Text

ER-W3-2005-0378-000, Outside Containment Leak Reduction Program Test Medium Change
	ML061280112
Person / Time
Site:	Waterford
Issue date:	09/14/2005
From:	Pickering C; Entergy Nuclear South
To:	; Office of Nuclear Reactor Regulation
References
	ER-W3-2005-0378-000
	Download: ML061280112 (11)
	v • d • e

1.

OVERVIEW/ SIGNATURES Facility : Waterford 3 Steam Electric Station Document Reviewed : ER-W3-2005-(3378 ChangelRev. : NAI00 System Designator(s)/Description : CVR, HRA, PASS Description of Proposed Change :

CR-WF3-20040340 Corrective Action #2 requires ER-W3-2005-0378 to change FSAR Section 11.9.37.0 to specifically state that Containment Vacuum Relief (CVR) Essential Instrument Lines, Hydrogen Analyzers (HRAs), and Gaseous portions of the Post Accident Sampling System (PASS) testing may use instrument air in addition to an inert gas or nitrogen for system testing per STA-0031-0fl4.

Check the applicable review(s) : (Only the sections indicated must be includes! in the Review.)

Preparer :

Chris Pickerin Name (print)/1 Signature l~Cornpagy 1 Department 1 Dat Reviewer:

Kenneth Bou& auxk' 6~6-t~ l

/Engineering/ 2 Name (print) / Signature 1 Company~rtment I t

OSRC:

Cl

~j Chairman same (pri } I Signature i to tRequired only for Programmatic Exclusi Screenings and 501.59 Evaluations.]

LI-1011-0t, Rev. 7 Effective Date : 213105

[]

50.59 EVALUATION EXEMPTION Sections 1, 11, and III required 50.59 EVALUATION (# :

05-C Q-3

)

Sections 1, 11, and IV required

Page 2of11 11. SCREENINGS A.

Licensing Basis Document Review 1.

Does the proposed activity impact the facility or a procedure as described in any of the following Licensing Basis Documents?

' If "YES," see Section 5.2[5l

. No LBQ change is required If "YES,' notify the responsible department and ensure a 50.54 Evaluation is performed. Attach the 50.54 Review.

' Changes to the Emergency Plan, Fir,- Protection Program, and Offsite Dose Calculation Manual must be approved by the OSRC in accordance with NMM OM-119.

If "YES," evacuate the change in accordance with the requirements of the facility's Operating License Condition or under 50.59, as appropriate LI-101-01, Rev. 7 Effective Date. 213105 LBDS controlled under other

~. YES--F1 T

-CHANGE # (if applicable) and/or SECTIONS regulations e

IMPACTED Quality Assurance Program Manual Emergency plan2' 3 Fire Protection Program 4 L1 loom],

(Includes the Fire Hazards Analysis)

Off site Dose Calculations Manua13, 4 If "YES", evaluate any changes in accordance with the appropriate regulation AND initiate an LBD change in accordance with NMM ENS-LI-113. No further 50.59 review is required.

LBDs controlled under 50.53

..--jYES - NO

. i CHANGE # (if applicable) and/or SECTIONS IMPACTED FSAR F-1 I DRN-t05-1265 i

TS Bases Technical Requirements Manual Core Operating Limits Report NRC Safety Evaluation Report and supplements for the initial FSAR'

. NRC Safety Evaluations for

[l

' 1 amendments to the Operating License' J

If "YES", perform an Exemption Review per Section III OR perform a 50.59 Evaluation per Section IV OR obtain NRC approval prior to implementing the change. If obtaining NRC approval, document the LBD

[ change in Section II.A.5 ; no further 50.59 review is required. However, the change cannot be implemented until approved by the NRC. AND initiate an LSD change in accordance with NMM ENS-L1-113.

Operating License YES 4 NO CHANGE # and/or SECTIONS IMPACTED Operating License E

TS NRC Orders

~I If "YES", obtain NRC approval prior accordance with NMM ENS-LI-113.

to implementing the change by initiating an LBD change in (See Section 5.2[13] for exceptions.)

2.

Does the proposed activity involve a test or experiment not described in the FSAR?

Yes No 3.

