Text

Supplemental Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems.
	ML090540060
Person / Time
Site:	Robinson
Issue date:	02/13/2009
From:	Baucom C; Progress Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-08-001, RNP-RA/09-0007
	Download: ML090540060 (14)
	v • d • e

10 CFR 50.54(f)

& Progress Energy Serial: RNP-RA/09-0007 FEB 1.3 2009 United States Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/LICENSE NO. DPR-23 SUPPLEMENTAL RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" Ladies and Gentlemen:

On January 11, 2008, NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," was issued requesting that licensees provide a response within nine months. Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. (PEC), provided a response for H. B.

Robinson Steam Electric Plant (HBRSEP), Unit No. 2, on October 14, 2008.

In that letter HBRSEP, Unit No. 2, committed to providing a supplemental response 90 days following the completion of Refueling Outage 25. Based on discussion with the NRC Project Manager, it was determined that an additional week was amenable for submitting the requested information. PEC is providing the supplemental response for HBRSEP, Unit No. 2, in Attachment II to this letter.

Attachment I provides an Affirmation in accordance with the provisions of Section 182a of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f).

If you have any questions concerning this matter, please contact Mr. C. A. Castell at (843) 857-1626.

Sincerely, C. T. Baucom Manager - Support Services - Nuclear CTB/ahv Progress Energy Carolinas, Inc.

Robinson Nuclear Plant 3581 West Entrance'Road Hartsville, SC 29550 4 3

United States Nuclear Regulatory Commission Serial: RNP-RA/08-0036 Page 2 of 2 Attachments:

I. Affirmation II. Supplemental Response to NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" c: L. A. Reyes, NRC, Region II M. G. Vaaler, NRC, NRR NRC Resident Inspector

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/09-0007 Page 1 of 1 AFFIRMATION The information contained in letter RNP-RA/09-0007 is true and correct to the best of my information, knowledge, and belief; and the sources of my information are officers, employees, contractors, and agents of Carolina Power and Light Company, also known as Progress Energy Carolinas, Inc. I declare under penalty of perjury that the foregoing is true and correct.

Executed On: P1 9/09 E. A. PMcCaU-tney N.

Site Vice President, HBRSEP, Unit No. 2

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 1 of 11 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 SUPPLEMENTAL RESPONSE TO NRC GENERIC LETTER 2008-01, "MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS" In the nine-month response to Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," Progress Energy Carolinas, Inc. (PEC), H. B. Robinson Steam Electric Plant, Unit No. 2, committed to providing a 90-day supplemental response following the completion of Refueling Outage 25 (RO-25). Based on discussion with the NRC Project Manager, it was determined that an additional week was amenable for submitting the requested information. The following provides the supplemental information:

1) Updated summary of locations potentially susceptible to gas accumulation based on containment walkdowns completed in RO-25.

System walkdowns have been completed for the previously inaccessible sections of piping. In addition to physical walkdowns, the system walkdowns employed the use of a laser scanning technique, which supported the development of three-dimensional models.

The walkdowns and modeling were performed to confirm the location and orientation of system vents, and to identify areas potentially vulnerable to gas accumulation.

Table 1, "Locations Susceptible to Gas Accumulation," provides a listing of susceptible locations based on the design reviews and walkdowns completed prior to and during RO-

25. Ultrasonic testing (UT) was performed at each of the 67 identified locations and the results of the UT are provided in Table 1. (Note that the October 14, 2008, letter identified 69 susceptible locations. Two of those locations were subsequently determined to be part of the Chemical and Volume Control System, which is not within the scope of Generic Letter 2008-01.)

2) Resolution for void detection and control at the identified locations potentially susceptible to gas accumulation, including the location of new vent valves installed or planned for installation.

