* Asterisk annotated sections are performed by the resident inspector only, prior to the

commencement of heatup of the reactor coolant system above 200F, as required in the

minimum inspection program of IE MC 2515.

Issue Date: 12/23/86 - 1 - 61715

NRC INSPECTION MANUAL DI

INSPECTION PROCEDURE 61715

VERIFICATION OF CONTAINMENT INTEGRITY

PROGRAM APPLICABILITY: 2515 (BASIC*)

61715-01 INSPECTION OBJECTIVES

*01.01 Verify that the licensee has established containment

integrity prior to commencing heatup of the reactor coolant system

(RCS) above 200F.

01.02 Evaluate the adequacy and implementation of the licensee's

procedures designed to ensure and maintain containment integrity.

01.03 Evaluate the adequacy and implementation of the licensee's

procedures designed to mitigate contamination release in the event

of a loss of containment integrity following a loss-of-coolant

accident (LOCA).

61715-02 INSPECTION REQUIREMENTS

*02.01 Perform the following containment integrity checks:

*a. Verify through local observation the proper positioning of all

electrical or mechanical barriers and isolation valves

associated with at least 10 separate containment penetrations.

*b. Witness the air lock local leak rate test performed after

final containment closure.

*c. Walk down a system designed to maintain containment integrity

or to mitigate contamination release in the event of a LOCA.

02.02 Perform the following containment integrity checks:

a. Verify through local observation the proper positioning of all

electrical or mechanical barriers and isolation valves

associated with at least 20 separate containment penetrations.
61715 - 2 - Issue Date: 12/23/86

b. Determine if the 20 penetrations reviewed above meet the

required General Design Criteria (GDC 55, 56, or 57) of 10 CFR

Appendix A.
Issue Date: 12/23/86 - 3 - 61715

c. Walk down a system designed to maintain containment integrity

or to mitigate contamination release in the event of a LOCA.

02.03 Review the licensee's records of the periodic

surveillances of primary containment integrity as required by

Technical Specifications (TS). This review should cover

surveillances performed during the previous 6 months of unit

operation with RCS temperature above 200F. At a minimum, the

following periodic surveillances shall be included in the test

records reviewed:

a. verification of the proper alignment, operability, and

isolation time, as applicable, for all primary containment

penetrations with the exception of air locks

b. demonstration of air lock operability

c. verification of the main steam isolation valve leakage control

system operability

02.04 Verify that the combined local leakage rate for all Type

B and C tested containment penetrations was determined to be within

specifications if any of these containment penetrations were opened

following the current (or last) Type A, B, or C test.

02.05 Determine if post-maintenance operability was verified

during the past 6 months for containment air locks and five primary

or secondary containment isolation valves prior to RCS heatup above

200F.

02.06 Review the licensee records for the past 6 months of unit

operation with RCS temperature above 200F to ensure that TS

required surveillances were performed in the following categories:

a. verification of licensee operation within the required

containment pressure and temperature limits

b. demonstration of the operability of containment pressure and

temperature reducing systems

c. verification of the operability of the combustible gases

monitoring and control systems

d. control of containment building venting and purging operations

02.07 Review the licensee records for the past 6 months of unit

operation with RCS temperature above 200F to ensure that TS

required surveillances were performed to demonstrate the integrity

and/or operability of one of the following systems:

a. spray additive system

b. iodine removal system (PWRs)/standby gas treatment system

(BWRs)

c. penetration room exhaust air cleanup system
61715 - 4 - Issue Date: 12/23/86

d. secondary containment/shield building and associated systems

02.08 Review maintenance requests, equipment operability

records, and licensee event reports applicable to containment

penetration boundaries, LOCA pressure reduction systems, and LOCA

contamination release mitigation systems for a month of unit

operation with RCS temperature above 200F. Verify that all

appropriate TS required actions were performed as necessary and that

the maintenance/modification requests contained adequate information

regarding restoration of the containment boundary.

61715-03 INSPECTION GUIDANCE

General Guidance

a. Containment integrity must be maintained whenever RCS

temperature is above 200F to ensure in the event of a LOCA

that contamination would not be released in unacceptable

quantities to the outside environs. One measure of this

integrity is taken through the performance of containment

integrated leakage rate tests (CILRTs). The CILRT ensures

that at peak LOCA pressures, containment leakage would not

result in an unacceptable release. However, satisfactory

completion of the CILRT does not guarantee that containment

integrity is or would remain intact during plant heatup,

operation above 200F, or in the event of a LOCA. This

procedure is designed to assist in evaluating the licensee's

normal state of containment integrity and the operability of

the containment support systems, exclusive of the containment

leakage rate requirements examined in IE MCs 61720, 70307,

70313, and 70323. Programmatic inspection emphasis shall be

placed on verifying that containment integrity was established

before RCS heatup after each cold shutdown outage because the

majority of containment breaches occur at this time.

b. The requirements of this inspection procedure are generally

applicable to all boiling water reactors (BWRs) and

pressurized water reactors (PWRs). The inspector should use

this procedure as is applicable to the facility being

inspected; making inspection modifications as necessary to

ensure the adequate verification of all containment integrity

requirements and commitments.

c. Specific details on each individual TS surveillance are not

provided in this procedure as they often vary widely depending

on the type of containment, the vendor, and licensee-specific

TS requirements.