If "yes, perform a 50.59 Evaluation per Section IV OR obtain NRC approval prior to implementing the change AND initiate an LBD change in accordance with NMM LI-1'13.

If obtaining NRC approval, document the change in Section II.A.5 ; no further 5[1.59 review is required. However, the change cannot be implemented until approved by the NRC.

Basis Explain why the proposed activity does or does not impact the Operating LicensefTechnical Specifications and/or the FSAR and why the proposed activity does or does not involve a new test or experiment not previously described in the FSAR. Discuss other LBDs if impacted. Adequate basis must be provided within the Screening such that a third-party reviewer can reach the same conclusions. Simpiy stating that the change does not affect TS or the FSAR is not an acceptable basis.

An electronic search of Licensing Basis Documents was conducted using the LRS Retrieval function of Autonomy (WF3) with the 50.59 Search filter applied, Quality set to 20%, and using the search terms listed in Section II.A.4. Some hits were redundant to documents that had already been manually reviewed. The remaining hits were either not relevant to the scope of the reviewed revision or only provided confirmatory or peripheral information. FSAR sections identified by the electronic search were reviewed as well as Change Notices (DRNs) against those FSAR sections. This review found no applicability to or impact upon the proposed changes by the reviewed sections and Change Notices under this portion of the 50.59 review. There were no conflicts found between the evaluated change items and the Environmental Protection Plan, Security Plan, or the QAPM.

ER-W3-2005-0378 changed FSAR Section 1.9.37.0 to specifically state that Containment Vacuum Relief (CVR) Essential Instrument Lines, Hydrogen Analyzers (HRAs), and Gaseous portions of the Post Accident Sampling System (PASS) testing is required to use an inert gas, nitrogen, or instrument air for system testing by visually inspecting for leakage with a soapy solution.

Previously FSAR Section 1.9.37.0 stated that CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS only used an inert gas or nitrogen to perform testing (or equivalent method The FSAR 1.9.37.0 statement intent was to be in accordance with NUREG-0737 Item 111.D.1.1 for monitoring leakage and to reduce detected leakage to as low as practical levels for systems outside containment which could contain radioactivity post accident. NUREG-0737 Item 11).D.1.1 specifically states that testing of gaseous system should include helium leak detection or equivalent testing method. The response to the NUREG-0737 Item III.D.1.1 requirement was to use an equivalent method of pressurizing the system and inspecting for leaks with a soapy solution. The FSAR specifically identifies the use of an inert gas or nitrogen to pressurize the system. The FSAR change is just explicitly listing that instrument air can be used and does not change the equivalent method identified which is to inspect a pressurized system for leaks using a soapy solution.

CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS normal system fluid medium is air. Specifically, these systems sample from and are exposed to the containment atmosphere (Drawings B430 SP01A. B430 SP01 B, B430 DP26, B430 DP291. The use of instrument air as a testing medium is not exposing the CVR Essential Instrument Lines, HRAS, and Gaseous portions of the PASS systems to any environment different than normal.

Instrument air is a clean dry air system. The use of this system to pressurize the CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS systems does not pose a threat of contamination or pollutants entering those systems. Instrument air will has similar properties to the inert gases for the identification of system leakage using a soapy solution. The use of instrument air to pressurize the identified systems is an equivalent method.

LI-101-01, Rev. 7 Effective Date_ 213105

Page 4 of 11 Operating License/Technical al SPecificati©.ns 50.59 REVIEW FORM -

Technical Specification (TS) Section 6.8 provides administrative controls for procedures and programs. TS 6.8.1 requires written procedures to be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide (RG) 1.33 Revision 2 (Quality Assurance Program Requirements) Appendix A.

RG 1.33 Appendix A recommends that procedures should be established for operation and surveillance testing.

TS 6.8.1 and RG 1.33 only provide that a surveillance and operation procedures are required.

It does not provide specifics on what is to be included in the procedure or specific equipment information

. Thus, the proposed changes are above the level of detail that is explicitly required.

Technical Specification (TS) 3.6.1.2 requires that the overall containment leakage rate and the secondary containment bypass leakage rate shall be in accordance with the Containment Leakage Rate Testing Program. TS 3.6.1.2 is applicable in Modes 1-4. The proposed change does not impact this TS.

