducting a series of studies in support of this NRC program. NUREG/CR-4330 covers a portion of PNL's work. That report presents information on the risks, cost and benefits of streamlining regulatory requirements such as reactor contain-ment leakage rates. The option under consideration in the analysis is to increase the allowable leakage rate for a PWR to 10% per day. Sensitivity studies to show the effect of varying this numerical value are included in the report. Some recent events which may have influenced containment performance under severe accident conditions are misaligned containment isolation valves such as certain purge and vent valves, mistakes in either administrative or procedural controls, and water hammer events. Each of these events resulted in a corrective action plan to address the problem. The action plans may have resulted in increased surveillance activities, additional monitoring capabilities such as limit switches for valve position, design modification to reduce water hammer transients, etc. The Appendix J Test Program does address some of these events; however, they would not necessarily be detected when the event actually occurred. The detailed system alignments would detect misaligned valves. The containment inspection would detect gross liner or penetration boundary degradation if the general area was accessible for inspection. The type C program or the Type A test would detect valve or boundary degradation caused by water hammer. The Appendix J Test Program has to be considered as the double check on the overall plant work control program. As severe accident condition challenges are discovered, they need to be separately analyzed and specific corrective action plans should be developed to address them.

13. What other approaches to validating containment integrity could be used that might provide detection of leakage paths as soon as they occur, whether they would result in any adjustments to the Appendix J test program and why.

Comment We know of no other practical approaches that would provide detection of all leakage paths as soon as they occur. A continuous lei"Kage monitoring system would detect certain containment conditions, however, it would not detect valve degradation.

14. What effect "leak-before-break" assumption could have on the leakage test program. Current accident assumptions use instantaneous complete breaks in piping systems resulting in a test program based on pneumatic testing of vented, drained lines. "Leak-before-break" assumptions presume that pipes will fail more gradually, leaking rather than instantly emptying.

Comment The leak-before-break criteria could remove some systems from consideration of Appendix J; this would simplify the type A test (simpler valve line-ups, fewer systems to drain) and would reduce the burden of Type C testing. With proper analysis, the peak pressure Pa could possibly be reduced further facilitating the leak test program.

15. How to effectively adjust Type A test results to reflect individual Type Band C test results obtained from inspec-tions, repairs, adjustments, or replacements of penetrations and valves for the years in between Type A tests.

a. All type Band C performed during same outage as a Type A test, or performed during a specified time period (nominally 12 months) prior to Type A test, be factored into the determination of a Type A test "as found" condition.

b. If a particular penetration or valve fails two consecu-tive Type B or C tests, the frequency of testing that penetration must be increased until two satisfactory B or C tests are obtained at the nominal test frequency.

Attention to focus on correcting component degradation, no matter when tested, and the "as found" Type A test would reflect the actual condition of the overall containment boundary.

c. Increases or decreases in Type B or C "as found" test results (over the previous "as left" Type B or C test results) shall be added to or subtracted from the previous "as left" Type A test result.

i. If this sum exceeds 0.75 La but is less than 1.0 La, take measures to reduce sum to no more than 0.75 La. This is not reportable.

ii. If this sum exceeds 1.0 La, take measures to reduce sum to no more than 0.75 La. This is a reportable condition. iii. The existing requirements that the sum of all Type B and C tests be no greater than 0.60 La shall remain in effect. Comment "As found" Type A leakage rates should only be determined when the Type Band C test results are fairly current to give a true picture of the containment integrity at that moment. At all times, the Type Band C program limits should govern. The licensee should only be required to perform "as found" tests on Type Band C penetrations performed in conjunction with the ILRT refueling outage as needed for determination of the "as found" Type A test adjustment. No adjustment to the "as left" Type A test result should be required in the years between ILRT outages, since the information does not provide an accurate picture of containment integrity at that moment. By ensuring that the Type Band C test results do not exceed 0.60La, containment integrity is verified in the years between ILRT outgages. Therefore, no Type A adjustment should be required. Comments on Draft Regulatory Guide Task MS 021-S "Containment System Leaka'3e Testing" Current evaluations of the source terms and of the leak before break concept are likely to result in change in the containment leak testing within a year or two. When this occurs, 10CFRS-0 Apfendix J, the companion Regulatory Guide, and ANSI/ANS-56.8 w1 1 all need major change. Under this scenario the most reasonable approach to this draft Regulatory Guide is to defer it until a more long term view is possible. If, inspite of this, the draft change effort is to go ahead, it should endorse ANSI/ANS-56.8 standard without so many additional unneeded and confusing requirements. These additional requirements would require expenditure of resources on minor 1 or 21 effects when source term studies show that the public health and saf~ty is adequately asiured with a maximum allowable containm~nt leakrate (LaJ that is many times larger than currently permitted. Also, the "Extended ANSI Method" prescribed in the Draft Regulatory Guide adds two new conditions for passing a Type A test which are unnecessarily stringent. Although the scope of the revision to . the 10 CFR SO Appendix J is stated to exclude new criteria, the extended ANSI method in the Draft Regulatory Guide is, in effect, ,the addition of new criteria for the termination of a successful test. Following are specific comments on the Regulatory Position section of the Draft Regulatory Guide. Position 3 - Pressurizing Considerations Inleakage should be allowed if it can be properly accounted for. For example, the inboard MSIVs at

• some plants have pneumatic accumulators which aid in their closure. The inleakage could easily be accounted for, but under this section they would have to be vented and drained.

Position 6 - Verification Test Item 6.1(6) The period of time between the end of the Type A test and the verification test should not be con-sidered part of the Type A test. In the past this

time has been used to take reactor water samples, air samples, and add make up water to the reactor ves~el. These activities could significantly dis-turb the containment atmosphere. ~!a*o1e conditions must be established for the start of the verifi-cation test. To include this additional time as part of the Type A test adds an unwarranted penalty. Item 6.1(7) There should not be a requirement to use a data point between the end of the Type A test and the beginning of the verification test as specified in item 6.1(6). This should be clarified by adding "of the official Type A test" to the end of the sentence. Position 9- Type Band C Test Schedule This regulatory position allows Type Band C testing intervals to exceed two years if containment integritf is not needed. This position is in conflict with the proposed rule, Appendix J, sections III.B(l)(a) and III.C(l). However, we prefer the draft Regulatory Guide position which is more reasonable. Position 11 - Calibration Item 11.1 Instrumentation used for Type Band C tests should not be required to have a semiannual calibration. Some instruments are currently on a one-year calibration cycle. Many of the flowmeters cannot be calibrated on-site and must be sent to an outside laboratory for calibration. Item 11.3 Substituting the word "calibration" for "calibra-tion checks" in Section 4.2.4 of ANSI/ANS-56.8-1981 may require that LLRT instrumentation be cali.brated to NBS standards every day. It is not practical, nor possible in some instances, nor necessary to perform daily calibration on a.11 pieces of equipment used for Type Band C tests. This is particularly true for test rigs that use rotometers. Calibration of rotometers is time consuming and, in some cases, cannot be accomplished onsite. If an instrument is found to be out-of-tolerence or calibration, there are existing measures that can be taken to ensure an accurate leakage rate (i.e.; retests, statistical analysis.) Position 12 - Containment Atmosphere Stabilization These items add new criteria that will require further evaluation and additional software documentation. It is ~stimated that these additional requirements will substantially increase testing time and costs. Position 13 - Data Recording and Analysis Item 13.1 If the data supports a restart as of "time backward" then it should be allowed. Start time should be representative of the actual leakage rate, not a time chosen arbitrarily in the future. As an example, sensor malfunctions may not be apparent until hours after the end of pres-surization, and, once the sensor is deleted from

             ~alculations, the leakage rate appears stable and acceptable. In such a case, the early elapsed time that has passed should be allowed to be included in the test.

Item 13.3 The "Extended ANSI Method" acceptance criteria for Type A and verification tests is new criteria for termination of a successful test for which no technical ba~is has been provided. The very extensive comments on the "Extended ANSI Accep-tance Criteria" by Bechtel Power Corporation and submitted to the NRC in January 9, 1987, provides an excellent analysis of the "Extended ANSI Method." We conclude that this additional criteria add nothing to the interpretation or understanding of test results. It is recommended that the NRC delete this item and the Appendix, "Extended ANSI Method" from the Draft Regulatory Guide. Position 20 - Recording of Leakage Rates Accounting for packing leakages outside the primary containment is a significant backfit, especially in BWR plants. Many containment iso-lation valve pairs have to be tested by pressuriz-

           . ing through a test tap between the two valves.

But for some valve designs, the packing on the inboard valves does not experience the test ressure. Therefore, to account for packing f eaks~ test taps and/or block valves would need to be installed in containment. The costs of such modifications cannot be justified, especially in light of the testing of the packing by Type A leak tests. Appendix: This modification to the Mass Point Method would allow the performance of Type A tests for periods shorter than 24 hours. However, all Type A tes*ts, including the shorter tests, would also have to meet two new conditions for passage. These additional conditions should not be required. There has never been shown any need for additional conditions on cuivature and scatter. The Mass Point Method has proven to be an accurate and reliable method in its current form in hundreds of tests over the last ten years. Therefore, there is no need for additional conditions on curvature and scatter. Moreover, because the two additional conditions are unnecessarily stringent, they would result in the failure of many valid Type A tests. For these reasons, the proposed conditions should not be required. JUCKET NUMBER ED PR'-j?J l(ij) a1 ~ ..J9ni) t!_!,J DOCKETED USNRC NUCLEAR OPERATING CORPORATION '87 MAR 30 P1 :24 March 25, 1987

u. s. Nuclear Regulator y Corcmission Attention: Docketing and Service Branch ROOOl 1121 1717 H Street NW Washington, D.C. 20555 Letter: WM 87-0021 Re: Docket No . 50-482

Subject:

Comnents on Proposed Changes to 10 CTR Part 50 Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants Gentlemen: Enclosed are Wolf Creek Nuclear Operating Corporation's carments on the proposed changes to 10 CTR 50 Appendix J which were published in the October 29, 1986 Federal Register (51 FR 39539). The comnents address specific major changes being proposed, specific questions identified under "Invitation to Comnent", specific paragraphs in the proposed Apperrlix J revision, arrl the backfit analysis. If you have any questions on this subject, please contact me or Mr. o. L. Maynard of my staff. Very truly yours, Bart D. Withers President and Chief Executive Officer BI:M:wbb Enclosure cc: PO'Connor (2) JCumnins P.O. Box 411 / Burlington, KS 66839 / Phone: (316) 364-8831 An Equal Opportunity Employer M/F/HCNET

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Enclosure to WM 87-0021 Page 1 of 6 Comnents on Proposed Changes to 10 CFR Part 50 Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants A. Conments to Major Changes Proposed: Item 5: TypeA test pressure

1. The type A test pressure change described is not believed to be a prudent change. The statement "This change reflects the opinion that extrapolating low pressure leakage test results to full pressure leakage test results has turned out to be unsuccessful" appears to be an unsubstantiated statement when applied to Pressurized Water Reactors (:EWRs). It is believed that the reduced pressure test is more conservative for PWRs since many leakage barriers, such as equipment hatches and air locks, seal tighter with higher pressure.

2. 3/4CNOC performed an evaluation using accident analysis parameters defined in Updated Safety Analysis Report Chapter 6. Results of the evaluation indicate that Integrated Leakage Rate Testing at reduced pressure would produce containment conditions more closely matching that which would exist under design basis accident (OBA) conditions for leakage considerations than testing at the OBA peak pressure.

One factor that supports this reduced pressure testing is the similarity in densities. Air density differences would affect leakage flow rates. Containment air density at reduced pressure testing conditions more closely resembles the containment densities experienced in a OBA. Another factor which supports performance of a reduced pressure test program is the existence of choked flow conditions in containment during part of the OBA. Conparison of the choked flow conditions experienced during a OBA with the peak and reduced pressure tests indicates that the choking conditions at the reduced pressure test would more closely match that of a OBA.

3. The reduced pressure test is as mathematically sound as the full pressure test. The data collection process for a reduced pressure test continues until the same confidence level is met as that for a full pressure test. Refer to comnent on Item 7 "Major Change" which addresses the test duration.

4. Equipment inside containment as well as the containment structure itself is not subjected to the high stress levels associated with a full pressure test. Therefore, the level of confidence in the equipment to perform its safety function during a postulated accident is increased.

r-- Enclosure to~ 87-0021 Page 2 of 6 Item 7: Type A test duration

            ~NOC supports the proposed change of deleting the duration as being a test criteria.       The test continues until the required confidence level is achieved. The duration is more appropriately dictated by the data collection process.

B. Comnents on Specific Questions: Question 4: "Estimates of the costs and benefits of this proposed revision, as a whole and of its separate provisions;" Cooment: ~NOC believes the estimated costs of the proposed rev1s1on, while not quantified, are not justified. The methods used to ensure containment integrity through existing regulation, administration, and good engineering practice provide an exceptionally high level of confidence that contairnnent integrity will be provided during a postulated DBA. Implementation of the proposed revision will not, in our opinion, increase the level of confidence already provided. Question 5: Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule (reflecting consideration of public cooments) becomes effective;" Comnent: ~OC supports the opportunity to continue to meet the current Appendix J provisions. See response to Questions 4 and 8. Question 6: "If the existing rule or its proposed revision were carpletely voluntary, how many licensees would adopt either version in its entirety and why;" Cc.mnent: ~OC would not adopt either in its entirety. More accurate, less time consuming methods are available in determining the Type A test leakage rate than is described in the current version of Appendix J/ANSI N45.4. The proposed revision, if conpletely voluntary, would not be used in its entirety for reasons provided in the comnents to this proposed rule. Question 8: "Since the NRC is planning a broader, more comprehensive review of contairnnent functional and testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation;" Conment: In the opinion of ~oc, the level of confidence that containment integrity is available, as required, is sufficient to preclude need for the subject revision. If that same level of confidence is not shared by the NRC, more frequent monitoring of Type Band C test results

Enclosure to WM 87-0021 Page 3 of 6 and leakage rate trend analysis can be accomplished with insignificant impact on the established programs. Appropriate measures can be taken on an as needed basis if containment integrity degradation is noted. Question 9: "The advisability of referencing the testing standard (ANSI/ANS 56.8) in the regulatory guide (MS021-5) instead of in the text of Appendix J;" Comnent: W::::NOC supports referencing the appropriate testing standard or parts thereof in the Regulatory Guide (MS021-

5) instead of in the text of Appendix J. If better test methods are developed, the revision of the regulatory guide would preclude a revision to Appendix J or the applicable ANSI standard i.e., ANSI N45.4 or ANSI/ANS 56.8 depending on the specific license corrmitments.

Question 10: "The value of collecting data from the "as found" condition of valves and seals and the need for acceptance criteria for this condition;" Comnent: W::::NOC does not support the need to collect and report the "as found" condition of valves and seals nor the need for acceptance criteria. Records are currently maintained documenting "as found" leakage rates for Type Band C tests. The magnitude of this value is the primary factor used in deciding when to rework an isolation valve. Wolf Creek Generating Station maintains a sum of all leakages below the 50% of 0.6 La as recomnended in EPRI NP-2726, "Containment Integrated Leak-Rate Testing Improvements". Question 14: What effect "leak-before-break" assumption could have on the leakage rate test program. Current accident assumptions use instantaneous complete breaks in piping systems, resulting in a test program based on pneumatic testing of vented, drained lines. "Leak-before-break" assumptions presume that pipes will fail more gradually, leaking rather than instantly emptying." Comnent: The "Leak-before-break" assumption provides a higher level of confidence that 10 CFR 100 exposure limits will not be exceeded during postulated accidents. This assumption would support our opinion that a sufficient margin of safety exists to preclude need for additional acceptance criteria for Type Band C tests as described in Question 10. Question 15: "How to effectively adjust Type A test results to reflect individual Type B and C test results obtained from inspections, repairs, adjustments or replacements of penetrations and valves in the years in between Type A tests **** "

Enclosure to WM 87-0021 Page 4 of 6 Comnents: W:NCC opposes factoring Type Band C tests into Type A test results for the following reasons:

1. It is irrpractical to tie the Type A tests and Type Band C tests together. The "integrated" test and the "local" tests will expose some leakage paths to test pressure Pac under both conditions, i.e. those penetrations designed in accordance with GOC 56, while penetrations designed in accordance with GOC 55 and 57 will normally be exposed to test pressure under one but not both test conditions.

2. The Type A test measured leakage rate is conservative . During the performance of a Type A test, all penetrations designated as Type A, are exposed to contairnnent atmosphere. This leakage rate is not credible during postulated accident scenarios due to the principle of single-failure-criteria. The Type Band C reported leakage rate is also conservative. As for Type A penetrations, the reported leakage rate is the sumnation of all penetrations and this is more conservative than is the principle of single-failure-criterion. Additionally, the individual penetration leakage reported is the maximum pathway leakage rate, adding more conservatism to the reported total Type Band C leakage rate.

3. The Type Band C leakage rate acceptance criteria of 0.60L a is met and the total leakage rate attributed to Type Band C penetrations is accounted for and procedurally tracked at all times. W:::GS maintains a sum of all leakages below the 50% of 0.60L a as recomrended in EPRI NP-2726, "Contairnnent Integrated Leak-Rate Testing Improvements". This provides a high level of confidence that any one isolation valve or penetration will not disproportionately contribute to containment leakage.

4. Single-failure-criteria precludes the possiblity of failure of both a penetration designated as Type A and a penetration designated as Type B or C. Design parameters used to meet single-failure-criteria coupled with acceptance criteria already established for both Type A testing, and Type Band C testing provides an exceedingly high level of confidence that exposure limits as specified in 10 CFR 100 are not exceeded during a postulated accident.

5. The method for adjusting a Type A test for the Type Band C tests described in Question 15.a on page 39539 would penalize a utility for reworking a penetration whose isolation valves are not exposed to contairnnent pressure during the conduct of a Type A test. For those penetrations that are exposed to containment pressure, the Type A test "as found" leakage rate is unaffected.

Enclosure to~ 87-0021 Page 5 of 6

c. Comnents on Specific Paragraphs:

III .A. 8.b. ii W:NOC supports the flexibility provided in increasing the frequency of Type B or C testing in lieu of two consecutive Type A tests in case of a Type A test failure provided a cause and effect relationship can be detennined. III.B.4.c W:NOC believes this paragraph is unnecessary because failure of a Type B test implies an acceptance criteria for each penetration exists . If an acceptance criteria does exist, i.e. Technical Specification for containment air locks, an action statement is already defined. If an acceptance criteria does not exist, then the penetration leakage is included in the 0.60 La. III.C. 2.a Qualified Water Seal System is not defined. w:NOC proposes that "Qualified Water Seal System" be defined as it is described in ANSI/ANS 56.8 - 1981, Section 6.4: "Systems that are designed to contain water subsequent to a leakage design basis loss of coolant accident (LDBA) such that the containment isolation valves seating surface remains water covered (considering the water volume and water leakage of the isolation valve) for at least 30 days. " III.C.2.b W:GS proposes the word must" be replaced with "may". This change will not corrpromise the validity of the Type C test but will provide greater flexibility. V.B. The proposed requirement to report an "as found" leakage rate for Type A testing by factoring the "as found" and "as left" results of the Type B and C tests is opposed because a penalty in the "as found" Type A test would be taken for repairing a penetration that is not exposed to containment atmosphere during the conduct of a Type A test. This is contradictory to the maintenance of a tight containment. Also see comnents to Question 15. D. Comnents to Backfit Analysis:

1. The specific "proof" of the statement" * *

• extrapolating low pressure leakage test results to full pressure leakage test results has turned out to be unsuccessful * * * " should be included in the Backfit Analysis (Ref: "Major Change" Item 5).

.. ,. r

• Enclosure to WM 87-0021 Page 6 of 6

2. Backfit Analysis only addressed an" * *

• additional 3-10 hours pumping time * * * " for the change from a reduced pressure test to a full pressure test (Ref: Backfit Analysis Factors Paragraph 2).

This is not a realistic evaluation of the increased time and equipment needed for a full pressure test. Preparing containment equi~nt and instrumentation for the full pressure test in lieu of the reduced pressure test would entail an estimated two (2) days critical path. This change is a significant cost and must be so evaluated.

3. We agree with your throwing out the cost savings (Ref: Backfit Analysis Factors Paragraph 5) as they are really "apples and oranges". Savings/losses must be canpared with a set of rules, i.e. the Technical Specifications.

PR-1.1?J (57F~ .3t/5'8f @

PHILADELPHIA ELECTRIC COMPANY ooc;KETED USNRC 2301 MARKET STREET P.O. BOX 8699

                                                                                          ~7 HAR 27 P12 :19 PHILADELPHIA. PA. 19101 (2151 841 - 5001                          Offl E uf     $ t.L. , t1f h'*

JOSEPH W . GALLAGHER DOCKET! G i srrw1u: VIC .... IDKNT BRANCH NUCL.KAft Ol' IIATIONS March 23, 1987 Docket No. 50-277 50-278 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, o.c. 20555 ATTENTION: Docketing and Services Branch

SUBJECT:

Comments on Proposed Rule Regarding Leakage Rate Testing of Containments (10 CFR 50 Appendix J), Published October 29, 1986

Dear Mr. Secretary:

Philadelphia Electric Company appreciates the opportunity to comment on the subject proposed rule and offers the following items for your consideration. I. The proposed rule specifies several calendar related test frequencies. These are:

1. Section III.A.(3): " the interval between the preoperational and first periodic Type A tests must not exceed three rears, and the interval between subsequent periodic Type A tests must not exceed four ye a rs ...* " --

2. Section III A (8) (b): "If two consecutive periodic as found Type A tests exceed the as found acceptance criterion of l.0LA * .

• a Type A test must be performed at least every 24 months **.. "

APR 11997 Acknowledged by carlf. *r-rrr.-., " ,... ,, 011 _.

LI, . NUCLEAR REGULATORY COMMISSIC& DOCKE'f!NC P., SERVICE SECTIO~

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Mr. Daniel R. Muller March 23, 1987 Page 2 It is recommended that a provision be added to the regulation permi tting an extension to the test interval provided plant conditions permit a breach of primary containment integrity at the time the four year/24 month interval is exceeded, and the Type A Test is performed pr ior to the time primary containment integrity is required to be re-established. Otherwise, refuel outage activities may be disrupted if the test interval expires during the middle of the outage requiring performance of a Type A (Integrated Leak Rate Test) test. The most effective timing of a Type A test is near the end of a refueling outage, following completion of all the repair and modification work that has a potential for degrading containment integrity. Further, performing a Type A test well in advance of the time containment integrity is required, prematurely starts the four year/24 month clock, increasing the potential that the Type A test cannot be synchronized with future refueling outages. This situation jeopardi zes plant availability. The time between the expiration of the test interval and the performance of a Type A test is of no safety consequence provided containment integrity is not required during the same period. The period of safety significance is the time interval between performance of the previous test and the last time containment integrity is required prior to the next test. Under PECo's proposal, this period will not exceed four years/24 months, and therefore meets the intent of the proposed regulation. The recommended change would permit optimization of Type A test schedules during refueling outages and will improve plant availability without degrading plant safety. Optimization of the test schedule, with consideration of containment vessel and valve outage maintenance, will enhance the effectiveness of the containment integrity surveillance program. The following addition is therefore proposed to Sections III .A.(3) and III.A.(8)(b):

           "The interval may exceed four years/24 months provided plant conditions permit a breach of (do not require) primary containment integrity prior to expiration of the test interval, and the Type A test is performed prior to the time plant conditions require containment integrity to be re-established."

II. The proposed rule (VI.A.2) requires the submittal of a report to the NRC Regional Administrator within 30 days of completion of any Type B or c test that fails to meet the as found acceptance criteria. Since the Type B or C test acceptance criteria are incorporated into the plant Technical Specifications, failures must be reported under the provisions of 10 CFR 50.73 (a)(2)(i)(b) as a Licensee

Mr. Daniel R. Muller March 23, 1987 Page 3 Event Report (LER}. To avoid the need to submi t redundant reports, this reporting provision in Appendix J should reference the LER rule. Consequently, compliance with the LER rule satisf i es this reporting requ i rement. Normally, most Type Band C tests are performed during refue l ing outages. It i s not uncommon to experience several valve failures during a single outage. To avoid the administrative burden of processing a single report for each failure, it is recommended that the first failure be reported within 30 days of completion of the test, and that all subsequent failures experienced during the same outage be reported as a revis i on of the first report within 30 days following resumpt i on of electrica l power production. The following revision to Section VI.A.2 is recommended:

              "Reports must be submitted to the NRC Regional Administrator pursuant to the requirements of 10 CFR 50.73(a}(2}(i}(b} within 30 days of completion of any Type B or C Tests that fail to meet the as found acceptance cr i teria. A combined report addressing subsequent valve failures may be submitted within 30 days following resumption of electrical power production as a revision to the report for the first failure experienced during the same outage."

III. The proposed rule (III.B.(3}(b)( i )) requires, in part, that "Air locks opened during per i ods when containment integrity is required by the plant's Technical Specifications must be tested within 3 days after being opened" and" Air locks opened during periods when containment integrity is not requ i red by the plan t 's Technical Specifications need not be repeatedly tested during such periods. However, such testing must be initiated pr i or to the plant requiring containment i ntegrity." The proposed rule would require two air lock tests for each start - up at some p l ants. At some plants the Techn i cal Spec i fications require that primary conta i nment integrity be maintained at all times when the reactor is critical. The latter two sentences cited above would therefore require performance of an air lock test prior to the reactor achieving crit i ca li ty. Later i n the start - up, when t he reactor reaches full pressure, some utilities perform leak inspections inside the primary containment. Because these i nspections require the a i r lock to be breached, the f i rst sentence cited above would require a second air lock test to be performed. In most cases, the second

Mr. Daniel R. Muller March 23, 1987 Page 4 test would be performed shortly (about a day or so) after the first test was completed. Additionally, the first test, which would have to be completed prior to reactor criticality at some plants under the proposed rule, would be a critical path item. These tests require 24 -hours for stabilization and data gathering due to the large test volume of the air lock. It is recommended that the sentences in the proposed rule 10 CFR 50, Appendix J, Section III.B.(3)(b)(i), which state:

           "Air locks opened during periods when containment integrity is not required by the plant's Technical Specificat ions need not be repeatedly tested during such periods. However, such testing must be initiated pr ior to the plant requiring containment integrity. 11 be replaced with:

11 Air locks opened during periods when containment i ntegrity is not required by the plant's Technical Specifications need not be repeatedly tested during such periods. However, such testing must be initiated prior to the plant resuming electrical power production, but in no case greater than 72 hours after attainment of full reactor pressure. 11 We hope that the enclosed comments will assist you in institutionalizing a final rule. Very tr uly yours, cc: Dr. T. E. Murley, Administrator, Region I, USNRC T. P. Johnson , Resident Site Inspector

10 CFR 50 App. J \ ASCE&G South Carolina Electric & Gas Company P 0. Box 764 Columbia. SC 29218 (803) 748-3513 Dan A. Nauman Vice President Nuclear Operations DOC.:KETED

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USNRC

                                                                                     '87 t1AR 23 P2 :52 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn:    Docketing and Servicing Branch

Subject:

Virgil C. Summer Nuclear Station Operating License No. NPF-12 Docket No. 50-395 Request for Comments on Proposed Revision to Appendix J, 10CFR50 Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants FR Doc 86-24496

Dear Sir:

In the above referenced Federal Register Notice, the Commission requested comments on the subject of Leakage Rate Testing of Containments. This letter is being submitted in response to that request. As members of the Atomic Industrial Forum (AIF), we have reviewed and subscribe to the comments provided by the AIF Subcommittee on Operation and Maintenance. In addition, South Carolina Electric & Gas Company (SCE&G) would like to submit the attached comments for your consideration. SCE&G supports the Commission's commitment to clarify the existing Appendix J requirements. However, there are issues in the proposed revision to Appendix J that appear unduly burdensome. Responses addressing the issues identified in the "Invitation to Comment" section in the subject Federal Register Notice are provided in Attachment I. Included within these responses are comments regarding the broader base considerations addressed elsewhere in the subject Federal Register Notice. We appreciate the opportunity to comment at this time. Should you require additional information, please contact us at your ,,-- convenience. I I ours, DCB/DAN:jez c: Page 2

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Mr. Samuel J. Chilk March 20, 1987 Page 2 c: 0. W. Dixon, Jr./T. C. Nichols, Jr. E. C. Roberts

0. S. Bradham J. G. Connelly, Jr.

D.R. Moore W. A. Williams, Jr. Group Managers W.R. Baehr C. A. Price C. L. Ligon (NSRC) R. M. Campbell, Jr. NPCF Fi le 811.02

Attachment I to Mr. Samuel J. Chilk Letter March 20, 1987 Page 1 of 6 (1) The extent to which these positions in the proposed rule are already in use Those items generally in use at present are identified in the proposed Appendix J IIIA (1), (2), (5), {6), (9), and VA. Many utilities are unable to use ANSI/ANS 56.8 in its entirety due to inherent conflicts with the current Appendix J requirements. (2) The extent to which those in use, and those not in use but proposed, are desirable Major advantages are found in: a) having additional and more precise definitions, b) the reduced duration of testing, c) use of the mass point technique to compute Type A leakage rate, d) reduction of the excessive leakage isolation provisions during Type A testing, e) the provision of approved alternative leakage test program, f) airlock test extensions where no openings have occurred during a 6 month interval since last successful test, g) and the possible alternative to continue under the current requirements. Negative aspects of the proposed Appendix J include: a) the provision for increased local testing incurring increased downtime and radiation exposure, b) more frequent reporting as in the case of failed Type B and C tests, c) more detailed and stringent requirements for reporting, i.e., to prevent recurrence {having an allowed leakage rate suggests some recurrence under normal operating conditions), d) the potential for changes to Technical Specifications and existing programs currently underway with possible system modifications requiring additional outage time.

Attachment I to Mr. Samuel J. Chilk Letter March 20, 1987 Page 2 of 6 (3) Whether there continues to be a further need for this regulation Where the stringent l eakt i ghtness of containment is required to be maintained, regulatory guidance will be needed in defining inspection programs and acceptance criteria. The requirements should be stated clearly and remain flexible so as to facilitate licensee compliance. Further investigation into the need for stringent requirements should be continued with considerations given to NUREG/CR-4330, Vol. 2, June 1986:

      "Probabilistic risk assessments, beginning with the Reactor Safety Study, WASH-1400 (NRC 1975), have shown that containment leakage (at, or slightly above the design leakage rate) is a relatively minor contributor to overall nuclear reactor risk."

