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**UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555-0001**

April 20, 1998

**Addressees**

All holders of operating licenses for nuclear power reactors except those that have permanently ceased operations and havecertified that fuel has been permanently removed from the reactor vessel.

**Purpose**

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert addressees of the requirementto complete pressure tests and leak tests of the reactor pressure vessel (RPV) before core criticality. It is expected thatrecipients will review the information for applicability to their facilities and consider actions, as appropriate, to avoidsimilar problems. However, suggestions contained in this information notice are not NRC requirements; therefore, nospecific action or written response is required.

**Background**

Under the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) , Section XI, Class 1and 2 leakage tests provide a level of defense-in-depth for detecting pressure boundary leakage. From a safety perspective,performing this test using nuclear heat defeats the intended purpose of ensuring the integrity of the RPV as a fissionproduct barrier.

A December 1995 rule change to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50), Appendix G,Section IV.A.2.d, clarified the staff position as follows: "Pressure tests and leak tests of the reactor vessel that are requiredby Section XI of the ASME Code must be completed before the core is critical." The final rule was published in the FederalRegister on December 19, 1995. In addition, the Federal Register notice referenced a letter to Messrs. Reynolds andStenger of the Nuclear Utility Backfitting and Reform Group (NUBARG) from James M. Taylor, NRC Executive Directorfor Operations, dated February 2, 1990, in which Mr. Taylor discussed the explicit prohibition of using nuclear heat toperform pressure and leak tests (Accession Number 9002120362).

**Description of Circumstances**

On June 22, 1997, the licensee for Quad Cities Station performed the required ASME Code, Section XI leak test of theRPV following Unit 2 criticality and startup from a refueling outage.

The reactor was at approximately 12-percent power. On October 1, 1997, while reading Appendix G for guidance on aseparate issue, the licensee discovered that it had violated the requirement to complete pressure and leak testing before thecore is taken critical.

In December 1997, a Region III inspector reviewed (1) ASME Code Class 1 system pressure tests for the Quad Cities Units1 and 2 refueling outage 14 and (2) problem identification forms (Inspection Report 50-254/97-27, Accession Number9803170418). The licensee had previously documented the violation that took place on June 22, 1997, of Appendix Grequirements in one of the problem identification reports. The Inspector found that the visual VT-2 examinations of theUnit 2 drywell area required by the ASME Code were conducted in a very short time. In an effort to keep exposure time toa minimum, licensee personnel covered very large examination areas in a very short time (e.g., 50 examination areas in 12minutes). The short examination time called into question the adequacy of the visual VT-2 examinations.

The NRC and the licensee discussed apparent violations during an open, predecisional enforcement conference that tookplace on January 9, 1998. On March 12, 1998, the NRC issued a Notice of Violation and Proposed Imposition of CivilPenalty in the amount of $330,000 for violations of Appendix G to 10 CFR Part 50, 10 CFR 50.59, and TechnicalSpecification surveillance requirements.

**Discussion**

This issue is of significant concern because licensees should recognize that the intent of performing the ASME Codepressure and leak tests before the reactor is taken critical is to ensure the integrity of the RPV without using nuclear heat.The staff's position has been, and continues to be, that performing pressure and leak tests after the core is critical isunacceptable. This point was clarified in the December 1995 rule change.

This information notice requires no specific action or written response. However, recipients are reminded that they arerequired to consider industry-wide operating experience (including NRC information notices) when practical and whensetting goals and performing periodic evaluations under 10 CFR Section 50.65, "Requirement for Monitoring theEffectiveness of Maintenance at Nuclear Power Plants," If you have any questions about the information in this notice,please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation (NRR)project manager.

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