LR-N25-0010, License Amendment Request to Revise Containment Fan Cooler Unit Surveillance Requirement

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License Amendment Request to Revise Containment Fan Cooler Unit Surveillance Requirement
ML25093A108
Person / Time
Site: Salem  PSEG icon.png
Issue date: 04/03/2025
From: Sharbaugh D
Public Service Enterprise Group
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
LR-N25-0010, LAR S24-06
Download: ML25093A108 (1)
v • d • e


Text

David Sharbaugh Salem Site Vice President, PSEG Nuclear PO Box 236 Hancocks Bridge, New Jersey 08038-0221 856-339-2900 david.sharbaugh@pseg.com 10 CFR 50.90 LR-N25-0010 LAR S24-06 April 3, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

License Amendment Request to Revise Containment Fan Cooler Unit Surveillance Requirement In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear LLC (PSEG) is submitting a request for an amendment to the Technical Specifications (TS) for Salem Generating Station (Salem) Units 1 and 2.

The proposed change will revise Salem Unit 1 and 2 Technical Specification (TS) Surveillance Requirements (SRs) for the containment fan cooler units (CFCUs), consistent with the corresponding SRs in NUREG-1431, "Standard Technical Specifications - Westinghouse Plants."

The Enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides the existing TS Bases marked up to show the associated TS Bases changes and is provided for information only.

PSEG requests approval of this LAR in accordance with the standard NRC approval process and schedule. Once approved, the amendment will be implemented within 90 days from the date of issuance.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of New Jersey Official.

There are no regulatory commitments contained in this letter.

If you have any questions or require additional information, please contact Mr. Shane Jurek at Shane.Jurek@pseg.com.

LR-N25-0010 10 CFR 50.90 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on _______________________

(Date)

Respectfully, David Sharbaugh Site Vice President Salem Generating Station

Enclosure:

Evaluation of the Proposed Changes : Mark-up of Proposed Technical Specification Pages : Mark-up of Proposed TS Bases Pages cc:

Administrator, Region I, NRC NRC Project Manager, Salem NRC Senior Resident Inspector, Salem Manager, NJ Bureau of Nuclear Engineering PSEG Commitment Tracking Coordinator Digitally signed by Sharbaugh, David L Date: 2025.04.03 08:04:11 -04'00'

LR-N25-0010 LAR S24-06 Enclosure Evaluation of the Proposed Changes Contents 1

SUMMARY

DESCRIPTION................................................................................................... 2 2

DETAILED DESCRIPTION.................................................................................................... 2 2.1 System Design and Operation........................................................................................ 2 2.2 Current Technical Specifications Requirements............................................................. 3 2.3 Reason for the Proposed Change.................................................................................. 3 2.4 Description of the Proposed Change.............................................................................. 3 3

TECHNICAL EVALUATION................................................................................................... 4 3.1 SR 4.6.2.3.b.1................................................................................................................. 4 3.2 SRs 4.6.2.3.b.2 and 4.6.2.3.c.1...................................................................................... 4 3.3 SR 4.6.2.3.c.................................................................................................................... 4 4

REGULATORY EVALUATION............................................................................................... 5 4.1 Applicable Regulatory Requirements/Criteria................................................................. 5 4.2 Precedents..................................................................................................................... 5 4.3 No Significant Hazards Consideration Analysis.............................................................. 6 4.4 Conclusion...................................................................................................................... 7 5

ENVIRONMENTAL CONSIDERATION.................................................................................. 7 6

REFERENCES...................................................................................................................... 8 ATTACHMENTS:

1. Mark-up of Proposed Technical Specification Pages
2. Mark-up of Proposed Technical Specification Bases Pages for Information Only

LR-N25-0010 LAR S24-06 Enclosure 1

SUMMARY

DESCRIPTION The proposed change will revise Salem Unit 1 and 2 Technical Specification (TS) Surveillance Requirements (SRs) for the containment fan cooler units (CFCUs), consistent with the corresponding SRs in NUREG-1431, "Standard Technical Specifications - Westinghouse Plants."