(4) Estimates of the costs and benefits of this proposed revision, as a whole and of its separate provisions In addition to the con111ents in (3) above, it would be prudent to add that, with the extensive testing and reporting requirements, and the foreseeable possibility of increased outage time and increased radiation exposure, the relevance of NUREG/CR-4330, Vol. 2, June 1986, should be considered at this time. (SJ Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule becomes effective Licensees should have the option of continued operation under the existing program which is adequate and generally understood by licensees and contractor personnel. No imposition of this Rule should be required without 10CFRS0.109 having been addressed. In view of NUREG/CR-4330, Vol. 2, June 1986, it would be contradictory to require implementation of the additional requirements at this time without consideration of the Backfit Rule. (6) If the existing rule or its proposed revision were completely voluntary, how many licensees would adopt either version in its entirety and why It is difficult to answer this question knowing that further review of the issue has been planned. The choice to continue a testing program under the existing criteria could be a locked in" situation whereby a utility may not be allowed to opt for less stringent criteria that could result from further NRC studies.

Attachment I to Mr. Samuel J. Chilk Letter March 20, 1987 Page 3 of 6 (7) Whether (a) all or eart of the proposed Appendix J revisions would constitute a "backfit' under the definition of that term in the Commissions Backfit Rule, and (b) there are parts of the rule which do not constitute backfits, but which would aid the staff, licensees, or both Despite obvious advantages to parts of the proposed rule as in (2), some of the new provisions may precipitate individual utilities opposing the proposed rule due to the backfit nature of specific requirements involving changes to systems, software, Technical Specification or procedures. (BJ Since the NRC is planning a broader, more comprehensive review of containment functional and testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation Based on the need for upgraded standards, and consideration given to the issues discussed in (5) and (7), the worthiness of the proposed revision is questionable. While the need for more concise definitions and interpretations may exist, these have been accomplished in publication of the proposed Appendix J, "The scope of this revision to Appendix J is limited to corrections and clarifications, and excludes new criteria." However, additional regulatory requirements are included. The clarification of the existing regulations could be accomplished without the additional regulatory burden. In so much as ANS I N45-4 is outdated and new standards would be an asset to the program, direct reference predisposes incorporation and any endorsement of new standards should be done through a companion regulatory guide, not the Code. However, increased conflicts between regulations and current procedures would result. (9) The advisability of referencinv the testing standard (ANSI/ANS 56.8) in the Regulatory Guide (MS 021-5) mstead of in the text of Appendix J It would allow more flexibility to both the NRC and the licensees to reference the testing standard in the Regulatory Guide. This allows changes to the standard without requiring periodic revision to the regulations. In addition, the comment is appropriate that there are existing conflicts between ANSI/ANS 56.8 as well as exceptions. For example, proposed Appendix J states that "the interval between subsequent periodic A test must not exceed four years" whereas the ANS I standard has "at intervals not to exceed five years. " The supportive statements described in (3) from NUREG/CR-4330, Vol. 2, June 1986, and the Draft Regulatory Guide (MS 021-5) which addresses the regulatory position with respect to Type A Test Frequency as being "a practical and logical interpretation of the end of the test interval" indicate that five years is a considerably less burdensome interval with respect to testing frequency.

Attachment I to Mr. Samuel J. Chilk Letter March 20, 1987 Page 4 of 6 (10) The value of collecting data from the "as found" condition of valves and seals and the need for acceptance criteria for this condition The value of such a program would be outweighed by the disadvantages of additional down time. Type Band C testing is labor-intensive and commands critical resources. Preventative maintenance (PM) programs would be equal to or better than continually testing. PM would identify problem areas which subsequently may require testing and documentation for future reference. Data collection other than mandatory testing of components should not be a requirement. Certain repairs and replacements incorporated in the PM program should not require pretesting, i.e., changing valves, or repairs made in which no disturbance of the seal has occurred. (11) Whether the technical specification limits on allowable containment leakage should be relaxed and if so, to what extent and why, or if not why not The limits on allowable leakage should be relaxed. This has been previously indicated in reference to NUREG/CR-4330, Vol. 2, June 1986. Recognizing the extreme conservatism entailed in the original criteria, the extent to which that criteria is relaxed should be based on valid analyses using up to date information. (12) What risk-important factors influence containment performance under severe accident conditions, to what degree these factors are considered in the current containment testing requirements, and what approaches should be considered in addressing factors not presently covered Again, reference to NUREG/CR-4330, Vol. 2, June 1986, which addresses this to some extent in Section 2.0, "Risk and Cost Impact for Nuclear Reactor Containment Leaktightness. 11 Gross failure of containment due to rupture or failure of an isolation function appear to be the dominant risk factors. The variety of regulatory coverage with respect to design, operation, inspection and testing is a broad issue involving many technical aspects being studied throughout the industry. (13) What other approaches to validating containment integrity could be used that might provide detection of leakage paths as soon as they occur, whether they would result in any adjustments to the Appendix J test program and why No practical alternative exists beyond routine testing and preventative maintenance. Continuous leakage monitoring, however unfeasible, could be a partial solution, but given that the design and operation have met the current regulatory criteria, it would be impractical to backfit.

Attachment I to Mr. Samuel J. Chilk Letter March 20, 1987 Page 5 of 6 (14) What effect Leak-before-break" assumption could have on the leakage test program. Current accident assumptions use instantaneous complete breaks in piping systems resulting in a test program based on pneumatic testing of vented, drained lines. "Leak-before-break" assumptions presume that pipes will fail more gradually, leaking rather than instantly emptying "Leak-before-break" would be a less conservative approach. Since the risk factor of containment leak rate has been described as relatively minor, it would be appropriate to take a less conservative approach, which would ultimately increase the allowable limits. (1 SJ How to effectively adjust Type A test results to reflect individual Type B and C test results obtained from inspections, repairs, adjustments, or replacements of penetrations and valves for the years in between Type A tests

a. All Type B and C performed during same outage as a Type A test, or performed during a specified time period (nominally 12 months) prior to Type A test, be factored into the determination of a Type A test "as found" condition.

b. If a particular penetration or valve fails two consecutive Type B or C tests, the frequency of testing that penetration must be increased until two satisfactory B or C tests are obtained at the nominal test frequency. Attention to focus on correctini component degradation, no matter when tested, and the "as found ' Type A test would reflect the actual condition of the overall containment boundary.

c. Increases or decreases in Type B or C "as found" test results (over the previous "as left" Type 8 or C test results) shall be added to or substituted from the previous "as left Type A test result.

i. If this sum exceeds 0.75 La but is less than 1.0 La, take measures to reduce sum to no more than 0.75 La. This is not reportable.

ii. If this sum exceeds 1.0 La, take measures to reduce sum to no more than 0.75 La. This is a reportable condition. iii. The existing requirements that the sum of all Type B and C tests be no greater than 0.6 La shall remain in effect. It would not be economical to schedule outages for the sole purpose of either CILRT (Type A} or LLRT (Type Band C). Most probable schedules would entail LLRTs at each refueling and (unless a five year interval is granted) every other refueling for CILRTs. It would be more appropriate to allow that current Type B and C test results be factored into Type A tests results providing that a higher leakage rate is allowed commensurate with the analysis found in NUREG/CR-4330, Vol. 2, June 1986.

Attachment I to Mr. Samuel J. Chilk Letter March 20, 1987 Page 6 of 6 Type B and C tests which fail criteria must be reported to the NRC within 30 days. If Type A tests fail the criteria, reports are due within 90 days. Should Type A test failures be subjected to Type B and C test failures, reporting would be redundant. All reports should be as in the existing Appendix J, on a 90 day schedule. Redundancy is again indicated in Corrective Action reporting. Relatively frequent low pressure checks should not be considered once a plant has begun operation. Appendix J testing should be sufficient. The trend wou 1d be to disagree with any added containment integrity verifications which exceed the present ultraconservative requirements. Required increased frequency of testing should be attendant only when failures are caused by the same feature. Repairs and corrective action fol lowed by successful testing should preclude the increased frequency tests. The limits for Type Band C tests should be 0.75 La, as it is for Type A tests. The same 11 as found" criteria should apply to Type Band C tests, i.e., if sum exceeds 1.0 La, reportable; if sum less than 0.75 La, extend test frequency; and if greater than 0.75 La but less than 1.0 La, repairs should be warranted but no reportable condition should exist. There is very little guidance in the rule for incorporating Type Band C leakage in the "as found" Type A. The NRC requires any Type B or C "as found" leakage tested up to 12 months prior to the Type A be added to the Type A "as found." It is possible to fail the 11 as found" ILRT before it is ever done if a Type C valve fails within the 12 months prior to the Type A test. Adding "as found" results from B or C tests to a previous Type A "as left 11 result should not be considered unless higher leak rates are allowed. This could cause Type A test failures well after the fact. Results of any Type A test should reflect the sum of as left Type B and C results. There is a need for further clarification of the rule for incorporating Type Band C tests, but this should be applicable to concurrent testing. Whether the Commission should continue its attempts to apply the Backfit Rule to all rulemaking, or whether the Rule should be revoked as it applies to rulemaking activity per se. The Backfit Rule should not be revoked since its application to the ru 1emak i ng process is of utmost concern to the regu 1ated community. The Commission should continue to apply the Backfit Rule to all rulemaking including the "substantial increase" provision.

ROCHESTER GAS AND ELECTRIC CORPORATION

• 89 EAST AVENUE, ROCHESTER, N. Y. 14649-0001 Q.,.

                                                                                  -S7 ~11 Al. 4 ROGER W. KOBER TELEPHONE VICE PRESIDENT ELECTRIC PRODUCTION                                                    A RC A C OD E 716 546 -2~<;)0          S ,l'V FflCC Of ~t          I ' "'" '

• January 26, 1987 IC ETING 5E. \I IC:f.

tV,HC~ U.S. Nuclear Regulatory Commission Attn: Docketing and Service Branch Mr. E. Gunter Arndt Office of Nuclear Regulatory Research Wash i ngton, DC 20555

Subject:

Proposed Revision to 10CFR50 Appendix J

Dear Mr. Arndt:

Rochester Gas and Electric (RG&E) appreciates the opportunity to comment on the proposed changes to 10CFR50 Appendix J and the related regulatory guide. RG&E is a member of the Nuclear Utility Backfitting and Reform Group (NUBARG) and endorses the comments which are being filed by that group. In addition, the following comments are made. A significant effort has gone into plant modifications, test procedures and exemption request reviews to achieve compliance with the existing Appendix J. The proposed rule will require revised procedures and will result in new exemption requests and perhaps additional plant modifications. The costs associated with this work have not yet been developed, however, the Staff cost/benefit analysis assumption that a cost savings will result because of fewer exemption requests is in error. Plants currently with an approved program for containment testing will be required to develop new compliance methods, including perhaps, additional exemption requests. A viable option suggested in the invitation to comment is to allow currently operating plants the opportunity to continue to meet the current Appendix J. We feel that option should be established in the rule. We applaud the Staff attempt to reduce the time required for containment type A testing by deleting the reference to a minimum test duration. Re~uced outage time is a significant benefit to our customers. Much of the savings, however, will be lost by deleting the reduced pressure test option and thus requiring additional time (approximately 10 hours) for pressurizing and depressurizing the containment. Our experience at Ginna has been that potential Type A test difficulties appear early in the test process, are detectable at reduced pressure and have resulted from containment isolation valve leakage. Since individual containment isolation valves and penetration assemblies receive full pressure tests, little is gained to warrant full pressure type A tests. Ackm>vrl db r ' MAR 1 1.,...,...,,~~ y Cil g .. * * *** : * !,.*_ 1987

. :., 't U.S. NUCL6AR REGULATORY COMMISSIO.N DOCKE G & 5fR lCf StCTI T, ~ Postr ' Co, Add

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A specific difficulty in performing the proposed full pressure tests will be the requirement to test at greater than accident pressure (P ) but less than design pressure (Pd). Because of the diffi~Blty in controlling the final pressure while pressurizing containment, a broader band should be allowed in those cases where P approaches Pd. ac Test data analysis methods require further study and justification before they are included in any containment leak rate test regulatory guide. Work performed for RG&E by a testing contractor established that our two most recent tests quickly meet the "Extended ANSI" acceptance criteria of the proposed regulatory guide. However, the calculated parameters may not be well behaved and may not converge predictably from unacceptable to acceptable results with certain data sets. The adoption of this analysis technique is, at least, premature. Other analysis methods should be investigated as a minimum. Formulation of the specific technique in the regulatory guide may make other analysis methods, which are equally acceptable or preferable, more difficult to establish. RG&E has implemented a successful containment test program to implement the requirements of 10CFR50 Appendix J. We welcome the opportunity to work with the Staff to assure continued protection of the public health and safety by maintaining containment leakage within accident analysis assumptions. v/) truly yours, k:1r w.w. ~-----~ Roger Kober

JUCKET NU 8£(( pR- A7/ &

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{~/ ~ ~t?J-3P} STONE & WEBSTER ENGINEERING CORPORATION OCKETrn USN! C 245 SUMMER STREET, BOSTON, MASSACHUSETTS ADDRESS ALL CORRESPONDENCE TO P.O. BOX 232!5, BOSTON. MASS. 02107 *a7 FEB 17 P5 :17 W . U . TELEX: 94-0001 BOSTON 94-0977 DESIGN NEW YORK CONST.RlJ(:.TION CHERRY HILL, N ,J . REPOR]'J; ; DENVER EXAMl"1.f('l'IONS CHICAGO CONSULTING HOUSTON ENGINEERING PORTLAND. OREGON SAN DIEGO WASHINGTON . D . C. Secretary of the Commission February 10, 1987 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Docketing and Service Branch LEAKAGE RATE TESTING OF CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS (51FR39538) This letter is in response to the NRC request for comments on the proposed amendment of 10CFRSO, Appendix J set forth in the Federal Register, 51FR39538 dated October 29, 1986. Our comments on specific sections of the proposed rule are as follows: Section II. Definitions o "Containment Isolation System Functional Test" is defined, but is not used further in the proposed rule. Therefore, it should be deleted. o The definition of "qualified water seal system", as used in Paragraphs III.C.(2)(a) and (b) should be added. o The definition of "Containment System" uses the term "closed systems". This latter term should be defined. Paragraph III.A.(4). o For plants with Pac equal to or very close to the design pressure, there should be an allowance for a test pressure margin above the design pressure. It is recommended that "by 2 psi" be added after "containment design pressure" on the fourth line of the paragraph. Paragraph III.A.(5) o On line 6, change "performance" to "leakage". Paragraph III.A.(6) o On the line 10, "leadkage" should be "leakage".

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2 Paragraph 111.A.(9) o The last word of the paragraph, "license", should be changed to "technical specifications". Paragraph 111.B.(i) (sic) o "(i) Frequency" should be changed to 11 (1) Frequency". Paragraph III.B.(3).(a) o The first full sentence should be changed to read "Air lock volumes must be tested prior to the preoperational Type A Test and at least *** ". Paragraph III.B.(3).(b).(i) o On line 6, add the word "doors" after "air lock". o On line 8, change "Air locks opened" to "Air lock doors opened". o On line 11, delete the word "repeatedly". o On line 13, change "the plant requiring" to "establishing". Paragraph III.B.(4).(c) o Change the last sentence to read "Corrective action to correct the leak must be developed, implemented and reported in accordance with Section VI." Paragraph 111.c.(2).(a) 0 Add "or as specified in the technical specifications" to the end of the existing sentence to cover BWR main steam isolation valve leakage tests with limits of 25 psi which generally is less than Pac* Paragraph VI.A.2 o Revise the last sentence to read "Any Type B or C test(s) whose results cause the as found or as left acceptance criteria to be exceeded shall be reported to the NRC Regional Administrator within 30 days of the performance of the test(s). Paragraph VI. B o Change the last word, "reqort" to "report". As requested in the notice of proposed rulemaking, enclosed are counnents addressing the fifteen specific questions set forth in the notice.

3 We appreciate the opportunity to comment on the proposed rule and hope that our comments will assist in its finalization. 14..~ Chief Engineer, Nuclear Technology and Licensing Division Enclosure JBS:ht

Comments to Questions in Proposed Rule (51FR39538)

1. The extent to which these positions in the proposed rule are already in use.

Connnent A partial listing of items already being used is:

a. Trying to eliminate the use of the partial pressure Type A test.

b. Disallowing the use of the mass step change verification test.

c. The "as found" Type A provisions have only been used (generally on an informal basis) since 1982. Previous to 1982, many plants did not record "as found" local leak rate test (LLRT) information, let alone determine an "as found" Type A leakage rate.

d. Testing of systems outside of containment that can contain primary coolant sources are done under NUREG-0737, Item III.D.1.1, not under 10CFR50, Appendix J.

e. Use of the 10CFR50, Appendix A, General Design Criteria 54, 55, 56, and 57 for "newer" plants.

f. Use of the Design Basis Loss-of-Coolant Accident scenario for Pac and system alignment justification.

g. Provisions for isolating excessive leakage paths during the Type A test.

h, The Type Band C acceptance criteria of 0.60 LA*

i. More frequent testing of certain repeat offenders (e.g. the purge and vent valves).

j. Use of ASME XI lWE-5222 for Type A Test deferral.

k. The use of the upper confidence limit.

Utilities could not implement those portions of ANSI/ANS 56.8 which conflict with the existing Appendix J and ANSI N45.4 standard, such as, performing an 8 hour Type A test. The inconsistency of different NRC Region IE Inspections, led to a reluctance by utilities to implement any new test program requirements as they were not required from a licensing standpoint. Older plants which were designed prior to the 10CFR50, Appendix A General Design Criteria will not satisfy the containment isolation valve definitions.

2. The extent to which those in use, and those not in use but proposed, are desirable.

2 Comment ANSI N45.4 is outdated and a new endorsed standard would be beneficial. The major benefits of the new standard are the reduced duration test, use of the Mass Point Analysis Method, provisions for isolating excessive leakage during a Type A test, the potential to extend the Type A frequency based upon the Type B and C program validity, or on an approved corrective action program with more frequent testing, as required, and air lock test extensions. Some negative features involve the need to develop new technical specification sections to incorporate the changes, the potential for more frequent testing with increased down time, more frequent reporting requirements for LLRTs, the potential for NRC re-evaluation of previous exemptions by use of current design criteria and models to analyze older plant designs and uncertainty in how future revisions to the Regulatory Guide are to be handled.

3. Whether there continues to be a further need for this regulation.

Comment The containment leakage test program requirements and criteria should be clearly stated in the regulations. Should future source term or other studies show that greater leakage rates could be allowed, then less rigorous criteria and testing would be required.

4. Estimates of the costs and benefits of this proposed revision as a whole and of its separate provisions.

Comment The NUREG/CR-4398 cost analysis of revisions to 10CFR50, Appendix J claim a reduction in replacement energy costs due to expected reductions in plant outage times. This is due to the proposed use of more frequent Type Band C testing coupled with less frequent Type A testing (see Section 5.1.4). What is not included in the analysis is the additional plant outage time associated with doing the more frequent (mid-cycle) testing and the potential for resulting repair work. To date, the penetrations that have been tested more frequently are generally the purge and vent valves which are used minimally during the cycle. Testing other penetrations that are in use (i.e., main steam isolation valves, feedwater check valves, etc) could result in extended outage time to repair. Hardware improvements are long term solutions, so mid cycle testing outage time needs to be included in a cost-benefit analysis. The additional radiation exposure would be higher for work done during short mid-cycle outages than corresponding work done during long refueling outages. Also, the compliance effort to revise the Appendix J program procedures to satisfy ANSI/ANI 56.8 and the additional Regulatory Guide material, needs to be addressed.

3 S. Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule becomes effective. Comment This issue is dependent upon the disposition of the Backfit Analysis as required by 10CFRS0.109. The claim that fewer exemption requests and interpretive debates would result appears to be geared to the newer operating plants. Licensees should have the option to use the new rule as a guidance document. New plants will probably have to meet the new rule except as otherwise controlled by 10CFRS0.109.

6. If the existing rule or its proposed revision were completely voluntary, how many licensees would adopt either version in its entirety and why.

No comment.

7. Whether (a) all or part of the proposed Appendix J rev1.s1ons would constitute a "backfit" under the definition of that term in the Commission's Backfit Ru l e, and (b) there are parts of the rule which do not constitute backfits, but would aid the staff, licensees, or both.

Comment It seems clear that the proposed rule is a backfit as defined in 10CFRS0.109 . As such, the determination that there is no resultant substantial increase in the overall protection of the public health and safety indicates that the rule change cannot be justified for backfitting. It is, however, appropriate to pursue rule changes such as this and state applicability to new license applications. Appropriate criteria for exemptions are contained in 10CFRS0.12 and consider both safety and cost. Thus, the regulations already provide a mechanism for exemptions to current regulations, and the Backfit Rule should not be degraded.

8. Since the NRC is planning a broader, more comprehensive review of containment functional and testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation.

Comment Yes, a revision of some degree is needed due to the outdated ANSI N45.4. Based upon some explanation of how Items 5 and 7a are handled by the NRC, this would be a worthwhile revision.

9. The advisability of referencing the testing standard (ANSI/ANS 56.8) in the Regulatory Guide (MS 021-5) instead of in the text of Appendix J.

4 Comment The testing standard (ANSI/ANI 56.8) should be referenced in the Regulatory Guide. The regulation (Appendix J) should identify overall testing requirements and criteria. Methods to achieve these requirements and criteria should be in the Regulatory Guide and ANSI/ANS 56.8. Efforts should be made by the staff and the testing standard committee to minimize the exceptions made in the Regulatory Guide.

10. The value of collecting data from the "as found" condition of valves and seals and the need for acceptance criteria for this condition.

Comment This is useful for assessing degradation, although the mechanics of performing this "as found" Type A analysis may focus all the attention and resources on the penetrations feeding non-seismic systems versus those feeding seismic systems. The real emphasis should be placed on any valve group that has shown to repeatedly exhibit excessive degradation.

11. Whether the technical specification limits or allowable containment leakage should be relaxed and if so, to what extent and why, or if not, why not.

Comment Advancements in source term related work may allow relaxation of current requirements. These advancements should be factored into the evaluation as appropriate.

12. What risk-important factors influence containment performance under severe accident conditions, to what degree these factors are considered in the current testing requirements, and what approaches should be considered in addressing factors not presently covered.

Comment Some recent events which may have influenced containment performance under severe accident conditions are misaligned containment isolation valves such as certain purge and vent valves, mistakes in either administrative or procedural controls, or water hammer events. Each of these events resulted in a corrective action plan to address the problem. The action plan may have resulted in increased surveillance activities, additional monitoring capabilities such as limit switches for valve position, design modification to reduce water hammer transients, etc. The Appendix J Test Program does address some of these events. The detailed system alignments would detect misaligned valves or missing administrative controls. The containment inspection would detect gross liner or penetration boundary degradation if the general area was accessible for inspection. The Type C program or the Type A test would detect valve or boundary degradation caused by water hammer.

5 The Appendix J Test Program has to be considered as the double check on the overall plant work control program. It will also detect certain severe accident conditions although it may not be timely. It really should not be considered as the sole means of detection. As severe accident condition challenges are discovered, they need to be separately analyzed and specific corrective action plans should be developed to address them.

13. What other approaches to validating containment integrity could be used that might provide detection of leakage paths as soon as they occur, whether they would result in any adjustments to the Appendix J test program and why.

Couunent A continuous leakage monitoring system would detect certain containment conditions, however, it would not detect the valve degradation which is the most serious challenge to the containment integrity.

14. What effect "leak-before-break" assumption could have on the leakage rate test program. Current accident assumptions use instantaneous complete breaks in piping systems resulting in a test program based on pneumatic testing of vented, drained lines. "Leak-before-break" assumptions presume that pipes will fail more gradually, leaking rather than instantly emptying.

Couunent A revised accident analysis would be required, in which a more realistic look at the leakage mechanisms, the system boundaries, specification of water rates, etc, would be developed. This would greatly aid the test program.

15. How to effectively adjust Type A test results to reflect individual Type B and C test results obtained from inspections, repairs, adjustments, or replacements of penetrations and valves for the years in between Type A tests.

a. All Type B and C performed during same outage as a Type A test, or performed during a specified time period (nominally 12 months) prior to a Type A test, be factored into the determination of a Type A test "as found" condition.

b. If a particular penetration or valve fails two consecutive Type B or C tests, the frequency of testing that penetration must be increased until two satisfactory B or C tests are obtained at the nominal testfrequency. Attention to focus on correcting component degradation, no matter when tested, and the "as found" Type A test would reflect the actual condition of the overall containment boundary.

c. Add/subtract Type B or C test result increases or decreases.

i. If this sum} 0. 75 La but<. La, take measures to reduce sum to no more than 0.75 La* This is not reportable.

6 ii. If La, take measures to reduce sum to no more than 0.75 La* This is a reportable condition. iii. Keep 0.60 La in effect. Comment

a. There would be a problem analyzing the data collected over a long period. A problem would exist of how to combine penetration leakages if only one valve out of total is tested (due to repair) or if multiple tests are done with various results. This .happens as plant test provisions and test methods were not developed with this concept in mind. All penetrations should be tested during a refueling outage to rezero the surveillance clock.

As found Type A leakage rates should only be determined when the Type B and C test results are fairly current to give truer picture of the containment integrity at that moment. At all other times, the Type Band C program limit should govern. This assumes that the Type Band C program is a comprehensive program.

b. If penetrations fail two consecutive tests (assume at 2 year frequency), the frequency of testing is increased until two successful tests are done.

Say mid-cycle or when next shutdown occurs not to exceed "X" months, the valve shall be tested to verify excessive degradation has not occurred. Once the degradation cycle is known, testing shall be done at this frequency until a "fix" is performed which allows resumption of a longer frequency - preferably the original cycle. This places the needed attention on the problem valves, and the Type A test frequency "as found" determination will provide the overall picture as some system credits can be used to determine which valves to concentrate on.

c. The method of combining Type B and C information should better represent system alignments considering the single failure criteria as opposed to determining the maximum pathway analysis for each penetration. Also, new Type B or C information would simply replace the previous information if a one-for-one replacement can be made (i.e. a single valve leakage rate replaced by a single valve leakage rate). If combination test data is all that is available, adequate documentation of the methods used to develop the replacement leakage rate shall be provided. The Type Band C program limit should be increased to 0.75 La unless the NRC provides the bases of why 0.60 La is used.

It makes sense to use the same limits for both the "as left" Type A and the "as left" Type B and C total when we are combining the programs for analysis purposes or extending the Type A frequency based upon a validated Type Band C program.

7

i. If "as found" Type B and C tally > O. 75 La but < La, repair but trend problem valves. This would not be considered a reportable condition due to the conservative nature of the test program.

ii. If the tally is> La, repa ir, report, and consider more frequent testing. iii. If the tally is ( 0.75 La , consider extending frequencies if fixes on certain problem valves have been demonstrated to be acceptable. BX6-4224800-IVA-01

J JOCl<~T ~=PR (51 Pf Jc/J'3i

                                               -S?J FEB 1 2 1987
                                                                        *s7 ~EB 13 A11 :52 1":t Ms. Carolyn Comer P.O. Pox 2862 Dallas, Texas 75?21

Dear Ms. Comer:

As requested in your February 6, 1987 letter, enclosed is some further information related to the Federal Register notice to which you referred.

1. Copy of Federal Register notice of October 29, 1986, including proposed revision to 10CFR Part 50, Appendix J.

2. Copy of Federal Register notice of October 28, 1986, noticing the availability for comment of proposed regulatory guide MS 021-5.

3. Copy of proposed regulatory guide MS 021-5, dated October 1986.

4. Copy of two Federal Register notices of January 22, 1987, extending the public comment periods for both the proposed rule (#1 above) and the proposed regulatory guide (#3 above) to April 24, 1987.

Your interest in this subject is appreciated. Sincerely, E. Gunter Arndt Engineering Branch Division of Engineering Safety Office of Nuclear Regulatory Pesearch

Enclosures:

As stated DISTRIBUTION: (w/incoming, w/o enc l) RESRead i ng GArndt JBurns JRichardson LShao GArlotto PDowning, SECY EB~S EGi; *,r . km 2/ /I /P7

Ms. Carolyn Comer P.O. Box 2862 Dallas. TX 75221 February 6. 1987

                                                                   *a7     FEB 13 A11 :5 2
    \1r. E. Gunter Arndt Office of Nuclear Regulatory Research                        l  i*

11

• S. Nuclear Regulatory Commission fJ Cl, /'

Washington, D. C. 20555

Reference:

NUCLEAR REGULATORY COM~nssroN, 10 CFR Part 50, Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants: Extension of Comment Period: AGENCY: Nuclear Regulatory Commission. ACTION: Proposed rule: extension of comment period. Page 2416, FEDERAL REGISTER, Tuesday, January 20, 1987. Please send me further information. I will read it, then give it to Dallas City Hall. This is important to everyone. During WWII, I served in the Women~*:s Army Corps, with Headquarters Squadron, US Army Air Forces, Bolling Field, Washington, D. C. l received an excellent efficiency rating. Later, I served with Headquarters Squadron, Far East Air Service Command, Hollandia, Dutch, New Guinea, SW Pacific, 12,000 miles from San Francisco, California in combat area in the jungles. We had so many tropical diseases that I came back on the Hospital Ship Mermac Sea. After my discharge, I attended Wayne State ljni versi ty, Detroit, Michigan.

                                                                        /
                                                                     / /)

Sincerely, \

                                              ~u__,,~---

i~1~, ~&,'1//.A.__J-,J Carolyn Comer

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, . NewVorkPower , C(i' 11 p ? *.:.{;hn C. Brons 87 1L.. l..; - -;t'l() \ P1 1*~ !I .,, Authori1y r* f'<1r l , l ll' r-l t 1 Februrary 6, 1987 JPN-87-006 IPN-87-003 U.S. Nuclear Regulatory Commission Washington DC 20555 Attention: Docketing and Service Branch Room 1121 1717 H Street NW. Washington, DC

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Indian Point Unit 3 Nuclear Power Plant Docket No. 50-286 Leakage Rate Testing of Containments of Light-water-Cooled Nuclear Power Reactors

Reference:

1) NRC Notice of Proposed Revision to 10 CFR 50, Appendix J, 51 FR 39538, dated October 29, 1986.

