ML20203P017

Clarifies Position Re IE Info Notice 85-071, Containment Integrated Leak Rate Tests, in Response to . Notice Will Be Used as Insp Guidance Representing Headquarters Interpretations of Leak Rate Test Requirements

ML20203P017
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire, 05000000
Issue date:	04/14/1986
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tucker H DUKE POWER CO.
References
IEIN-85-071, IEIN-85-71, TAC-59796, TAC-59797, TAC-60601, TAC-60602, NUDOCS 8605060276
Download: ML20203P017 (2)

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f APR 141996 Duke Power Company tATTN: Mr. H. B. Tucker, Vice President Nuclear Production Department 422 South Church Street' Charlotte, NC 28242 Gentlemen: .

SUBJECT:

IE INFORMATION NOTICE 85-71, CONTAINMENT LEAK RATE TESTS We appreciate your letter, dated March 11, 1986, concerning the NRC's position on containment integrity as expressed in IE Information Notice (IEN) 85-71, "Contain-ment Integrated Leak Rate Tests." The IEN was published to assist licensee's in proper, conservative application of 10 CFR 50, Appendix J. The IEN also enables inspectors in all Regions to uniformly inspect these areas. Upon review of your letter, there appears to be some misunderstanding of our positions by your staff.

Therefore, I need to further clarify the NRC's position on the issues in IEN 85-71.

Technical Specifications (TSs) require maintenance of containment integrity (CI) in operational modes 1, 2, 3, and 4. Knowledge that CI exists is demonstrated by performing Type A, B, and C tests (as defined in 10 CFR 50, Appendix J). If a containment boundary is repaired or adjusted (RA) before a Type A test is per-formed, knowledge of the past CI performance is lost unless the as-found condi-tion is determined and an adjustment is made to the Type A test results.

If the. adjustment to the Type A causes the test results to exceed the leak rate limits, the Type A test may be considered a failure. When this occurs, the future schedule for Type A tests is reviewed by the NRC. Depending on the situation, additional testing may be required in order to reestablish a high degree of confidence in CI.

It is fundamental for a quality test program that the system to be tested should not first be fine tuned prior to the test. Any RA to containment boundary made as a result of the fine tuning would therefore require adjustment to the test results.

The NRC staff went further in what you referred to as " Staff Position 2," or Item 4 under Discussion in IEN 85-71, in clarifying our position as to when an adjustment needs to be considered. Our position is that if any operating service time is achieved following RA, no adjustment is required to the test results.

This is based on the idea that a licensee would not restart their facility, for a brief period, only to avoid having to^ adjust Type A test results. We expect, over the long period, that data would be available to determine an accurate historical assessment of CI. No guidance was given in the IEN on the operating period to allow licensee's maximum flexibility. This information would enable an assessment of the periodicity of Type A testing and an evaluation.of how well CI h~

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-was maintained during the past operating cycle. Obviously, if we find a CI problem for a very short operatirg cycle between RA, some changes in this position may be required. The current flexibility assumes, and the NRC will insist, that sufficient data be available to clearly indicate that the current testing schedule is adequate for maintaining CI.

If you or your staff have an alternate method that would indicate acceptable CI as required by TS, we ask that you share this with us.

The NRC staff concludes that the guidance as presented in IEN 85-71 is consistent with 10 CFR 50, Appendix J, requirements and is an acceptable method to satisfy the appropriate TS requirements. The inspection staff in Region II intends to use IEN 85-71 as inspection guidance representing headquarters interpretations of containment leak rate test requirements in subsequent inspections.

Sincerely.

OElGINAL SIGNED BYs J. NELSOA GRAM J. Nelson Grace Regional Administrator cc: 4. L. Dick, Vice President -

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