The proposed change removes procedural details for meeting TS requirements and details of system design. In addition, an explicit allowance is added to take credit for an unplanned actuation if sufficient information is collected to satisfy the surveillance test requirements.

2 DETAILED DESCRIPTION 2.1 System Design and Operation The Containment Fan Cooling System is an Engineered Safety Features (ESF) system. The system is designed to remove heat from the containment during normal operation, and remove heat and reduce pressure in the containment following a Loss of Coolant Accident (LOCA). The system consists of five containment fan cooler units (CFCUs), each including motor, fan, motor heat exchanger, cooling coils, roughing filters, dampers, duct distribution system, instrumentation, and controls.

The CFCUs are powered from three separate vital buses as follows: one CFCU is powered from the A vital bus and two CFCUs are powered from each of the B and C vital buses. This ensures that, in the event of a single failure of a vital bus, the minimum number of three CFCUs required to maintain containment integrity would remain available during a design basis event.

Two CFCUs are each supplied with cooling water from one of the two separate service water headers. One CFCU is supplied from both service water headers through normally open isolation valves and check valves from each header.

The CFCUs operate in high speed during normal plant operation where the CFCUs direct air through the roughing filters, cooling coil, fan and discharge header.

Low speed operation of the Fan Cooling System is entered during post-accident conditions which is actuated by a safety injection signal. During post-accident operation, air is drawn through a moisture separator, a post-accident high-efficiency particulate air (HEPA) filter section and cooling coils and is discharged to the duct header.

A minimum of three CFCUs in operation with a single containment spray train is capable of maintaining post-accident containment temperature and pressure below their design basis values, assuming a worst-case single active failure.

LR-N25-0010 LAR S24-06 Enclosure 2.2 Current Technical Specifications Requirements TS SR 4.6.2.3.b requires that each containment cooling fan shall be demonstrated OPERABLE in accordance with the Surveillance Frequency Control Program (SFCP) by:

1. Starting (unless already operating) each fan from the control room in low speed.
2. Verifying that each fan operates for at least 15 minutes in low speed.
3. Verifying a cooling water flow rate of greater than or equal to 1300 gpm to each cooler.

TS SR 4.6.2.3.c requires that each containment cooling fan shall be demonstrated OPERABLE in accordance with the SFCP by verifying that on a safety injection test signal:

1. Each fan starts automatically in low speed.
2. The automatic valves and dampers actuate to their correct positions and that the cooling water flow rate to each cooler is greater than or equal to 1300 gpm.

2.3 Reason for the Proposed Change The proposed changes revise SRs 4.6.2.3.b and 4.6.2.3.c to be consistent with the corresponding SRs in NUREG-1431. The proposed changes remove unnecessary information and relocate it to licensee controlled documents. The information being removed consists of details of system design and procedural details for meeting TS requirements. The information is not required to be retained in the TS and is not included in NUREG-1431.

SR 4.6.2.3.c requires verification of automatic CFCU actuation in response to a safety injection test signal. Credit for performing the SR should also be permitted for an unplanned actuation if sufficient information is collected to satisfy the SR requirements.

2.4 Description of the Proposed Change SR 4.6.2.3.b.1 is deleted to remove the details regarding starting each fan from the control room (unless already operating).

SRs 4.6.2.3.b.2 and 4.6.2.3.c.1 are revised to relocate the details regarding CFCU low speed operation to the TS Bases.

SR 4.6.2.4.c is revised to replace the requirement for "a safety injection test signal' with "an actual or simulated actuation signal."

The marked-up TS pages are provided in Attachment 1.

Marked-up TS Bases pages are provided in Attachment 2 for information only.

LR-N25-0010 LAR S24-06 Enclosure 3

TECHNICAL EVALUATION 3.1 SR 4.6.2.3.b.1 SR 4.6.2.3.b.1 requires each containment cooling fan to be demonstrated OPERABLE by starting each fan from the control room in low speed, unless the fan is already operating. The Frequency is controlled by the SFCP and is currently 31 days. Salem SR 4.6.2.3.b.1 does not correlate to a specific SR in NUREG-1431, but the requirement for the containment cooling fan to start is inherent in NUREG-1431, SR 3.6.6A.2.