Dear Sir:

The New York Power Authority has reviewed and evaluated the proposed revision to 10 CFR 50 Appendix J concerning leakage rate testing of light-water-cooled nuclear power reactor containment structures (Reference 1). This letter summarizes the Authority's comments on the proposed revision. Attachment I contains comments on specific items of the proposed revision to Appendix J. Attachment II contains comments on the specific issues raised in the "Invitation to Comment" section of Reference 1. The Authority evaluated the revision in light of its stated scope and on its affects upon the Authority's two nuclear power plants. Reference 1 states that "the scope of this revision to Appendix J is limited to corrections and clarifications, and excludes new criteria." The Authority agrees that a revision to Appendix J meeting this scope would be beneficial. However, several items within the proposed revision, in fact, constitute new criteria and/or more stringent regulatory requirements. FEB 13 1987 Acknowledged by canS ** , * * * * * *

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Specifically, the "as found" acceptance criteria is a new requirement. This conclusion is detailed in Attachment I. The minimum pathway leakage characteristics of each containment penetration and pressurization of each valve in the "accident direction" are required to accurately assess the "as found" condition of the containment structure. Many nuclear power plants (including the Authority's FitzPatrick station) do not have the necessary equipment, piping, and valve configurations to accurately perform these tests. Additional block valves and test connections would have to be installed to meet this new requirement. Since the proposed revision may require hardware changes to certain nuclear power plants, and does not constitute a substantial increase in overall protection to the general public, the Authority considers that the proposed revision to 10 CFR 50 Appendix J do not meet the criteria of the Backfit Rule. Commissioner Bernthal in his views on the proposed rulemaking (October 29, 1986, 51FR39540 column 2) implies that the proposed revision does not substantially increase the overall protection for the general public. He then proposes to waive provisions of the Backfit Rule to allow the proposed revision to be implemented. The Authority endorses the Backfit rule as a realistic and practical method of assessing the merits of changes in the regulatory environment. Bypassing provisions of this rule to implement the proposed revision to Appendix J, sets a precedent which defeats the intent of the Backfit Rule. Should you or your staff have any questions regarding this matter, please contact Mr. J. A. Gray, Jr. or Mr. P. Kokolakis of my staff. Very truly yours,

                                       ,,tG~

ohn c. Brons enior Vice President uclear Generation Enclosures cc: Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission Buchanan, NY 10511 Office of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093

ATTACHMENT I TO JPN-87-006, IPN-87-003 AUTHORITY COMMENTS CONCERNING THE PROPOSED REVISION TO 10 CFR 50, APPENDIX J II. Definitions a) There is a definition of "Containment Isolation System Functional Test" but there is no mention of a requirement to perform such a test. This definition should be deleted from the regulation. b) The definition of Type C tests include only pneumatic tests. This should be ammended to include reference to valves tested with water. Also, a typographical error merges "Verification Test" into "Type C Test." III.A. (7) & (8) The requirement for an "as found" acceptance criteria constitutes a new requirement. The NRC considers this new requirement to be a "clarification" of an existing position as stated in I.E. Information Notice 85-71. However, NUREG/CR-4398, Cost Analysis of Revisions to Appendix J states,

          " ..* reporting of the "as found" condition for the Type A test does not appear to be presently done. The NRC has been requesting that the utilities supply sufficient data from the Type Band C tests results to derive an "as found" condition for the containment. However,
           ... this requirement or request has not been enforced in all NRC regions."

The Authority and other utilities have considered the applicable sections of the existing Appendix J and ANSI N45.4-1972 as a request by the NRC staff for the utilities to provide data which can be used to determine the "as found" condition of the containment, not as an "as found" acceptance criterion for the Type A test. III.A. (7) (a) & (b) In determining the acceptance criteria for a Type A test, the term "properly justified statistical analysis" is subject to interpretation. The regulation should specify the appropriate means of determining acceptability in its text or by means of reference to the ANSI Standard. The manner in which it is currently written allows the NRC staff to impose any requirement that they may desire.

III.A. (7) (c) (ii) There should be some mechanism whereby this requirement could be waived when it is deemed impractical or undesirable from a standpoint of severe penalties on plant availability or ALARA considerations. Does this section imply that Type B penetrations (eg. drywell head, CRD hatch, torus hatch seals) must be tested prior to opening? If so, it is suggested that exceptions for such items be included in the regulation. III.A. (7) (d) In most cases, quantifying such leakage is not practical and should not be a requirement without the term "when practical" added to the statement. IV.A Does this imply that Type B penetrations (eg. drywell head, CRD hatch, torus hatch seals) must be tested prior to opening? If so, it is suggested that exceptions for such items be included in the regulation. There is no reason why such details are required in the Technical Specifications since acceptable test methods are prescribed in the regulation and an ANSI Standard. VI.A.l This should state that the report is to be submitted not later than 3 months after the conduct of a Type A test, not "each test." VI.A.2 The 30 day reporting requirement should be clarified. At the time of a single test, there is no mechanism of evaluation with respect to the 0.6 La acceptance criterion since the acceptance criterion is based on the sum total of all of the Type Band C tests performed over a period of time. It is recommended that this be changed to require the reporting within a reasonable time interval (perhaps 30 days) following completion of all Type Band C tests performed during an outage.

ATTACHMENT II TO JPN-87-006, IPN-87-003 AUTHORITY COMMENTS CONCERNING THE PROPOSED REVISION TO 10 CFR 50, APPENDIX J WITH REGARD TO INVITATION TO COMMENT

• l. The extent to which these positions in the proposed rule are already in use; Comment:

As many of the changes are primarily minor or editorial in nature, many of its positions are already in use. The elimination of the reduced pressure test would not affect the Authority's two plants since their ILRT's are currently performed at Pc* One position, the new "as found" acceptance criteria woulg have a substantial impact on the Authority's plants. (See Attachment I)

2. The extent to which those in use, and those not in use but proposed, are desirable; Comment:

The Authority has no comment on this specific issue.

3. Whether there continues to be a further need for this regulation; Comment:

The present status of the offsite doses associated with design basis accidents indicate that the models used in the FSAR are overly conservative by as much as several orders of magnitude. Inherent design features of water cooled reactors will maintain offsite doses below the guidelines on 10 CFR 100 even with containment leakage rates well beyond the presently specified acceptable limits. For events beyond the design basis, gross containment failure, rather than leakage rate is considered to be the prime contributors to offsite risk.

4. Estimates of the costs and benefits of this proposed revision, as a whole and of its separate provisions;

• Note: Item numbers correspond to the numbers in the "Invitation to Comment" section of the NRC Proposed Rule, 51 FR 39538, dated October 29, 1986.

Comment: The benefits associated with the proposed revision are minimal. The administrative burdens associated with the lack of clarity in the current Appendix J do not alone justify this revision. The costs of implementing the revision are primarily the effect of the new "as found" acceptance criterion. The costs of modifications to the plants in order to be able to perform a more accurate "as found" determination will be substantial. Even if performed, the "as found" determination will not result in a substantial increase in safety, and therefore cannot be justified. Increased Type A test frequency as a result of "as found" failures will lengthen refueling outages and will not result in an increase in safety.

5. Whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appendix J provisions if the proposed rule (reflecting consideration of public comments) becomes effective; Comment:

The Authority has no comment on this specific issue.

6. If the existing rule or its proposed revision were completely voluntary, how many licensees would adopt either version in its entirety and why; Comment:

The Authority has no comment on this specific issue.

7. Whether (a) all or part of the proposed Appendix J revisions would constitute a "backfit" under the definition of that term in the Commission's Backfit Rule, and (b) there are parts of the rule which do not constitute backfits, but which would aid the staff, licensees, or both; Comments:

The proposed revision involves editorial changes which would not require changes in plant procedures or hardware. These portions of the revision should not require the detailed analysis as required by the "Backfit Rule." Care should be taken, however, that certain items such as the new "as found" acceptance criteria, are properly classified as a new requirement, not as a clarification of an existing position. As such, a full backfit analysis is required prior to implementation.

8. Since the NRC is planning a broader, more comprehensive review of containment functional and testing requirements in the next year or two, whether it is then still worthwhile to go forward with this proposed revision as an interim updating of the existing regulation; Comment:

There is little to be gained in this "interim" change considering the fact that this review will be well underway and probably completed before the regulation is enacted and the associated regulatory guide is issued. The proposed revision is not necessary to protect the welfare of the general public and results in no "substantial increase" in the level of safety.

9. The advisability of referencing the testing standard (ANSI/ANS 56.8) in the regulatory guide (MS 021-5) instead of in the text of Appendix J; Comment:

Since the points made in the regulatory guide are not necessarily complex and, in the case of conflicts between the regulatory guide and the regulation the regulation takes presidence, it would be better if the issues raised in the guide and the reference to the Standard were written directly into the regulation.

10. The value of collecting data from the "as found" condition of values (sic] and seals and the need for acceptance criteria for this condition; comments:

Collecting "as found" leak rate data could provide a way of evaluating Appendix J. However, the electric utility industry is not engaged in such a program. The operational impact and personnel exposure must be weighed against any potential gain. There are times when pre-maintenance testing can severely affect plant availability and may become a factor in decisions to perform elective maintenance or inspection - with the potential of adversely affecting plant safety and reliability if such activities are curtailed by the testing impact.

11. Whether the technical specification limits on allowable containment leakage should be relaxed and if so, to what extent and why, or if not, why not;

Comments: Containment leakage rates could be relaxed if it can be shown that limiting offsite doses during design basis accidents will not exceed those used in the FSAR and licensing basis of the plant. This evaluation should be based upon state-of-the-art techniques and research, and not upon the overly conservative assumptions used in the original licensing basis of the plant. The Technical Specification limit should also be relaxed if that limit is overly conservative with respect to the assumed leak rate used in the offsite dose calculations. NUREG/CR-4330 "Review of Light Water Reactor Regulatory Requirements" concludes that increasing containment leakage rates to 10% per day for PWRs and BWRs has little effect on the calculated risk.

12. What risk-important factors influence containment performance under severe accident conditions, to what degree these factors are considered in the current containment testing requirements, and what approaches should be considered in addressing factors not presently covered; Comments:

The factors which influence containment performance under severe accident conditions are still being investigated. It would be impractical to impose testing requirements for phenomena which are not yet fully understood.

13. What other approaches to validating containment integrity could be used that might provide detection of leakage paths as soon as they occur, whether they would result in any adjustments to the Appendix J test program and why; Comments:

Gross breaches in containment integrity such as open valves, open hatches, or structural openings in the containment structure can be easily detected if the containment is normally operated at a slightly positive or negative pressure. Inability to maintain the required pressure, or excessive make-up or vacuum pump operation, would indicate a loss of integrity. The routine valve line-ups, verifications, and the ASME IST leak rate testing are sufficient to assure a relatively leak-tight containment system.

14. What effect "leak-before-break" assumption could have on the leakage rate test program. Current accident assumptions use instantaneous complete breaks in piping systems, resulting in a test program based on pneumatic testing of vented, drained lines. "Leak-before-break" assumptions presume that pipes will fail more gradually, leaking rather than instantly emptying.

Comments: At this time, the entire ECCS requirements and containment response is based upon the instantaneous rupture scenario. The instantaneous rupture presents the most severe scenario, and therefore, the most conservative response requirements. Currently "leak before break" assumptions are applied to primary system leakage detection requirements and pipe support system design. If its application is expanded to include other areas, than its use should be uniform and applied to all systems which are currently governed by the instantaneous rupture scenario.

15. How to effectively adjust Type A test results to reflect individual Type Band C test results obtained from inspections, repairs, adjustments, or replacements of penetrations and valves in between Type A tests ....

Comments: The Authority has a number of comments on the subject of Type B and C test requirements and their effect on the Type A test. a) Paragraph III.A. (8) (a) requires that 11 * *

• a Corrective Action Plan (CAP) that focuses attention on the cause of the problem must be developed and implemented ... " for a single "as found" Type A test failure. This CAP does not necessarily include a requirement for increased frequency of Type Band C testing.

A certain level of flexibility is implied so that this CAP should deal with the specific root cause of the "as found" Type A test failure. Section III.A.(8) (b) (ii) provides an alternative to an increased frequency of Type A testing in the case of two consecutive "as found" Type A test failures. Such a plan would require some provision for mid-cycle Type B and C tests of problem penetrations and isolation valves. These tests should be performed during a shutdown period, however some could be performed during operation. b) Any CAP would most likely be the result of the "as found/as left" minimum pathway leakage improvement determined from Type Band C testing and repairs. Type A tests at each refueling outage remain as a permitted alternative to a CAP with an alternate leakage testing program. This increased frequency of Type A tests does very little to provide improved assurance of the reliability of the containment system during the operating cycle.

c) A CAP with an alternative leakage testing program would be developed indirectly as a result of Type Band C "as found" failures. It seems more logical to address "as found" Type B and c failures directly rather than penalize the Type A test program with "as found" failures as a result of Type Band C testing. d) The situation of repeated "as found" Type Band C failures is of concern to the NRC. The current and proposed regulation only requires a thirty day report to the NRC via a Licensee Event Report of any Type B or C test that fails to meet its "as found" acceptance criteria. To address the problem of "as found" Type Band C failures by means of the "as found" Type A test failure is a "back-door" regulation. "As found" Type A test failures may not produce the desired improvement in Type Band C "as found" test results. Discussed in the notice, but outside the scope of this proposed revision, is increased frequency of Type Band C tests based on "as found" Type Band c failures. This is more logical, but would constitute new criteria and would therefore require a greater Backfit analysis and justification. e) Further consideration should be given to the submittal of a CAP with an alternative leakage test program. Acceptance criteria for mid-cycle Type Band C tests may be set at a higher level than the nominal 0.6 La maximum pathway leakage. Containment isolation valve improvements are already being made as part of Appendix A and Regulatory Guide 1.97 efforts. This could be a major part of a proposed CAP. It should be possible to schedule mid-cycle Type B or C tests on certain penetrations during mini-outage periods, thus minimizing the impact of Type A tests at each refueling outage.

                                          'tT  NUMBERPR Of'O ED RULE    -fl !IL (SIP£ ..395"3t)

DOCV.ET l USNl-r EDISON DRIVE ATom,c POWER comPAllH . AUGUSTA, MAINE 04336

                                                      *97 FEB -9 A10 :17          (201) 623-3s21 GDW-87-23 United States Nuclear Regulatory Commission Washington, D. C. 20555 Attn:  Docketing and Service Branch

Subject:

10CFR50, Appendix J Proposed Rule

• • Gentlemen:

Maine Yankee appreciates the opportunity to participate in the NRC's rulemaking process and offers our comments on the proposed revisions to 10CFR50, Appendix J. The proposed rule in part would require Type A containment leak rate tests to be performed at highest theoretical pressure following a hypothetical worst case accident. The practice of determining the containment leak rate using lower pressures would no longer be allowed. Maine Yankee believes that testing at lower pressures is adequate to accurately determine the containment leak rate and should continue to be allowed. The basis of our position is summarized below. First, the peak pressure which the containment is subjected to during a hypothetical worst case accident is maintained for a brief period of time and typically decays to less then the lower test pressure after ten minutes. During a Type A test at reduced pressure, the test pressure is held continuously for approximately 30 hours, thus, the total integrated pressure applied during this test is greater than the integrated pressure following a theoretical worst case accident. Second, the NRC has agreed that high energy piping systems will leak before catastrophically failing (leak-before-break) and does not require the failure to be assumed when designing pipe restraints. Thus, it is highly improbable that the containment woul d ever be subjected to the maximum design pressures produced by a theoretical worst case guillotine rupture. Finally, containment leak tightness is more likely to be affected by modifications and maintenance on containment penetrations which are typically required to undergo Type Band C testing at full containment design pressure. FEB 'l 1987 card .***********

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MAINE YANKEE ATOMIC POWER COMPANY United States Nuclear Regulator Commission MN-87-13 Page two GDW-87-23 We appreciate this opportunity to provide our comments on the proposed revision of 10CFRSO, Appendix J. Very truly yours. MAINE YANKEE ATOMIC POWER COMPANY

                                        -&19-~

G. D. Whittier. Manager Nuclear Engineering and Licensing GDW/bjp cc: Mr. Ashok C. Thadani Mr. Richard H. Vollmer Mr. Pat Sears Mr. Cornelius F. Holden 84O2L-LMO

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D .C. 20555 February 9, 1987 OFFICE OF THE SECRETARY NarE TO RECIPIENTS OF PR-50 (51 FR 39538) GENERAL REVISION OF APPENDIX J Please note Comment No. 10 is a duplicate of Comment No. 7. This number will be used again. Docketing and Service Branch

                                                                                ...,Oli-'.~'U I )NHC
                                                                        '87 FEB -4 P12 :20 Off11..:.                A 't 1 CKE. r 1, ,        r *v1cF.

11\ANcH Pl e~ :5e reply tc, Marvin I. Lewis 7801 Roosevelt Blvd.#62 Phila ** PA 19152 Secretary of the Commission USNRC Washington, D.C. 20555 tr'*"li- Mi-. Secretary; Please accept this as my limited comment on the 10CFRPart 50 Leakage rate testing of containments Proposed Rule. My major objection to this proposed rule is that it will depend too greatly on the unproven and undemonstrated technology of leak before brea~. LBB means that the NRC expects to see some sign before a pipe gives way catastrophically as in a double er1ded qLtillc,tlne pipc;,i bre.-ak. There is re,:d ly no reasc,n to believe that I BB will occur before a catastrophic break or that the leakage will be detected in a timely fashion to mitigate the consequences. The proposed rule makes any possible detection in a timely fashion most unlikely and problematical as leakage rate testing will not have to be done continuously and in the minute manner i*equired tc, detect small leakages. The acceptance of this ru le will therefore be an admission on effce the part of the staff and commission that the LBB concept is a and provides inadequate prc,tection crf the he.-.dth and safety c:if the public. Respectfully submitted,

                                        /# ,                 /y-_ I/,,,,~
                                         ~~                / ~c,-:7 , /'-}~ij Please reply to Marvin I .. Lewis 7801 Roosevelt Blvd.#62 Phila., PA 19152

/ U S. NU CLEAR REGULATORY C0M MISSIOII{ DOC K :TI NG & SERVICE BR,~NCH Orf ,CE OF TH C: SECRE1 ARY OF THE COMM .,..,j 1 Oocu,.,- em s 'a s Post rn rk C resRce ed D ate_f'-t;-A-/

                         /

Add1 Cor, es R 1

Toledo Edison Company DavlsBesle Artul- Powwr & Ught Company AN0-1 Oconee I, 2, J T..,.,..... V*H-,, Authority Bellefoncel,2 Duke-* Company WNP'1 Crystal Rlvar J Wahington Publlc -

• Supply flortdll -
• Corporation Synem Gl'U Nucle*r Corpo*all- TMl*I Babcock & Wllco* Company S-**- Munlclpal Utlllty District R*nchoSeco Working Together to Economically Provide Reliable and Safe Electrical Power Suite 220 7910 Woodmont Avenue Bethesda, Maryland 20814 January 23, 1987 (301) 951-3344 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission

Subject:

B&W Owners Group .,., rrl ... C )

                                                                                                                        ,:-*J Comments on Proposed 10CFR50, Appendix J,                                         co      : ::~
                                                                                                                .- ...: :~

Leakage Tests for Containments of Light-Water Cooled I ~~ r-, Nuclear Power Plants (51 FR 39538, 10/29/86) N *:) ~

                                                                                                                         ':-:J

Dear Mr. Chilk:

The B&W Owners Group Technical Specification Subcommittee has reviewed the pro-posed revision to 10CFR50, Appendix J, Leakage Rate Testing of Containments of Light-Water Cooled Nuclear Power Plants. Comments generated during this review have been limited to those aspects of Appendix J that pertain to technical speci-fications. The proposed rule makes progress towards improving technical specifications by eliminating the need for many of the Appendix J exemptions currently in technical specifications. This will help make the current technical specifications easier to use by eliminating the inconsistencies caused by these exemptions. The B&W Owners Group Technical Specification Subcommittee, which is working to achieve technical specification improvement, concurs with this positive step. The B&W Owners Group Technical Specification Subcommittee has been a strong supporter of industry and NRC efforts to improve technical specifications. The Supplementary Information to the proposed rule refers to the NRC efforts at improving technical specifications and alludes to the possibility of changes in the form of implementation of the Appendix J requirements. One of the major events of the technical specification improvement effort has been the development of a selection criteria for those elements that should remain within technical specifications. Application of this proposed criteria to the existing Standard Technical Specification (STS) Containment Leakage LCO resulted in it not being selected as an element to be included in the improved version of technical speci-fications. It did not meet any one of the selection criteria. FEB 2 knowle ed by card . ********** ***

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  $ . NUCLEAR REGULA rQRY COMMISSION I '.E 61{,.1.l'lCH Ot r,~   uf T**c ::,,.c,;E.irKY Ur I lL CU" ,1 .,.::, 1J1~

Mr. Samuel J. Chilk January 23, 1987 Page 2 It should be noted that the draft version of the B&WOG improved technical speci-fications does include LCO's for containment air locks, containment equipment hatch, and containment isolation valves. As a result of this effort, the B&W Owners Group Technical Specification Subcommittee recommends that 10CFR50 Appen-dix J not refer to requirements contained in technical specifications, with one exception. This one exception is the inclusion of La and Pa in the Design Fea-tures of technical specifications. All other elements needed by a licensee to implement the requirements of 10CFR50, Appendix J can and should be implemented by a program. (Attachment 1 provides our suggested wording changes to Appendix J) This use of a program to implement a regulatory requirement is not unique. In fact, several appendices to 10CFR50 are implemented by programs (e.g. Appendix B, QA Plan; Appendix E, Emergency Plan; Appendix R, Fire Protection Plans). To this end, it is recommended that 10CFR50, §50.54(0) be revised to require implementa-tion via a means similar to 10CFR50, §50.54(p) (Safeguards) or 10CFR50, §50.54(q) (Emergency Plans). Such an implementation process could include initial NRC approval of the plan and an administrative process for licensee review and approval of changes. Details of the process could either be in the regulation or in the Administrative Controls of technical specifications. (Attachment 2 provides our suggested changes to technical specifications) The primary basis and justification for this recommendation is the following statement taken from operating licenses issued by the NRC which indicates that licensees are required to comply with federal regulation as well as plant tech-nical specifications.

     "This license shall be deemed to contain *** and is subject to all applicable provisions of the Act and to the rules, regulations *** and is subject to the additional conditions specified or incorporated below ... "

As a result of this license condition, there is no need to repeat federal regu-lations in technical specifications to ensure compliance with these requirements. The duplication of requirements only adds to the administrative burden of both the NRC and licensee. Furthermore, technical specifications are to be reserved for those matters of the highest level of importance. The selection criteria that has been developed provides a means by which such a determination can be made. Our proposal to require implementation via a program should not result in any significant new efforts. Licensees presently have programs that implement not only the requirements of 10CFR50, Appendix J, but also the surveillance requirements for Integrated Leak Rate Tests in the technical specifications. These are periodically reviewed by NRC Inspectors during routine inspections. Thus, conversion of procedures that exist to a "program" should not require extensive re-review by NRC and could be handled as a part of the inspection process. The implementation of this recommendation maintains the enforceability of the regulatory requirement, reserves technical specifications for those matters of the highest importance, and reduces the administrative burden of duplication of

Mr. Samuel J. Chilk January 23, 1987 Page 3 requirements in both regulations and technical specifications. Furthermore, it is consistent with NRC practice relative to requiring programs to implement other appendices to 10CFRSO. Very truly yours, 1/ 11, Jr. / Chairman B&WOG Technical pecification Committee RLG/144/jgm xc: N.A. Rutherford Pat Rogers (AP&L) Dan Green (FPC) Courtney Smyth (GPU) Ron Colombo (SMUD) Bill Salyer (TVA) Jerry Lammars (TED) (7)

ATTACHMENT 1 PROPOSED WORDING CHANGE TO APPENDIX J Appendix J Reference Proposed Disposition to Technical Wording Specifications II. Definitions La (weight percent/24/hr) The maximum allowable Type A test leakage rate in units of weight percent per Type A test leakage rates 24-hour period at pressure shall be located in the Pac as specified in the Design Features section of Technical Specifications. No Change Technical Specifications. Pac (psig) The calculated peak containment internal pressure related to the Containment internal design basis pressure shall be located loss-of-coolant accident as in the Design Features specified in the technical section of Technical specifications. No Change Specifications. Preoperational Leak Test Test conducted upon completion of construction of a primary or secondary containment, including installation of mechanical, fluid, electrical, and instrumentation systems The reference is penetrating these unnecessary since the time containment systems, and when containment integrity prior to the time is required is clearly containment integrity is defined in plant documents required . by the Technical Delete the underlined as well as Technical Specifications. phrase Specifications. t

ATTACHMENT 1 PROPOSED WORDING CHANGE TO APPENDIX J Appendix J Reference Proposed Disposition to Technical Wording Specifications III. General Leak Test Requirements B. Type B Test (1)(b) For containment penetrations employing a continuous leakage monitoring system that is at a pressure not less than Pac leakage readings of sufficient sensitivity to permit comparison with Type B 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 FI.A. When practical, continuous leakage monitoring systems must not be operating or pressurized during Type A tests. If the continuous leakage monitoring system cannot be isolated, such as inflatable air lock door seals, leakage into the Replace the underlined containment must be phrase with The type B test intervals accounted for and the Type specified in the shall be located in the A test results corrected licensee's Appendix J proposed Appendix J accordingly. program. program. (2) Pressure. Type B must be conducted, whether individually or in groups, at a pneumatic pressure not less than Pac except as provided in paragraph Replace the underlined Specific Type B test III.B(3)(b) of this section phrase with . . . or in pressures shall be located or in the Technical the licensee's Appendix in the proposed Appendix J Specifications. J program. program.

ATTACHMENT 1 PROPOSED WORDING CHANGE TO APPENDIX J Appendix J Reference Proposed Disposition to Technical Wording Specifications (4) (d) Individual Replace the underlined Acceptance er i ter ia for acceptance criteria for all phrase with ... in the all air lock tests shall air lock tests must be licensee's Appendix J be located in the proposed stated in the Technical program. Appendix J program. Specifications. (3)(b) Intermediate tests must be conducted as follows: (i) Air locks opened during periods when containment integrity is required by the plant's Delete the underlined The reference is Technical Specifications phrase unnecessary since the time must be tested within 3 when containment integrity days after being opened. is required is clearly For air lock doors opened defined in plant documents more frequently than once as well as Technical every 3 days, the air lock Specifications. 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 Delete the underlined ------//------ Technical Specifications phrase need not be repeatedly tested during such periods. However, they must be tested prior to the plant requiring containment integrity. For air lock doors having testable seals, testing the seals fulfills the intermediate test requirements of this paragraph. In the event that this intermediate testing cannot be done at Replace the underlined The air lock test pressure Pac the test pressure must phrase with ... in the shall be located in the be as stated in the licensee's Appendix J proposed Appendix J Technical Specifications. program. program. 1u.d v , ATTACHMENT 1 PROPOSED WORDING CHANGE TO APPENDIX J Appendix J Reference Proposed Disposition to Technical Wording Specifications C. Type C Test (3)(b)(i) The valves have Replace the underlined Type C valve leakage rate been demonstrated to have phrase with . . . in the acceptance criteria shall leakage rates that do not licensee's Appendix J be located in the proposed exceed those specified in program. Appendix J program. the Technical Specifica-tions, and IV. Special Leak Test Requirements B. Multiple Leakage Barrier or Subatmospheric Containments The primary reactor containment barrier of a multiple barrier or subatmospheric containment shall be subjected to Type A test to verify that its leakage rate meets the requirements of this appendix. Other structures of multiple barrier or subatmospheric containments (e.g., secondary containments for boiling water reactors and shield buildings for pressurized water reactors that enclose the entire primary reactor containment or portions thereof) shall be subject to individual tests in Replace the underlined Special Leak Test accordance with the phrase with ... in the Requirements shall be procedures specified in the licensee's Appendix J located in the proposed technical specifications. program. Appendix J program. ATTACHMENT 1 PROPOSED WORDING CHANGE TO APPENDIX J Appendix J Reference Proposed Disposition to Technical Wording 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 containment and its penetrations and isolation valves for light water-cooled power reactors Replace the underlined must be referenced or phrase with ... in the Test details shall be defined in the Technical licensee's Appendix J located in the proposed Specifications. program. Appendix J program. VII. Application A. Applicability The requirements of this appendix apply to all operating nuclear power reactor licensees as specified in § 50.54(0) of this part unless it can be demonstrated that alternative leak test requirements (e.g., for certain containment designs, leakage mitigation systems, or different test pressures not specifically addressed in this appendix) are demonstrated to be adequate on some other defined basis. Alternative leak test requirements and Alternative leak test the basis for them will be Replace the underlined requirements and their made a part of the plant phrase with the basis shall be located in Technical Specifications if licensee's Appendix J the proposed Appendix J approved by the NRC staff. program. program. ATTACIDIEHT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES 5.0 DESIGN FEATURES 5.2 CONTAINMENT CONTAINMENT LEAKAGE RATE 5.2.3 The maximum allowable Type A test leakage rate at [Pa] psig is [La] weight per cent per 24 hour period. 6.0 ADMINISTRATIVE CONTROLS 6.8 PROCEDURES AND PROGRAMS 6.8.4 The following programs shall be established, implemented and maintained:

e. Appendix J A program for implementing the requirements of 10CFR50 Appendix J.

This program for Type A, B, and C leak testing shall include: ( i) Test pressures (ii) Test frequencies (iii) Acceptance criteria (iv) Test methods and ( V) Procedures

P~_:'v@ BOSTON EDISON ~l)Lt' ~. L General Offices SN r 800 Boylston Street Boston, Massachusetts 02199

                                                             '87 JAN 29 P3 :29
                                                             &Fl eoc Err.          ,,, .r James M. Lydon                                                            NU 1 Chief Operating Officer                                                                 January 23, 1987 BECo 87-013 U.S . Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, D.C. 20555 License DPR-35 Docket 50-293

Reference:

Proposed Rule 10CFRSO Appendix J (51FR39538) Draft Regulatory Gu i de MS021-5 (51FR39440)

Dear Sir,

Boston Edison Company has begun a thorough review of the Proposed Ru l e and Regulatory Guide concerning Pri mary Containment Testing. Based on our review to date, we respectfully request a 90-day ex t ension of the public comment period (to April 26, 1987). The changes represented by these documents have necessitated an extremely detailed comparison with our current test programs. For our comments and responses to your fifteen (15) questions to be generated, this additional time is necessary. Furthermore, we are actively supporting the BWR Owner's Group Committee on Containment Testing. We are aware of their letter requesting an extension and support that request. Should you have any questions regarding the request, please do not hesitate to contact me or M. T. Lenhart at (617) 849- 8937. MTL/ns cc: E. Gunther Arndt CNRC) FEB 2 1987 by

   ' U S. NUCLEA R REGULATORY CO MM ISSION Do~ '<;     rt N  1 & SEHVl,~E 8t1ilNC H 0 ,,         vr   T .    ~ C' ,l'1f,RY (J ,    I     ( Ui-1.

