U.S. NUCLEAR REGULATORY COMMISSION REGULATORY
editor evaluating revisionSeptember 1995 GUIDE
OFFICE OF NUCLEAR REGULATORY RESEARCH
REGULATORY GUIDE 1.163
(Draft was DG-1 037) PERFORMANCE-BASED CONTAINMENT LEAK-TEST PROGRAM
A. INTRODUCTION
The Nuclear Regulatory Commission has amended its regulations (60 FR 49495) to provide a performance-based option, Option B, for leakage-rate testing of containments of fight-water-cooled nuclear power plants. Licensees may voluntarily comply with this Option B as an alternative to compliance with the current requirements in Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Pow er Reactors," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities." The amend ment is aimed at improving the focus of the body of regulations by eliminating prescriptive requirements that are marginal to safety and by providing licensees greater flexibility for cost-effective implementation methods for regulatory safety objectives. This regulato ry gui
de provides guidance on an acceptable perfor mance-based leak-test program, leakage-rate test methods, procedures, and analyses that may be used to comply with the performance-based Option B in Ap pendix J to 10 CFR Part 50.
The information collections contained in this regu latory guide are covered by the requirements in Appendix J to 10 CFR Part 50, which have been ap proved by the Office of Management and Budget Approval number 3150-0011.
B. DISCUSSION
The Commission has stated that future regulatory initiatives should use a performance-oriented and risk based regulatory approach in which safety standards are established based upon risk, regulatory require ments are expressed in terms of meeting a perform ance standard, and regulated entities are provided flexibility to adopt cost-effective methods for comply ing with the performance-based safety standard. See Staff Requirements Memorandum dated May 18, 1994, on SECY-94-090, "Institutionalization of Con tinuing Program for Regulatory Improvement."1 In accordance with the policy that regulated entities should be allowed flexibility to adopt cost-effective methods for complying with regulatory requirements, detailed technical methods for compliance with the performance standar
d would not be incorporated into the regulatory requirement. Instead, the detailed methods would be described either in NRC regulatory guides or in industry standards and guidance docu ments that are reviewed and approved by the NRC lCopies are available for inspection or copying for a fee from the NRC Public Document Room at 2120 L Street NW., Washington, DC; the PDR's mailing address Is Mall Stop LL-6, Washington, DC 20555; telephone (202)634-3273; fax (202)634-3343.
USNRC REGULATORY GUIDES Written comments may be submitted to the Rules Review and Directives
Branch, DFIPS, ADM, U.S. Nuclear Regulatory Commission, Washing Regulatory Guides are Issued to describe and make available to the public ton, DC 20555-0001.
such information as methods acceptable to the NRC staff for Implement
ing specific parts of the Commission's regulations, techniques used by The guides are Issued In the following ten broad divisions:
the staff In evaluating specific problems or postulated accidents, and    1. Power Reactors    6. Products
data needed by the NRC staff In its reviewofapplicatlons for permits and    2. Research and Test Reactors 7. Transportation
licenses. Regulatory guides are not substitutes for regulations, and com-    3. Fuels and Materials Facilities S. Occupational Health
pliance with them Is not required. Methods and solutions different from    4. Environmental and Siting 9. Antitrust and Financial Review
those set out In theguldes will be acceptable If they provide a basis forthe    5. Materials and Plant Protection 10. General
findings requisite to the Issuance or continuance of a permit or license by Single copies of regulatory guides may be obtained free of charge by writ
the Commission. Ing the Office of Administration, Attention: Distribution and Services
Section, U.S. Nuclear Regulatory Commission, Washington, DC
This guide was Issued after consideration of cornments received from the 20555-0001; or by fax at (301)415-2260.
public. Comments and suggestions for Improvements in these guides are Issued guides may also be purchased from the National Technical infor
encouraged at all times, and guides will be revised, as appropriate, to mation Service on a standing order basis. Details on this service may be
accommodate comments and to reflect new Information or experience, obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.
I
staff as an acceptable means for demonstrating com pliance with the regulatory requirement.