The requirement to start a fan from the control room is a specific method of performing the SR.

Prescriptive procedural information in a TS requirement does not typically contain all procedural considerations necessary for the plant operators to comply with TS. Referral to plant procedures is, therefore, required in any event. Further, NUREG-1431 SR 3.6.6A.2 does not contain an explicit requirement to start containment cooling trains from the control room for surveillance testing. NUREG-1431, SR 3.6.6A.2 only requires the containment cooling train fan unit to operate for at least 15 minutes to demonstrate operability of the system. Therefore, it is acceptable to relocate this type of detail from the TS to station procedures and the relocation establishes consistency with NUREG-1431.

3.2 SRs 4.6.2.3.b.2 and 4.6.2.3.c.1 SR 4.6.2.3.b.2 requires that each containment cooling fan shall be demonstrated OPERABLE by verifying that each fan operates for at least 15 minutes in low speed. The Frequency is controlled by the SFCP and is currently 31 days. Salem SR 4.6.2.3.b.2 corresponds to NUREG-1431 SR 3.6.6A.2.

SR 4.6.2.3.c requires that each containment cooling fan shall be demonstrated OPERABLE by verifying that on a safety injection test signal, each fan starts automatically in low speed. The Frequency is controlled by the SFCP and is currently 54 months. Salem SR 4.6.2.3.c.1 corresponds to NUREG-1431 SR 3.6.6A.8.

CFCU low speed fan operation is an element of the Containment Fan Cooling System design, which is subject to quality assurance requirements of Appendix B to 10 CFR Part 50 and the change control requirements of 10 CFR 50.59. The details of low speed fan operation are being added to the TS Bases which are controlled in accordance with Salem Unit 1 TS 6.17 and Salem Unit 2 TS 6.16, Technical Specification (TS) Bases Control Program. Removing details of system design is acceptable because the revised SR requirements are adequate to ensure safe operation of the facility. Therefore, the relocation of these details from the SRs to the TS Bases establishes consistency with the corresponding SR 3.6.6A.2 and SR 3.6.6A.8 in NUREG-1431.

3.3 SR 4.6.2.3.c SR 4.6.2.3.c requires that each containment cooling fan shall be demonstrated OPERABLE by verifying system response to a safety injection test signal. The Frequency is controlled by the SFCP and is currently 54 months. Salem SR 4.6.2.3.c corresponds to NUREG-1431 SR 3.6.6A.8.

The actuation signal (a safety injection signal) for the Containment Fan Cooling System is an element of system design, which is subject to quality assurance requirements of Appendix B to

LR-N25-0010 LAR S24-06 Enclosure 10 CFR Part 50 and the change control requirements of 10 CFR 50.59. The specific actuation signal is being added to the TS Bases which are controlled in accordance with Salem Unit 1 TS 6.17 and Salem Unit 2 TS 6.16. Removing details of system design is acceptable because the associated SR requirements are adequate to ensure safe operation of the facility.

The purpose of SR 4.6.2.3.c is to ensure the Containment Fan Cooling System CFCUs operate correctly upon receipt of an actuation signal. Explicitly allowing the use of either an actual or simulated actuation signal is acceptable for verification that the equipment used to meet the LCO can perform its specified safety functions. Equipment cannot discriminate between an "actual," "simulated," or "test" signal and, therefore, the results of the testing are unaffected by the type of signal used to initiate the test. This change allows taking credit for unplanned actuation if sufficient information is collected to satisfy the Surveillance test requirements.

Therefore, allowance for an actual actuation to satisfy SR 4.6.2.3.c establishes consistency with the corresponding SR 3.6.6A.8 in NUREG-1431.

4 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, "Technical specifications," provides the regulatory requirements for the content required in the TS, including Surveillance Requirements (SRs). 10 CFR 50.36(c)(3) states that SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The NRC staffs guidance for the review of TS is contained in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ML100351425). As described therein, the NRC staff has prepared standard TS (STS) for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable STS NUREG.

