Issue Date: 10/03/85 - 1 - 61720

NRC INSPECTION MANUAL DI

INSPECTION PROCEDURE 61720

CONTAINMENT LOCAL LEAK RATE TESTING

PROGRAM APPLICABILITY: 2513, 2515 (BASIC)

61720-01 INSPECTION OBJECTIVES

01.01 Ascertain through inspector observation, records review,

and independent calculations whether the containment local leak rate

test (LLRT) program is being properly conducted.

01.02 Independently verify the acceptability of the test results

through on-the-spot analysis.

61720-02 INSPECTION REQUIREMENTS

02.01 Verify that all containment penetration boundaries (CPBs)

and containment isolation valves (CIVs) have been local leak rate

tested at the required frequency since the previous containment

integrated leak rate test (CILRT).

02.02 Determine if the sum of the local leak rates for all

boundaries and valves subject to LLRTs meets the acceptance

criteria.

02.03 Ensure that the licensee performed the actions required

by the Technical Specifications (TS), if the combination of the

local leak rates was in excess of the acceptance criteria.

02.04 Review the LLRT procedures and ensure that the following

items are included:

a. All applicable CPBs and CIVs are subjected to local leak rate

testing.

b. LLRTs are performed at CILRT peak pressure except where

reduced pressure tests have received prior NRR approval in the

TS (e.g., main steam isolation valves or air locks).

c. LLRT program utilizes approved methods for testing CPBs and

CIVs.
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d. Penetration leakage rates are determined using the maximum

pathway leakage.

e. Criteria and response for LLRT and combined leakage rate

failure.
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f. Criteria and response for the leakage rate failure of

components specifically cited in the TS.

02.05 Review 10 of the licensee's Maintenance Requests performed

on CPBs and CIVs since the last CILRT to verify that these

repairs/modifications were preceeded and followed by LLRTs on the

applicable penetrations.

02.06 Observe LLRTs on at least two CPBs and two CIVs and

determine if the licensee is properly complying with regulation and

procedural commitments.

02.07 Ensure that the test equipment for the LLRTs observed was

within calibration at the initiation of the LLRT.

61720-03 INSPECTION GUIDANCE

General Guidance. The purpose of the LLRT program is to provide a

continually updated evaluation for the leak-tight integrity of each

containment penetration and of the containment as a whole.

Repeated leak rate failures of penetrations or sets of penetrations

would indicate either a generic problem with the penetration or a

licensee failure to properly maintain containment components. These

failures should be addressed to correct the causes of loss of

containment integrity.

03.01 Specific Guidance

a. Inspection Requirement 02.01. The required frequency for

performing LLRTs on CPBs and CIVs is provided in the TS. This

TS periodicity must be at a minimum as restrictive as the

following test frequencies:

1. CPB LLRTs

(a) Every 2 years following the successful completion of

the initial preoperational LLRT for that penetration.

(b) If opened following a CILRT or LLRT, prior to

returning the reactor to a mode requiring containment

integrity.

(c) If the penetration employs a continuous leakage

monitoring system, every 3 years or every other

refueling outage, whichever comes first.

(d) Air locks every 6 months and if opened:

(1) when containment integrity is not required, at

the end of such opened periods.

(2) when containment integrity is required, within

3 days of being opened or once every 3 days

during periods of frequent openings.
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(3) the air lock seal test will not replace the

required 6 month LLRT.

2. CIV LLRTs. Every refueling outage or 2 years, whichever

comes first.

b. Inspection Requirement 02.02

1. The continuous running sum of local leak rates for all

penetrations required to be subjected to LLRTs shall be

less than 0.60 La, where:

La = the maximum allowable leakage rate at the

calculated peak containment internal pressure related to the design basis loss of

coolant accident (Pa).

2. CIVs that are sealed with fluid (e.g., water) from a seal

system which has a sufficient inventory to provide a seal

for at least 30 days at a pressure of 1.10 Pa are

excluded from the combined local leak rate criteria.

No other containment penetrations are excluded unless it

can be shown that these penetrations are not part of a

potential containment-to-atmosphere leakage path.