TS 6.15 (CONTAINMENT LEAKAGE RATE TESTING PROGRAM) requires that a program shall be established to implement the leakage rate testing of containment as required by 1 OCFR50.54(o) and 1 OCFR50 Appendix J Option B as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163. The proposed change does not affect the testing program.

TS 6.8.4.a lists the program requirements to ensure that leakage from systems that could contain highly radioactive fluid to as low as practical levels. TS 6.8.4.a does not list specifics for testing media.

TS 3.6.3 requires that each containment isolation valve shall be OPERABLE. TS 3.6_3 is required in Modes 1-4. Technical Requirements Manual (TRM) Table 3.6-2 lists the applicable containment isolation valves. The proposed change does not impact this TS or TRM.

Technical Requirements Manual (TRM) 3.6.4.1 requires 2 independent hydrogen analyzers be OPERABLE in Modes 1-2. The proposed change does not affect the operation or flow paths to the hydrogen analyzers.

TS 3.6.5 requires 2 containment vacuum relief lines be OPERABLE in Modes 1-4

. The proposed change does not affect the operation or flow paths through the CVR system.

This change does not after the Operating License or Technical Specifications but rather reflects conditions that have already been addressed by other procedures. The LCOs, surveillances and other controls in the Operating License and Technical Specifications are not impacted by this change.

Final Safety Analysis Report (FSAR)

FSAR Section 13.5 (Plant Procedures) describes the operating procedures that are used by the plant operations organization to ensure that routine operating, off-normal, and emergency activities are conducted in a safe manner. FSAR Section 13.5.1.3 (Procedures) explicitly lists operation and surveillance testing procedures that were generated.

FSAR Section 13.5 only provides that a surveillance procedures and system operation procedures are required.

It does not provide specifics on what is to be included in the procedure or specific LI-101-01, Rev. 7 Effective Date : 213105

age 5of11 50.59 REVIEW FORM m

equipment information. Thus, the proposed changes are above the level of detail that is explicitly required.

ER-W3-2005-0378 changed FSAR Section 1.9.37.C to specifically state that Containment Vacuum Relief (CVR) Essential Instrument Lines, Hydrogen Analyzers (HRAs), and Gaseous portions of the Post Accident Sampling System (PASS) testing is required to use an inert gas, nitrogen, or instrument air for system testing by visually inspecting for leakage with a soapy solution_

FSAR Section 9.3.8 describes the Post Accident Sampling System (PASS). The PASS system is designed on the criteria set forth on NUREG-0660 and NUREG-0737 Item II.B.3 which deals with the implementation of capabilities for sampling the reactor coolant system and containment atmosphere during post accident conditions. All lines in the PASS are constructed of corrosion resistant stainless steel. Each portion of the system is designed for source pressure and temperature [FSAR 9.3.8.3],

This FSAR section does not explicitly address the system leakage tests or associated testing medium.

FSAR Section 6.2.5 describes the combustible gas control system in containment_ The HRA system has the capability of sampling and measuring the containment atmosphere at various locations. The HRA system is available for periodic testing and inspection [FSAR 6.2.5.1]. This FSAR section does not explicitly address the system leakage tests or associated testing medium.

FSAR Section 6.2_4.2.2 describes the CVR Essential Lines. The essential line senses differential pressure across the containment vessel and provides a signal to actuate the Vacuum Relief Valves.

This FSAR section does not explicitly address the system leakage tests or associated testing medium.

Electronic and Manual searches showed that some of the keywords used are found in sections of the FSAR. However, none of the changes to the FSAR impact the way these system, structures or components (SSCs) are described, drawn, or applied in the FSAR.

New Test or Experiment ER-W3-2005-0378 changed FSAR Section 1.9.37.C to specifically include instrument air as a testing medium. The STA-001-004 procedure has been previously approved and is already testing CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS for the purpose of measuring leakage past the boundary valves as part of the Appendix J Containment Leakage program. Thus, this change does not modify the testing methodology or components tested. The same tests are performed and no new tests have been created. Thus, this change does not involve an activity not described in the FSAR.