03.01 Specific Guidance

*a. Inspection Requirement 02.01. This inspection requirement

shall be performed during each unit cold shutdown outage

before final containment closeout in preparation for RCS

heatup above 200F. The only exception to this requirement

would be when such an inspection was previously performed

within the last 31 days.
Issue Date: 12/23/86 - 5 - 61715

*b. Inspection Requirement 02.01a. Each performance of this

requirement fulfills the biweekly inspection requirement of

section 02.03f of IE MC 71707.

c. Inspection Requirements 02.01c and 02.02b

1. The walkdowns conducted should cover the following types

of systems:

(a) containment penetration isolation actuation systems

(not including the actual isolation valves)

(b) containment penetration pressurization systems

(c) containment pressure and temperature reduction

systems

(d) combustible gases monitoring and control systems

(e) contamination (e.g., iodine) removal systems

(f) secondary containment and associated support systems

(g) ice condenser

2. The inspector shall verify the proper alignment of each

component in the containment support system inspected.

3. Each performance of this requirement fulfills the weekly

inspection requirement of section 02.02a of IE MC 71707.

d. Inspection Requirement 02.03a. The inspector shall evaluate

the following licensee surveillance test records for the past

6 months of unit operation with RCS temperature above 200F:

1. Monthly alignment check of each penetration that is

required to be closed for a LOCA and is not capable of

being closed by operable automatic isolation valves.

This check is not required for any closed penetration

located inside containment if that penetration is locked,

sealed, or otherwise secured in the closed position.

However, these penetrations shall be verified closed

during each cold shutdown at least every 92 days.

2. Demonstration of the operability of TS specified

containment isolation valves

(a) by verifying actuation upon initiation of a

containment isolation test signal during cold

shutdown or refueling at least once per 18 months.

(b) by verifying that the valve isolation time is within

TS limits at the frequency prescribed by the ASME

Boiler and Pressure Vessel Code and applicable

Addenda.
61715 - 6 - Issue Date: 12/23/86

(c) (subatmospheric containments only) by cycling each

weight or spring loaded check valve through one

complete cycle and verifying that the check valve

responds appropriately to changing differential

pressures. Valves testable during plant operation

with RCS temperature above 200F shall be verified

operable at least every 92 days, whereas, those not

testable shall be tested during cold shutdown or

refueling at least once per 18 months.

3. Demonstration of the operability of each TS specified

reactor instrumentation line excess flow check valve at

least every 18 months (BWRs only).

4. Verification of the operability and alignment of the

containment purge supply and exhaust isolation valves

(PWRs) or the drywell and suppression chamber purge

supply and exhaust isolation valves (BWRs).

5. Verification of the operability and alignment of the

containment vacuum relief valves (PWRs) or the

suppression chamber - drywell vacuum breakers and the

reactor building - suppression chamber vacuum breakers

(Mark I BWRs).

6. Determination that all required containment and drywell

penetrations are isolated before conducting containment

purge system operability checks; verification that purge

flow is maintained below 5000 cfm during this operability

check (BWRs only).

e. Inspection Requirement 02.04

1. The total combined local leakage rate shall be less than

or equal to 0.60 La, where:

La is the maximum allowable leakage rate when measured at

Pa.

Pa is the calculated peak internal containment pressure

related to the design-basis accident and is specified in

the TS or associated bases.

All local leakage rate tests must be performed at a

pressure not less than Pa.

2. If the combined local leakage rate is greater than 0.60

La when operating above 200F, the containment integrity

must be restored within an hour or the unit must be

placed in the cold shutdown operational mode. If already

in cold shutdown, the containment integrity must be

reestablished before increasing RCS temperature above

200F.

f. Inspection Requirement 02.06b. The pressure and temperature

reducing system surveillance records reviewed shall include

those conducted during the previous year for the following:
Issue Date: 12/23/86 - 7 - 61715

1. containment spray systems

2. containment cooling fans (N/A to BWRs or subatmospheric

PWRs)

3. ice condenser and related systems and components

including the following:

(a) ice bed

(b) ice bed temperature monitoring system

(c) ice condenser doors

(d) inlet door operation monitoring system

(e) personnel access doors and equipment hatches between

the upper and lower containment compartments

(f) air recirculation system

(g) ice condenser floor drains

(h) refueling canal drains

(i) divider barrier seal

4. steam jet ejectors and mechanical vacuum pumps

(subatmospheric PWRs only)

5. suppression pool and cooling system; drywell -

suppression pool differential pressure and monitoring

instrumentation (BWRs only)

61715-04 REFERENCES

10 CFR 50, Appendix J

Standard Technical Specifications

END