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OlKET(( JANUARY 26, 1987 USNHC COMMENTS OF OH 10 er TI ZENS r o R RESPONSIB L E ENERGY. INC. <* ocRI< > JAN 29 Al l :57 ON PROPOSED EVISION TO 10 CFR 50 APPENDIX J, 51 FED REG 39538 <OCTOBER 29, 1986) CFF oc OCRE supports t is revi ion to Appendix J and incorporation or ANSI/ANS 56.8-1981 in th regulator y guide, Thi revision would implement o number or long-advocoted im rovement

• e,g,,

use or moss point method only, elimination or reduced pressu r e t sting (Type A), and repo r ting requir ments better reflecting

• as round* and *os lert* leak rotes ( and discouraging pre-test tampering to create the illusion or better performance), OCRE add esses below the broade r issues contained in the *invitation to comment* section of the Fed. Reg, notice ( P. 39539 ) . The numeration below corresponds to that or the 15 questions in the notice, Not all questions are addressed; some con only be answered by the industry,

3. There der*nitely is a need ror this regulation, Accident ono1yses, ror both severe and milder (design basis) accidents, have shown the importance or restricting conta i nment leakage in mitigating o rsite occid nt consequences, OCRE's studies of t h e BWR Mark III containment performance ond accident consequences

( using 10 Cf"R 100 assumptions ) indicate that containment lea k rat_ is t e dominant Factor in determining offsite dose, Further ore, the siting and design or present reactors i-predicated on the assumption that containment leak rotes do not exceed those postulated in th accident analyses. In order ror the licensing basis to remain valid, there must be continued assur1nce that the leak rates are indeed low, i.e., within that orig ina ll y postulated. This assurance can only be provided through periodic testing as required by Appendi x J. periodic leak r ate t sting also gives information on containment availabilit y and p rformance which ( 1) provides insights as to severe accident mitigation capability and consequences; a nd (2) indicate tr nds in component performance o r plant management / maintenance p actices. APPendi~ J serves a neces$ory and useful function in pres rving defense in depth,

5. IF the propo$e rule becomes effective , it should be binding on all licensees and applicants, As noted above, the proposed rule contains a number of improvements over current practice, If these improvements are such to war ant revision to Appendix J

( and OCRE belie v es they a e ) , then th new r equirements sho u ld be worth enrorcing, It is also the letter and spirit of the Atomic Energ y Act and the Commission ' s regulate y practice that compliance with all regulations ( including new ones ) be mandatory, It hardly makes sense to revise a rule to implement FEB 2 1987 by card.:._... -----*

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page 2 improvements but then to ollow lic ensee s to follow the old, less de iroble standord. OCRE has long e xpr essed concern r eg arding the legalit y and practicality or the Backfi t Rule. As commission er Bernthol hos noted, the aackfit Rule, when applied to rulemaking , exacts *NRC r sources wholly disproportionate to a ny conceivable benefit to the public,* OCRE believes thot the sackfit Rules ould be r epealed due to this and other flaw s. OCRE furth er belie ves thot the Appendix J revisions, applying not to hardware or plant design but to test procedures, should not be considered a bOCkfit.

a. The proposed revisions to APPendix J should be approved quickly, The 1981 ANSI standard has been recognized as superior to that now in use; in the 1982 workshop on containment Integrity Micheal Weinstein or American Nuclear Insurers ecommended that *proposed changes to 10 CFR 50 Appendix J should be expeditiously made, The new ANSI/ANS 56,8 Standard should be adopted for use by all facilities.* NUREG/CP-0033, Vol. 1, P, 333. Delaying these revisions because t e NRC is planning o brooder review or containment functional and testing requirements (which may or may not yield sig nificant changes, at some unknown date in the future) is unwise. To the extent that the NRC is contemplating r laxation or elimination of containm en t leak rate testing ,

p rhops in the context or the program to identify egulo tory r equirements having marginal importance to safety or risk, it is OCRE's posi ion, for the reasons stated in the r esponse to it m 3 abov , that this is unacceptable, 9, Re erencing the ANSI standard in the r egulator y guide , whi e keeping Appendix J general , does have the advantage of g eater flexibility for inco rporatin g any amendments or revisions which may be made to the standard or the NRC's evaluation thereof.

0. Collecting data rom the *as found* condition of valves and seals is very important, as this provid s i ndication on the actual pe rormance and availability or containment. As noted above, ~uch data are useful in establishing severe accident mitigation capability, trends in component per~ormance or maintenance practices, and the d gree of compliance with the technical specirications and licensing basis for the plant.

Acceptance criteria for individual valv es and seals may be more approp~iate in encouraging the maintenance of a leaktight contoinm~nt boundar y than the current summing of all Type Band Ct sts.

11. Allowable containment leakage hould not be relaxed, for a number of reasons. First, increasing the allowable leak rate would vitiate the siting and licensing basis ror the reactor, as

Poge 3 a speciric containment leo k r ate was assu~e d in occident analyses demonstrating tha t t he part 100 dose limits would not be exceeded. Increasing the allowable l eak r ate would result in calculated doses gr e ate r tha n t e port 1 00 l i mits, thereb y invalidating the racility*s compliance with t h at regulation. second, the importance of containment integ r ity in mitigating the consequences of accidents ( across the spectrum, from benign to seve e) is such that relaxation of leakage limits is clearly i prud nt. Third, here is the practical effect of a goal ror compliance , ond the unfortunate laxity with which many licensees treat this goal, U.S. experience with containment availability has not been r avorab 1 e. see we ins tei n, NUREG / CP-0033, Vol. 1. Ov ra 1' containment availability is 893/4, with th current stringent requi ements. Relaxation of the requirements is likely to lead to even less availability , as too many licensees appear to accept 'barely adequate* as an appropriate level of performance, rather than excellence, Stated another way, if *excellenc_* today is equivalent to leak ates of 0,1 - 0.21/4 / day , and many licensees are willing to accept something less than excellence (i.e. , more leakage), then setting *excellence* as 13/4 / day would result in many licensees accepting much great r leakage simpl y because thy do not aim for excellence in their management and operation of their facilities, particularly when excellence competes with profit, The result is that nuclear power facilities would become decidedly less safe t han postulated at the relaxed leak ra e, and much more dangerous than with the cu ent, stringent allowable *

12. Containment performance under severe accident condition should be considered by the NRC, and some t y pe or standard should be establish d for nuclear facilities to meet regarding containment performance, due to the dominant role t e containment performs in mitigating severe accident consequences, The NRC did consider several options or containment perrormance D sign ObJectives in a workshop held May 12- 3, 1986, but it appears that no quantitati v e standard will be developed at this time, OCRE finds this unfo r tunate; an appropriate 1 vel of protection to the public would require substantial a surance, ror each operating and proposed r eactor ,

that there is a high reliabili y of containment function during a severe accident. *Hi9h' means 993/4 or better, or, in other words , .01 failure probability, ( *Failure* meaning leakage exceeding e tech spec allowable, ) his definition of failure makes the leak rote testing requirements of Appendix J highly important and relevant to severe accident mitigation capability, The relevance of lea* test data to containment performance under s vere accident conditions is revealed by the discussion at the 1982 wo~ksho on Containment Integrity CNUREG/CP-0033, Vol. 1, P. 349, attach d }

page L where Hr. Weinstein arrirms that leak test data ( obtained near or below design pressu es ) does not support containm e nt capability at p essures greatly exceeding desi n pressures.

13. Detecting containment leakage as soon as it occurs, instead or waiting until an outage or ot er testing int e rva l, would obviously be benericial. Weinstein has noted that the use of on-line leak detection systems is one reason for an increas in containment availability for 1979-80, NUREG/CP-0033, Vol. 1, PP. 330-331. Th e concepts noted at P, 39538 or th e Fed, Reg.

notice (continuous containment leakage monitoring, low pressu r e pumpup bero e operation) should be explored rurther. However, as stated, such measures would not test the post-accident boundary, including isolation valv es, as does Appendi x J, so they cannot be considered a substitute ror APP ndix J,

4. OCRE assumes that this question re ers to changing th design basis accident For containment design, Since containment d sign is bosed on the double-ended guillotine pipe rupture, now considered unlikely due to leak- erore-break assumptions (now the subject of a proposed revision to GDC e dynamic e fects ),

should containment design ( e,9., design pressures and leak rates) be r ela x d as well? he answer is no, Even if large pipe breaks are conside ed unlikely (and BWR expe ience with IGSCC in r ecirculation piping does not give one comfort that this is SO ) there is no doubt that other accident scena ios, including t ose leading to severe core damage, would r esult in containment loads equalling or exceeding those postulated ror the deign basis occident. While ther are those who call such seve re accidents extremel y unlikely as ell, operating events, e.g. , M!-2 and Ch rnobyl, suggest otherwise. Prudence and conservatism therefore dictate that current containment design bases not b eroded , but rather strengthened,

15. here should be some means to assess th e leaktight beha v ior or containments on a more continuous basis, as suggested.

Proposal b, would be a workable approach, and, as noted i~ NUREG/CR-3549 ( P. 19>, increasing th e testing freque ncy with railures would pro vid e an incentive to licensees to improve the leoktightness or Type Band C components. Respectrully submitted, Susan L. Hiatt OCRE Representative 8275 Munson Rd, Mentor, OH 4060 (216) 255 -3 158

INTERNATIONAL WORKSHOP ON CONTAINMENT INTEGRITY SESSION III Discussion and Question & Answer My name is TOM AHL, CBI Company: My question is directed to Mr. Weinstein. It appears as though the larg~st Aope ning in a containment vessel is actually the personne l, W1oc k, inasmuch as the door is 4 ft.x6'8". You just gave us the analysis of the failures. Even though the personnel

• lock is the largest opening you didn ' t mention it as part . of the potential problems or at least the historical problems.

How many actually experienced difficulties in the mechanical drive system being violated? MIKE WEINSTEIN: I didn't mention it Torn, but they do occur. There have been cases where the top of the containment dome has tended lift off when containment was pressurized in a couple of plants. There have also been cases where the equipment hatch door penetration has tended to unseat during pressurization. The reason I didn't mention those cases specifically was that the failures that did occur only l asted through periods when the reactor was ano t in operation and also existed for a relatively short 9Pe riod of time. I * * ., .~. ~:,\ * . -*~ ~~'1'*-.:?F ~~ If a containment system has a means of monitoring leakage :-6"n' a continuous basis, then the systems like the persorihel l~ck have a much shorter leakage duration. So, to get the maximum ALI, monitoring appears to be very effective. When you are talking about low pressure leak testing and high pressure leak testing, I want to emphasize that in u.

s. reactor operational history there have been cases where the leakage path developed during the testing process as the pressure was being increased. In one case that I mentioned a pressure diaphrarn blew out and in another case a pipe plug blew out: so you run the possibility of running the l ow pressure test with a good containment shown and then when it is pressurized it is wide open .

c. SEISS: That doesn ' t give much comfort about going to three times the design pressure.

M. WEINSTEIN: Tha t is the case.

                                        *s7   J~N 27 P2 :i. 6 U.S. Nuclear Regulatory Commission Washington, DC 20555, Attention: Docketing and Service Branch Mad r id , Jan u a r y ,       14 ,        19 87 *

Subject:

Submittal of comments on the 10 CFR 50 Appen-d ix J proposal.

Dear Sirs:

My name is Fernando Robledo. I work in "Consejo de Seguridad Nuclear" (CSN), the Spanish Nuclear Regulato-ry Body, and one of my competences is the evaluation of the containment leakage rate testing performed in the S pan i sh n u c 1 e a r po we r p 1 ant s

• Th i s 1 e t t er enc 1 o s e s m y personal comments on the 10 CFR 50 App.J proposal issued in Federal Register on Wednesday, October 29, 1986. It should be emphasized that these comments re-present my personal opinion, by no means these comments represent the opinion of CSN or CSN staff as a whole.

Best regards F B2 1 7 rd ***-.~.-. *** -***** .....-...

• 1 D ;

(

r - --------- I. Spanish position on containment leakage rate testing. There are nine light-water-cooled reactors in Spain. Eight of them were designed in U.S.A. and the other one was designed in West Germany. Table I shows the main characterstics of these nuclear power plants (NPPs). It should be noted that plants n92 and nQ3 are twin-units erected in the same site. The same holds true for plants nQ 5 and n.Q 6. In Spain, by law, every NPP has to com p 1 y on n u c 1 e a r s a f e t y w i th t he a pp 1 i c ab 1 e r u 1 e s in the country to which the NPP has been bought. There-fore, the Spanish NPPs designed in U.S.A. have to com-ply with 10 CFR 50 Appendix J and the Spanish NPP de-signed in west Germany has to comply with the applica-ble German rules. It is my opinion that the American rules on containment leakage rate testing are the most adequate and consequently, we are making efforts to im-plement the U.S. legislation to all the Spanish light-wa te r- cooled r eac tors. Regarding the American designed NPPs, we are making efforts to implement the proposed Appendix J at least in part. Significant items are: i) A11 type A t e st s a r e per f o r med at Pac

• ii) We are making efforts to implement the "as found" , "as left" methodology.

As far as item ii) is concerned, the IE. Information Notice No

• 8 5- 7 1 : "Containment Integrated Leak Rate Tests" was submitted by CSN to Spanish utilities for comments in April, 17, 1986. The comments are being evaluated. Attachment includes some of the possibili-ties we are considering to implement the "as found",

   "as left" methodology.

Several features of leakage testing in Spain are des-cribed below. In Spain, the type A tests last for 8 hours, at most 1 0 hours. During this period of time, we have already collected enough data to determine the leakage rate of the containment with enough accuracy. As it is indicated in ref. 1, I think that type A test is a check of the type Band C tests. The main objetive of this test is to discover leak paths indetected du-ring type Band C tests, ref.2 provides a good example of this. In general, I have empirically observed that this check is conservative, as the table II shows.As it could be noted from this table the type A test result is generally greater than the type Band C results even using maximum pathway leakage. It could also be noted the lack of correlation between the type A and type B and C results. I I. COMENTS. My first comment is focoused on three items: i) The following paragraph of the page 39540: "9. Ty-pe A test allowable leakage rate prorating". ii) The acceptance criterion for "as left" type A test. iii) The following statement of the paragraph III.A.8.a of the Appendix J proposal: "An as left type A test that meets the acceptance criterion of 0,75 La is required prior to plant startup". The reasons exposed in the item i) above mentioned are not technically correct. In my opinion, the deter iora-tion should be measured by the "as found" type Band C test results. It could be shown with the following example. During a shutdown for refueling, the "as left" type A test result is 0,54 La, but a penetration leaked as much as 2,0 La during the corresponding "as

found " type C test , th i s v a 1 u e became 0 after the co-rresponding reparation. It is clear, that this valve should be submitted to a type C test during the cycle, for instance, six months after the startup. When it was accomplished, the results are: 1,80 La "as found", 0 "as left". On this context, it makes no sense to retain a 0, 2 5 La for deter i oration

• The on 1 y reason for this margin is, in my opinion, to add an additional conser-vatism for the type A test. But does this conserva-tism add anything to the safety? In a negative case, shouldn't it be more appropriate to establish al,0 La "as left" acceptance criterion and change, as appropriate, the paragraph III.A.8.a? The Spanish expe-rience shows the two sides of the coin. Plants number 5 and 6 had to increase the La value, because of the ex-cessive leakage from a type A test. In both plants, one type A test provided a leakage lesser than La but greater than 0,75 La. The extensive rounds accompli-shed, failed to find an indetected leak path. The only solution was to increase the La value from 0,lt/day to o, 15t/day. As a consequence, the radiological calcula-tions were reassesed, this reassesment showed the ac-ceptability of the decision. This problem occurred du-ring the preoperational test, had it during a periodic test ocurred, it could have resulted in an innecessary burden for the utility without any benefit for the sa-fety.

But the oppossite happened during a type A test in plant number 8. Table III shows the results of this f i r st fa i 1 e d at t em pt

• It may be noted that the outcome is lesser than La but greater than O, 75 La. After ex-tensive searchs, it could be detected a gross leakage through the seat of a con ta i nmen t isolation valve be-longing to PASS, a closed loop outside containment, no previously submitted to a type C tests. When this leak was plugged, the test was repeated and the outcomes we-re:

Leakage= 0,8339t/day U.C.L. = 0,85731/day

As it could be seen, the benefits in terms of safety are remarkable. Another reason to increase the "as left" type A accep-tance criterion stems from the table II and the co-mments in part I of this report. Now, I am not sure about the adecuacy to maintain a o, 25 La as an added conservatism, therefore this deci-sion should be very carefully considered. Another comment is concerned with the "as found" type A acceptance criterion and with the way to obtain it. Spanish experience shows that "as found" type A test should be deleted or, at most, should have an orienta-tive meaning, because the methodology for the correc-tions could be some misleading. During a shutdown for r e f u e 1 in g in p 1 ant number 1 , the r es u 1 ts of 1 ea k age rate tests were: i) "as found" type B and C results using maximun pathway leakage. 0,79 La ii) "as left" type B and C results using maxim un pathway leakage. 0,40 La iii) "as found" type A results Qt a 4 La iv) "as left" type A results 0,46 La According to Appendix J proposal, the tests verify the acceptance criteria. But, if we look more carefully at the results of type Band C tests, we observe the fo-llowing. Penetration M-12 ( service air system) is a 3 i n c he s w id e 1 i n e

• Th e " a s found " 1 e a k a g e r a t e o f t he outside isolation valve was 58 slm (i.e. 0,32 La). No leakage was observed for the inside isolation valve.

Penetrations M-40 (H2 supply to RCS) is a inch wide line. The "as found" leakage rate for the inside isola-t ion v a 1 v e was 2 , 6 s 1 m ( 0 , 0 1 La ) but for the out s id e isolation valve was 60 slm (0,33 La). Clearly, the uti-lity has to send a corrective plan to improve this si-tuation. Therefore, the corrective plan should be deci-ded taking into account the "as found" type Band C re-sults using maximum pathway leakage, rather than "as found" or "as left" type A test results. Caution should be taken to implement "as found" and "as left" methodology. Certains containment isolation valves could give excesive "as found" leakage rate systematically because of problems such as: vibrations of systems ( specially RCS), problems with boron cristalization, *** To make leakage rate testing more frequently could be very onerous and unefficient. It could be onerous, because the plant would have to shutdown to make the test. It could be unefficient, because the deterioration is very fast, i.e. the integrity is lost in a very short period of time. Otherwise, these kind of isolation valves, have usually to act in case of LOCA plus one single failure. Some relaxation in the application of the single failure criterion could be appropiated to prevent unnecesary local leakage rate tests. Spanish experience in this field is still very limited and nothing definitive can be said. As the note enclosed in attachment 1 stays, ex c e pt ion s to t h e " a s f o u n d" , " a s 1 e f t " me t hod o 1 og y could be considered by CSN on a case by case basis.

III Conclusions. Appendix J proposal stay an "as left" type A test acceptance criterion of 0,75 La. Without the compliance with this criterion a plant can not startup. The re-maining 0,25 La is mantained as a margin for deteriora-tion until next type A test. In my opinion, to mantain 0,25 La as a margin for dete-rioration has not technical reasons. The deterioration between two type A tests should be measured with the "as found" type B and C results. The only reason to maintain a 0,25 La is to have an additional conserva-t i sm

• I t i s not c 1 e a r , t h at t h i s add i t i o n a 1 con s e r v a -

tism improves the safety of the plants. Spanish expe-rience shows that this margin may have advantages, but may also create unnecesary burdens to the plants. Therefore, it should be carefully thought to stay a 0,75 La as "as left" acceptance criterion for type A test. Appendix J proposal provides acceptance criteria for "as found" and "as left" type A test. If, for any pe-r i o d i c Type A test , the " as found " 1 ea k age rate fa i 1 s to meet the acceptance criterion, a Corrective Action Plan should be submitted. It is my opinion that "as found" type A test acceptance criterion should be deleted or, at most, should only have an orientative meaning, because the methodology for the neccesary corrections to obtain "as found" res u 1 ts co u 1 d be m is 1 ea d i ng , i

• e
• the method o 1 og y can mask excessive leakage from certain components. The CorrectiveAction Plan should be submitted based on the "as found"type B and C results rather than the type A "as found" results.

Caution should be taken to implement the "as found", "as left" methodology. Some isolation valves could give sistematically excesive "as found" leakage rate. Reparations could be unefficient, because the nature of the problem (for instance: vibrations, boron cristalization, *** ) would produce a very fast deterioration of the seat integrity. In addition, to make local leakage rate tests more frequently could result in unplanned outages of the plants with significant economical damage for the utilities without benefits in terns of safety. Solutions for this problem should be taken on a case by case basis.

IV Re f e r enc e s *

1) ACRS. Transcript of the Meeting of Subcommittee on Reactor Safeguards, Vol. 1524. "Proposed Revisions to 1 OCFR Part 50, Appendix J, Regarding Leak Rate Testing". June, 4, 1985.

2) I.E.Information Notice No. 86-16. "Failures to Iden-tify Containment Leakage Due to Inadequate Local Testing of BWR vacuum Relief System Valves".

Table I. Characteristics of the Spanish light-water-cooled reac-tors. Plant. Re actor Power Free La (t/day) type. ( Mwe)

• Vo 1 ume. ( *) *

( m3) Number 1 PWR 160 23000 0,35 ( 1 8 9) Number 2 PWR 1000 62092 0, 1 0 ( 1 8 9) Number 3 PWR 1000 62092 0, 1 0 ( 1 8 9) Number 4 PWR 1000 62296 0, 1 0 ( 1 9 0) Number 5 PWR 100 0 59465 0, 1 5 ( 2 7 2) Number 6 PWR 1000 59465 0, 1 5 ( 2 7 2) Number 7 PWR 1000 57740 0,25 ( 6 3 7) Number 8 BWR 500 6153 1, 6 ( 2 8 2) Number 9 BWR 1000 35344 0, 5 ( 2 1 5) (*) In parenthesis the equivalent in standard liters per minute.

Table II. Comparison between the type A test and type B and C test results, when these tests are performed in the s am e out a g e for r e f u e 1 i ng

• Type A test Type B and C Plant. Date. result test results (as left). (as left)(*).

Number 5 March- 84 0,955 La ( * *) 0, 1 0 La Number 2 August-85 0, 71 4 La 0,03 La Number 8 Decem-85 0, 5 3 6 La 0, 3 7 La Forth Cal ho um 1985 0,44 La 0,07 La Diablo Canyon 1985 0,53 La 0, 1 0 La Millstone 2 June-85 0,258 La 0,02 La Brunswick-1 Sept-85 0,568 La 0,06 La Number 1 October-86 0,46 La 0,37 La Shearon Harris Feb- 8 6 0, 51 2 La 0,05 La Brunswick-2 May-8 6 0, 3 8 2 La 0,43 La Number 5 Dec- 8 6 0, 56 9 La 0, 1 0 La (*) using maximum leakage path. (**) La=0, 1 t/day. It had to be increased up to La=0, 15 t/day.

Table III. Evolution of type A test results in plant number 8. Time u.c.L. (1) elapsed (hours). (' I day)

• 6,25 1,4686 6,50 1,4644 6, 7 5 1,4665 7,00 1,4652 7,25 1,4680 7,50 1,4791 (2 )

(1) La= 1, 6 I/day according to Tech. Spec. ( 2 ) At t em pt de c 1 a r e d as a fa i 1 u re

• A T T A C H ME N T 1

We are making efforts to implement in Spain, the "as found", "as left" methodology. To carry it out, we sent the document I.E. Information Notice No. 85-71 "Con-tainment Integrated leak Rate Tests" to the Spanish utilities, for comment. These cements are being evaluated. This attachment includes the english tr ans-lation, we are considering to implement the "as found", "as left" methodology. i) Any modification, repair or replacement of a com-ponent subject to type B or type C testing must be preceded by a type B or type C test. Otherwi-se, it shall be considered that the "as found" leakage rate is excessive. It is said that the "as found" leakage rate is excessive when the acceptance criteria are exceeded. These acceptan-ce criteria are stayed in Technical Specifica-tions or in the test procedures. (In Spain, the test procedures contains the acceptance criteria included in ASME XI article IWV-3420). ii) Any modification, repair o replacement of a com-ponent subject to type B or type C testing must be followed by a type B or type C test. iii) It shall be reported to CSN inmediately any exce-sive "as found" leakage rate measured during any type B or type C test. The report shall also con-tain the corresponding Corrective Action Plan. iv) Exceptions to the item i) ii) and iii) could be considered by CSN on a case by case basis. v) " As 1 e ft" type A test r es u 1 t s sh a 11 be co r r e ct e d to obtain the corresponding "as found" type A test results. The methodology for the corrections shall be stayed in the test procedure. The "as found" type A test results shall have only an orientative meaning.

vi) For plants with Operating Licensee granted after December 31, 1986 the interval between the preo-perational and first periodic Type A tests must not exceed three years. For plants with Operating Licensee granted before December 31, 1986 the present frecuency shall be maintained.

uoc<<n N1JM8£rt . Commonwealth Edison One First National Plaza, Chicago, Illinois onnn ....- -

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                                                                                             ) '£ January 15, 1987                      '87 J:'.~! 27 P2 :oo Mr. Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, DC 20555

Subject:

Proposed Rule on Leak Rate Testing of Containments for Light-Water-Cooled Nuclear Power Plants e

Dear Mr. Chilk:

(51 Fed. Reg. 39538, October 29, 1986) This provides Commonwealth Edison Company's ( 11 Edison 11 ) comments on the Nuclear Regulatory Commission's ( 11 NRC 11 or 11 Commission 11 ) proposal to amend 10CFR Part 50, Appendix J. For the reasons discussed below, Edison believes that promulgation of this rule would be premature. Edison also is concerned that this rule would impose significant new requirements contrary to its stated purpose. Finally, Edison opposes the promulgation of any rule which does not satisfy the backfit requirements in 10CFR50.109. The stated scope of the proposed revision to 10CFR50 Appendix J was limited to corrections and clarifications, and excludes new criteria. However, a close review of the proposed regulations reveals many changes and new criteria, most of which have not and cannot be justified either under the Backfit Rule or on a cost-benefit basis. The large number of new requirements outweighs the few clarifications such as airlock door testing and leaves the proposed Appendix J more unclear than the current version. As a result, this proposed rule would require a large expenditure of resources to 'fine tune* the leak testing regulations with no significant resulting increase in public health and safety. Such expenditures would be premature in view of current comprehensive reviews of containment functional testing and source term calculations. Until these studies have been completed and their results analyzed, no new regulations should go into effect. Examples of the potential waste of resources are provided by some aspects of the proposed Regulatory Guide which would accompany the new Appendix J. That Reg. Guide would include several minor contributions to leak rate analysis including: daily leak testing rig calibrations, local leak testing instrument error correction and valve directionally leak testing requirements. It would be wasteful to now require the expenditure of resources on FEB 2 1987

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these minor 1 or 2% effects when we believe that the new source term study will show that the public health and safety is adequately assured by maximum allowable containment leakrates (La) many times larger than those currently permitted. Another drawback of adopting these rules now is that such adoption may delay later rule changes which could address other, more realistic safety concerns such as inadvertent breaches in containment. Such events could be discovered by using continuous monitoring systems or a low pressure pump-up prior to unit start-up. But now these concepts are very difficult or impractical to implement because of the unrealistically low magnitude of La, Instead of perpetuating these unrealistic low values as proposed, the NRC should await test results which should show that future increases in La could make these alternative discovery techniques much more practical. Edison also opposes the proposal to provide greater regulatory flexibility by deleting from Appendix J the ANSI Standard, the criteria for venting and draining valves, and a description of what types of valves need not be leak tested. Greater flexibility would be very detrimental to licensees. Experience with the NRC's flexible enforcement of Appendix J requirements in recent years shows it to be inconsistent. New interpretations which gave rise to new requirements have been appearing every few months. Various parts of the new Appendix and the regulatory guide/ANSI Standard have appeared and disappeared in recent years as the NRC continued to modify its interpretations of current Appendix J requirements. Typically, new requirements lacked a valid regulatory basis, were technically flawed, and were poorly thought out. They have cost the utilities much lost operation time and personnel dose while adding nothing to public health and safety. Almost every time a Type A test was performed at a particular plant, the NRC inspector reinterpreted some regulations to make demands different from those imposed for the previous test. Examples of such transient requirements are zero pressure testing, running totals of Type A test leakages, running totals of Type B & c test leakages, use of the 95% UCL, mass plot method, and additional requirements for temperature surveys. Moreover, the licensee often is not informed of the latest *requirement* until the entrance meeting just prior to the start of a test. These NRC procedures for administering leak tests have led to unnecessary expenses for licensees. Therefore, these negative experiences lead Edison to believe that any new regulations should be clearly and concisely written, leaving little or no flexibility for interpretation and that all requirements, including the new ANSI Standard (not the current one), should be referenced as mandatory in the Appendix.

This proposal can be implemented by ensuring that the new version of Appendix J:

1) Not be issued in its current form and not be issued in a modified form until the source term and the containment functional testing studies are completed.

2) Minimizes the number of exemptions required.

3) States the rules in a clear unambiguous manner that is subject to as little interpretation as little as possible.

4) References as mandatory. a complete and acceptable ANSI Standard in lieu of the Reg. Guide. {Any referenced standard should have undergone a thorough and complete cost-benefit/backfit analysis.)

5) Undergoes a thorough and complete cost-benefit/backfit analysis by objective reviewers other than those who wrote the regulations.

Specific portions of the proposed Appendix J are addressed in Attachment A and specific portions of the proposed Reg. Guide are addressed in Attachment B. Finally. Edison is concerned by the Commission*s continuing erosion of the principled regulatory process signalled by the Backfit Rule. 10CFRS0.109. once again, although proposed amendments to a rule would increase regulatory costs without a compensating 11 substantial increase 11 in the overall protection of the public health and safety, the commission has determined to proceed with those more costly regulations due to their unquantifiable benefits. The Commission*s repeated reliance on such intangible benefits is contrary to the central role of cost-benefit analysis in the Backfit Rule and is verging closely on constituting a de facto amendment to the Backfit Rule by exempting from it rules promulgated by the Commission. Edison opposes any such modification of the Backfit Rule without the opportunity for Notice and Comment guaranteed by the Administrative Procedure Act. In the absence of such an opportunity for comment, Edison must assume that the Backfit Rule applies to this proposed rulemaking unless the Commission can justify an exemption from the 11 substantial increase 11 criterion in 10CFRS0.109. Should the Commission propose to grant itself such an exemption. Edison also would expect an opportunity to comment on that proposal. Otherwise. in the absence of a proposal either to modify the Backfit Rule or to seek an exemption from it, Edison urges the Commission not to promulgate this proposed rule unless it can be shown to satisfy the criteria in the Backfit Rule. 2601K

                                    ~~#,~4)

Nuclear L1cens1ng Director

l ATTACHMENT A Specific Comments on Proposed Appendix J II. Definitions: Minimum Pathway Leakage Rate The Minimum Pathway leakage is defined as the smallest leakage of two valves in series. This definition is overly conservative, it ignores the restriction of the worse of the two valves. Ignoring this restriction results in a calculated minimum path leakrate which can be up to 30% over-conservative when compared with the actual leakrate. This over-conservatism can be eliminated by redefining Minimum Pathway Leakage Rate to be:

1) the smallest leakage of two valves in series, or

2) the measured leakage from inboard of the first valve to outboard of the second valve in a dual valve isolation system with both valves closed, or

3) the measured individual valve leakages analytically combined using the orifice equations.