The voids found before and during RO-25 were determined to not impact the safety function of the associated systems. The voids were evaluated in accordance with the Corrective Action Program (CAP). Evaluations considered and utilized, as appropriate, gas transport analysis, Owners Group pump suction void fraction acceptance criteria, Net Positive Suction Head requirements, Reactor Coolant System void acceptance criteria, structural design capabilities, and relief valve setpoints.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 2 of 11 The locations of vent valves installed during RO-25 are described in Table 1. One additional vent valve is currently planned for installation during the next refueling outage, as described in Table 1. Seven voids remained in the affected systems at the end of RO-25 that were determined to be acceptable. These voids are listed in Table 2, "Post Fill and Vent RO As Left Voids." These void locations will be ultrasonically tested on a quarterly basis as part of the new program for void detection. Alternative techniques for monitoring these voids on a longer-term basis may be evaluated to help minimize the radiological impacts associated with UT of these locations.

3) A description of the new program for void detection.

HBRSEP, Unit No. 2, will implement a program for the detection and control of voids in the subject systems by April 30, 2009. UT will be used for the identification of voids and for quantifying void volumes. Table 1 is divided into two sections. The first section provides those locations that will be tested on a quarterly frequency due to their relatively higher potential for gas accumulation. The locations in the second section of Table 1 were tested for GL 2008-01. The testing frequencies for the locations shown in Table 1 are subject to change based on the results of evaluation in accordance with program requirements.

4) Listing of new procedures or procedure changes to be made for filling and venting.

A listing of new procedures and procedure changes for filling and venting is provided in Table 3, "List of New Procedures/Changes in Procedures for Filling/Venting, Operations, Testing, or Maintenance." The procedure revisions are currently scheduled to be completed by April 30, 2009.

5) Listing of procedure changes to be made to operations, testing, or maintenance procedures to prevent, detect, or mitigate gas intrusion.

A listing of operations, testing, or maintenance procedures requiring changes to prevent, detect, or mitigate gas intrusion is provided in Table 3. The procedure revisions are currently scheduled to be completed by April 30, 2009.

Following completion of evaluations, walkdowns, and testing, PEC has concluded that the SI, RHR, and CS Systems are operable, as required by Technical Specifications, are in conformance with commitments to the applicable General Design Criteria (GDC), as stated in the UFSAR, and are in conformance with commitments to 10 CFR 50, Appendix B, Criterion III, V, XI, XVI, and XVII.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 3 of 11 Table 1 - Locations Susceptible To Gas Accumulation (Locations for which Ultrasonic Testing will be performed on a Quarterly Frequency)

Comments Location Docation Vent valve UTViReut()20 (es, No)

System Location Designation Void (Yes, No)

Safety Pipe 4-SI-16, above the Boron Local high point, sloping upwards towards SI-2b SI-883K No Injection Injection Tank (BIT) at the reducer (SI) reducer Pipe 4-SI- 110 between orifice and Local high points SI-2c No currently; vent valve to SI-2c - No SI SI-867A/B, second local high SI-2d be installed during RO-26 at SI-2d- No point at elevation 238-9, BIT SI-2c Room Pipe 10-SI-15 at elevation 239-3 Local high point, RHR to SI/CS cross-tie. SI-6a ,b, c, d SI-968 (installed during SI-6a - Yes, 5 in. arc (four locations Pipe Alley) Ultrasonic Test (UT) at each end of the pipe and RO-25) at SI-6c SI-6b - No SI 30 percent length from north section of pipe. SI-6c - Yes, 7 in. arc SI-6d - Yes, 5 in. arc Length = 748 in.

(NCR 298036)

Pipe 6-SI-88 (four locations, SI Local high point, four locations for UT SI-9a, b, c, d SI-969 (installed during SI-9a - Yes Pump Room, Pipe Alley) 1) Elevation 242 North Pipe Alley, RO-25) at SI-9a SI-9b -No

2) Elevation 236 SI Pump Room above SI-9c - Yes "C" SI Pump, SI-9d - Yes, 4 in. arc SI 3) Elevation 242 South Pipe Alley, at the (NCR 297331) highest part of the vertical elbow

4) Elevation 233 South Pipe Alley, at the vertical elbow, pipe is about 75 feet long, from the SI Pump Room to the RHR return line

Pipe 6-SI-84, above SI-891C Local high point at the horizontal elbow SI-15 SI-972 (installed during Yes, 5 in. to 1 in. arc RO-25) at SI-15 SI-891C is locked SI closed and will not be opened. Length = 10 ft.