CONCLUSION In conclusion, ER-W3-2005-0378 change to FSAR Section 1.9.37.C is the only Waterford 3 Licensing Basis Documents impacted.

L1-101-01, Rev. 7 Effective Date : 213105

age 6 of 11

4.

References Discuss the methodology for performing LSD searches. State the location of relevant licensing document information and explain the scope of the review such as electronic search criteria used (e.g., key words) or the general extent of manual searches per Section 5.5.1[51(d) of LI-101. NOTE : Ensure that manual searches are performed using controlled copies of the documents. If you have any questions, contact your site Licensing department.

LBDs/Documents reviewed via keyword search :

Waterford 3 AUTONOMY was used to search :

Technical Specifications and Bases Technical Requirements Manual and Bases Final Safety Analysis Report FSAR Questions Safety Evaluation Report SER (NUREG-0787)

LBDs/Documents reviewed manually :

FSAR sections identified by the electronic search and Change Notices (DRNs) against those FSAR sections.

FSAR Sections 1.9.20, 1.9.37, 3.8.2.3, 6.2.4.2.2, 6.2.3, 6.2.5. 9.3.8, 13.5 Technical Specifications and Bases Technical Requirements Manual and Bases Commitment A17806, P17601, P17895, P20306, P24336, P24240, P24239 50.59 REVIEW FORM Keywords :

.'leakage rate" (HITS 71)

"LLRT- (HITS 7)

"leak rate" (HITS 79)

"decay test" (HITS 7)

"pressure test" (HITS 73)

"hydrogen analyzer" (HITS 43) `HRA" (HITS 13)

"accident sampling (HITS 23) "PASS" (HITS 162)

"vacuum relief' (HITS 44)

"CVR" (HITS 14) inert (HITS 26) 111.D.1.11" (HITS 9)

REFERENCE DOCUMENTS 1. Technical Specification 16A.2,3-6,3,3.6.5,6.8,6.15 2. Technical Requirements Manual 3.6.4.1 and Table 3.6-2 Final Safety Analysis Report 1.9.201, 1-9.37, 3.8.2.3, 6.2.4.2.2, 6.2.3, 10CFR50.34, Contents of applications ; technical information NRC Supplemental Safety Evaluation Report 8 Section 111.13.1.1 Regulatory Guide 1.33 Revision 2, Quality Assurance Program Requirements NUREG-0737, TMI NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations 9. NUREG-0660, NRC Action Plan Developed as a Result of the TMI-2 Accident 10. NUREG-0694, TMI Related Requirements for New Operating Licenses 11. NUREG-0933, 12. NUREG-0800, Standard Review Plan 13. 1E Circular No. 7921, Prevention of Unplanned Releases of Radioactivity 14. Information Notice No. 86-60, Unanalyzed Post LOCA Release Paths 15. STA-001-004, Local Leak Rate Tests 16. ANSIJANS-56.8-1981, Containment System Leakage Testing Requirements 3.

4.

5.

6.

7.

8-5.

Is the validity of this Review dependent on any other change?

If "YES", list the required changes/submittals. The changes covered by this 50.59 Review cannot be implemented without approval of the other identified changes (e.g., license amendment request).

Establish an appropriate notification mechanism to ensure this action is completed.

LI-101-01, Rev. 7 Effective Date : 213105 6.2.5

. 9.3_8, 13.5, 15 0 Yes No

B.

ENVIRONMENTAL-SCREENING If any of the following questions is answered "yes," an Environmental Review must be performed in accordance with NMM Procedure ENS-EV-115, "Environmental Evaluations, and attached to this 50.59 Review. Consider bath routine and non-routine (emergency) discharges when answering these questions.

Will the proposed Change being evaluated :

4.

L^]

50.59 REVIEW FORM Involve a land disturbance of previously disturbed land areas in excess of one acre (i.e.,

grading activities, construction of buildings, excavations, reforestation, creation or removal of ponds)?

2_

3.

El Involve dredging activities in a lake, river, pond, or stream?

Increase the amount of thermal heat being discharged to the river or lake?

5.

6.

[J Discharge any chemicals new or different from that previously discharged?

7.