There is no valid technical or regulatory reason not to include criteria 2 and 3 into the definition of minimum path leakage. III.A. (3) Test Frequency The new regulations decouple the Type A retest schedule from the ten year !SI schedule. Instead of the requirement to perform at least three tests in each ten year period, a maximum interval between tests of four years would be allowed. This would leave test frequency essentially unchanged but could result in the loss of flexibility important for scheduling tests. IS! scheduled surveillances have a 25% grace period on test dates. This is a very important feature that could save unit operation time or eliminate the need to obtain an exemption due to unexpected/unplanned events. The new Appendix J should explicitly state that decoupling Type A

testing from the ISI scheduled does not result in loss of this grace period. Also, the Appendix should state that the maximum interval may pass without a test being performed while the containment is in a condition in which containment integrity is not required, provided that the test is performed prior to start-up. This section also would impose a new regulatory requirement by setting a maximum interval of three years between the pre-operational and the first periodic Type A test. The current regulations contain no such requirement: the 10 year ISI retest schedule clock starts with initial plant operation. The proposed rule is extremely costly because it will usually require an additional Type A test, due to the time interval between the pre-op test and the start of plant operation. This additional test adds little or nothing to plant safety because the plant has not experienced any service life during that time interval, and Type Band C test requirements mandate complete local leak testing prior to operation. Under these circumstances, the only possible new sources of leakage are from inadvertent damage to the containment structure. All plants have controls on work being done in containment. These controls protect the containment structure as well as every other safety related component. If there are potential deficiencies in those controls, those deficiencies should be addressed directly rather than indirectly by retesting a system already turned over for operation. The cost-benefit analysis performed for Appendix J did not adequately address this change in the regulations. III.A.(5) Test Pressure This paragraph should be amended, (or a new paragraph added) to specifically allow the use of a qualified seal water system during an ILRT. The water volume injected into containment must be accounted for in the ILRT results. This would reflect current practice. III.A.(6) Verification Test This section constitutes a change in the regulations by requiring that the verification test be done after the leak test. The existing rules do not specify when the verification test should be conducted. There is no technical reason why the verification test must be performed after the leak test. Actually, it can be shown that performing a verification test first is usually more conservative. This is because the leakrate must remain constant for a much longer period of time to pass a type A test.

Although it is not normally desirable to perform the verification test first, in some instances it makes sense. For example, if the leak test is performed first and passed but the verification test is performed and fails due to a flaw in the initial leak test, the subsequent passage of a new corrected leak test would not invalidate the previous verification test. Thus, a new verification test would be unnecessary. One example of flawed leak test is presented by a decision to end the test with too great a rate of change of leak rate. such transient leakrates can be caused by unstable containment conditions, diurnal effects, or isolation of small leaks during the leak test without test restart. III.A.(7)C.ii Acceptance Criteria This section would change current regulations by requiring the local leak testing of leakage paths both before and after they are isolated. repaired, or adjusted during a Type A test. This change will adversely affect Type A testing by disallowing three important current practices.

1) current regulations allow for isolation of a locally leak testable leakage path during a Type A test without local leak testing prior to the isolation.

After isolation, the Type A test is restarted and completed. After the Type A test, the isolated leak path is unisolated and then locally leak tested. The local leak tests are performed both before and after repairs and/or adjustments to the leakage path. The appropriate penalties are then added on to both the

               'As Found' and 'As Left' Type A test results. This requires the leakage path to have been isolated in such a way that the 'As Found' leak rate was not affected.

The above method is most useful for leakage paths that cannot be locally tested while the containment is pressurized. The time required to blowdown the containment, test locally, and repressurize is saved. This time is typically about 24 hours of critical path time.

2) current regulations allow for isolation, adjustment, or repair of a locally testable leakage path during a Type A test without prior local leak testing if the licensee concedes that the 'As Found' total containment leakage is greater than 0.75 La (i.e.

failed as found Type A test with indeterminate leakage).

The subsequent 'As Left' Type A test leakrate is corrected for the 'As Left' local leakage of the leakage path.

3) Under current regulations. when a pre-operational Type A test is performed, 'As Found' leakages have no meaning. Isolation, adjustment, or repair of locally leak testable leakage paths during the Type A test are allowed without prior quantification. The Type A test results are later corrected as appropriate with

               'As Left' local leakages.

These proposed changes to the regulations would be very costly in terms of increased testing time. but add nothing to safety. The cost-benefit ratio analysis for this change was not properly performed. The current rules should be left in place. III.A.(7)d Acceptance Criteria This section is a change in the existing regulations because it requires that the effects of 'additional tightening of manual valves* performed after the start of the Type A test be accounted for in the Type A test results. This statement can be interpreted to require taking leakage penalties for manual valves that were not fully or tightly closed in the Type A pretest valve line-up. The assessment of a leakage penalty would not be an accurate representation of the valve's sealing ability. The word "additional is ambiguous between additional (excessive) valve closure force versus additional (later) proper valve positioning. This phrase should either be deleted from the proposed regulations or changed to read

         'abnormal tightening of manual valves*.

This section also requires that the effects of 'any action taken that will affect the leakage rate'. (performed after the start of the Type A test) be accounted for in the Type A results. This blanket statement should be stricken completely from the Appendix. Below is a partial list of events that penalties would have to be unnecessarily assessed for. Failure to properly close or tighten a valve in the pretest valve line-up. Leakage due to correctly performing an incorrect valve line-up specified in the test procedure. Leakage through a qualified seal system that was not initially being used during the test, or through a valve pair that gets seal water from the system.

Leakage through the inner airlock door that was stopped during the Type A test by closing the outer door and equalizing the volume between the two doors. NOTE: It is common practice to start a Type A test with the inner airlock door closed and the outer door open. If this is not done. a leaky inner door will cause an undetectable containment leak. until the innerdoor volume is finally at test pressure. Under the current regulations no leakage penalty is required for any of the above events. This implies that leakage penalties for these events are not necessary to assure public health and safety. Therefore. the proposed change in the regulations requiring such penalties would unduly penalize the licensee without any compensating increase in the assurance of public health and safety. III.A.(8}.a. III.A(8).b.ii. III.B.(4).c and VI.B Acceptance Criteria These new regulations require a licensee who fails either a Type A. B. or c test to submit a *corrective Action Plan' to the NRC staff for its review and approval. The plan would focus on the specific cause of the test failure. This is a new requirement which should be deleted from the regulations as unnecessarily duplicative. currently. when a Type A. B. or c test fails. an LER is written. That LER contains both the root cause of the failure and the proposed corrective action. 10CFR 50.73 is sufficient. The completeness of the LER makes unnecessary the submittal of an additional document containing the same information. such additional documentation serves a different purpose only if the Commission intends to use these plans to require actions beyond those currently taken. If this is the case. then this requirement is a potential major change in the regulations. Since the regulations do not provide a limit on the scope or type of these required corrective actions. there can be no basis for the Commission's cost-benefit justification of this requirement. In particular. no analysis has been provided to justify the costly increase in the frequency of Types B or c testing which could be accomplished only through mid-cycle plant shutdowns. The potential for such substantial cost increases requires that this proposal be clearly circumscribed and analyzed before being promulgated. III.B.(2).b.ii Type B Test This section combines the current regulations with commonly granted exemption requests. It requires that a complete airlock test at Pac be performed whenever maintenance involving the airlock's pressure retaining boundary is performed. Testing due to maintenance on airlock seals is not required because they are locally leak testable. The regulations should recognize that the

airlock equalization valve and the shaft seals for many types of airlocks are also locally leak testable. Past experience has shown that the overwhelming majority of airlock leaks are from the shaft seals or equalization valves. Except for structural leaks. the shaft seals. equalization valves and door seals are the only possible paths leakage for most types of airlocks. By performing full pressure local leak tests on those three locations. the total leakage out of the airlock can be determined. Total leakage measured in this manner will probably be more accurate than that measured from the complete airlock test. This is because the shaft seals are locally leak tested by pressurizing the volume between the inner and outer seals on both doors. This results in at least one of the seals on each door being pressurized in the proper direction. (from containment toward the outside). When a full airlock test is performed. only the seals on the outer door are tested in the proper direction. both seals on the inner door are tested in the wrong direction. Shaft seals have been shown to be particularly directional sensitive. In many past instances. airlocks have passed the full airlock test while failing the subsequent Type A test due to leaking inner door shaft seals. For the foregoing reasons. the regulations should be changed to: only require local leak tests on shaft seals or equalization valves following work on those areas. (for plants that have testable shaft seals and equalization valves). and allow local leak testing of the seals and equalization valves in place of full airlock tests. The above changes would increase safety by enabling the licensee to obtain more accurate airlock leakrates while minimizing testing time. Plants that don't currently have testable seals may be enticed by this rule change to convert over to them. Also. eliminating full airlock testing during plant operation would eliminate the risk of pressurizing the inner door off it's hinges due to improper or lack of strong-back placement.

III.C. (2)a Pressure/Medium This section makes no allowances for the reduced pressure testing of MSIVs in BWR plants. These tests are performed by pressurizing between the two angle valves. A full pressure test would lift the inner valve (pressure applied to the downstream side of an angle valve will ift the valve at pressures very much below the setpoint). Because there is no provision for this consequence, almost all the BWR plants will require major backfits or exemptions. Backfits cannot be justified and exemptions would be contrary to the intent of this rule to clarify regulations. Therefore, this requirement should be modified to provide explicitly for the reduced pressure testing of MSIVs in BWR plants. IV.A Special Leak Test Requirements This regulation requires that any modification, repair, or replacement of a component subject to Type B or Type C testing must be both preceded and followed by a Type B or C test. This requirement should be either deleted or severely qualified. The current regulations require testing after any modification, repairs, or replacements that may affect the sealing ability of the component. Prior testing is only required:

1) In a Type A outage, prior to the Type A test.

or

2) If the component is known to leak. However, 'As Found', local leak testing is not required if the leakage is known to be greater than La due to gross failures such as a stuck open isolation valve or a valve whose packing has blown out.

or

3) Within a specified time period prior to regularly scheduled Type B or c tests, (the component must experience some service life prior to testing).

Even if one or more of the above conditions were met,

         'As Found' local leak testing is not be required if the repairs, modifications, or replacements do not affect the sealing ability of the component. The current regulations in this area should remain in place.

To adopt the proposed regulations in their current form would result in a large increase in the number of Type Band C tests performed. The increased cost and personnel radiation exposure would have no offsetting increase in plant safety. This proposed change in the regulations is in effect a requirement to keep running totals of Type B and C leakage. In the past, running totals for Type A testing was proposed and then withdrawn because it could not be cost justified. This is the same kind of requirement and it should be withdrawn for the same reasons. Local and integrated leak tests are spot checks, not a running totals that must be continuously updated. The proposed regulation has not been and cannot be properly justified on a cost- benefit basis.

ATTACHMENT B Comments on Proposed Regulatory Guide MS-021-5 2* Type A Test Reguirement This position requires the inclusion of instrument system error in the local leakages used to correct Type A test results. Inclusion of this small effect in the calculations and reports cannot be justified because local leak testing equipment typically is accurate to only a few percent. Moreover. the inclusion of such small effects is not justified when results of the new source term study indicate that our current allowable leakrates are already much too conservative. Therefore. because this requirement would not benefit public safety, it should be deleted. 6* Verification Test Zero-pressure testing should not be required. Zero-pressure testing requires over four hours of critical path time but yields no additional useful information. Zero-pressure testing has never been shown to be useful by any valid technical study. Because zero-pressure testing is technically flawed, it should be abandoned.

8. Type Band C Test Pressures At almost all Boiling Water Reactors ("BWR"). the Main Steam Isolation Valves ("MSIV") are angle valves.

They are leak tested locally by pressurizing between them. Testing the MSIV at full pressure would lift the inboard valve. Therefore. a requirement of full pressure testing could be implemented only after major backfits. such backfits could not be justified under the backfit rule.

9. Type Band c Test Schedule These two positions would permit the test intervals to be extended during periods when containment integrity is not required. Such an extension provision has long been needed and would remove the need for many of the current requests for exemptions from Appendix J. Unfortunately.

these positions are in direct conflict with sections III.A.3 and III.B.l of the proposed Appendix J. Accordingly. these sections of Appendix J should be amended to provide for the extension of test intervals.

11. Calibration These requirements for instrument calibration are unnecessary. Experience shows that the instruments are very reliable and stable. Instruments sent out for recalibration after storage for years prior to a test usually meet calibration standards in their as found condition. Instrument failure almost always has been due to the failure of a cable or connector; not calibration errors. Therefore, instrument failure modes are easily observed because they cause a rather obvious massive failure. These circumstances show that the calibration requirements wou l d not substantially improve instrument precision. Accordingly, the calibration requirements should be deleted.

12. Containment Atmosphere Stabilization These additional requirements will substantia l ly increase testing time and costs. The effects of transient atmospheric conditions on the final test results depends on the speed of the transient, the containment geometry, and the ability of the instrumentation system to model transient conditions. The magnitude of errors induced by transient effects upon the final results are not known.

The 0.SOF/hr/hr criteria specified may be well below the fastest transient that most plants can handle. Therefore, it is premature to specify an exact numerical acceptance criteria in the regulations. Rather, the procedures and criteria for dealing with transients should be left up to the judgment of those performing the tests. The stability of calculated dry air mass points, and not the average air temperature, is the appropriate evaluation tool. The licensees should establish their own plant specific maximum acceptable scatter of dry air mass points during the test and slope at the end of the test. The verification test is the ultimate indicator of containment stability, especial l y in PWRs.

14. Temperature Measurement For the following reasons, we question the validity of performing temperature surveys using the ventilation configuration for the Type A test and the requirement to re - run a survey for the first periodic Type A test due to different heat sources from Pre - Op conditions.

No good comprehensive technical study has every shown a quantitative relationship between temperature distributions and calculated containment leak rates. The small modeling errors resulting form ignoring the above requirements would probably have a trivial effect on final calculated leak rates. Moreover, the failure to ventilate continuously could result in great personal safety hazards to those making temperature surveys. In recent tests, temperatures of 1250F have been measured in BWR containments in which the ventilation system was turned off to simulate test conditions. Moreover, when the Type A test is performed at the start of the outage, the failure to continuously ventilate could result in nitrogen (inerting medium) pockets. These potential safety hazards show that survey requirements must be supported by comprehensive technical studies which establish a clear relationship between temperature surveys and leakrate calculations.

20. Recording of Leakage Rates Accounting for packing leakages outside the primary containment is a major backfit, especially in BWR plants.

Many containment isolation valve pairs have to be tested by pressurizing through a test tap between the two valves. But for some valve designs, the packing on the inboard valves does not experience the test pressure. Therefore, to account for packing leaks, test taps and/or block valves would need to be installed in containment. The costs of such modifications cannot be justified, especially in light of the frequent testing of the packing by Type A leak tests. APPENDIX: This modification to the Mass Plot Method would allow the performance of Type A tests for periods shorter than 24 hours. However, all Type A tests, including the shorter tests, would also have to meet two new conditions for passage. These additional conditions should not be required. There is no (nor has there ever been shown) any need for additional conditions on curvature and scatter. The Mass Plot Method has proven itself to be an accurate and reliable method in its current form in hundreds of tests over the last ten years. Therefore, there is no need for additional conditions on curvature and scatter. Moreover, because the two additional conditions are unnecessarily stringent, they would result in the failure of many valid Type A tests. For these reasons, the proposed conditions should not be required.

REGULATORY ANALYSIS: A separate regulatory analysis was not prepared for this draft regulatory guide. A full and complete analysis should be performed. This would include a cost-benefit and backfit analysis. In order to insure an objective study, the NRC should contract out the analysis to an impartial organization that has no ties to the authors of this Reg. Guide. Moreover, to the extent that the regulatory guide is based on ANSI 56.8, that ANSI Standard also should be subjected to the same vigorous regulatory analysis. 2601K

                                                                                     '87 J~N 27 P1 :SB Florida                                                                               GFF DOC Power CORPORATION January 23, 1987 3F0187-21 Mr. Samuel J. Chilk Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Comments on Proposed 10CFR50, Appendix J, Leakage Tests for Containments of Light-Water Cooled Nuclear Power Plants (51 Fed. Reg. 39538, 10/29/86)

Dear Mr. Chil k:

Florida Power Corporation (FPC) has reviewed the proposed rev1s1on to 10CFR50, Appendix J, Leakage Rate Testing of Containments of Light Water Cooled Nuclear Power Plants. The comments that follow have been generated as a result of this review. FPC would like to direct the Commission's attention to the inadequacy of the backfitting analysis which accompanied the rule. While the draft backfitting analysis appears to address the pertinent factors under Section 50.109(c), it concludes that no substantial increase in protection "can presently be quantified from the proposed back fit." We emphasize that if the "substantial increase" determination cannot be made, then the Commission may not, consistent with its own regulations in Section 50.109, impose the backfit as a requirement on licensees. It is not clear from the analysis, however, whether consideration was given to all relevant and material nonquantifiable factors in assessing whether the "substantial increase" standard has been met. As explained above, the Commission is empowered to tailor any given backfitting analysis to the particular change under consideration by evaluating both quantitative and qualitative factors, and that the risk reduction aspect of the proposal need not necessarily be strictly quantified as with a probabilistic risk assessment. It appears, therefore, on the present record, that the proposed rev1s1ons have not yet been shown to meet the substantial increase test. This being the case, FPC would encourage the Commission to withdraw this revision. In evaluating the NRC questions in the NPRM, we were concerned to see question (5) which appears to ignore 10CFR50.109. GENERAL OFFICE: 3201 Thirty-fourth Street South

• P.O. Box 14042
• St. Petersburg, Florida 33733 * (813) 866-5151 A Florida Progress ComP. ¥no d d b cercJ - £...EB !_

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 ,January 23, 1987 3F0187-21 Page 2 The purpose of 10CFRS0.109 was to insure any requirement changes were carefully evaluated before imposition on a licensee. To question in a NPRM whether 11 present operating plants should be given the opportunity to continue to meet the current Appendix J provisions 11 , indicates to FPC that the provi s i ans of the back fit rule are being ignored by the Staff in preparation of new requirements.

Many of the changes in the proposal provide administrative improvements by eliminating conflicts, ambiguities, and lack of uniformity in the regulation. However, while the background information in the Federal Register Notice states 11 the scope of this revision to Appendix J is limited to corrections and clarifications, and excludes new criteria 11 , the proposed change does include an additional requirement which does not appear to have been addressed. Specifically, the change of the definition of Containment Iso1 ati on Valve ( CIV) appears to be inadequate. The proposed definition references General Design Criteria (GDC) 55, 56, and 57 of 10CFR50 Appendix A. As a result, utilities whose CIV designs do not meet (nor were ever required to meet) GDC 55, 56, or 57, due to the vintage of their plants; but have been previously approved by the NRC, would be required to make significant modifications to their plants. Since the backfit analysis presented in the NPRM does not meet the requirements of 50.109, FPC would regard this changed requirement as a 11 backfit 11

• The Federal Register Notice also indicated that this proposed rule change was designed to provide greater flexibility for licensees to apply the requirements of Appendix J.

The intent was to minimize the number of exemptions requested by licensees. In view of this, it is recommended that leakage testing intervals be provided tolerances to account for scheduling and operational considerations. One method would be to allow a maximum extension not to exceed 25% of the test interval for Type A, B, and C tests. These extensions could be restricted to only those plants whose previous leakage history justifies the extended period. This would allow much greater flexibility while still meeting the intent of the regulation. - Florida Power Corporation is a member of the Nuclear Utility Backfitting and Reform Group (NUBARG) which is also submitting comments on this rule. We support the co111T1ents provided by NUBARG which are in response to the separate views of Commossioner Bernthal on the proposed rule. We are providing suggested wording to help resolve our concerns on CIVs and Test Intervals in Attachment 1 and 2. Should you have any questions regarding these comments, please do not hesitate to contact this office. Sincerely, 2e~ E. C. Simpson Director, Nuclear Operations Engineering and Licensing DGG/JWT / jk Attachments

ATTAClf'1ENT 1 Wording Change to Appendix J Definition of Contaiment Isolation Valve (Suggested wording changes are underlined to facilitate identification) Suggested wording: II Definitions Containment Isolation Valve Any valve defined in GDC 55, 56, or 57 of Appendix A "General Design Criteria for Nuclear Power Plants," to this part or any valve which is relied upon to perform a containment isolation function in accordance with the design previously reviewed and approved by the NRC. Justification: The proposed definition would require utilities whose containment isolation valve designs do not meet GDC 55, 56, or 57 to make significant modifications to their pl ants. By altering the definition with the suggested wording above, the definition is clarified without requiring earlier vintage plants to make modifications.

ATTAC1-14ENT 2 Wording Change to Appendix J regarding Test Intervals (Suggested wording changes are underlined to facilitate identification) Suggested Wording: III.A.(3) Test Frequency Unless a longer interval is specifically approved by the NRC staff, the interval between the preoperational and first periodic Type A tests must not exceed three years (with a maximum allowable extension not to exceed 25% of the test interval), and the interval between subsequent periodic Type A tests must not exceed 4 years (with a maximum allowable extension not to exceed 25% of the test interval). III.A.(8)(b)(i) Regardless of the periodic retest schedule of III.A.(3), a Type A test must be performed at least every 24 months (with a maximum allowable extension not to exceed 25% of the test interval

• III.B.(l)(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 (with a maximum allowable extension not to exceed 25% of the test interval

• III.B.(3)(a) Air Locks 4t Initial and periodic tests. Air locks must be tested prior to initial fuel loading and at least once each 6-month interval (with a maximum allowable extension not to exceed 25% of the test interval) thereafter at an internal pressure not less than Pac* Alternately, if there have been no 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, with a maximum allowable extension not to exceed 25% of the test interval). Reduced pressure tests must continue to be performed on the air 1ock or its door seals at 6-month intervals (with a maximum allowable extension not to exceed 25% of the test interval
• III.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 (with a maximum allowable extension not to exceed 25% of the test interval).

Justification: The above modifications to the proposed rule would make the required test frequencies more flexible for plants. Additionally, the new rule, as stated, does not appear to take in to account plants which will soon be operating with a 24-month refueling interval. Theoretically, a plant on a 24-month refueling outage can just meet the four and two year requirements. However, the proposed minimal tolerances would provide all plants, including those plants on a 24-month refueling interval, additional flexibility for scheduling and operational considerations. The allowable tolerance would be in accord with both the maximum allowable extension for Surveillance Requirements as well as ANSI/ANS-56.8 - 1981 which allow a 5 year frequency for Type A tests. JOCf((T NIMIDPR-:;tJ ' { 5/ ,=.,e, ~-:-ci=--

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[7590-01 1 DOCK[ Tl . t/ "lf<C NUCLEAP REGULATORY COMMISSION 10 CFR Part 50 "87 JAN 20 P2 :QS Leakage Rate Testing of Containments of Light-Water-Cooled Nuclear Power Plants; Extension of Corrment Period uf ll ~ , OC ETI,~

• J N

AGENCY: Nuclear Regulatory Conmission ACTION: Proposed rule; e~tension of comment period.

SUMMARY

On October 29, 1986 (51 FR 39538), the Nuclear Regulatory Conmission published a proposed revision to its requirements for leakage rate testing of containments of light-water-cooled nuclear power plants as set out in Appendix J to 10 CFR Part 50. The comment period for this proposed rule was to expire on January 26, 1987. Several potential corrmentators requested an extension of this comment period because of significant aspects of the proposed rule that require detailed review. The NRC has evaluated these requests and agrees to extend the comment period for this proposed rule.

DATE: The comment period is extended to April 24, 1987. However, the NRC encourages early submittal of comments to expedite completion of this rule-making action. e ADDRESSES: Mail written comnents to: U.S. Nuclear Regulatory Comnission, Washington, DC 20555, Attention: Docketing and Service Branch. Deliver comments to: Room 1121, 1717 H Street, NW., Washington, DC, between 8:15am and 5:00 pm Federal workdays.

FOR FURTHER INFORMATION CONTACT: Mr. E. Gunter Arndt, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301) 443-7893.

                                ~

Dated at Washington, DC, this IL ~ day of January 1987. For The Nuclear Regulatory Commission: 11/41_.;~ he Commissi~

Bechtel Power Corporation Eng ineers-Constructors coc\( [ T[::

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Fifty Beale Street San Francisco , Califo,eil., f'l 1 1 P12 :()8 Mail Address: P 0. B9x' 39J, 'San Francisco, CA 94119 January 9, 1987 U.S. Nuclear Regulatory Connnission Attention: Docketing Sei:vice Branch Washington, D.C. 20555 SUbj ect: Proposed Rule and Reg. Guide Leakage Rate Testing of Containments for Light-water-cooled Nuclear Power Plants 10CFR50, Appendix J Draft Regulatory Guide M.5021-5 Gentlemen: This letter constitutes our conunents on the proposed rule and regulatory guide. General conunents and overall conclusions regarding the new docrnrents are presented in this cover letter. Attachment A contains specific comments on the proposed 10CFR50 Appendix J, and attachment B provides specific conunents on proposed Regulatory Guide MS 021-5. Attachment C is a detailed discussion of problems in using the Extended ANSI method of analysis with Integrated Leakage Rate Testing and reconnnends an alternative analysis method. Generally, we support the Nuclear Regulatory Conunission's initiative to eliminate detail in Appendix J and endorse the ANSI/ANS standard through the use of a regulatory guide. In addition, certain content of the proposed rule, such as definitive explanations of teD!lS such as minimum and niaxirnum pathway leakages, -which have caused considerable confusion in the recent past, are clarified. Raising the allowable limit to 1.0 Ia for "as found" conditions will place the testing program in better perspective and resolve a number of problems which have arisen since IE Notice 85-71 established the new rules for "as found-as left" testing requirements. The proposed rule also sei:ves to fo:nnalize the IE Notice testing and reporting requirements, which will solve the questions raised over using an IE Notice to make rules. Uncoupling the Type A test frequency from the 10 year ISI, and pennitting short or reduced duration testing in accordance with current technologies will further enhance the testing programs for many plants, as will the refocusing of corrective action, if it occurs as planned following test failures. JAN 15 1987 5026 SUM058 1

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Bechtel Power Corporation However, despite these obvious advantages to the proposed rule, some significant new provisions may require that some utilities perfo:rm major retrofits to comply with the rule as written. In particular, the definition of :minimum and maxinn.nn pathway leakages, reporting requirements for Type Band C failures and the requirement for single active failure analysis to be used for Type Band C testing criteria all point to a necessity to be able to test each valve individually. For many plants this will mean the addition of multiple block valves and test connections, as well as vents arrl drains, on lines penetrating containment. 'Ihe expense of these retrofits and the outage work required to comply may prove to be a significant problem in the implementation of the new rule. As a result of the "as found-as left" requirement, we expect that a significant number of "as found" test failures will result. From what we have seen applying :minimum arrl maxinn.nn pathway analysis to recent IIRIs, the "as found" failure often results from the inability to test each valve individually or in selecting the wro~ valve of two in series to repair first, making luck a far bigger factor than it should be in detennining a "paper value" for an "as found" test. Correction of this problem requires the same extensive retrofit program as mentioned earlier. Containment isolation systems were designed to be tested in a certain manner, based on requirements existing at the ti.ma the plant was licensed. By changing or re-defining requirements and requiring compliance, a tremendous amount of confusion results. 'Ihis confusion is obvious from the reaction to m Notice 85-71, which addresses only one aspect of the Apperrlix J revision. The asSlilllption that the impact of the increased frequency of failures can be lessened by increased Type B and C testing is unproven. There is no assurance that a corrective action plan calling for such increased testing will be approved or that, if approved, will not result in an increased number of outages for the sole purpose of these additional tests for a reason which may or may not have been valid to call a test a "paper" failure. Ll.censees now perfo:rm Type Band c tests every refueling outage or every two years. For plants on an 18-month refueling cycle, it is difficult to imagine a shortened Type Band C Test cycle which does not involve taking systems out of service and this may require shutdown.

    'Ihe draft regulatory guide contains similiar problems as discussed in Attachments Band c. The biggest problem foreseen with the draft regulatory guide is the mandatory use of the extended ANSI method during both the Type A test and the verification test. OUr experience in using this method of analysis is that the results are unpredictable and that the limits for verification test results are unrealistic. '!he use of single active failure criteria as a leakage rate testing requirement again poses the problem of testing each valve individually, with consequences as mentioned before. In addition, the requirement for restarting a test SUM058                                   2 5028

Bechtel Power Corporation only "time forward" can excessively delay test conclusion for reasons not warranted using state-of-the-art testing equipment and with the extensive testing experience found in licensee and contractor organizations. Based on the above considerations, and the statement in the proposed rule the Commission itself is planning a broader more comprehensive review of requirements in the next year or two, we nrust conclude that it is not the proper time to change the existing nu.es. The present test requirement, although difficult to interpret, is reasonably well understood by both licensees and inspectors. The ix>tential of the new rule to force the licensees into costly retrofit programs to assure compliance provides further reason not to change at this time. In addition, the regulations may change further before full compliance with these proposed rules is achieved. We reconnnend the Commission not issue the proposed rule and regulatory guide until the additional issues mentioned in the description of the proposed rule are resolved. Additionally, a very detailed review of the ilrpact nrust be perfonned. Licensees should then be given the option of whether or not to test under the new rules, or continue their test programs as initially designed and established. We would like to take this opportunity again to canunend the Commission for its efforts in attenq:rt:ing to clarify and resolve the problems associated with contai.rnnent leakage rate testing. 'lhe proposed nu.es have meet most of these objectives. However, uncertainties in interpretation and the i:x>tential for unwarranted, extensive retrofit programs are subjects which should be addressed further before the final n.Il.e is issued. Questions regarding the content of this comment document should be directed to Mr. Fhilip J. Galanti at (415) 768-8648. Very truly yours,

                                            \K~~

R. P. Schmitz ) Manager, Nuclear Engineering RPS:RJG:kep Attachments SUM058 3 5028

A'ITACHMENT A SPECIFIC COMMENTS ON PROFOSED RUIB APPENDIX J TO 10CFR50 Part I - 'Ihe Specific Requested Comments in the "Invitation to comment". Question Number Comments (1) (2) (3) (4) (7) See Table 1 Table 1 COMMENT QUESTION NUMBER APP J (1) (1) (2) (3) (7) (4) SECTION CHANGE? EXTENT USED NOW DESIRABILITY NEED BACKFIT III.A. (1) NO ALL HIGH HIGH NO (2) NO ALL HIGH HIGH NO (3) YES NONE HIGH HIGH NO (4) YES MOST HIGH HIGH NO MED (5) NO ALL HIGH HIGH NO (6) NO ALL row row NO (7) YES MOST MED MED YES HIGH (8) YES SOME JMED MED NO HIGH (9) NO ALL HIGH HIGH NO III.B. YES SOME HIGH HIGH NO III.C. YES SOME HIGH HIGH NO YES MOST HIGH HIGH NO V.A. NO ALL HIGH HIGH NO V.B. YES SOME MED MED NO VI.A.l. YES MOST HIGH HIGH NO VI.A.2. YES SOME row r.ow YES JMED VI.B. YES SOME MED MED NO HIGH VII. YFS N/A row r.ow YES HIGH Question Number Comments 5 Present program is generally adequate and understood by licensees and contractor personnel. 6 Most would not use proposed rules because of possible retrofit requirements and the Extended ANSI Criteria. Present rules would be generally accepted as currently interpreted except for "as found-as left" recent interpretation. 8 In present fonn, the proposed rule should not be issued. 9 Good. 10 Data collection per se should not be a licensing requirement. Acceptance criteria for an as found condition should be able to allow for one-time SUM058A A-1

Question Number Corrnnents (cont'd) 10 hap:penings, such as changing valves, without pretesting. Also, Type B "as found" testing on double a-ring seals, if the seals have not been disturbed, should not be required. 11 Yes; the extent of possible relaxation is dependent on recognizing the extreme conservatism in both source tenn definition and off-site dose calculations. 12 Severe accident conditions and a I.DCA testing requirement are totally different problems. If Appendix J were to t:cy to address severe accidents, it is doubtful any plants would be allowed to operate, because of design limitations. 13 Contirruous leakage testing for gross. leaks should be considered, and if demonstrated feasible by a licensee, replace the Type A test requirements. 14 The "leak before break:"' assu:rrption would reduce expected: leakage, and if thoroughly analyzed, probably lower accident pressures and source tenns and increase allowable limits. 15 The sum of Type B aI)d C testing not exceeding ;,6 Ia appears adequate. The testing requirements It1U.St be seen from a global perspective, and the interaction of acceptance criteria serves to assist in the goal of increased public health and saftey. Part I i - Specific comments on Appendix J, 10CFRSO. Section Connnent II-Definitions consider including GOC 55, 56 and 57 of Appendix A to 10CFR50. II-Definitions F.d.itorial - Verification Test is fo:nnatted incbrrectly. III-General The commission should consider the use cif 11 sball 11 rather than "must" for consistency with codes :a:na. standards.