6 in. (NCR 297834)

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 4 of 11 Location Dsgation Vent valve UTViReut0()3 Res, No)

System Location Comments yDesignation Void (Yes, No)

Residual Pipe 10-AC-2, elbow downstream Local high point RHR-la RHR-791 (installed during Yes, 6 in. arc at one end Heat of RHR-757A (RHR Heat RO-25) at RHR-la and 3 in. arc near the Removal Exchanger Room) other end. Length = 2 ft.

(RHR) 4 in. (NCR 298039)

Pipe 10-AC-1, upstream of RHR- Local high point RHR-2 RHR-792 (installed during No RHR 757B at elevation 241-3 (RHR RO-25) at RHR-2 Heat Exchanger Room)

Pipe 4-SI-222, at SI-915 and Local high point, on both sides of the orifice RHR-3a, b SI-970 (installed during 3a - Yes, 3.5 in. total FE-608A RO-25) arc RHR SI-971 (installed during 3b - Yes, 5 in. total arc RO-25) Length = 13 ft. 6 in.

(NCR 298042)

Pipe 4-SI-224, at SI-916 and Local high point, on both sides of the orifice RHR-4a, b SI-974 (installed during 4a - No RHR FE-608B RO-25) 4b - No SI-975 (installed during RO-25)

Pipe 14-AC-9, North Pipe Alley, Local high point RHR-10 RHR-789 (installed during Yes, 8 in. maximum arc elbow above penetration to RHR RO-25) at RHR-10 Length = 14 ft. 11 in.,

RHR Pump Room void arc varies throughout the length (NCR 298044)

Pipe 12-AC-8, upstream of RHR- Local high point RHR-1RO RHR-790 (installed during Yes, 12-AC-8 744A/B at elevation 243-6, RO-25) (10 in. arc and 2 in. arc).

Penetration 17 Length = 24.7 ft.,

RHR RHR-790 is located inside the 10-AC-238 (10 in. arc).

Containment Vessel (CV). UT Length = 9 ft.

can be performed on the pipe (NCR 298198) section located in Pipe Alley.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 5 of 11 (Other areas tested for GL 2008-01)

Comments Location Lsnation Vent valve UT Vi (es, No)

Reut0()3 System Location Designation Void (Yes, No)

Between orifice and SI-867A/B, 4- Local high points SI-i No No SI SI-110, first local high point at elevation 239-8, SI Pump Room Pipe 4-SI- 110, Pipe Alley, up from Slope at the elbow, high point SI-2a No No SI 75 ft. run of piping at elevation 234-7 Near Penetration 63, Pipe Alley, Local high points SI-3 No Yes, SI Pipe 2-SI-63 Length 22 in.

(NCR 299347)

Near Penetration 62, Pipe Alley, Local high points SI-4 No Yes, 4 in. arc SI Pipe 2-SI-64 Length = 22 in.

(NCR 299334)

Near Penetration 64, Pipe Alley, Local high points SI-5 SI-873A Yes, 3 in. arc SI Pipe 2-SI-65, upstream of SI-873A Length = 59 in.

(NCR 299353)

SI Pipe 3-SI-14, SI Pump Room Local high point, slope SI-8a No No S! Pipe 3-SI-14, below SI-869 Vertical run of pipe with closed valve at the SI-8b No No (normally closed) top Pipe 3-SI-14, elevation 246-6, Local high point SI-8c No No SI above valve SI-869, South Pipe Alley, Penetration 43 SI Pipe 6-SI-93, above SI-886D Horizontal/local high point, very minor slope SI-10 No No SI Pipe 6-SI-85, above SI-891D, Pipe Local high point at vertical elbow, elevation SI-11 SI-973 (installed during No Alley 236-3 RO-25) atSI-I 1 SI Pipe 8-SI-94 Slight bow up in the middle of the pipe near a SI-12 No No tee connection SI Pipe 8-SI-95 in Middle Pipe Alley Local high point, second elbow upstream of SI-13 No No SI-863B Pipe 3-SI-12, discharge of SI Local high point at the first vertical elbow SI-14 SI-922C No SI Pump "C," above SI-888C, SI Pump Room SI Upstream of SI-873B, outside Local high point SI-IRO SI-923 No missile barrier, Pipe 2-SI-64