[l Change the design or operation of the intake or discharge structures?

8.

9.

Modify the design or operation of the plant that will change the path of an existing water discharge or that will result in a new water discharge?

10.

11.

El involve the installation of stationary fuel burning equipment or use of portable fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

12.

El Involve the installation or use of equipment that will result in a new or additional air emission discharge?

13.

[1 Involve the installation or modification of a stationary or mobile tank?

14. D Involve the use or storage of oils or chemicals that could be directly released into the environment?

15. 0 Involve burial or placement of any solid wastes in the site area that may affect runoff, surface water, or groundwater?

' See NMM Procedure ENS-EV-117, "Air Emissions Management Program," for guidance in answering this question.

U-101-01, Rev. 7 Effective Rate : ?,13/05

Page 8 of 11 G.

SECURITY PLAN SCREENING LI-9 01-01, Rev. 7 Effective Date : 2/3105 Documentation for acce Review or referenced below.

If any of the following questions is answered "yes," a Security Plan Review must be performed by the Security Department to determine actual impact to the Plan and the need for a change to the Plan.

Could the proposed activity being evaluated :

50.59 REVIEW FORM any "yes" statement for these reviews will be attached to this 50.59 Yes d

Add, delete, modify, or otherwise affect Security department responsibilities (e.g.,

including fire brigade, fire watch, and confined space rescue operations)?

2.

[l Result in a breach to any security barrier(s) (e.g., HVAC ductwork, fences, doors, walls, ceilings, floors, penetrations, and ballistic barriers)?

3 F~

Cause materials or equipment to be placed or installed within the Security Isolation Zone?

4.

El Affect (block, move, or alter) security lighting by adding or deleting lights, structures, buildings, or temporary facilities?

El 2 Modify or otherwise affect the intrusion detection systems (e.g,, lw-fields, microwave, fiber optics)?

6.

El 0 Modify or otherwise affect the operation or field of view of the security cameras?

7

[]

P Modify or otherwise affect (block, move, or alter) installed access control equipment, intrusion detection equipment, or other security equipment?

8_

Modify or otherwise affect primary or secondary power supplies to access control equipment, intrusion detection equipment, other security equipment, or to the Central Alarm Station or the Secondary Alarm Station?

9.

[]

Modify or otherwise affect the facility's security-related signage or land vehicle barriers, including access roadways?

10

[]

Modify or otherwise affect the facility's telephone or security radio systems?

Page 9 of 11 IV.

511.59 EVALUATION License Amendment Determination Does the proposed Change BASIS :

BASIS:

LI-101-01, Rev. 7 Effective Date : 213105 50.59 REVIEW FORM Does the proposed Change being evaluated represent a change to a method of evaluation Yes ONLY? If "Yes, Questions I -- 7 are not applicable ; answer only Question 8. If "No," answer No all questions below.

1.

Result in more than a minimal increase in the frequency of occurrence of an accident

[] Yes previously evaluated in the FSAR?

o The proposed change affects CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS.

These systems are used post accident for specific functions. These systems are not an accident initiator.

This means that the frequency of occurrence of an accident has not risen because the failure of any of these systems is not an accident and correspondingly would not affect the frequency.

2.

Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a

[ Yes structure, system, or component important to safety previously evaluated in the FSAR?

No CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS normal system fluid medium is air. Specifically, these systems sample from and are exposed to the containment atmosphere

[Drawings B430 SPOIA, B430 SPO1 B, B430 DP26, B430 DP29. The use of instrument air as a testing medium is not exposing the CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS systems to any environment different than normal.

Instrument air is a clean dry air system. The use of this system to pressurize the CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS systerns does not pose a threat of contamination or pollutants entering those systems. The response to the UREG-0737 Item III.D.1.1 requirement was to use an equivalent method of pressurizing the system and inspecting for leaks with a soapy solution. The FSAR specifically identifies the use of an inert gas or nitrogen to pressurize the system. The FSAR change is just explicitly listing that instrument air can be used and does not change the equivalent method identified which is to inspect a pressurized system for leaks using a soapy solution.

Since, the testing medium (air) is the same as the system normal operating medium, the likelihood of this change causing a malfunction in the specified system has not risen.