Consistent with this approach, the revision to Ap pendix J of 10 CFR Part 50 is less prescriptive, utilizes risk-based insights, and allows the licensee the flexibil ity to adopt cost-effective methods, including setting test intervals, for implementing the safety objectives underlying the requirements of Appendix J. This regu latory guide approves an industry guideline that de scribes in detail a performance-based leak-test pro gram, leakage-rate test methods, procedures, and analyses; the NRC staff has determined this industry guideline to be an acceptable means of demonstrating compliance with the requirements of the amendment of Appendix J to 10 CFR Part 50.
C. REGULATORY POSITION
NEI 94-01, Revision 0, dated July 26, 1995, "In dustry Guideline for Implementing Performance Based Option of 10 CFR 50 Appendix J,"I prepared by the Nuclear Energy Institute, provides methods ac ceptable to the NRC staff for complying with the provi sions of Option B in Appendix J to 10 CFR Part 50, subject to the following:
1. NEI 94-01 references ANSI/ANS-56.8-1994,
"Containment System Leakage Testing Require
ments,"2 for detailed descriptions of the technical
methods and techniques for performing Types A,
B, and C tests under the amendment of Appendix
J to 10 CFR Part 50. However, as stated in NEI
94-01, the test intervals in ANSI/ANS 56.8-1994
are not performance-based. Therefore, licensees
intending to comply with Option B in the amend
ment to Appendix J should establish test intervals
based upon the criteria in Section 11.0 of NEI
94-01, rather than using the test intervals speci
fied in ANSI/ANS-56.8-1994. All other techni
cal methods and techniques for performing Types
A, B, and    C tests contained in ANSI/
ANS-56.8-1994 are acceptable to the NRC staff.
2. Section 11.
3.2, "Programmatic Controls," of NEI
94-01 provides guidance for licensee selection of
an extended interval greater than 60 months or 3
refueling cycles for a Type B or Type C tested
component. Because of uncertainties (particular
ly unquantified leakage rates for test failures, re
2 Copies may be obtained from the American Nuclear Society, 555 North Kensington Avenue, La Grange Park, Illinois 60525.
petitive/common mode failures, and aging ef
fects) in historical Type C component perform
ance data, and because of the indeterminate time period of three refueling cycles and insufficient
precision of programmatic controls described in Section 11.3.2 to address these uncertainties, the guidance provided in Section 11.3.2 for selecting
extended test intervals greater than 60 months for
Type C tested components is not presently en
dorsed by the NRC staff. Further, the interval for
Type C tests for main steam and feedwater isola
tion valves in BWRs, and containment purge and
vent valves in PWRs and BWRs, should be limited
to 30 months as specified in Section 3.3.4 of
ANSI/ANS-56.8-1994, with consideration given
to operating experience and safety significance.
3. Section 9.2.1, "Pretest Inspection and Test
Methodology," of NEI 94-01 provides guidance
for the visual examination of accessible interior
and exterior surfaces of the containment system
for structural problems. These examinations
should be conducted prior to initiating a Type A test, and during two other refueling outages be
fore the next Type A test if the interval for the Type A test has been extended to 10 years, in order to allow for early uncovering of evidence of structural deterioration.
4. Section 10.2.3.3 states that an as-found Type C
test or an alternative test or analysis is to be per
formed prior to any maintenance, repair, modifi
cation, or adjustment activity if it could affect a
valve's leak-tightness. "Alternative test or analy
sis" is not endorsed as an appropriate substitute
for an as-found test, because the as-found test provides clear and objective evidence of perform
ance of isolation components.
D. IMPLEMENTATION
The purpose of this section is to provide informa tion to applicants and licensees regarding the NRC staff's plans for using this regulatory guide.
Except in those cases in which an applicant or li censee proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, the methods described in this guide re flecting public comments will be used in the evaluation of submittals for construction permits and operating li .censes (as appropriate) and will be used to evaluate the implementation of Option B of Appendix J to 10 CFR Part 50.
1.163-2
REGULATORY ANALYSIS
A regulatory impact analysis has been prepared for the revision to Appendix J of 10 CFR Part 50 and t
his regulatory guide. The analysis is available for in spection or copying for a fee in the Commission's Pub-lic Document Room, 2120 L Street NW., Washington, DC; the PDR's mailing address is Mail Stop LL-6, Washington, DC 20555; phone (202)634-3273; fax (202)634-3343.
Federal Recycling Program
1.163-3