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 6 of 11 Comments Location Ds nation Vent valve UTVi (es , No)

Reut°)2° System Location Designation Void (Yes, No)

SI Upstream of SI-873C, outside Local high point SI-2RO No No missile barrier, Pipe 2-SI-63 SI Next to SI-875A, Pipe 10-SI-47 Local high point SI-3RO SI-875N and SI-875M, No one on each side of valve Next to SI-875B, Pipe 10-SI-48 Local high point SI-4RO SI-875P and SI-875S, one No on each side of valve SI Next to SI-875C, Pipe 10-SI-54 Local high point SI-5RO SI-875T and SI-875R, one No on each side of valve Next to SI-874C (vent valve), Local high point SI-6RO SI-874C No Pipe 2-SI-56 Next to SI-874D (vent valve), Local high point SI-7RO SI-874D No Pipe 2-SI-57 Next to SI-874E (vent valve), near Local high point SI-8RO SI-874E No Penetration 43 Near Penetration 63, Pipe Alley, Local high point SI-9RO No No Pipe 2-SI-63 Near Penetration 62, Pipe Alley, Local high point SI-IORO No No Pipe 2-SI-64 Near Penetration 64, Pipe Alley, Local high point SI-1IRO SI-873L No Pipe 2-SI-65, upstream of SI-873A Pipe 10-AC-2, between RHR- Local high point RHR-l No No RHR 757A and RHR-754A at elevation 243-0 in Pipe Alley Pipe 10-AC-2, second elbow Local high point RHR-lB No' No RHR upstream of RHR-754A at elevation 236-6 in Pipe Alley RHR Pipe 10-AC-1, at elbow above Local high point RHR-2A No No RHR-754B in Pipe Alley RHR Pipe 10-AC-1, downstream of Local high point RHR-2B No No RHR-754B in North Pipe Alley Pipe 10-AC-1, elbow in North Pipe Local high point RHR-2C No No RHR Alley corridor at penetration to RHR Pump Room RHR Pipe 6-SI-84, above SI-891C Local high point RHR-5 No No RHR Pipe 6-SI-89, above SI-891D Local high point RHR-6 No No RHR Pipe 6-SI-84, below SI-891C Vertical run of pipe with closed valve at top RHR-7 No No

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 7 of 11 Location Location Vent valve UTViReut0*)a (es, No)

System Location Comments Designation Void (Yes, No)

RHR Pipe 6-SI-89, below SI-891D Vertical run of pipe with closed valve at top RHR-8 No No RHR Pipe 12-AC-8, in Pipe Alley Elbow in South Pipe Alley RHR-9A No No RHR Pipe 12-AC-8, in Pipe Alley Upstream of FE-605 in Middle Pipe Alley RHR-9B No No RHR Pipe 12-AC-8, in Pipe Alley Downstream of FE-605 in Middle Pipe Alley RHR-9C No No Containment Pipe 4-SI-245, below SI-928 Vertical line with a normally closed valve at CS-1 Vents to RWST No Spray (CS) the top, test recirculation discharge to RWST CS Pipe 4-SI-244, below SI-925 Vertical line with a valve at the top normally CS-2 Vents to RWST No (normally closed) closed, test recirculation discharge to RWST CS Pipe 2-SI-59 Uninsulated above CV Spray Pumps CS-3, 4 SI-835A No CS Pipe 2-SI- 151 Uninsulated at CV Spray Pumps CS-5, 6 No No CS Pipe 2-SI-152 Uninsulated at CV Spray Pumps CS-7 SI-835B No CS Pipe 2-SI-153 Uninsulated at CV Spray Pumps CS-8, 9, 10 SI-835B No CS Pipe 2-SI-154 Uninsulated above CV Spray Pumps CS-11 No No (1) These are the results of the UT examinations performed just prior to or at the beginning of RO-25. As-left UTs were also performed near the end of RO-25. Refer to Table 2 for voids that were left post-RO-25 fill and vent. In some locations, there was no void present during as-found UT, but there was a void present during the as-left UT.