3.

Result in more than a minimal increase in the consequences of an accident previously F1 Yes evaluated in the FSAR?

BASIS:

The CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS change specifically allows the use of instrument air as a testing medium. The use of instrument air as a testing medium is not exposing the CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS systems to any environment different than normal.

The system functions and components are not changed or affected by this change. Thus, CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS post accident functions and failure modes have not changed. This also means that the consequences of an accident previously evaluated has not changed.

4.

Result in more than a minimal increase in the consequences of a malfunction of a structure,

BASIS:

BASIS :

LI-101-01, Rev. 7 Effective Date: 213105 50.59 REVIEW FORM No No The CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS change specifically allows the use of instrument air as a testing medium

. The use of instrument air as a testing medium is not exposing the CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS systems to any environment different than normal.

The system functions and components are not changed or affected by this change. Thus, CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS post accident functions and failure modes have not changed. This also means that the consequences of an equipment malfunction previously evaluated has not changed.

5.

Create a possibility for an accident of a different type than any previously evaluated in the El Yes FSAR?

No The proposed change affects CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS These systems are used post accident for specific functions. These systems are not an accident initiator.

This means that a new or different accident can not be initiated by one of these systems.

The system functions and components are not changed or affected by this change. Thus, CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS post accident functions and failure modes have not changed. A single failure in these systems will not create a new or different accident than was previously evaluated.

Page 11 of 11 BASIS:

BASIS:

LI-101-01, Rev. 7 Effective Date : 213105 50.59 REVIEW FORMY.

6.

Create a possibility for a malfunction of a structure, system, or component important to safety El Yes with a different result than any previously evaluated in the FSAR?

No The CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS change specifically allows the use of instrument air as a testing medium. The use of instrument air as a testing medium is not exposing the CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS systems to any environment different than normal.

The proposed change affects CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS.

These systems are used post accident for specific functions. The system functions and components are not changed or affected by this change. Thus, CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS post accident functions and failure modes have not changed.

Since, the structure, system, and components are not affected by this change, the possibility of a malfunction with different results has not been created.

7 Result in a design basis limit for a fission product barrier as described in the FSAR being E3 Yes exceeded or altered?

No The proposed change affects CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS These systems are used post accident for specific functions. The system functions and components are not changed or affected by this change. Thus, CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS post accident functions and failure modes have not changed which also means that fission product barriers (fuel, reactor coolant system, and containment) limits have not changed.

8.

Result in a departure from a method of evaluation described in the FSAR used in establishing Yes the design bases or in the safety analyses?

No Previously FSAR Section 1.9.37.0 stated that CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS only used an inert gas or nitrogen to perform testing (or equivalent method

. The FSAR 1.3.37.0 statement intent was to be in accordance with NUREG-[1737 Item III.D.1.1 for monitoring leakage and to reduce detected leakage to as low as practical levels for systems outside containment which could contain radioactivity post accident

. NUREG-0737 Item III.D.1,1 specifically states that testing of gaseous system should include helium leak detection or equivalent testing method. The response to the NUREG-0737 Item III-D.1.1 requirement was to use an equivalent method of pressurizing the system and inspecting for leaks with a soapy solution. The FSAR specifically identifies the use of an inert gas or nitrogen to pressurize the system. The FSAR change is just explicitly listing that instrument air can be used and does not change the equivalent method identified which is to inspect a pressurized system for leaks using a soapy solution CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS normal system fluid medium is air. Specifically, these systems sample from and are exposed to the containment atmosphere

[Drawings B430 SP01A, B430 SPQIB, B430 DP26, B430 DP291. The use of instrument air as a testing medium is not exposing the CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS systems to any environment different than normal.

Instrument air is a clean dry air system. The use of this system to pressurize the CVR Essential Instrument Lines, HRAs, and Gaseous portions of the PASS systems does not pose a threat of contamination or pollutants entering those systems. Instrument air will has similar properties to the inert gases for the identification of system leakage using a soapy solution. The use of instrument air to pressurize the identified systems is an equivalent method.

If any of the above questions is checked "YES", obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure ENS-1_I-113.

ML061280112

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