The revised SRs are similar to the NUREG-1431 SRs and are considered adequate to assure, pursuant to the requirements of 10 CFR 50.36(c)(3), that the necessary quality of systems and components is maintained, facility operation will be within safety limits, and that the limiting condition for operation associated with the CFCUs will be met.

4.2 Precedents Removal of Salem SR 4.6.2.3.b.1 is consistent with NUREG-1431 and the amendments listed below.

Vogtle Electric Generating Plant, Units 1 and 2, Amendment Nos. 96 and 74 (ADAMS Accession No. ML012390239)

Braidwood Station, Unit Nos. 1 and 2, Amendment No. 98 (ADAMS Accession No. ML020870040)

Changes to SRs 4.6.2.3.b.2 and 4.6.2.3.c.1 are consistent with NUREG-1431 and the amendment listed below.

LR-N25-0010 LAR S24-06 Enclosure Vogtle Electric Generating Plant, Units 1 and 2, Amendment Nos. 96 and 74 (ADAMS Accession No. ML012390239)

Changes to SR 4.6.2.3.c are consistent with NUREG-1431 and the amendments listed below.

Vogtle Electric Generating Plant, Units 1 and 2, Amendment Nos. 96 and 74 (ADAMS Accession No. ML012390239)

Braidwood Station, Unit Nos. 1 and 2, Amendment No. 98 (ADAMS Accession No. ML020870040)

Turkey Point Nuclear Generating Unit Nos. 3 and 4, Amendment Nos. 297 and 290 (ADAMS Accession No. ML23234A192)

Although there are design differences between Salem and the plants identified above, those design differences have no impact on the bases for approval of the requested changes.

4.3 No Significant Hazards Consideration Analysis PSEG Nuclear LLC (PSEG) requests approval of a change to the Technical Specifications (TS) for Salem Generating Station (Salem) Units 1 and 2. The proposed change revises Surveillance Requirements (SRs) 4.6.2.3.b and 4.6.2.3.c for the containment fan cooler units (CFCUs), consistent with the corresponding SRs in NUREG-1431, "Standard Technical Specifications - Westinghouse Plants."

The proposed change removes procedural details for meeting TS requirements and details of system design. In addition, an explicit allowance is added to take credit for an unplanned actuation if sufficient information is collected to satisfy the surveillance test requirements.

PSEG has evaluated whether a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed changes to the TS will not alter the way any structure, system, or component (SSC) functions, and will not alter the manner in which the plant is operated.

The proposed changes do not alter the design of any SSC. Therefore the probability of an accident previously evaluated is not significantly increased.

The revised SRs will continue to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Therefore, the consequences of an accident previously evaluated are not increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

LR-N25-0010 LAR S24-06 Enclosure

2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed changes do not involve a modification to the physical configuration of the plant or changes in the methods governing normal or off-normal plant operation. The proposed changes do not impose any new or different requirement or introduce a new accident initiator, accident precursor, or malfunction mechanism.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The revised SRs will continue to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The proposed amendment will not result in a design basis limit being exceeded or altered.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, PSEG concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5 ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

LR-N25-0010 LAR S24-06 Enclosure 6

REFERENCES

1. NRC NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21259A155 and ML21259A159, respectively).
2. Letter from NRC to C. K. McCoy, Issuance of Amendments - Vogtle Electric Generating Plant, Units 1 and 2 (TAC Nos. M92131 and M93132), dated September 25, 1996 (ADAMS Accession No. ML012390239 )
3. Letter from NRC to Oliver Kingsley, Issuance of Amendments (TAC Nos. M97546, M97547, M97548 and M97549, dated December 22,1998 (ADAMS Accession No. ML020870040)
4. Letter from NRC to Bob Coffey, Turkey Point Nuclear Generating Station Unit Nos. 3 and 4 - Issuance of Amendment Nos. 297 and 290 regarding conversion to Improved Standard Technical Specifications (EPID L-2021-LLI-0002), dated September 27, 2023 (ADAMS Accession No. ML23234A192)

LR-N25-0010 LAR S24-06 Mark-up of Proposed Technical Specification Pages The following Technical Specifications page for Renewed Facility Operating License DPR-70 is affected by this change request:

Technical Specification Page 3/4.6.2.3, Containment Cooling System 3/4 6-11a The following Technical Specifications page for Renewed Facility Operating License DPR-75 is affected by this change request:

Technical Specification Page 3/4.6.2.3, Containment Cooling System 3/4 6-13

CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.3 Five containment cooling fans shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a.