• III-General leak Test Requirements A(4) Test pressure must not exceed contairnnent design pressure. For some contairnnents, Pa > re but :_is less than the maximum allowable contairnnent pressure, e.g.,

Hatch Nuclear Plant Units 1 and 2. Wording should be changed. to allow pressure up to a maximum allowable SUM058A

Section Comment (Cont'd) A(4) (or equivalent wording) pressure. A(6) can be interpreted to mean the preoperational test does not require a verification test.

• A. 7.c. (i). All potential leakage paths are locally leak tested.

                 'Ihi.s will require retrofits to all0vi1 testing individual valves and will require additional leak testing to test each valve with attendant additional radiatioh
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A.7.c.(ii). ,.., ..1..u-:, " * *

• must be quan't'f'ed The W0....,...,.:i;,...;... le l. * *
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rigorous. Some penetrations can not be tested *. accurately with the contaimnent at test pressure, and, if so, this would require complete depressurization. The words 11 * *

• must be quantified to the extent feasible *.* " should be used.

A.8.a,b. Requires "as found," leakage rate with Corrective Action Plan if leakage exceeds 1.0 I.a. IE Notice 85-71 indicates intent is to use more :frequent Type :s* and c testing to assm-e containment integrity. Paragraph III.A.8.B says :that two consecutive "as found" Type A failures will require a Type A test at least e:very 24 months or refueling outage until two consecutive successful Type A tests are perfo:rmed. An alternative is all0vi1ed but the acceptability of such an alternative will be subject to interpretation. III.B.4.a. The sum of the "as found" Type Band C test results should be able to exceed 0.60 Ia as long as the "as found" Type A result is less than I.a. Only the "as left11 Type Band C results should be subject tq the 0.60 I.a maximum. . III.c. 'Ihis paragraph refers to a qualified water seal system, but it does not state the requirements of such a system. IV. Special leak Test Requirements IV.A. This paragraph requires an "as found.YI test to be performed prior to any modification, repair, or replacement. CUrrent understanding of NRC requirements by utilities and AE personnel is that "as found" testing is required only during refueling outages, not during forced or other maintenance outages. 'Ibis new requirement will have a la:rge impact on maintenance activities and will increase radiation exposure to personnel. Data collection should not be the '.prime . reason for conducting surveillance activities .. SUM058A A-3

Section Comment VI.A.2. 'Ibis paragraph may be. interpreted t0 mean that each contairnnent barrier (e.g., valves, flexible seals) has a separate acceptance criterion. 'Ihe only stated acceptance criteria are that Type Band C total leakage must not exceed 0.60 Ia and 11as found.-as left" Type A results must not exceed 1.0 Ia and 0.75 Ia, respectively. SUM058A A-4

A'ITAOIMENT B SPECIFIC roMMENTS ON PROrosED RmJIA'IDRY GUIDE MS021-5 Section Comments 3 Inleakage, if properly accounted for, should be allowed. 6.1(6) 'lhe containment atmosphere may have been distu:t;bed significantly by sample taking or other activities at the end. of the test. To include th.is additional time adds an unwarranted penalty. Data should be collected during th.is period, and reported. if necessary to show the disturbance. 6.1(7) '!his section should allow deletion of data sets not representative of I.am, such as water invento:ry changes or air sampling done between the *end. of the Type A test and the beginning of the verification test. 10 By applying this rule, URI' instrumentation must be calibrated to NBS standards evffi:Y' day, or at frequencies which will assure minimum retest liability. 12.1 Is there a time limit for which the UCL should, be equal to zero or will a single data set suffice? 12.2(b) 'Ihe statement 11 * *

• the rate of change of the slope of the temperature versus time curve ... averaged over th,e last two hours." can only be approx:irnctted because IIRI' data are discrete and not continuous. What appro~tion is acceptable?
• 12.3 Can this criterion be used. to reject a single data point due to a temperature outlier?* Experience points to a conclusion that the temperature is changing to** such a great extent the UCL will be unacceptable because of scatter. '!he paragraph adds another acceptance criterion to all tests.

13.1 can start time be time backward? The paragraph states

        "* .. restarted ... 11 In any case, start time should be representative of the actual leakage rate, not a time chosen a:mitrarily in the future. As an example, sensor ma.lfunctions may not be apparent until hours after the end. of pressurization, and, once the sensor is' deleted:

from calculations, the leakage rate appears stable and acceptable. In such a case, the time that has*cpassed should be allowed to be included. in the test. ** SUM058B B-1

section Cormnents 13.3 This paragraph is covered in some detail in the. following Attachment C. Generally, equation 1.1 is a poor test for linearity, it is erratic and may :be satisfied by data being more cubic than linear. , F.quation 2.1 should not apply to the verification test due to the allowable shorter duration of the test. Alteni.ately, if the 2.1 equation is used, its limit should be doubled. 14.2 Since sensor reassigrnnent must be based on the , temperature survey, at least a survey check to revalidate the first periodic test su:rvey temperature distribution should be required before each test. SUM058B B-2

ATI'AOJMENT C . CXM-1ENTS ON .THE "EXTENDED ANSI" A<X!EPI'ANCE CRITERIA OF PROFOSED RmJIA'IORY GUIDE MS021-5 Proposed Regulatory Guide MS021-5 introduces two statistical tests that must be satisfied by the containment ainnass vs. time data during tl,ie 'fype A and verification tests. The first test sets an upper limit on the curvature of the data, and. the second test sets an upper limit on the data scatter. In order to evaluate the above statistical tests they have been applied to data from 14 actual 'fype A tests. Figures 1-14 a, b, and. c show plt>ts of ainnass and. parameters al, a2, and b for the 14 cases where: right hand side of equation 1.1 al= left hand side of equation 1.1 right hand side of equation 1.2 a2 = left hand side of equation 1.2 left hand side of equation 2.1 b = right hand side of equation 2.1 For these ratios, equations 1. 1, L 2 and 2.1 are the statistical ti!pts presented as are the equations in the proposed Regulato::r:y Guide.

• Values of al, a2 and. b in the plots which are attached are clipped for values greater than approximately 2. The acceptance criteria for the statistical tests in tenns of al, a2, and b are:

1. al andjor a2 < l

2. b > 1 Condition 1 sets a limit on the curvature and condition 2 sets a limit on the data scatter.

The statistical tests were originally applied for 16 cases in Reference 1. (cases 10 and 15 of the 16 cases studied in Reference 1 are not considered here because the program used in this study cannot correctly use tlleir databases) . In Reference 1, the original NRC fo:rmulation of equation* 1. 2 was used, i.e. !c't/A' I < 0.25 as apposed to the revised criteria 2400 Ic' t/B' Ia I < o. 25. The paper concludes that the statistical tests on the curvature exhibit "eratic behavior (and) complicate the analysis of II.RI' data also, the method is "too complex". Reference. L Iarry R. Young "Method for Determining Integrated leakage

• Test D.rration - case Studies". Proceeding from the Third Workshop* on Containment Integrity "NUREG/CP - 0076, SAND86 - 0618, August 1986:.

SUM058C C-1

'!he general trend observed in Figures 1 - 14c are,

1. Parameters al and a2 are very erratic and do not progress from a no pass region, >1, to a pass region, <1, with any obvious*

predictability.

2. Parameter b behaves smootbly and prcxJresses from .a no pass region,

        <1, to a pass region, >1, predictably.

• Beca.use of the erratic behavior of the al and a2 parameters, the proposed limit on curvature is not a reasonable condition to place on the Type A test.

Applying these same criteria to the verification test suggests that the duration of the verification test should be approxima.tely the same*as the Type A test duration. Since the verification test duration is nonnally not greater than half the Type A test duration, the new extended ANSI criteria should be relaxed or eliminated for the verification test. An additional a:rguement against the use of the limit of curvature criteria is that satisfying equation 1. 1 does not necessarily indicate that the data are linear. CUbic regressions were applied to the 14 cases studied above, and Figures l - 14d present plots of the quadratic and cubic contributions to the data. As can be seen, in general small quadratic tenns indicate that the cubic tem is la:rger. According to Bethea, Reference 2, a general rule is for detennini.ng significance of higher order regressions is to include higher order tenns ootil two consecutive tenns are . insignificant, i.e., quadratic and cubic, not just the quadratic tenn as required by the proposed Regulato:ry Guide. To summarize, the only criteria of those presented that should be . considered is to apply the limit on scatter condition to the Type A test and neither condition (as currently proposed) to the verification test. By itself, the limit on scatter test is fairly easy to pass. It is therefore recommended. that an additional acceptance criteria be adopted. Reference 1 reaches the conclusion that the predictor of Reference

• 3 be used. Since the NRC choose not to incorporate this method in the proposed Regulato:ry Guide it is 11ot clear that the predictor would be accepted as an alternative to the limit on curvature test. Therefore, the follCMing "window test. is proposed as an alternate. '!he wind.ow criterion would require that the leakage rate calculated for all intervals equal to 1/2 the test duration must be iess than
• 75 Ia. Windows of 1/3 the test duration were also considered. in evaluating the method.

Reference 2, Bethea, R. M., Duran, B. Srici Boullion, T. L., "stati$tical Methods for Engineers and Scientists" 2- Edition Marcel Dekker, Inc., New York 1985. Reference 3 "SUggested Criteria for a Short Duration IIRr", Ted Brown and Louis Estengsoro, Wiss, Janney, Elstner and Associates, January 18, 1982. Presented at Reactor Operations Division, ANS, First Workshop on .* Containment I.eakage Rate Testing. SUM058C C-2

Figures 1 - 14e and f present plots of the mcnd:mum leakage rates for windows equal to 1/3 and 1/2 of the test duration. The criterion is satisfied if the mcnd:mum window leakage rate is less than .75 I.a. For example, in Figure 7f (window= 1/2 test duration) the criterion is first satisfied at 0100 606, or a duration of 16.5 hours. For this duration, the mcnd:mum leakage rate for any 8.25 hour interval in the ra.ng-e 0830 605 to 0100 606 is . 088%/day (. 75 I.a = . 090%/day) *

• Figures 1 - 14e and f indicate that both window criteria behave smoothly and progress from a no pass region, > *75 Ia, to a pass region, < *75 I.a, is predictable. '!he slight st;:epping character of the plot is caused by truncating the window to correspond to the interval between data points.

Table 1 lists the intervals over vmi.ch the 1/2 and 1/3 of test durat::ion window criterion is satisfied, and also the intervals over vmi.ch the NRC proposed limit on curvature (al, a2,) and limit of scatter (b) are satisfied.

• Table 2 presents minimum test durations (> 8 hrs.) for the MS021-5; 1/2 and 1/3 duration wind.ows plus equation b; and the predictor plus equation b methods. The following points should be noted. about the :

results in Table 2*.

1. MS021-5 and the 1/2 duration window plus b criteria pass and fail the same tests, with MS021-5 giving shorter test durations.*

2. The predictor plus b criteria pass, case 6 a case which is failed by the other 3 criteria.

3. While case 8 is failed by the 1/3 duration window plus b and the predictor plus b criteria, it is reasonable to assume that they would have passed the test at same point after the 9 hours of test data.

4. The 1/3 duration window plus b criteria fail cases 5 and 16, vmi.ch are passed by the other 3 criteria.

While the test duration criteria of MS021-5 give the shortest test* duration, the criteria are also the least predictable. The lack of predictability could lead to serious consequences if the criteria results change from pass to no pass immediately before imposing the verifitjltion flow. The licensee could then find itself in a position of having *imposed the flow for a test that hasn't passed the acceptance criteria.

• From the studies conducted with the extended ANSI method, both the ,current and previous versions, it is Bechtel's conclusion that consideration should be given the 1/2 window and predictor criteria as additional criteria to satisfying test requirements, rather than the Extended ANSI method of MS021-5. The fonnulae and derivation of the equations used are on file in Bechtel* s san Francisco offices, should you require more infonnation.

SUM058C C-3

TABIE 1 CRITERIA SATISFACI'ION RANGES (HOURS OF TEST) (includes UCL< . 75 Ia) MS021-5 Window (Minimum 4 hours) al and/or a2 ___Q_ 1/2 duration 1/3 Duration 1 3-4 3-24 4 1/2-24 6 3/4-24 6 1/2-24 2 3-10 2 1/4-24 4-24 7 1/2-24 12-12 1/4 13-24 3 12 3/4-15 3/4 NS NS NS 4 1 3/4-3 3/4 2-24 4-24 5 1/4-24 - 5 6 4-24 1/2-4 1/4 12 3/4-24 NS 3-24 21-26 1/2 4-5 21-24 NS 4 NS 7 12 1/4-17 4 1/4-5 16 1/2-30 1/2 24 3/4-30 1/2 17 3/4-28 12 1/2-30 1/2 8 2-6 1/2 3-9 4-9 4 1/2-6 1/4 8-9 9 11/4-10 1/2-10 4-10 4-10 10 11 1 1/2-3 1/4 11/2-8 4-8 4-8 3 3/4-8 12 1 3/4-24 2 1/4-24 4-24 4 1/2-24 13 1 1/4 11/4 4-10 5 1/4-10 2 2 3/4-10 3 1/4-10 14 3 3/4-4 1/4 3 1/4-24 4-24 7 1/2-11 1/4 7 1/2-10 3/4 12-24 12-12 3/4 18-24 15 16 1 3/4-3 1/2 3 1/2 13 1/2-18 NS 8 3/4-10 3/4 9 3/4-25 18 1/2 16 1/4-25 22 1/2-25 NS= never satisfied. SUM058C

TABIE 2 . MINIMUM IXJRATION (> 8 HRS) 1/2 OORATION WINOOW 1/3 IXJRATION WINOOW PREDICTOR CASE MS021-5 PIUS B PIUS B PIUS B 1 8 8 8 8 2 8 8 8 8 3 NS NS NS NS 4 8 8 8 8 5 12 3/4 21 NS 11 3/4 6 NS NS NS 21 7 12 1/2 16 1/2 24 3/4 13 1/4 8 8 8 NS NS 9 8 8 8 8 10 11 8 8 8 8 12 8 8 8 8 13 8 8 8 8 14 8 8 8 8

*15 16      9 3/4          13 1/2                      NS            11 SUM058C

FIGURE 1-A

                                 *CASE 1

_ AIRMASS LBM X 1000

, 651 75 '**--")

I

            **---.~~

6 51 5 9 I "**-.****-... I.J'*-*~

                   ,              --.                -.._.. *---~:::tr-..
                                     --------.                          -~     **.   --~

651. 44 '-~....___ ------ 651. 28 ----._

                                                                                                 ............~....._

651.13 *---.

                                                                                                                        .._"\.~---.

650 m 97 ----....,__

• START TIME DATE END TIME FIGURE 1-B MASS POINT LEAHAGE RATE AND UCL - X/DAV

     .350
     .280
     .210
     .140                                        0.75 La
     .070
     .000.......,-,....__..----'-l'~~---~.-.rrr~~-'-ri-,.,......__.,.~

START TIME DATE END TIME DATE

FIGURE 1-C

                          -CASE 1 PARABOLIC INEQUALITIES al a2 h RATIO 2.000 1.600 1.200
  .800
  .400 START TIME DATE                              END TIME DATE FIGURE 1-D CASE 1 POLVNOMINAL TERMS 20.000 16.000 12.000

_t' i**J I',

                                                                                )

8.000 {

                                                                            .t~

4. 000 t

                                                                     ,...../

f r, CUBIC~/ .---***. **

 .000+-.--J,~.....:L-:t~~...i...,.~n-i-'l~rt--=.__..."-'-.ril-r-l~~~

START TIME DATE END TIME DATE

FIGURE 1-E MAXIMUM WINDOW LEAKAGE RATE

  .141
  .113
  .085
  .05?
  .028 FIGURE 1-F MAXIMUM WINDOW LEAKAGE RATE
 .113
 .091
 .068
 .045
 .023

FIGURE 2-A CASE 2 AIRMASS LBM X 1000 AND REGRESSION LINE 615.76 615.66 615.56 0.'75 La 615.47 END TIME DATE FIGURE 2-B . MASS POINT LEAKAGE RATE AND UCL - X~DA¥

   .100 0.75 La.
   .080~.-+----------------t
   .060
   .020
   .000r'x-l~~t':llnr"-.........r"lll'-r.l,.....,_rrx,~~--r,~lt--l-.......,.~

jSTA~T TIME DATE END TIME DATE

FIGURE 2-C

            . -CASE 2 PARABOLIC INEQUALITIES al a2 h RATIO 2.000 I_,./

V 1.600 1.200

 .800
 .400 START TIME DATE*                     END TIME DATE FIGURE 2-D CASE 2 POLYNOMINAL TERMS 10.000 8.000 6.000 4.000 2.000
  .000~~U-Ua~....._.....,....,r#lt.L.rr~~L.-l..~~__.__i,lw~

START TIME DATE END TIME DATE

FIGURE 2-E MA~IMUM WINDOW LEAKAGE RATE

   .129
   .103
   .052
   .026 FIGURE 2-F I

MAXIMUM WINDOW LEAMAGE RATE

   .0'75
   .060
   .045
   .030
   .015

FIGURE 3-A CASE 3

• AIRMASS LBM X 1000 506.69 506.55 506.47 506.40 FIGURE 3-B MASS POINT. LEAKAGE RA-TE AND UCL - Y./DAY

   .200
    ,160        \

1,..f,

    .120 1I~1 \I I        \
    . 080      \V/\\\ \

I I

                           '***, \*1 I *,

1, -...__

                                         *-                  --=-

• 040 0 . 7 5 L f*-------:::---=----
• 000_.....__................,,,._.....,._.i-r...,..,......,...........,~~~---+.....-.,_.~~

START TIME DATE END TIME DATE

FIGURE 3-C CASE :3 PARABOLIC INEQUALITIES al a2 b RATIO 1.600 1.200

 . 800
 .400 .

START TIME DATE END TIME DATE FIGURE 3-D CASE 3 POLYNOMINAL TERMS 10.000 8.000 6.000 4.000 2.000

  .000_.Mlll...-~'ll--'-~~ffllr'-"Tr.l!t'ri"-'l-x--i~..........,_.-,.~-

START TIME DATE END TIME DATE

FIGURE 3c..E MAX. WINDOW LEAKAGE RATE

   .230
   .184
   .138
   .092
   .0461----t----------------t FIGURE 3-F l MAXIMUM WINDOW LE~KAGE ~ATE
   .146
   .117
   .088
   .058
   .029

FIGURE 4-A 804.60 804.35 804.10 803.84 START TIME DATE END TIME DATE FIGURE 4-B MASS POINT LEAKAGE RATE AND UCL - X/DAV

  .200
  .160 .,___ _ _ _0. 75 La _ _ _ _ _ _ _---4
  .120
  .080
  .040
  .000 ........._____........,____,~~.......................- .............--..,.....~

START TIME DATE END TIME DATE

I , FIGURE 4-C START T_IME DATE END TIME DATE FIGURE 4-D CASE 4 POL¥NOMINAL TERMS 10.000 8.000 6.000 4.000 2.000 _r

                                             ~ I
     .000             ..\

START TIME DATE END TIME DATE

FIGURE 4-E MAXIMUM WINDOW LEAKAGE RATE

 .209
 .16?
 .125
 .083
 .042 FIGURE 4-F MAXIMUM WINDOW LEAMAGE RATE
 .150       I
             '7
 .120                  \_
 . 090                                          - .....-.
                                                                                 ---------i
 .060
 .030

FIGURE 5-A CASE 5 AIRM~SS LBM X 1000 AND REGRESSION LINE 792.34 792.23 *--..........,.._ -~--

                                       "71'
                                   ~-- -~~--.......
                                                         *0.75 La ..-~--.. .           '.

791.87 END TIME DA:TE FIGURE 5-B MASS POINT LEAMAGE RATE AND UCL - X/DAV I- .100

     .080~------------------1 0.75 La

FIGURE 5-C

                              -CASE 5 PARABOLIC INEQUALITIES al a2 h RATIO 2.000            -----i 7        ,i'----,.A--.,_ ___,l                              1 al 1

1.600 1 *\.\ 11 If

                                                  \_ _        l  ~

1. 200* I

             .I I 1:1.1**__,-,.._____...r--
                  ~ "
                                                    ~-4---

I

                                                        \:J i

I

 .400 START TIME DATE*                                             END TIME DATE FIGURE 5-D CASE 5 POLYNOMINAL TERMS 20.000 16.000 12.000 8.000 4.000
 .000~-i'-WL-:.A.TT"--~~.r.-.-'rftll-~~~-----..i,,,-;.--...._;._.,..~

START TIME DATE END TIME DATE

FIGURE 5-E

 .118
 .094
 .071
 .*047
 .024 FIGURE 5-F MAXIMUM WINDOW LEAHAGE RATE

• 0a 9 v,..-~.r "-'"'--~.

  .072
 .054
 .036
 .018

FIGURE 6-A CASE 6

~IRMASS LBM X 1000 834. 39 1 .

l_t, !834.21~

           .                  **-:::;i~

8 3 4 . 04 *-----<:::,-.:--,

                                                    --~"":,.
                                                           ;:c:,

833

• 87. .........,,.<--:~

                                                                                          ............- .      ~
                                                                             --**--*-***-._               I,, I **-.--*-,,*,,,*:

833 *69 0 . 7 5 La --....._..._-...--..~... 833.52 --' START TIME DATE END TIME DATE FIGURE 6-B MASS ~OINT LEAH~GE RATE AND UCL - X/DAY

    .500
    .400
    .300
    .200
    .0001/'-x-..................."WlC~-

jSTART TIME DATE

                                                    ...      "Thrl-rrXT~~~~---~~~

END TIME DATE

FIGURE 6-C CASE 6 PARABOLIC INEQUALITIES al a2 b RATIO 2.000 _ _ _ _ _a2 _ _ _ _ _ _ _ __ al 1.600 I ,.i l, 1: I

1

                                                                   *.L,*..                                                             ___,_...-- ,

_ _ _ _; - - -

• f

                                                                    "                                 -------                                      1
         '   {              :i
    ,. l!WI       :j'     ,JI      .,,

I

(

     , 400              '
    . 000 Jl-flf!"* .........

l """-'-:IIE"'Jlr-:i------1........~-h-:.llt-rl',illlnlr"'----.i~~~lll:"!llir!-Jrl:--' START TIME DATE END TIME DATE FIGURE 6-D CASE 6 POLYNOMINAL TERMS 50.000 t, 1-1**.. 40.000 Ir \. QUADRATIC_,.,

                                                                                                          /
                                                                                                            .-,*-~

II \ / 3 0. 000 I l I -. II i' J 20 000 I' ~ /\ / 1

                                                              ~1.1            \.~ ,/

• 1111 I /* *, \_,,/(CUBIC

10. 000 Iii' ,'I I,**.... -----*,*** - ----------***.

I fJ l I *---* I

• 000 . /i *1 ,*

I START TIME DATE END TIME DATE

FIGURE 6-E MAXIMUM WINDOW LEAJtttGE RATE

 . 297 *
 . 238 .
 . 119
 .059 FIGURE 6-F MAXIMUM WINDOW LEAMAGE RATE
 .261      '-....,_
                     *-....,"\.,
 .209                           **-,-........
                                                          "\.,
 .157                                                           .
                                                                                 ----------c.._)
 .104
 .052

FIGURE 7-A CASE 1 AIRMASS LBM X 1000

392.09 392. 00.

391.90 391.80 END TIME DATE FIGURE 7-B MASS POINT LEAKAGE RATE AND UCL - Y./DA~

   .150
   .120  \
   .090
   .060
   .030
   .000~___.................,_-.'-'-+M..-.,,.r+Tftll-tr-'-~----....-......................

START TIME DATE END TIME DATE

FIGURE 7-C

                    -CASE 7 PARABOLIC INEQUALITIES al a2 h RATIO 2.000
                                                              -1 I*                              ai I* I},j                           I l      __.-

1.600 I I __.-"-1._ I 1 --1-- n I

                                  .I                   I~

I------f" I I ---- I I I LJF* I I 1.200 11 __.,"'11

                                         -'- - I             ,-,

11 I

                                                                         \ ,..,,,,**,1  1 I
                                                                                          /

I

   . 800
   .400 START TIME DATE FIGURE 7-D CASE 7 POLVNOMINAL TERMS 20.000 16.000 12.000*

8.000 4.000

   .000~~--~ril,l,A-.........~rt"fl~.,.....,r1/2w'1f!-~.......~---'-"'t~,.i-.J START TIME DATE                                                 END TIME DATE

FIGURE 7-E I I - . 1 MAXIMUM WINDOW LEAKAGE RATE

      .240
      .192
      .144
      * *096,____,____ _ _ _ _ _ _ _ _ ~------t
                                        ***~.
      . 048 FIGURE 7-F I MAXIMUM WINDOW LEAKAGE RATE
      .178
      .142
      .107
      .071
      .036

FIGURE 8-A CASE 8 AIRMASS LBM X 1000 AND REGRESSION LINE 611.60 611.56' 611.53 611.49 START TIME DATE END TIME DATE FIGURE 8-B MASS--POINT LEAKAGE RATE AND UCL - X/DAV

  .150
  .120
  .090
  .060
  .030 START TIME DATE               END TIME DATE

FIGURE 8-C CA-SE 8 PARABOLIC INEQUALITIES al a2 b RATIO 2 000 I / -.._ .. 1, 1'-.. . :i i, A / --t->I'*..... b a2 I I I *I 1 /' \ ,.) (.,r-.-*-i 1 6 00 I .I Ii I II / \, 11 \ f

                                                             '1/

1

                                                                                   .l I
                                                                                               \I
                                              ~

I ' 1! //

             ,,              1 :1 ,  /.              ._r . .,                 li

1. 200* *I 1 ' ' 'I *,.*1* I, f I

                                         '                             1.r                    ',
 .800
 .400 START TIME DATE                                                      END TIME DATE FIGURE 8-D CASE 8 POLYNOMINAL TERMS 5.000 4.000 3.000
                                          ~UADRAT IC~                                      /l
                                                  .                       ~/I 2.000                                     .                                           ,/ I cuBic ~ r-;~                                     1 I

l I I

                                                                                        '\

1.000 START TIME DATE END TIME

FIGURE 8-E MAX. WINDOW LEAKAGE RATE

 .096
 .038:
 .019 FIGURE 8-F MAXIMUM WINDOW LEAKAGE RATE
 .075
 .060
 .045
 .030
 .015

FIGURE 9-A CASE 9 AIRMASS LBM X 1000 AND REGRESSION LINE 653.11r--~z~~-v;;::;:*,~~-~;~,..;:-\-=--------7

                                           ---=~~ .
                                                        *-* * . . . . . ~--===. ~~..... --**-

653.09 **.,,* v-* 653.01

                                                      .  -~-

0

• 7 5 L~-----....,.

                                                                                         '°!*
                                                                                             *~--*~--

652 .84 *-.,*-.__

652.76 ~~.......... START TIME DATE

                        ~~-w~-------~~~~-.. . .                           END TIME DATE
                                                                                                                                 ~~~~

FIGURE 9-B MASS POI.NT LEARAC-E--RATE -AND UCL - X/DAY

    .200 a
    .120
    .080
    .040         I . .- .._     .__ -... -      __..- --__. - -                                :. - --------
                 ~_..      -**<.------~-*-- --=--------
    .000~~---,..,...,~----illrTT:nii.---mi:'rr.~-~-,-.:--..."T"-J..-~

START TIME DATE END TIME DATE

FIGURE 9-C

                         .CASE 9 PARABOLIC INEQUALITIES al a2 h RATIO 1.600 FIGURE 9-D CASE           9

. *pouY,NOM I NA L TERMS 2.500 2.000 1.500 1.000 I

                                  ,1/ ,II l ', .1' \**- . . . \I             1' V11             ',f I        1 ll
     .500             -1 ii I I _**--!

I I,' I It1 I I

                     / :f /                         1 1            .        /'

1

     .000          ./ I'**-. /                        1.......**** ***..*/
                                                        --~

jsTART TIME DATE END TIME DATE

FIGURE 9-E MAXIMUM WINDOW LEAKAGE RATE

 .150
 .120
 .090:
 .060
 .030 FIGURE 9-F MAXIMUM WINDOW LEAKAGE RATE
  .150
  .120
 .090
 .060
*. 030

FIGURE 10-A CASE 11 AIRMASS LBM X 1000 AND REGRESSION LINE 116. 45 ~-=-=--

              * --.__ .a::::---.:::--._.

116 . 3 9 . *--....___ -----=--==-=.:::--_

                                                     *--.. . ._...__                                                                 ---====...-=--.=:::;-__              --.:::,
                                                                     '*~-

115.33: ' ****--.... 0

• 15 La *--......

11:6

• 2 7 i *--.*..__

116 . 21 * ..................

• 116 .16 -.. . . .