(2) Arc length is the outside diameter circumferential measurement of the void.

(3) The NCR number is the Corrective Action Program Nuclear Condition Report that was used to evaluate the detected void.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 8 of 11 Table 2 - Post Fill and Vent RO As Left Voids Location Designation Pipe Identification Void Fraction 1%] Void Volume [ft3l NCR No.

at Void Location SI-2c 4-SI- 110 1.791 0.0214 304243 SI-6b 10-SI-15 0.0574 0.000681 304399 SI-6d 10-SI-15 0.264 0.00157 304399 SI-9a 6-SI-88 0.573 0.0971 304429 SI-9b 6-SI-88 0.244 0.000245 304429 SI-9c 6-SI-88 8.138 0.135 304429 RHR-4a, b 4-SI-224 0.098 0.0000576 304705

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 9 of 11 Table 3 - List of New Procedures/Changes in Procedures for Filling/Venting, Operations. Testing. or Maintenance Procedure Procedure No. Revision Procedure Title Requst Description of Change No. Request (PRR) No.

Engineering Safeguards 314736 APP-002-C3 directs actions to open SI pump drain valves to reduce header pressure. The procedure contains APP-002 cautions to not vent below 50 psig to avoid gasses coming out of solution and gives direction to preferably not vent below 100 psig. The direction in the caution needs to be a "shall" instead of a "should" and the venting step needs to be revised to remove "preferably"so it is clear the intent is to not vent below 100 psig.

Cold Shutdown to Hot 314737 GP-002, Attachment 10.8, provides guidance to vent SI and CV Spray Pump casings until "a solid stream of GP-002 Subcritical at No Load Tavg water issues." Guidance is not sufficient per the GL and needs to specify an appropriatetimefor venting to ensure gas is removed Residual Heat Removal 314741 General comment - throughoutprocedure the direction is to open a vent valve until a solid stream of water is OP-201 System obtained This needs to specify an appropriatetime for venting to ensure the system is properly vented No verification is performed following the sections that vent pumps or the entire system (8.1.2, 8.1.3, and 8.1.4) to ensure affected portions of the system are properly vented.

Residual Heat Removal 287613 New procedure written to include existing RHR System venting guidance and to add additional guidance for OP-201-1 System determining the system is properly vented following activities that have the potential to affect system pressure boundary integrity.

Safety Injection and 314754 General comment - throughout most of the procedure the direction is to open a vent valve and close when OP-202 Containment Vessel Spray venting is complete. This is not sufficient per the GL and needs to specify a solidstream and an appropriate System timefor venting to ensure the system is properly vented No verification is performed following the sections that vent pumps or the BIT (8.1.2 - 8.1.6, 8.4.9, and 8.4.11) to ensure the system is properly vented.

Safety Injection and 287614 New procedure written to include existing SI System venting guidance and to add guidance for determining the OP-202-1 Containment Vessel Spray system is properly vented following activities that have the potential to affect system pressure boundary System integrity.

Safety Injection and 287615 New procedure written to include existing CV Spray System venting guidance and to add guidance for OP-202-2 Containment Vessel Spray determining the system is properly vented following activities that have the potential to affect system pressure System boundary integrity.

Pressure Isolation Check 314759 This procedure tests pressure boundary check valves. In doing so, sections of the piping are depressurized.

OST-160 Valve Back Leakage Test Refilling of these sections does not include venting or assurance of complete refill. OST-160 needs to be revised to ensure this piping is properlyfilled.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 10 of I1 Procedure Procedure No. Revision Procedure Title Requst Description of Change No. Request (eRR) No.