With one or two of the above required containment cooling fans inoperable, restore the inoperable cooling fan(s) to OPERABLE status within 14 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With three or more of the above required containment cooling fans inoperable, restore at least three cooling fans to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY WITHIN the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore the remaining inoperable cooling fans to OPERABLE status within 14 days of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.2.3 Each containment cooling fan shall be demonstrated OPERABLE:

SALEM - UNIT 1 3/4 6-11 Amendment No. 321 No changes on this page. For information only.

CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) a.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying the water level in each service water accumulator vessel is greater than or equal to 226 inches and less than or equal to 252 inches.

2.

Verifying the temperature in each service water accumulator vessel is greater than or equal to 55°F and less than or equal to 95°F.

3.

Verifying the nitrogen cover pressure in each service water accumulator vessel is greater than or equal to 135 psig and less than or equal to 160 psig.

b.

In accordance with the Surveillance Frequency Control Program by:

1.

Starting (unless already operating) each fan from the control room in low speed.

2.

Verifying that each fan operates for at least 15 minutes in low speed.

3.

Verifying a cooling water flow rate of greater than or equal to 1300 gpm to each cooler.

c.

In accordance with the Surveillance Frequency Control Program by verifying that on a safety injection test signal:

1.

Each fan starts automatically in low speed.

2.

The automatic valves and dampers actuate to their correct positions and that the cooling water flow rate to each cooler is greater than or equal to 1300 gpm.

d.

In accordance with the Surveillance Frequency Control Program by verifying that on a loss of offsite power test signal, each service water accumulator vessel discharge valve response time is within limits.

SALEM - UNIT 1 3/4 6-11 a Amendment No. 299 Deleted an actual or simulated actuation signal:

XXX

CONTAINMENT SYSTEMS CONTAINMENT COOLING SYSTEM LIMITING CONDITION FOR OPERATION 3.6.2.3 Five containment cooling fans shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a.

With one or two of the above required containment cooling fans inoperable, restore the inoperable cooling fan(s) to OPERABLE status within 14 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With three or more of the above required containment cooling fans inoperable, restore at least three cooling fans to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY WITHIN the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore the remaining inoperable cooling fans to OPERABLE status within 14 days of initial loss or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.2.3 Each containment cooling fan shall be demonstrated OPERABLE:

SALEM - UNIT 2 3/4 6-12 Amendment No. 302 No changes on this page. For information only.

CONT Al NM ENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) a.

In accordance with the Surveillance Frequency Control Program by:

1.

Verifying the water level in each service water accumulator vessel is greater than or equal to 226 inches and less than or equal to 252 inches.

2.

Verifying the temperature in each service water accumulator vessel is greater than or equal to 55°F and less than or equal to 95°F.

3.

Verifying the nitrogen cover pressure in each service water accumulator vessel is greater than or equal to 135 psig and less than or equal to 160 psig.

b.

In accordance with the Surveillance Frequency Control Program by:

1.

Starting (unless already operating) each fan from the control room in low speed.Deleted 2.

Verifying that each fan operates for at least 15 minutes in low speed.

3.

Verifying a cooling water flow rate of greater than or equal to 1300 gpm to each cooler.

c.

In accordance with the Surveillance Frequency Control Program by verifying that on a safety injection test signal:

1.

Each fan starts automatically in low speed.

2.

The automatic valves and dampers actuate to their correct positions and that the cooling water flow rate to each cooler is greater than or equal to 1300 gpm.

d.

In accordance with the Surveillance Frequency Control Program by verifying that on a loss of offsite power test signal, each service water accumulator vessel discharge valve response time is within limits.