START TIME DATE END TIME DATE FIGURE 10-B MASs-*-PoINT LEARAGE-*RATE AND UCL - X/DAV 1.000

    .600
    .400
    .200
    .000-.-.l"l'R'_:ll"':lllt'r---.......rftllr-rr_,.....---r,t-~a..,.,.--

START END TIME DATE

FIGURE 10-C

                              . CASE 11 PARABOLIC INEQUALITIES al a2 h RATIO 2.000 17           I     al 1.600                 II         /

J I I

1. 200.

jl I l I I I

                 .o!,       !   :1      -**
    .800 FIGURE 10-D CASE 11

,POLV NOMI NAL 1 TERMS 20.000 16.000 12.000 8.000 4.000

    .000.._~...1..-~~--_,&_..r,.,.r-'"h-'K'T'l".rw--~_..-----~___.

isTART TIME DATE END TIME DATE

FIGURE 10-E MAXIMUM WINDOW LEAKAGE RATE

   .?50
   .600 11150 FIGURE 10-F

MAXIMUM WINDOW LEAHAGE RATE

  .150
  .600
  .450 1---------- '

I ----------1

  .300
  .150 l

FIGURE 11-A CASE 12 AIRMASS LBM X 1000 AND REGRESSION LINE 566.01 565. 50' END TIME DATE FIGURE 11-B

MAss*-po1NT LEA:KAGE*- RATE AND UCL - Y./DAV

    .200
    . 160 1--.,........_ _ _ _0. ?5 La _ _ _ _ _ _- - - f
    .120
    .080
    .040
    .000JrT-iy_..~___...r-....._.,.:rirr~~~~..........,......"llll---'....------~

• START TIME DATE END TIME DATE

FIGURE 11-C CASE 12 PARABOLIC INEQUALITIES al a2 h RATIO 2.000 11'ii 1.600 Iill I

               ,*I a2 1.200
     .400 I

!START TIME DATE END TIME DATE FIGURE 11-D CASE 12 POLVNOMINAL TERMS 20.000 16.000 12.000 8.000 I I 1' 4.000 ~. 1' I CUB I C .......-,,

                                                                    ,.-.,* * *. /
    .000.ll-r-~~~~a..l-~~~r'i-xl,rNPW,-~T-:11r-Jlir-'-T-,nlit"J,r--J iSTART TI ME DATE                     END TIME DATE

FIGURE 11-E MAX . . WINDOW LEAKAGE RATE

   .172
   .137
   .103 .
   . 069*

FIGURE 11-F 1 MAXIMUM WINDOW LEAKAGE RATE

   .150
   .120
   .090
   .060
   .030

FIGURE 12-A CASE. 13 833.85 833.80 833. 75:I DATE FIGURE 12-B MASS 'POIMT LEAKAGE RATflr AND UCL - Y./DAV

   .150
   .120

• 090 .~-~,,

         .,_._\~f_*__.\_ _ _ 0.?5 La
   .060
                 \
                   \1" ;'

l--ll \' l*\\

                            ... I
                                                                       ---,=== -~---

J ...._ _ _ _ _ _ -- i -----------------

   .030
   .000....._..~-~-------p1o-p,__,.._,__...__..._.,;.,_ _,_____....

1 START TIME DATE END TIME DATE

FIGURE 12-C

               . CASE 13

.PARABOLIC INEQUALITIES al a2 b RATIO 2.000 1.600

 .1. 200 START TIME DATE               END TIME DATE FIGURE 12-D CASE 13 POLYNOMINAL TERMS 5.000 4.000 I

CUBIC 3.000 QUADRATIC

2. 000 .

1.000 START TIME DATE END TIME DATE

FIGURE 12-E MAX. WINDOW LEAKAGE RAT~

 .092
 .074                         '*--,\
                                            *--,         (  ..---.,,,

I 055: 1 1

                                                 ',I_ _J(

I \

 * *0* 3*""'
        . *.r :
 . 01s*

FIGURE 12-F MAXIMUM WINDOW LEAHAGE RATE

 .075
 .060
 .045
                     \  I-._
                            "--J/
                                          ' * -......_/

I

 .030
 .015

FIGURE 13-A CASE 14 AIRMASS LBM X 1000 116.51 116.33, 116 .15*

115. 97 115.79 .t-Jt':l~..........--.ilil:-.lr'--'-........ir"rr.niil-+r:R:~~---'r~~.....,...X"J/---"

I START TIME DATE END TIME DATE FIGURE 13-B MASS POINT LEAKAGE RA"TE *AND UCL - ¥./DAY 1.000

• 800..,____ _ _ _ _ _ _ _ _ _ _ _ _ _---t

    .600
    .400

• 200 END TIME DATE

FIGURE 13-C

• CASE 14 PARABOLIC INEQUALITIES al a2 b RATIO 2.000 1.600

   .400

!START TIME DATE lE:ND TIME .DATE FIGURE 13-D CASE 14 POLYNOMINAL TERMS 20.000 16.000 \CU~IC 12.000 '1 QUADRATICll / ,l. v, I I 8.000 I

                                  . ~I I

I I / l \\--QUADRATIC I I II I - *v**~ 1

• I I I \

I l \ /-*\ l \*. .) / / l 1 \ 1

                                                                                       ,cu BI c 4.000       \... I I Y            /~**     ~I       l         ,I '*,,..._            \ -------------

1} I'* i I ,*

                 \_   1I 1 \---*** _                /               I        ._*--.:.::.~****
  .000~......L.....l.~P-L-L.._~~~_....c....J~,-b,,r,.L-.;,wpa-J

START TI ME DATE END TIME DATE

FIGURE 13-E MAx:-*wIND<>W LEAJ<AGE RATE

 . 840
                             -- **-**___....._              j*-*.-**......,
                                             .....,.       I               -
 .672                                                -,,,_J                  *......________ _
 . 504, FIGURE 13-F MAXIMUM WINDOW LEAHAGE RATE
 .750
 .600
 .450
 .300
 .150

FIGURE 14-A CASE 16 A I RM,rss-- LBM X 1000 - AND REGRESS I ON -LI NE 657.26 657.16 FIGURE 14-B

• MASS POI NT LEARAGE RATE --AND UCL*--= Y./'DAY

     .200
     .150
     .100 Hr~-tt--..,....,....__0:::..:__::

75 La --------t

     .050                 '--------~--=---==~
     .000 I

1 START TIME DATE

FIGURE 14-C

                         -CASE 16 PARABOLIC INEQUALITIES al a2 h RATIO 2.000           ----,__,

1.600 1 ..200

  .* '8:ni0:

l:JI. .

  .400*

START TIME DATE END TIME DATE FIGURE 14-D CASE 16 POLVNOMI.NAL TERMS 10.000 8.000 6.000 4.000 2.000 I ', L,. a000-t-x'~~~~~.-.iTffllir=i'l~l~\~--i-71n,,r-j,,r-J-'*~ ~~~ START TIME DATE END TIME DATE

FIGURE 14-E MAX. WINDOW LEAKAGE RATE

  . 408
  .326

16. a:

I ; , 19i

  .082F----t--------------~

FIGURE 14-F MAXIMUM WINDOW LEAJ<.AGE .R-Al'IE

  .210         ,**1
  .168         1\   ',
  .126
  . 0841----4-------..;i,..--------~--~-~-~-~~-.__~      -._
                                           *---*~*-
 *. 042

OOC.KETEQ USNPC

                                                                      *a7 JAN 13 A10 :16 Ms. Lynne Goodman 3228 East Fairchild La Crosse, WI 54601 January 6, 1987 Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Sir:

I have reviewed the proposed revision to 10 CFR 50, Appendix J, published in the Federal Register, Vol. 51, No. 209 on October 29, 1986. Based on my review, I have some coDDDents and questions. First, I will discuss some general comments, then coDDDents on the items solicited and finally comments on some specific provisions of the proposed rule. I have followed the progress of the proposed rule from the first information publicized on how it would simplify the rule and make it easier to conduct a reliable test to the currently proposed rule and regulatory guide out for comment. It has changed. I see advantages and disadvantages to the proposed changes. I do not agree that the changes are limited to corrections and clarifications and exclude new criteria. The proposed changes in the rule and the proposed Regulatory Guide involve some significant changes to leak rate testing. The impact will be felt the most at the smaller, older plants, where the staff size is smaller and the plants built before the General Design Criteria (GDC) were established. Most of these plants have been through the Systematic Evaluation Program and have had some items accepted which differ from the GDC, including containment isolation systems. In some systems, there may be only one containment isolation valve (possibly backed by an accessible manual valve in the turbine plant). The question then arises as to whether this proposed rule, if approved, would require installation of a redundant valve, so that it can be tested. I will further discuss changes later in my letter. Another question is whether plants that currently have an exemption from a portion of Appendix J are going to have to reapply for an exemption again, even if the requirement in Appendix J is not revised? This would be a waste of time for both licensees and NRC reviewers. I agree that containment integrity is important. I also feel that the rule and testing methodology should be as simple as possible, so that people can understand them and their basis. The more complicated a matter is, the greater the opportunity for error. Unfortunately, I believe the methodology provided in the proposed Regulatory Guide complicates the ILRT, especially considering the extended ANSI method conditions.

IJ. S. NUCLEA Y OMMI SSION DOCKET

• TION OFF .Y C

Postmark Co;,' s r. Ad 'IC pedal D1**

U.S. Nuclear Regulatory Commission January 6, 1987 Page Two I believe present operating plants should be given the opportunity to continue to meet the current Appendix J. For some plants, the number of changes may be considered to outweigh the benefits of the new rule. I am the engineer at the La Crosse Boiling Water Reactor responsible for leak rate testing. I speak for myself, not Dairyland Power Cooperative. If we had the choice to keep the status quo or adopt the new proposed rule and implementing Regulatory Guide, I would strongly recommend the status quo. Some reasons for this include the question of whether additional valves will need to be installed and tested, the increased complexity of the new methodology, the fixed Type A start time, and that makeup flow rate measurement will be required for Type C tests vs. leakage flow rate, which is what we currently use in most cases. I have some reservations as to the effect of the new Type A test requirements on testing our metal containment. One feature of the proposed rule I do appreciate is the option to increase Type Band C testing instead of Type A tests if specific valves or penetrations are causing problems. Historically, throughout the industry, the Type A test has generally identified leak paths that would have been identified by Type Band C testing. I think much of the proposed rule rev1s1ons and Regulatory Guide constitute backfitting. Changes to procedures will be needed as a minimum for most of the revisions. Procedure changes are one type of backfit. If additional valves need to be installed, a hardware backfit would exist. I do not think the backfit rule should be modified to waive the "substantial increase" provision. On the other hand, I do feel non- monetary considerations can be used in a cost benefit balance. If the NRC is truly planning on reviewing containment fwictional and testing requirements in the next year or two, it is not worthwhile to proceed with this change. Repetitive changes lead to confusion and errors. It does not make sense to institute a program of changes, if the requirements will be changed again. If we are talking a 1- 2 year timeframe, plants would barely have time to start implementing these changes before the next are being issued. Remember, that currently the Type A test interval is three times in ten years. A plant may not even have time to do a revised test before the methodology is changed again. I think it is a good idea to reference the Regulatory Guide in the rule and the standard in the Reg Guide, provided the Regulatory Guide references a specific version of the standard and will require revision and comment if the standard changes. I would not want the required methodology to change without NRC review and public opportunity to coDDDent. On the other hand, changing Appendix J has been so difficult that if there is another way to ensure changes go through appropriate review, I would rather not see the standard referenced in Appendix J.

U.S. Nuclear Regulatory CoDDDission January 6, 1987 Page Three Collecting as-found data has its purpose. For example, if leak rate measurements were only taken following valve repairs, there would be no measure of containment leak tightness. However, I feel ALARA also has to be considered. For example, if a facility modification package has been approved covering replacement of a containment isolation valve, it does not make much sense to test the old valve before it is removed. That measurement would not be indicative of the expected performance of that isolation boundary in the future. As a compromise measure between obtaining best leak rate data and ALARA, I would suggest that if a boundary is being modified, an as-found test is not needed. Otherwise, an as-found test should be required. I feel allowable leakage rates should be modified based on the source term work conducted. Exclusion area doses should be recalculated based on the revised source term and containment leakage rates based as they are now on the 10 CFR 100 dose. One factor that affects containment isolation valve leakage is its operating experience. The ANSI standard requires performing containment isolation functional tests prior to a Type A test. I disagree with this requirement. For example, during a LOCA or a plant shutdown, the main steam isolation valve is closed while the steam line is hot. There should not be a requirement for this valve to be cycled prior to the Type A test. A hot closure is similar to what it would experience during a LOCA, and so is an appropriate pre-Type A test condition. I do not like the idea of requiring a low pressure test prior to normal operation following a shutdown. The preparations and dose would be almost as great as for a full blown Type A test. As I mentioned before, Type A tests generally identify leak paths that would be detected by Type Band C tests. Therefore, I do not see the need for periodic Type A tests. I feel a pre-operational test is necessary, as is a test following maintenance or modifications to the containment boundary that cannot be adequately tested locally. I do not think the Type A test results need to be adjusted for Band C tests conducted between Type A tests. The criteria that the sum of the Type Band C test leakage rates must be i 60 percent La serves to cap the allowed leakage. Adding more criteria will adversely affect the ability of the people performing the tests to determine if a test is acceptable. It is better to have the test personnel evaluating the results as they perform the tests rather than merely recording numbers. Establishing a criteria that the frequency of Type B or C testing must be increased if the particular penetration or valve fails two consecutive tests makes sense, provided a couple issues are specifically addressed. First, would a cold plant shutdown be required to perform the test if the plant is running? Or should the increased testing be scheduled to coincide with a cold shutdown, if a cold shutdown occurs at an appropriate time between normally scheduled tests? I do not feel this requirement should cause a cold or any shutdown. I mention a cold shutdown, because some isolation valves can only _j

U.S. Nuclear Regulatory Commission January 6, 1987 Page Four be tested while the plant is cold. Second, should the increased test frequency continue if a major modification such as valve replacement, is accomplished? In any case, I feel two consecutive acceptable tests at the increased test frequency should be sufficient to return the test frequency to normal. One change in the new rule I appreciate is that it clarifies that La is the acceptable as-found leakage rate and that 0.75 La is the acceptable as- left leakage. LACBWR's Technical Specifications spell out that La is acceptance criteria and 0.75 La the startup criteria, but some years ago this was a matter of controversy. As I discussed before, some plants were built before the GDC and thus interpreting the definition of "containment isolation valve" may cause some trouble. Trouble will also be had in meeting the maximum pathway leakage rate requirement, in cases where only one valve is tested or the system is designed that either through or total leakage is measured. If this rule is to be approved, I think it would be wise to get together with representatives of the older plants to discuss how these portions of the rule will affect them. Allowing the test pressure to fall up to 1 psi below Pac during the test will allow some flexibility that would be nice. I also appreciate the way the proposed rule specifies that leak pathways can be isolated, etc. during the test, provided it is locally testable. I am slightly confused, however, when reading this section combined with the proposed Regulatory Guide requirements on test start time, on whether if a leak is detected after the test is started, it can be isolated and then data taking for leak rate detennination re-started after the isolation, so that the isolated leak does not affect some of the test data. I think this should be permissible, but I am not sure that it is. One item that surprised me was the proposed requirement that individual acceptance criteria for all airlock tests must be stated in Technical Specifications. Individual leak rate acceptance criteria used to be listed in LACBWR Technical Specifications, but a couple years ago the individual limits were removed and the combined Type Band C limit of 60 percent La established. Since airlock leakage rates are included in the 60 percent La criteria, I see no need to specify individual limits for the airlocks. Another new item is that valves tested by water must be tested at a pressure 2 1.10 Pac, rather than at Pac. I do not understand why. I also do not understand what is meant by "leakage from containment isolation valves that are sealed with water from a seal system may be excluded when determining the combined Type Band 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 *.**. " This implies to me that the Technical Specifications will need to be modified to insert individual valve leakage rate limits for those valves tested with water. Is this correct? I

U.S. Nuclear Regulatory Commission January 6, 1987 Page Five had thought Tech Specs were to be simplified, not made more detailed. My last comment regarding valves tested with water is that I am assuming that "a qualified water seal system" just means that following the design basis LOCA there will be water on the containment side of the valve for at least 30 days. This is basically the current criteria. If anything else is meant, it needs to be defined. If a specific water seal system needs to be installed to meet the criteria for a water test, then I am in disagreement. If it can be demonstrated that the valve will have water on its containment side for at least 30 days, this should be sufficient to show a water test is most appropriate. As I discussed before, I do not think the requirement that any modification, repair or replacement of a component subject to Type B or Type C testing must be proceeded by a Type B or C test is beneficial. It goes against the concept of ALARA to require testing of a valve which is undergoing a scheduled replacement or modification. This test would serve no purpose, since if the component was found to have excessive leakage, it would not affect plant operation or provide information about expected performance in the future. I do not understand what is meant by Section V.A, regarding that test methods, procedures, and analyses be referenced or defined in Technical Specifications. How detailed is this supposed to be? What analyses are to be referenced or defined in Technical Specifications? My last question is regarding reports of periodic Type Band C tests conducted at intervals intermediate to Type A tests. Currently, a mention in the monthly operating report is needed if the test(s) passes and an LER if it does not. Will a separate report be required under the proposed rule? How often or how soon after testing? For example, often only an airlock test is performed during a month. How will that need to be reported? Will the Type Band C reports need to include all the detail in the proposed Regulatory Guide (as contained in ANSI/ANS-56.8-1981)? Clarification would be helpful. As I have discussed, considerable changes can be required by this rule. Therefore, I appreciate that each plant can establish an implementation schedule. I hope if this rule change is approved, the NRC will get together with the licensees to discuss the new requirements and answer questions. I have separately submitted comments on the proposed Regulatory Guide. If anyone would like to discuss my comments and questions on the proposed rule with me, I can be reached during the work day at (608) 689-2331. Sincerely, Lynne S. Goodman

J8CICD elffllfD - PR-I {~1;:=-,,e, ~9.5g, BWR OWNERS' GROUP c/o NORTHERN STATES POWER CO.

• 414 Nicollet Mall
• Minneapolis, MN 55401 T. A. Pickens, Chairman (612) 330-5671 0

87 JAN 13 A10 :33 BWROG-8702 January 6, 1987 Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

Proposed Rules for Leakage Rate Testing of Containments - Request for Comment Period Extension

Reference:

Federal Register Volume 51, No. 209, Wednesday, October 29, 1986, pages 39538-39544 ATTENTION: Docketing and Service Branch The referenced Federal Register Notice requested comments on the pro-posed rules for leakage rate testing of containments. The current comment period for the proposed rule ends January 26, 1987. The purpose of this letter is to request extension of that comment period. On November 5 and 6, 1986, subsequent to the Federal Register Notice, the BWR Owners' Group authorized the formation of an ad hoc committee to address leakage rate testing of containments. This ad hoc meeting was held on December 2, 1986 and it was concluded that a full committee should be recommended to the Owners' Group. The BWROG will be voting on January 14-15, 1987 to form a full committee for these activities. The potential work scope of this committee would include a review of the current and proposed Appendix J revisions and draft Regulatory Guide MS 021-5. In order to perform a thorough review of the proposed rules and provide BWROG comments, the BWROG requests that the comment periods for Appendix J and Regulatory Guide MS 021-5 be extended an additional 90 days to April 26, 1987. In light of the extensive time involved in preparation of the proposed rules, and the number of questions which the staff requested comments on, the BWROG feels it would be beneficial to both NRR and the utilities to allow this additional time. The comments/positions provided in this letter have been endorsed by a substantial number of the members of the BWROG; however, it *should not

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I BWROG-8702 January 2, 1987 Page 2 be interpreted as a commitment of any individual member to a specific course of action. Each member must formally endorse the BWROG's posi-tion in order for that position to become the member's position. Very truly yours,

   ~t2~~

T. A. Pickens, Chairman BWR Owners' Group cc: BWROG Primary Representatives Appendix J Ad Hoc Committee R. F. Janecek, BWROG Vice Chairman D.R. Helwig, RRG Chairman J.M. Fulton, BECO J. W. Power, EPRI W. S. Green, INPO C. L. Tully, AIF E.G. Arndt, NRC S. J. Stark , GE

NOR'IIIEAST UTILfflES eneral Offices* Selden Street, Berlin, Connecticut []II] THE CONNECTICUT LIGHT *ND POW(A COMPANY WESlERN MASSACHUSETTS ELECTRIC COMPANY P.O. BOX 270 . ~ r_ ;* i_ i, '.. : HOLYOKE W.lTER POWER C0"4PANY NORTHE,1.ST UTILITIF.S SERVICE COMPANY HARTFORD, CONNECTICUT b!i'-141-0270 NORTHEAST NUCLEAR ENERGY COMPANY (203) 665-5000

                                                                                                   '86 OEC 10 P1 :02 December t+, 1986 Docket No. 50-213 50-245 50-336 50-423 B123t+5 A06209 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1, 2 and 3 Proposed Rulemaking - 10 CFR 50, Appendix J On October 29, 1986, the NRC Staff published in the Federal Register (51 FR 39538) a proposed revision to 10 CFR, Part 50, Appendix J - "Leakage Rate Testing of Containments of Light-Water Cooled Nuclear Power Plants." In the Federal Register notice, the Staff requested comments on the proposed rule by January 26, 1987. The NRC has been working for several years on this proposed revision to 10 CFR 50, Appendix J, and is requesting that utilities review the rule in a relatively short time period (3 months), which includes the major holiday and vacation period of the year. Based upon an initial review of the proposed rule, Northeast Nuclear Energy Company (NNECO), on behalf of Millstone Nuclear Power Station Unit Nos. 1, 2 and 3, and Connecticut Yankee Atomic Power Company (CYAPCO), on behalf of the Haddam Neck Plant, have identified several significant aspects of the rule which merit a detailed review by our personnel. We do not feel that a proper review can be performed in the time period allotted by the NRC. As such, NNECO and CYAPCO formally request that the comment period for the proposed rulemak-ing be extended to March 31, 1987. We would appreciate your prompt consideration and response to this request. Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY Senior Vice President

S. ~\JrL EA P r,*r* OOCKETI I - - QF1 0 t t lf'ostmerk n ; tc.

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AMERICANC~ h{J9}3i') NUCLEAR NUCL EAR EN~)N~J~<~:ING DEPARTMENT Ro nald Sanacore, Vice President BURT C. PROOM, CPCU INSURERS .86 NOV 20 P1 :57 President and Chief Executive Officer OFF IC:C :; -~ OOC kr. TIN,1 .-, November 20, 1986 '.'RAN Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Comments to Draft of Appendix J to 10CFR Part 50

Reference:

Federal Register Volume 51, Number 209, Pages 39538 through 39544 ANI/MAELU has reviewed the Draft of Appendix J to 10CFR Part 50 and conclude that it is a worthwhile contribution to the protection of the health and safety of the public. Generally we support the Draft in full and strongly support the following: 0 Type A testing at full design basis accident pressure (Pac) 0 Duration of Type A testing in concert with the state of technology. The test duration should be based on a reasonable level of confidence in that technology. Guidance for determining the level of confidence should be provided. 0 Submittal of an action plan by the utility when a problem with containment integrity is identified. The action plan should include a description of the problem, cause of the problem, what was or is being done to correct it and preventive measures to preclude recurrence. 0 Frequency of testing be adjusted as a result of identified problem areas. In addition, the interval between subsequent Type A testing must not exceed four years. As an independent effort, ANI/MAELU has assessed Type A testing at less than peak accident design basis pressure (Pac) as an increased risk. Therefore, we will be urging those of our insureds who do not test at Pac to do so. Although we know of no specific cases presently, ANI/MAELU recognizes that there may be plants that need some form of relief to Pac test conditions. These concerns will have to be negotiated on a plant specific basis as test problems are revealed. Therefore, reasonable measures should remain available, within the revision to the Draft, to ensure item, systems and containment boundary integrity are not jeopardized as a result of the test process. The Exchange. Suite 245 / 270 Farmington Avenue / Farmington. Connecticut 06032 / (203)677-7305 Eng.Dept. (203)677-7715 / TLX. No. 643- 029 AckfflM'tl!!dfed by ea ref *

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                                                                                                                  - . * , * , , * ..-.-'rnliiiif

WP-EAl REGULATORY COMMISS l)OCKETING & SE 0 VICE SECTION OFFI'". r ---:TARY 0 *** '.)N Po tmark 11/1?I Copi s ' d'I pectal r.;

I trust that these comments will be included in your final evaluations as to the disposition of the Draft. If ANI/MAELU can be of any further assistance or if you require any clarification of our comments please contact Mr. Martin Marugg at (203) 677-7715 extension 307. Very truly yours, Ronald Sanacore Vice President Nuclear Engineering Department RS/lgg cc: E.G. Arndt (NRC)

[7590-01] NUCLEAR REGULATORY COMMISSION OOtKETEO USNRC 10 CFR Part 50 Genera 1 Revis ion of Appendix }6 OCT 23 P3 :18 AGENCY: Nuclear Regulatory Conmission. ACTION: Proposed rule.

SUMMARY

The Nuclear Regulatory Commission is proposing to amend its regulations to update the criteria and clarify questions of interpretation in regard to leakage rate testing of containments of light-water-cooled nuclear power plants. The proposed rule would aid the licensing and en-forcement staff by eliminating conflicts, ambiguities, and a lack of uni-formity in the regulation of the inservice inspection program.

DATE: Conment period expires * 'AN. 2 6 1981 . Conments received after this date will be *considered if it is practical to do so, but assurance of consideration cannot be given except for comments received on or before this date. ADDRESSES: Mail written comments to: U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention : Docketing and Serv i ce Branch. Deliver comments to: Room 1121, 1717 H Street NW., Washington, DC, between 8:15 a.m. and 5:00 p.m. weekdays. Copies of draft regula t ory guide MS 021-5 may be obtained from the Nuclear Regulatory Commission, Document Management Branch, Washi ngton, DC 20555. 1

[7590-01] FOR FURTHER INFORMATION CONTACT: Mr. E. Gunter Arndt, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, ~lashington, DC 20555, telephone (301)443-7893. BACKGROUND SUPPLEMENTARY INFORMATION: Appendix J of 10 CFR Part 50 was originally issued for public com-ment as a proposed rule on August 27, 1971 (36 FR 17053); published in final form on February 14, 1973 (38 FR 4385); and became effective on March 16, 1973. The only amendment to this appendix since 1973 was a limited one, on Type_B {penetration) test requirements that was published for comment on January 11, 1980 (45 FR 2330); published in final form September 22, 1980 (45 FR 62789); and became effective on October 22, 1980. This revision of Appendix J has been in preparation for some time. It will provide greater flexibility in applying alternative requirements due to variations in plant design and reflects changes based on: (1) experience in applying the existing requirements; (2) advances in containment leak testing methods; (3) interpretive questions; (4) simpl-ifying the text (5} various external/internal comments since 1973; and (6) exemption requests received and approved. This proposed revision is for the purpose of updating the existing regulation. Other related, longer term, and broader issues are currently under review by the NRC staff, such as containment function, degree of integrity required, and validation of that integrity under conditions other than postulated in this rule. In order to better understand its 2

                                                                  * [7590-01]

function and scope, assumptions inherent in Appendix J are presented as fol low:

1. Certain levels of radiation exposure at the plant site boundary shall not be exceeded under (a} operatirrg or (b) design basis accident conditions.

2. Certain levels *of radiatioh exposure to plant operating personnel shall not be exceeded under (a) operating or (b) design basis accident conditions.

3. All four exposure levels (la, lb, 2a, 2b) may be different, but can be calculated.

4. Defense-in-depth will be used for protection against these levels of exposures. As the final barrier, a containment system is re-quired in order to maintain any or all of these exposure limits.

5. The required degree of containment system leaktightness for design basis accidents can be (a) calculated, (b) specifi~d, (c) built,

. (d) maintained, (e) inspected *.

6. A generic inspection program can be defined that verifies the required leaktightness of the containment following construction and periodically throµghout plant life.

7. NRC regulations should require such an inspection program; and define the test requirements and acceptance criteria.

8. A standard loss-of-coolant accident is assumed as the design*

basis accid~nt. Since the containment isolation system is an engineered safety feature, only safety grade systems and components are relied upon to define the containment boundary that must be exposed to the containment pneumatic test pressure for the integrated leak rate test. In addition, 3

[7590-01] all safety grade systems are assumed to be subject to a potential single active failure, and must be locally leak rate tested accordingly.

9. Pneumatic testing to peak calculated accident pressure is adequate without testing for, or at, accident temperatures or radiation levels.

10. Shielding tests need not be performed.

11. Periodic testing provides adequate confidence in the level of containment system integrity. Continuous monitoring of all indivi*dual isolation barriers is not necessary.

The scope of this revision to Appendix J is limited to corrections and clarifications, and excludes new criteria. However, this notice also addresses related, broader, longer term activities. Following is informa-* tion of some of these other related activities that are not reflected in this proposed rulemaking. In order to better identify the availability of containment leakage integrity, concepts of 11 continuous containment leakage monitoring 11 (such as negative containment operating pressure) and 11 relatively frequent gross containment integrity check 11 (such as a low pressure pumpup just prior to operation to check for openings) are under consideration by the NRC staff. These would identify large breaches of the containment system boundary, during, or just prior to, normal operating conditions. It should be noted they would only test the normal operating containment atmosphere boundary, not the Appendix J, post-accident boundary including isolation valves. Comments on these or alternative concepts, and what effect, if any, they would have on the proposed Appendix J requirements, are also being solicited in the following section of this preamble. 4

[7590-01] Past practice has been to implement the provisions of Appendix J by means of licensees' technical specifications *. Currently, a Technical Specification Improvement Project {TSIP) is underway to reevalu_ate the NRC's philosophy and utilization of the*technical specifications. While the proposed revision described herein assumes implementation of Appendix J by licensee's technical specifications, the work of the TSIP . may lead *to some changes in this form of implementation. Another program is presently bejng conducted to identify current NRC regulatory requirements that have marginal importance to safety and to recommend appropriate actions to modify or to eliminate these unneces- ,.. i I sary requirements. A Federal Register notice was published on October 3, . 1984, to announce the initiation of the program (49 FR 390~6). As a part of the program, regulatory requirements associated with containment leak-tightness are being evaluated. The risk and cost effecti.venessQf contain-

• . ment 1eakti ghtness requirements wi 11 be examined to determine their value with.respect to plant safety and possible alternative req~irements.