Accumulator Isolation and 314761 This procedure tests the Safety Injection Accumulator isolation and outlet check valves. The procedure OST-161 Check Valve Operability precautions state that nitrogen could be injected into the RCS (or as a minimum into the Accumulator outlet Test lines), but does not take sufficient steps to ensure this does not occur - need to establish limits on Accumulator level andpressure to ensure nitrogen is not injected Penetration 48, SI High Head 314765 This procedure breaches the SI System boundary by opening drain/vent/test valves. There are no provisions for Test Line (SI-895V and SI- checking the line is vented - need to revise to include steps to ensure system remainsfilled and vented OST-933-28 898F) Leakage Test - as Required And Every 18 Mo.

Penetrations 62, 63, and 64, 314767 This procedure breaches the SI System boundary by opening drain/vent/test valves. There are no provisions for Cold Leg SI Headers (SI- checking the line is vented - need to revise to include steps to ensure system remainsfilled and vented OST-933-4 870A/B, SI-883L, and SI-883W) Leakage Test - as Required And Every 18 Mo.

Penetration 44, Containment 314769 This procedure breaches the CV Spray System boundary by opening drain/vent/test valves. There are no Spray Header A Supply Line provisions for checking the line is vented - need to revise to include steps to ensure system remainsfilled and T-933-5 (SI-891A) Leakage Test - as vented Required and Every 18 Mo.

Penetration 45, Containment 314781 This procedure breaches the CV Spray System boundary by opening drain/vent/test valves. There are no Spray Header B Supply Line provisions for checking the line is vented - need to revise to include steps to ensure system remainsfilled and OST-933-6 (SI-891B) Leakage Test - as vented Required and Every 18 Mo.

Penetration 43, Hot Leg SI 314784 This procedure breaches the CV Spray System boundary by opening drain/vent/test valves. There are no OST-933-7 Header (SI-869) Leakage provisions for checking the line is vented - need to revise to include steps to ensure system remainsfilled and Test - as Required and Every vented 18 Mo.

Containment Spray (CS) 314788 OWP-004 provides guidance to support maintenance activities on the CV Spray System. For maintenance on a OWP-004 CV Spray Pump, filling and venting is directed in accordance with OP-202. Filling and venting is not directed following work on other components - need to establish guidancefor filling and venting of other components.

Residual Heat Removal 314799 OWP-013 provides guidance to support maintenance activities on the RHR System. For maintenance on an OWP-013 System (RHR) RHR Pump, filling & venting is directed in accordance with OP-201. Filling and venting is not directed I I I following work on other components - need to establish guidancefor filling and venting of other components.

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/09-0007 Page 11 of 11 Procedure Procedure No. Revision Procedure Title Requst Description of Change No. Request (PRR) No.

Safety Injection System (SI) 314790 OWP-016 provides guidance to support maintenance activities on the SI System. For maintenance on an RHR OWP-016 Pump, filling & venting is directed in accordance with OP-20 1. Filling and venting is not directed following work on other components - need to establish guidancefor filling and venting of other components.

Post-Maintenance Testing 287611 PLP-033 provides guidance for the selection and documentation of post-maintenance testing (PMT). This PLP-033 (PMT) Program procedure has been revised to ensure gas intrusion potential is identified for the RHR, SI, and CV Spray Systems as part of the PMT process.

Emergency Core Cooling 316399 PLP-085 is a new procedure for gas management for the Emergency Core Cooling Systems (ECCS). This PLP-085 System Gas Management program will ensure compliance with GL 2008-01 gas intrusion issues in the SI, RHR, and CV Spray Systems.

Program (GL 2008-01)

Leak Test For ECCS 270173 EST-140 provides instructions for determining individual seat leakage through ECCS boundary valves. Steps EST-140 Boundary Valves (Refueling) were developed to address the potential for gas intrusion. The procedure was revised during RO-25 prior to performance of this test.

Engineering Change 295517 Clarification/enhancement to provide further design input considerations upon design and system configuration EGR-NGGC- changes relative to GL 2008-01. Specifically, clarification has been provided to ensure the designer considers 0005 the adverse impact of gas intrusion when mechanical and electrical components (transmitters) are modified in the affected systems. A revision to Attachment 7, EC Screening Criteria,and adding GL 2008-01 as a reference has been recommended