SALEM - UNIT 2 3/4 6-13 Amendment No. 282 an actual or simulated actuation signal:

XXX

LR-N25-0010 LAR S24-06 Mark-up of Proposed Technical Specification Bases Pages The following Technical Specifications Bases pages for Renewed Facility Operating License DPR-70 are affected by this change request:

Technical Specification Page 3/4.6.2.3, Containment Cooling System B 3/4 6-3 B 3/4 6-4 The following Technical Specifications Bases pages for Renewed Facility Operating License DPR-75 are affected by this change request:

Technical Specification Page 3/4.6.2.3, Containment Cooling System B 3/4 6-3 B 3/4 6-4

CONTAINMENT SYSTEMS BASES 3/4.6.2.DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 CONTAINMENT SPRAY SYSTEM The OPERABILITY of the containment spray system, when operated in conjunction with the Containment Cooling System, ensures that containment depressurization and cooling capability will be available in the event of a LOCA.

The pressure reduction and resultant lower containment leakage rate are consistent with the assumptions used in the accident analyses.

Normal plant operation and maintenance practices are not expected to trigger surveillance requirement 4.6.2.1.d.

Only an unanticipated circumstance would initiate this surveillance, such as inadvertent spray actuation, a major configuration change, or a loss of foreign material control when working within the affected boundary of the system.

If an activity occurred that presents the potential of creating nozzle blockage, an evaluation would be performed by the engineering organization to determine if the amount of nozzle blockage would impact the required design capabilities of the containment spray system.

If the evaluation determines that the containment spray system would continue to perform its design basis function, then performance of the air or smoke flow test would not be required.

If the evaluation cannot conclusively determine the impact to the containment spray system, then the air or smoke flow test would be performed to determine if any nozzle blockage has occurred.

3/4.6.2.2 SPRAY ADDITIVE SYSTEM The OPERABILITY of the spray additive system ensures that sufficient NaOH is added to the containment spray in the event of a LOCA.

The limits on NaOH minimum volume and concentration, ensure that 1) the iodine removal efficiency of the spray water is maintained because of the increase tn pH value, and 2) corrosion effects on components within containment are minimized.

The contained water volume limit includes an allowance for water not usable because of tank discharge line location or other physical characteristics.

These assumptions are consistent with the iodine removal efficiency assumed in the accident analyses.

3/4.6.2.3 CONTAINMENT COOLING SYSTEM The OPERABILITY of the containment cooling system ensures that adequate heat removal capacity is available when operated in conjunction with the containment spray systems during post-LOCA conditions.

The surveillance requirements for the service water accumulator vessels ensure each tank contains sufficient water and nitrogen to maintain water filled, subcooled fluid conditions in three containment fan coil unit (CFCU) cooling loops in response to a loss of offsite power, without injecting nitrogen covergas into the containment fan coil unit loops assuming the most limiting single failure.

The surveillance requirement for the discharge valve response time test ensures that on a loss of offsite power, each discharge valve actuates to the open position in accordance with the design to allow sufficient tank discharge into CFCU piping to maintain water filled, subcooled fluid conditions in three CFCU cooling loops, assuming the most limiting single failure.

SALEM - UNIT 1 B 3/4 6-3 Amendment No. 287 (PSEG Issued)

INSERT-1

CONTAINMENT SYSTEMS BASES The surveillance requirements for the CFCUs ensure sufficient SWS flow through each operating cooler to provide the minimum containment cooling as assumed by the containment response analysis for a design-basis LOCA or MSLB event. The surveillance flow rate is selected to ensure adequate heat removal (with no two-phase flow). The specified surveillance flow rate represents the total flow from both the CFCU coils and the CFCU motor-cooler.

3/4.6.3 CONTAINMENT ISOLATION VALVES The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment. Containment isolation within the time limits specified ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a LOCA.

The opening of locked or sealed closed containment isolation valves (penetration flow paths) on an intermittent basis under administrative control includes the following considerations: (1) stationing a dedicated individual, who is in constant communication with the control room, at the valve controls, (2) instructing this individual to close these valves in an accident situation, and (3) assuring that environmental conditions will not preclude access to close the valves and that this action will prevent the release of radioactivity outside the containment.