Any resulting changes to existing regulations will be made through normal rulemaking procedures, including ACRS review and public comment. Comments on the questions posed in this notice will also provide early,* useful input to these associated activities. IN.VITATION TO COMMENT Comments from all interested persons oil all aspects of this revision and on the risk and cost effectiveness o~ containment leaktightness in general are requested by the comment expiration date in order that: {l) the final revision will reflect consideration of all points of* view, and 5

[7590-01] (2) the staff's assessment of the risk importance of containment le~k-tightness can benefit from such comments. Especially requested are com-ments which address the following questions: (1) the extent to which these positions in the proposed rule are already in use; (2) the extent to which those in use, and those not in use but proposed, are desirable; (3) whether there continues to be a further need for this .regulation; (4) estimates of the costs and benefits of this proposed revision, - as a whole and of its separate provisions; (5) whether present operating plants or plants under review should be given the opportunity to continue to meet the current Appen~ dix J provisions if the proposed rule (reflecting consideration of public comments} becomes effective; (6) if the existin~ rul, or its proposed revision were completely voluntary, how.many licensees would adopt either version in its entirety and why; (7) whether (a) all or part of the proposed Append~x J revisions would constitute a backfit'i under the definition of that term 11 in the Commission's Backfit Rule, and (b) there are parts of the rule which do not constitute backfits, but which would aid the staff, licensees, or both;

     * (8)" since the NRC is planning a broader, more comprehensive review of containment functional and testing requirements in the next year or two, whether it is then still wor.thwhile to go forward with thi~ proposed revision as an interim updating of the exist~

ing regulation; 6

[7590-01] (9) the advisability of referencing the testing standard (ANSI/ANS 56.8) in the regulatory guide (MS 021-5) instead of in the text of Appendix J; (10) the value of collecting data for the "as found 11 condition of valves and seals and the need for acceptance criteria for this condition; (11) whether the technical specification limits on allowable contain-ment leakage should be relaxed and if so, to what exten~ and why, or if not, why not; (12) what risk-important factors influence containment performance under severe accident-conditions, to what degree these factors are considered in the current containment testing requirements,

    ~nd what approaches should be considered in addressing factors not presently c~vered~

(13) what other approaches to validating containment integrity could be used that might provide detettion of leakage paths as soon as they occur, whether they would result in any adjustments to the Appen~ix J test program and why; (14) what effect 1eak-before-break assumptions could have on the 11 11 leakage rate test program. Current accident assumptions use instantaneous complete breaks in piping systems, resulting in a test program based on pneumatic testing of vented, drained lines. 11 Leak-before-br~ak" assumptions presume that pipes will fail_ more gradually, leaking rather than instantly emptying. (15) how to effectively adjust Type A test results to reflect indi-vidual Type *sand C test results obtained from inspections, repairs, adjustments, or replacements of penetrations and valves

                                . 7

[7590-01] in the years in between Type A tests. Such an additional crite-ridri, currently outside the scope of this proposed revision, would provide a more meaningful tracking of overall containment leaktightness on a more continuous basis than once every several years. The only existing or proposed criterion for Type B _and. C tests performed outside the outage in which a Type A test is

• performed is that the sum of Type B and C tests must not exceed 60% of the allowable containment leakage. Currently being dis-cussed by the NRC staff are:

a. All Type Band C tests performed during the same outage as a Type A test, or performed during a specified time period (nominally 1.2 months) prior to a Type A test, be factored into the determination of a Type A test 11 as found 11 condition.

b. If a particular penetration or valve fails two consecutive Type B or C tests, the frequency of testing.that penetra-tion must. be increased until two satisfactory B or C tests are obtained at the nominal test frequency. Concurrently, existing requirem~nts to increase the frequency of Type A tests due to consecutive 11 as found 11 failures are already being relaxed in the proposed revision of Appendix J.

Instead, attention would be focused on correcting compo-nent degradation, no matter when teited, and the "as found 11 Type A test would reflect the actual condition of the overall containment boundary.

c. Increases or decreases in Type B or C "as found 11 test results (over the previous 11 as left 11 Type B or C test 8

[7590-01] results) shall be added to or subtracted from the previous 11 as l eft 11 Type A test result. If this sum exceeds 0.75*La but is less than 1.0 La, mea-sures shall be taken to reduc~ the sum to no.more than 0.75 La. This will not be considered a reportable condition. If this sum exceeds , 1.0 La , measures shall be taken to reduce the sum to no more than 0.75 La. This will be considered a reportable condition. The existing requirements that the sum of all Type Band C tests be no greater than 0.60 La shall also remain in

• effect.

Major Changes The following are the major changes proposed in this rulemaking.

1. L~vel of detail. The level of detail addressed in the proposed revision of Appendix J has been limited. This revision of the regula-tion defines general containment system leakage test criteria.

2. Editorial. For increased clarity, an expanded and revised Table of Contents and set of definitions has been provided, conforming to current usage. The text has also been revised to conform to "plain English 11 objectives.

9

[7590-01]

3. Interpretations. Some changes have been made to resol~e past questtons of interpretation {e.g., defini~ions of "contain~ent fsolation valves 11

           ).

4. Greater flexibility. A major problem with Appendix J has been the lack of a provision for dealing with plants already built where

• design features are incompatible with Appendix J requirements (e.g., air lo~k t~sting). As~ result, provisidn has been made in this revision for consideration by the NRC staff of alternative leakage test require-.

ments when necessary.

5. Type A test pressure. The option. of performing period_ic reduced pressur~ testing in lieu of testing at full caiculated accident pressure

• has been dropped. This change reflects the opinion that extrapolating
• low pressure leakage test results to full pressure leakage test results has.turned out to be unsuccessful. Reasonable argument can be made for low pressure testing *. However, the NRC staff believes that the peak.cal-culated acGident pressure {a) has always been the intended reference test*

pressure, (b) is consistent with the typical practice for NRC staff evaluations of accident pressure for the first 24 hours in accordance with Regulatory Guides 1.3 and 1.4, (c) provides at least a nominal check for gross low pressure leak paths that a low pressure leak does ,not pro-vide for high pressure leak paths, (d) directly repre.sents technical specification leakage rate limits, and (e) provides gre~ter confid~nce in containment system leaktight integrity. For these reasons, the full, ratherthan reduced, pressure has been retained as the test pressure.

6. Type A test frequency. The test frequency has been uncoupled from the 10-year inservice inspection period used by the ASME Boiler &

10

                                                                   * [7590-01]

Pressure Vessel Code for mechanical systems. A different time base is used, but the frequency has remained essentially the same.

7. Type A test duration. The duration .has been dropped from the te5t criteria in Appendix J. It is considered as part of the testing procedures, and is a function of the state of the testing technology and the level of confidence in it.

a.. Type A test "as is" clarification. Appendix J originally noted in III.A.l(a) that the containment was to be " *** tested in as clos~ to the as is' condition as practical." This is re-emphasized and clarifi~d 1 by the explicit requirements that have been added to measure, record, and report "as found" and "as left" leakage rates.

9. Type A test allowable leakage rate prorating. Seventy-five per-cent of the allowable leakage rate represents the i'as left" Type A test acceptance criterion, leaving 0.25 of the allowable lea~age rate as a margin for deteri.oration until* the time of the next regulatory scheduled Type A test, when the "as found" leakage rate criterion is 1.0 of the allowable leakage rate.

10. Quantification of allowable leakage rates. It should be noted that no change has been made to the way in which the allowable test leak-age rates are quantified. The regulation still refers to the individual plant technical specifications for these values. Debate continues, how~

ever, on.what these values should be and whether they can be generically specified, rather than individually specified for each site and plant.

11. Refocusing of corrective actions. When a reportable problem is identified, a Corrective Action Plan is to be submitted. It identifies

• the problem to the NRC staff, and notes the cause, what was or ~ill be done to correct it, and what wi 11 be done to prevent its recurrence.

11

                                                                         .[7590-01]

Increased local leakage testing frequency may be necessary. Appendix J originally addressed increased test frequency only for Type A tests. This revision applies adjustment of test frequency directly to identified problem areas.

12. The final paragraph of the proposed amendment specifies a da.te by. which an implementation schedule must be submitted, rather than .

by which it must be implemented. This is because the ease with which* licensees will be able to implement all the provisions of the ~merrdment will be highly plant specific depending on plant design, outage and test-ing schedules, and amount of technical specification changes needed. The separate views of Commissioner Frederic M. Bernthal follow: The public should be aware of the fact that the Commission for over a year has attempted to adapt the Backfit. Rule to all .rulemaking, even

  . rulemaking that has nothing to do witb changes to powerplant hardware and the original intent of the Rule.

This rulemaking and the. accompanying analysis. illustrates the difficulty. When applied to human-f_actors rules, updating antiquated rules, and certain other rulemaking, the Backfit ,Rule continues to exact NRC resources wholly disporportionate to any conceivable benefit to the public. The record already shows cases where the Commission has been forced to sidestep a strict reading of the cost-benefit requirements and the 11

                                             *** substantial increase in overall protectton *** 11 threshold of the Backfit Rule, when it never~heless 12

                                                                . [7590-01]

finds broad agreement that a rulemaking is in the public interest {e.g. in the case Qf conversion of non-power reactors from HEU to LEU). The public may'therefore wish to.comment directly on the question of whether the Commission should continue its attempts to apply the Backfit Rule_ to all rulemaking~ or whether the Rule should be revoked as it applies to rulemaking activity per.se. Alternatively, the public may wish to consider whether the Commission should amend the Backfit Rule to waive the ~substantial increase" provision, and to indicate explicitly that non-monetary benefits may be weighed by the Commission in the cost-benefit balance, when such* considerations are found by the Commission to be in the public interest. FINDING OF NO SIGNIFICANT ENVIRONMENTAL IMPACT: AVAILABILITY The Commission has determined under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in Subpart A of 10 CFR Part 51, that this rule, if adopted, would not be~ major Federal action significantly affecting the quality of the human environment and therefore an environmental impact statement is not required. There will be no radiological environmental impact offsite, but there may be an occupational radiation exposure onsite of about 3.0 man-rem per year of plant operation for inspection personnel (about 0.4% increase). Alternatives to issuing this revision were considered. and found not acceptable. The environmental assessment and finding of no 13

[7590-01] significant impact on whi.ch this determination is based are available for inspection at the NRC Public Docume~t Room, 1717 H Street NW., Washington, DC. Single copies of the envi_ronmental assessment and the finding of no-significant impact are availabl~ from Mr. E; Gunter Arndt, Office of NuclearRegulatory Research, U.S. Nuclea.r Regulatory Commission, W'ashington, DC 20555, Telephone (301)443-7893. PAPERWORK REDUCTION ACT STATEMENT This proposed rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 USC 3501 et seq.). This rule has been submitted to the Office of Management and Budget for* review and approval of the paperwork requirements. REGULATORY ANALYSIS The Commission has prepared a draft regulatory analysis on the proposed revision. The analysis examines the costs and benefits of the alternatives considered by the Commission. The draft analysis is available for inspection and copying in the NRC Public Document Room, 1717 H Street, NW., Washington, DC. _The Commission requests pu_blic com-ment on the draft analysis. Comments may be submitted to the NRC as indicated under the Addresses heading. 14

[7590-01] BACKFIT ANALYSIS The Commission has prepared a backfit analysis on the proposed revi-sion. The analysis is required under 10 CFR Part 50, Section 50.109, as of October 21, 1985, for the management of backfitting for power

• . reactors. The analysis h available for inspection and copying in the NRC Public Document Room, 1717 H Str~et NW., Washihgton, DC. The Commfas ion requests public comment on the analysis. Comments may -be submitted to the NRC as indic~ted under the Addresses heading.

The analysis does not conclude that there is a substantial increase in the overall protection of the public health and safety or the common defense and security to be derived from the backfit. It does conclude, however, that the direct and indirect costs of implementation are justi-fied due to better, more uniform tests and test reports, greater confid-ence in the reliability of the test results, fewer exemption requests, and fewer foterpretive debates. For these reasons, which are presented in greater detail in the backfit analysis, the Commission has decided to proceed with publication of the ,Proposed rule for comment. The Commission's decision regarding promulgation of the rule, even though it may not provide a substantial increase in the overall protection of the public health and safety or the common defense and security? is tentative pendfog receipt of public comments on this issue. REGULATORY FLEXIBILITY CERTI~ICATION In accordance with the Regulatory flexibility Act of 1980, (5 U.S.C. 605{b)), the Commis.sion certifies that this rule will not, if 15

[7590-01] promulgated, have a significant economic impact on a substantial number of small entities. This proposed rule affects only the licensing and operation of nuclear power plants. The companies that own these plants do not fall within the scope of the defihition of "small entities" set forth in the Regulatory Flexibility Act or the Small Business Size Sta.ndards set out in regulations issued by the Small Business Administration at 13 CFR Part 121.

• LIST OF SUBJECTS* IN 10 CFR PART 50 Antitrust, Classified information, Fire prevention, Incorporation by reference, Intergovernmental relations, Nuclear power plants and reactors, Penalty, Radiation protection, Reactor siting criteria, Report-ing and recordkeeping requirements.

RELATED REGULATORY GUIDE The notice of availability of a draft regulatory guide on the same subject "Containment System leakage Testing" (MS 021-5) is also being* published elsewhere in this Federal Register.

• The draft regulatory guide contains specific guidance on acceptable leakage test methods, .*

procedures, and analyses that may be used to *implement these requirements and criteria. For the reasons set out in the preamble and under the authority of the Atomic Energy Act of 1954, as amended, the Energy Reorganization .Act I of 1974, as amended, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendments to 10 CFR Part 50. 16

[7590-01] PART 50 -- DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES

1. The authority citation for Part 50 continues_ to read as follows:

AUTHORITY: Secs. 103, 104, 161, 182, 183, 186, 189, 68 Stat. 936,937, 948, 953, 954, 955, 956, as amended, sec. 234, 83 Stat. 1244:, a_s amended . (42 U.S.C; 2133, 2134, 2201, 2232, 2233, 2236, 2239, 228~); sec~. 201, 202, 206, 88 Stat. 1242, 1246, as amended (42 U.S.C. 5841,' 5842,_ 5£46), unless otherwise noted. Section 50.7 also issued under Pub. L. 95-601, sec. 10, 92 Stat. 2951 (42 U.S.C. 5851} *. Sections so.,s, 50.91, and 50.92 also issued under Pub. L. 97-415~ 96 Stat. 2073 (42 U.S.C. 2239). Section 50.78 also issued und.er sec. 122, 68 Stat. 939 (42 U.S.C. 2152). Sections 50.80-50.81 also issued ~nder sec. 184, 68 Stat *. 954, as amended {42 U.S.C. 2234). Sect.ions 50.100-50.}02 also issu_ed .under sec. 186, 68 Stat. 955 (42 U.S.C. 2236). For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273); 50.lO(a), (b), and (c), 50~44, 50.46, 50.48, 50.54, and 50.BO(a) are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b)); 50.lO{b) and (c) and 50.54 are issued under sec. 1611, 68 Stat. 949, as amended (42 U.S.C. 2201{i)); and 50.55(e), 50.59(b), 50.70, 50.71, 50.72, 50.73, and 50.78 are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(0)) *.

2. Appendix J is revised to read as follows:

Leakage Tests for Containments of Light-Water-Cooled Nuclear Power Plants 17

[7590-01] 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. Pretest Requirements

7. Verification Test 8~ Acceptance Criteria

9. Retest fog

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

4. Valves That Need Not Be Type C Tested 18

[7590-01] IV. SPECIAL LEAK TEST REQUIREMENTS A. Containment Modification or Maintenance B. Multiple Leakage Barriers or Subatmospheric Containments V. TEST METHOD, PROCEDURES, AND ANALYSES A. Type A, B, and C Test Details B. Combination of Periodic Type A, B, and C Tests 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 s~ecif~ed in§ 50.S~(o) of this part is that primary containments meet the leak test requirements set forth in this appendix. The tests ensure that (a) leakage through the primary contain-ments or systems and components penetrating these containments does not exceed allowable leakage rates specified in the Technical Specifications and (b} inservice inspection of penetrations and isolation valves ts*per- - formed so that proper maintenance and repairs are made during their 19

[7590-01] service life. This appendix identifies the general requirements and. acceptance criteria for preoperational and subsequent periodic leak testing.l I I. DEFINITIONS ACCEPTANCE CRITERIA Standards against which test r_esul ts are to be compared for establishing the functional acceptability of the containment system as a leakage limiting boundary. 11 AS FOUND 11 LEAKAGE RATE The leakage rate prior to any needed repairs or adjustments to the leakage barrier being tested. 11 AS LEFT" LEAKAGE RATE The leakage rate following any needed repairs or adjustments to the leakage barrier being tested. CONTAINMENT INTEGRATED LEAK R,nE TEST (CILRT) The combination of a Type A test and its verification test. CONTAINMENT .ISOLATION SYSTEM FUNCTIONAL TEST A test to verify the proper performance of the isolation system by normal operation of-the valves. For automatic containment isolation . systems, a test of the automatic isolation system performed by actuation of the containment isolation signals. 1specific guidance concerning acceptable leakage test method, procedures, and analyses that may be used to implement these requirements and criteria will be provided in a regulatory guide that is being.issued in draft form for public comment with the designation MS 021-5~ Copies of the regulatory guide may be obtained from the Nuclear Regulatory Commission, Document Management Branch, Washington, DC 20555 20 *

                                                                       ,t7590-:-01]

CONTAINMENT ISOLATION VALVE* Any valve defined in General Design Criteria 55, 56, or 57 o.f Appen- . dix A !'General Design Criteria for Nuclear Power Plants," to this parL CONTAINMENT LEAK TEST PROGRAM

• The comprehensive testing of the containment system that includes

*Type A, B, ?nd C tests.

CONTAINMENT SYSTEM The.principal barrier, after the reactor coolant pressure boundary, to prevent the release of quantities of radioactive material that would have a significant radi.o l ogi cal effect* on* the hea 1th of the public. It includes: (1) the primary containment, including access openings and

• penetrat i ans. i

                                                                                    .I I

{2) containment isolation valves, pipes, clos_ed systems, and other components used to effect isolation of the containment atmosphere from the outside environs, and

      * (3)  those systems or portions of systems that by their functions extend the primary containment boundary to include their system boundary.

This definition does not include boiling water reactors* (BWR) reactor buildings or. pressurized water reactors' {PWR) shield buildings. Also excluded from the provisions of this appendix are the interior barriers such as the BWR Mark I I drywe 11 floor and the drywe 11 perimeters . of the BWR Mark III and the PWR ice condenser. La(WEIGHT PERCgNT/24 HR) The maximum allowable Type A test leakage rate in units of weight percent per 24-hour period at pressure Pac as specified in.the Technical Specifications. 21

[7590-01] Lam{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 as 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. 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 correcting the measured value of containment leakage rate from the Type A test (Lam) to obtain *the overall integrated leakage rate and generally assumes no single active failure of redund,nt leakage barriers under these test conditions. OVERALL INTEGRATED LEAKAGE Rl1TE The total leakage rate through all leakage paths, including contain-22

[7590-01] ment welds, valves, fittings, and components that penetrate the contain-ment system, expressed in units of weight percent of contained air mass at test pressure per 24 hours. Pac (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 operat.ing 1ifetime. 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 CONTAINMENT - The structure or vessel that encloses the major components of the reactor coolant pressure boundary as defined in§ 50.2(v) of this part and is designed to contain accident pressure and serve as a leakage barrier against the uncontrolled release of radioactivity to the environ-ment. The term containment as used in this appendix refers to the 11 11 primary containment structure and associated leakage barriers. STRUCTURAL INTEGRITY TEST A pneumatic test that demonstrates the capability of a primary containment to withstand a specified internal design pressure load. 23

[7590-01] 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 therea.fter; 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 e* *of 11 owing containment penetrations: (1) Those whose design incorporates resilient seals, gaskets, sealant compounds, expaniion bellows, or fitted with flexible metal seal assemblies. (2) Air locks, including door seals and door operating mechanism penetration~ 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 and equip-ment to measure La.

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:

(a) Type Band Type C*tests, (b) A structural integr.ity test.* 24

[7590-01] (2) Periodic Test. A .periodic Type A test must be performed on the containment system._ (3) Test Frequency. Unless a longer interval is* specifically* approved by the NRC staff, the interval *between the preoperational and first periodic Type A tests must not 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 preoperat1onal test will be necessary. If such an additional preoperational Type A test or an additional Type A test

• required by Sections IILA.8 or 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. Pac at the start of the test but must not exceed the containment design pressure and must not fall more than 1 psi below Pac for the duration of the test, not including the verification test.        The test pressure must be established relative to the external presiure 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 the Type A test must be accomplished by normal operation and without any- preliminary exercising or adjus~ments 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 valve leakage that requires corrective action prior to, during, or after the test (see Section V~B.) must be included in the report submitted to the Commission as specified in Sec.tion VI of this. appendix. 25

[7590-01] (6) Verification Test. A leakage rate verification test must be performed after a Type A test in which the leakage rate meets the criterion 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 containment 1eakage rate calculated from the Type A test (Lam) does not differ from the leakage rate calculated from the verification test by more than +/-0.25 La. (7) Acceptance Criteria. (a) For the preoperational Type A Test, the 11 as left 11 leakage rate must not exceed 0.75La' as determined by a properly justifie.d statistical analysis. The 11 as found 11 leakage rate does not apply to the preoperational test. (b) For each periodic Type A test, the leakage rate, as deter-mined by a properly justified statistical analysis, must not exceed: (i) La, for the 11 as found 11 condition, (ii) 0.75La, for the 11 as left 11 condition, (c) In meeting these Type A test acceptance criteria, isola-tion, 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 (ii) the local leakage rates are measured before and after the isolation, repair, or adjustment and are reported- under Section VI of this appendix. 26

[7590-01] (iii) All changes in leakage rates resulting from isola-tion, 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 left" containment leakage rates. (d) The effects of isolation, repair, or adjustmentf to the containment boundary made after the start of the Type A test _sequence on the Type A test 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). (8) Retesting. (a) If, for any periodic Type A test, the as found leakage rate fails to meet the acceptance criterion of 1.0La, a Corrective Action

                      .    ~                                            .

Plan that focuses attention on the cause of the prob_lem must be developed and implemented 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)) shall be submitted to the NRC staff for review and approval. An as left Type A . test that meets the acceptance criterion of 0.75La is required_prior to plant startup. (b) If two consecutive periodic as found Type A tests exceed the as found acceptance criterion of 1.0la: (i) 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 refueling cycle normally being about 18 months) unless an alternative leakage test program is acceptable to the NRC staff 011 some 27

[7590-01] other defined basis. This testing must be performed until two consecutive periodic 11 as found 11 Type A tests meet the acceptance criterion of 1.0la 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 appro-priate than the performance 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)(i). (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 R test, containment penetra-tions subject to Type B testing must be Type B tested prior to returning the reactor to an operating mode requiring containment integrity. 28

[7590-01] (b) For containment penetrations employing a continuous leak-

 ~ge monitoring system that is at a presstite. not less than Pac , leakage.

readings of sufficient sensitivity to permit comparison with Type B test

• leak rates must be taken at intervals specified in the Technical Specifi- _

cations. These leakage readings must be part of the Type B reporting of VI.A. When practical, continuous leaka9,e monitoring systems must not be* operating or pressurized during Type A tests. If the continuous leakage monitoring system cannot be isolated, such as inflatable air lock door seals, *leakage into the containment *must be accounted for and the Type A test results corrected accordingly. (2) Pressure. Type B tests must be conducted, whether individually or in groups, at a pneuma'tic pressure not less than Pac except as pro-vided in paragraph III.B.(3)(b) . . of

                                     . this section or in the Technic~l Specifications.

(3) Air Locks. (a) Initial and periodic tests. Air locks must be tested prior to initial fuel loading and at 1east once each 6*month interval* thereafter at an internal pressure not less than ~ac; Alt~rnatively, if there have been no 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)._ Reduced pressure tests must 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 lee.ks opened during per.iods when containment 29

[7590-01] integrity is *r.equired, by the piant'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 ever,y 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 repeatedly tested during 1 such periods. However, they must be'tested prior to the plant requiring containment integrity. For air lock doors having testable seals, testing the seals fulfills the,intermediate 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) Whene~er mainten~nce other than on door seals has been performed on an air lock, a comple.te air lock test at a test pressure of not less than Pac is required, if that maintenance involved the pressure retaining boundary. (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 s~m of the as founp or as left Type B and C test results must not exceed 0.60La using maximum pathway leakage and including leakage rate readings from continuous leakage mon.itoring systems.

(b) Leakage measurements are acceptable if obtained through component leakage survei11ance systems (e.g., continuous pressurization of individual or clustered containment components} that maintain a pres-sure not less .than Pac at individual

                                    .    . test chambers of those same contain-30

[7590-01] ment penetrations during normal reactor operation. Similar penetrations not included in the.component leakage surveillance system ate still sub-ject 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 gre~ter 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 water from a qualified seal system, must be t~sted 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 Band C test results must not exceed 0.60La using maximum pathway leakage and including leakage rate readings from continuou~ leakage monitoring systems. 31

[7590-01] (b) Leakage from containment isolation valves that are sealed with water from a seal system may be excluded when determining the combined Type Band C leakage rate if: (i) The valves have be~n 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 Pac* (4) Valves That Need Not Be Type C Tested. (a) 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 accident, con-sidering 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 prov.is ions of paragraph VI I.A. IV. SPECIAL LEAK TEST REQUIREMENTS 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 inte-grity 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 B 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 32

[7590-01] demonstrate whether *or*_not a structural integrity test is needed pr.:ior 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. Type A testing of certain minor modifications, repairs, or replacements may be deferred to the.next regularly scheduled Type A test if local leakage testing is not possible and visual (leakage) examinations. or non-destructive examinations have been conducted. These shall include: Welds of attachments to the surface of the steel pressure retaining boundary; Repair cavities the depth of which does not penetrate the -- required design steel wall by more than 10%; Welds attaching to the steel. pressure retaining boundary penetrations the nominal diameter of which does not exceed one inch. B. Multiple Leakage Barrier or Subatmospher.ic Containments The primary *reactor *containment barrier of a multiple barrier or

  -subatmospheric containment shall be subjected to Type A tests to verify that its leakage rate* meets the requirements o_f this appendix. Other structures of multiple barrier or subatmospheric containments *(e.g.,

secondary containments for boiling water reactors and shield buildings for prl:?ssurized water reactors that enclose the entire primary reactor

• containment or portions thereof) shall be subject to individual tests in accordance with the procedures specified in the technical specifications.

V. TEST METHODS, PROCEDURES, AND ANALYSES A. Type A, B, and C Test Details i Leak test methods, procedures, and analyses for a steel, concrete, .I 33

[7590-01] or combination steel and concrete containment and its penetrations and isolati'on 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 Band 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 c*ontainment system leak-tight status is determined on both an as found basis and an as left basis, i.e., its leak status prior to this periodic.Type A test together with

.the related Type Band C tests and its status following the conclusion of these tests *.

VI. REPORTS A. Submittal

1. The preoperational and periodic Type A tests, including sum-maries of the results of Type Band 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 Commission in the manner specified in§ 50.4. The report is to be titled 11 Containment

' Leakage Test. II

2. Reports of periodic Type B and C tests conducted at interval_s intermediate to the.Type A tests must also be submitted to the NRC in the manner specified in§ 50.4 and at the time of the next Type A test submittal. Reports must be submitted to the NRC Regional Administrator within 30 days of completion of any Type B or C tests that fail to meet thei~ as found acceptance criteria.

34

[7590-01] 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 Band 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(0) of this part unless it

.can be demonstrated that alternative leak test requirements {e.g., for certain containment designs, leakage mitigation systems, or different test pressures not specifically addressed in this appendix) are demon-strated to be adequate on some other defined basis. Alternative leak

. test requirements and the bases. for them will be made a part of the plant Techni ca 1 S_peci fi cations if approved by. the NRC staff.

• B. Effective Date This appendix .is effective {30 days after publication). By (insert a date 180 days after theeffective date of this revision), each licensee and each applicant for an operating license shall submit a plan to the Director of the Office of Nuclear 1?ec1.ctor Regulation for implementing this appendix. This submittal must include an implementation schedule, with a final implementation no later than (insert a date 48_months after the effective date of this revision). Until the licensee finally implements the provisions of this revision, the licensee shall continue

                                        . 35

[7590-01] to use in their entirety the existing Technical Specifications and the Appendix Jon which they are based. Thereafter, the licensee shall use in their entirety this revision and the Technical Specifications conforming to this revision. Dated at Washington, DC, this 4:2...1.Jday o f ~ ~ , 1986.

• 36

[7590-01] NUCLEAR REGULATORY COMMISSION. Draft Regulatory Guide: Issuance, Availability The Nuclear Regulatory Commission has issued for public comment a draft of a new guide planned for its Regulatory Guide Series. This series has been developed to describe and make available ~o the public methods acceptable to the NRC staff of implementing specific parts of the Commission regulations and, in some cases, to delineate techniques used by the staff in evaluating specific problems or postulated accidents and to provide guidance to applicants concerning certain of the information needed by the staff in it revision of applications for permits and licenses.* The draft guide, temporarily identified by its task number, MS 021-5 (which should be mentioned in all correspondence concerning this draft guide), is entitled "Containment System Leakage Testing" and is intended for Divi-sion 1, "Power Reactors. 11 It is being developed to provide guidance on procedures acceptable to the NRC staff for conducting containment leakage tests. This draft guide endorses American National Standard* ANSI/ANS-56. a:.1981, "Containment System Leakage Testing Requirements. This draft gui_de, as issued for comment, proposes endorsement of the 1981 version of ANSI/ANS 56.8. It should be noted that a revision to ANSI/ANS 56.8 is being completed~ Roughly two-thirds of the positions in the draft guide are expected to parallel revisions made to ANSI/ANS 56.8. The current apparent la1*ge number of _differences be:tween the guide and the standard will therefore be greatly reduced to a relatively few a~tual differences upon publication of the new ANSI/ANS 56.8 staf'ldard .. For information regarding the

[7590-01] pending revision to ANSI/ANS 56.8-1981, contact the American Nuclear Society, 555 North Kensington Avenue, La Grange Park, Illinois 60525. This draft_guide is being issued to involve the public in the early stages of the development of a regulatory position in this area. It has received complete staff review but does not represent a final NRC staff. position. A separate regulatory analysis has not been prepared for this guide. This is because an extensive analysis, including a contractor-generated

• e . cost/benefit analysis, has been prepared and made available in conjunction with the proposed revision to 10 CFR Part 50, Appendix J, that is also being published for public comment in the Federal Register.* This regulatory guide clarifies acceptable positions for implementing the criteria of the proposed revision to Appendix J. As such, it has bee~ an inherent portion of the development ~ackage for the proposed Appendix J revision. Readers. are therefore referred to the proposed Appendix J revision and to supporting documentatf6n for a compre~ensive perspective on thi us~ of this guide.

Public comments are being solicited on the draft guide (including any implementation schedule). Comments should be sent to the Division of Rules and Records, Office of Administration, Room 4000 MNBB, Washington, DC 20555 *. Although a time limit is given, comments and.suggestions in connection with (1) items for inclusion in guides currently being developed or (2) improvements in all published guides are encouraged at any time.

[7590-01] Regulatory guides are available for inspection at the Commission's Public Document Room, 1717 H Street NW, Washington, OC. Requests for single copies of draft guides (which may be reproduced) or for placement on an automatic dis-tribution list for single copies of future draft guides in specific divisions should be made in writing to the U.S. Nuclear Regulatory Commission, Washington, DC, 20555, Attention: Director, Division of Technical Information and Document Control. Telephone requests cannot be accommodated. Regulatory guides are not copyrighted, and Commission approval is not required to reproduce them. Dated at Rockville, Maryland, this_$ __/ _ _ _ day of ~j.bl.- 1986. Guy

• r otto, Director
• Divi ion of Engineering Safety Offic of Nuclear Regulatory Research}}