3. The method used to obtain the combined leak rate should

add the new LLRT results for the penetrations tested and

subtract the previous results for these same penetrations

to the combined local leak rate sum. Results of LLRTs

should be factored into the sum as soon as a set of LLRTs

are complete. Extensive lag time (more than 30 days)

between the LLRTs and the combined leak rate update

should not be permitted. Entry of the plant into a mode

requiring containment integrity shall never be permitted

until the combined leakage rate is updated.

c. Inspection Requirement 02.03

1. If the combined local leak rate is greater than or equal

to 0.60 La, the CPB's and CIVs shall be repaired to

restore the combined leak rate to less than 0.60 La prior

to entering a mode requiring containment integrity (e.g.,

increasing the Reactor Coolant System temperature above

200F).

2. If containment integrity is lost while operating the

reactor (e.g., a normally shut CIV fails open), integrity

must be restored within 1 hour or the plant shutdown to

hot standby within the next 6 hours and cooled down to

cold shutdown within the following 30 hours.

d. Inspection Requirement 02.04a

1. All CPBs and CIVs must undergo LLRTs with the exception

of fluid sealed CIVs as described in 03.02b2 of this
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procedure or those penetrations which are not located in

a potential containment-to-atmosphere leakage path.

2. The inspector shall verify that all penetrations listed

in the TS are incorporated in the licensee's local leak

rate test program.

e. Inspection Requirement 02.02c. The approved methods for LLRTs

are provided below. The test method used must provide a

quantitative leakage rate for the penetration in order to

determine the combined leakage rate. Tests which provide only

a positive or negative indication of leakage are not acceptable, unless, if leakage is detected, they are followed by a

quantitative leak rate test on the same penetrations.

1. CPBs

(a) halide leak detection test (or similar methods) on

a test chamber pressurized with air, nitrogen, or

pneumatic fluid which is constructed as part of the

individual penetration. (This test method provides

only a positive/negative indication of leakage.)

(b) measurement of the rate of pressure loss of a test

chamber of the penetration pressurized with air,

nitrogen, or pneumatic fluid.

(c) leakage surveillance by means of any system which

continuously or intermittently pressurizes penetrations and measures the pressure loss or the makeup

pressurization necessary to return the penetration

to its TS specifications. This method uses air,

nitrogen, or pneumatic fluid to pressurize the local

penetration being tested.

2. CIVs

(a) Testing shall be performed by local pressurization

with the pressure being applied in the same direction

as it would be when the valve performs its safety

function. Pressurization from a different direction

is permissible only if it can be proven that this is

at least as conservative as the normal testing

direction.

(b) Each CIV tested shall be closed by normal operation

without any preliminary exercising or adjusting of

the valve.

f. Inspection Requirement 02.04d. Only maximum pathway leakage

rates will be utilized for the determination of the combined

local leakage rate. The maximum pathway leakage rate is based

upon the assumption of a single active failure of the better

of two leakage barriers in series when performing Type B or

C tests. Thus, the maximum pathway leakage rate would be the

larger leakage rate of two barriers tested in series or the

actual leakage rate measured for barriers tested in parallel.
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g. Inspection Requirements 02.04e and f. LLRT acceptance

criteria are provided in the TS. This criteria should be

discussed in the test procedures or in administrative or

quality assurance procedures with the detailed actions

required for test failure included.

h. Inspection Requirement 02.07

1. All test equipment shall have been calibrated over the

normal range of conditions experienced during the LLRT.

Correction factors should be determined for each sensing

device prior to initiation of the LLRT.

2. All calibrations shall be traceable to NBS standards.

3. Calibration of instruments used in the LLRT shall have

been performed no more than 6 months before the LLRT. An

in-site check of all test equipment shall be performed

after installation and prior to pressurization. These

checks shall be performed within one month of the

initiation of the LLRT.

4. Though it is generally a good engineering practice to

calibrate all test equipment after completion of the

LLRT, it is not a requirement. The inspector should

determine whether the licensee has committed to

post-testing calibration prior to attempting to enforce

it.

61720-04 REFERENCES

10 CFR 50, Appendix J.

ANSI N45.4-1972, "Leakage-Rate Testing of Containment Structures for

Nuclear Reactors."

ANSI/ANS-56.8-1981, "Containment System Leakage Testing

Requirements."

END