The main steam isolation valves (MSIVs) fulfill their containment isolation function as remote-manual containment isolation valves. The automatic closure of the MSIVs is not required for containment isolation due to having a closed system inside containment. The remote-manual containment isolation function of the MSIVs can be accomplished through either the use of the hydraulic operator or when the MSIV has been tested in accordance with surveillance requirement 4.7.1.5 the steam assist function can be credited.

Surveillance Requirement (SR) 4.6.3.1.3 only applies to the MS7 (Main Steam Drain) valves and the MS18 (Main Steam Bypass) valves. The MS167 (Main Steam Isolation) valves are tested for main steam isolation purposes by SR 4.7.1.5.

For containment isolation purposes, the MS167s are tested as remote/manual valves pursuant to Specification 4.0.5.

The containment purge supply and exhaust isolation valves are required to be closed during plant operation since these valves have not been demonstrated capable of closing during a LOCA. Maintaining these valves (or equivalent isolation device) closed during plant operations ensures that excessive quantities of radioactive materials will not be released via the containment Purge system.

A containment purge valve is not a required containment isolation valve When its flow path is isolated with a blind flange tested in accordance with SR 4.6.1.2.b. The inboard valve of both the containment purge supply and exhaust penetrations has been replaced with a testable, double o-ring blind flange. The blind flange serves as the containment boundary and performs the containment integrity function in Modes 1,2,3,and 4. The outboard valve of both the containment purge supply and exhaust penetrations performs no containment integrity function in MODES 1-4; these valves operate during shutdown for normal system purging and containment closure when the blind flanges are removed.

SALEM - UNIT 1 B 3/4 6-4 Amendment No. 287 (PSEG Issued)

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CONTAINMENT SYSTEMS BASES 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 CONTAINMENT SPRAY SYSTEM The OPERABILITY of the containment spray system, when operated in conjunction with the Containment Cooling System, ensures that containment depressurization and cooling capability will be available in the event of a LOCA.

The pressure reduction and resultant lower containment leakage rate are consistent with the assumptions used in the accident analyses.

The containment spray system also provides a mechanism for removing iodine from the containment atmosphere and therefore the time reguirements for restoring an inoperable spray system to OPERABLE status have been maintained consistent with that assigned other inoperable ESF eguipment.

Normal plant operation and maintenance practices are not expected to trigger surveillance reguirement 4.6.2.1.d.

Only an unanticipated circumstance would initiate this surveillance, such as inadvertent spray actuation, a major configuration change, or a loss of foreign material control when working within the affected boundary of the system.

If an activity occurred that presents the potential of creating nozzle blockage, an evaluation would be performed by the engineering organization ta determine if the amount of nozzle blockage would impact the required design capabilities of the containment spray system. If the evaluation determines that the containment spray system would continue to perform its design basis function, then performance of the air or smoke flow test would not be required.

If the evaluation cannot conclusively determine the impact to the containment spray system, then the air or smoke flow test would be performed to determine if any nozzle blockage has occurred.

3/4.6.2.2 SPRAY ADDITIVE SYSTEM The OPERABILITY of the spray additive system ensures that sufficient NaOH is added to the containment spray in the event of a LOCA.

The limits on NaOH volume and concentration, ensure that 1) the iodine removal efficiency of the spray water is maintained because of the increase in pH value, and 2) corrosion effects on components within containment are minimized.

The contained water volume limit includes an allowance far water not usable because of tank discharge line location or other physical characteristics.

These assumptions are consistent with the iodine removal efficiency assumed in the accident analyses.

3/4.6.2.3 CONTAINMENT COOLING SYSTEM The OPERABILITY of the containment cooling system ensures that adequate heat removal capacity is available when operated in conjunction with the containment spray systems during post-LOCA conditions.

The surveillance requirements for the service water accumulator vessels ensure each tank contains sufficient water and nitrogen to maintain water filled, subcooled fluid conditions in three containment fan coil unit (CFCU) cooling loops in response to a loss of offsite power, without injecting nitrogen covergas into the containment fan coil unit loops assuming the most limiting single failure.

The surveillance requirement for the discharge valve response time test ensures that on a loss of offsite power, each discharge valve actuates to the open position in accordance with the design to allow sufficient tank discharge into CFCU piping to maintain water filled, subcooled fluid conditions in three CFCU coaling loops, assuming the most limiting single failure.

SALEM - UNIT 2 B 3/4 6-3 Amendment No. 270 (PSEG Issued)

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CONTAINMENT SYSTEMS BASES The surveillance requirements for the CFCUs ensure sufficient SWS flow through each operating cooler to provide the minimum containment cooling as assumed by the containment response analysis for a design-basis LOCA or MSLB event. The surveillance flow rate is selected to ensure adequate heat removal (with no two-phase flow). The specified surveillance flow rate represents the total flow from both the CFCU coils and the CFCU motor-cooler 3/4.6.3 CONTAINMENT ISOLATION VALVES The OPERABILITY of the containment isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment. Containment isolation within the time limits specified ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a LOCA.

The opening of locked or sealed closed containment isolation valves (penetration flow paths) on an intermittent basis under administrative control includes the following considerations: (1) stationing a dedicated individual, who is in constant communication with the control room, at the valve controls, (2) instructing this individual to close these valves in an accident situation, and (3) assuring that the environmental conditions will not preclude access to close the valves and that this action will prevent the release of radioactivity outside the containment.

The main steam isolation valves (MSIVs) fulfill their containment isolation function as remote-manual containment isolation valves. The automatic closure of the MSIVs is not required for containment isolation due to having a closed system inside containment. The remote-manual containment isolation function of the MSIVs can be accomplished through either the use of the hydraulic operator or when the MSIV has been tested in accordance with surveillance requirement 4.7.1.5 the steam assist closure function can be credited.

Surveillance Requirement (SR) 4.6.3.3 only applies to the MS7 (Main Steam Drain) valves and the MS18 (Main Steam Bypass) valves. The MS167 (Main Steam Isolation) valves are tested for main steam isolation purposes by SR 4.7.1.5. For containment isolation purposes, the MS167s are tested as remote/manual valves pursuant to Specification 4.0.5.

The containment purge supply and exhaust isolation valves are required to be closed during plant operation since these valves have not been demonstrated capable of closing during a LOCA. Maintaining these valves (or equivalent isolation device) closed during plant operations ensures that excessive quantities of radioactive materials will not be released via the containment purge system.

A containment purge valve is not a required containment isolation valve when its flow path is isolated with a blind flange tested in accordance with SR 4.6.1.2.b. The inboard valve of both the containment purge supply and exhaust penetrations has been replaced with a testable double o-ring blind flange. The blind flange serves as the containment boundary and performs the containment integrity function in Modes 1, 2, 3, and 4. The outboard valve of both the SALEM - UNIT 2 B 3/4 6-4 Amendment No. 270 (PSEG Issued)

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LR-N25-0010 LAR S24-06 INSERT 1 Five containment fan cooler units (CFCUs) are provided. Two CFCUs are each supplied with cooling water from one of the two separate service water headers. One CFCU is supplied from both service water headers through normally open isolation valves and check valves from each header. Air is drawn into the coolers through the fan and discharged to duct work which distributes the cooled air to the various containment compartments and areas.

During normal operation, up to four CFCUs are typically operating. The fans are normally operated at high speed with service water supplied to the cooling coils. The CFCUs are designed to limit the ambient containment air temperature during normal unit operation to less than the limit specified in LCO 3.6.1.5, "Air Temperature." This temperature limitation ensures that the containment temperature does not exceed the initial temperature conditions assumed for the DBAs.

In post-accident operation following an actuation signal, the CFCUs are designed to start automatically in low speed if not already running. If running in high (normal) speed, the fans automatically shift to low speed. The fans are operated at the lower speed during accident conditions to prevent motor overload from the higher mass atmosphere.

INSERT 2 SR 4.6.2.3.b.2 Operating each CFCU in low speed for 15 minutes ensures that all CFCUs are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure can be detected for corrective action.

SR 4.6.2.3.c.1 This SR requires verification that each CFCU actuates upon receipt of an actual or simulated safety injection signal.

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