LR-N07-0058, Application to Revise Technical Specifications (LCR S07-02) Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process

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Application to Revise Technical Specifications (LCR S07-02) Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process
ML071160156
Person / Time
Site: Salem  PSEG icon.png
Issue date: 04/15/2007
From: Joyce T
Public Service Enterprise Group
To:
Document Control Desk, NRC/NRR/ADRO
References
LR-N07-0058
Download: ML071160156 (77)


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 0 PSEG NuclearLLC AN* 16 24 *10 CFR 50.90 LR-N07-0058 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 SALEM GENERATING STATION - UNIT 1 AND UNIT 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 NRC DOCKET NOS. 50-272 AND 50-311

Subject:

APPLICATION TO REVISE TECHNICAL SPECIFICATIONS (LCR S07-02) REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448, REVISION 3, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS In accordance with the provisions of 10 CFR 50.90, PSEG Nuclear, LLC (PSEG) is submitting a request to the technical specifications (TS) for Salem Generating Station Unit 1 and Unit 2.

The proposed amendment would modify TS requirements related to control room envelope habitability in accordance with Technical Specification Task Force traveler (TSTF)-448, Revision 3, "Control Room Habitability." provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides existing TS Bases pages marked up. These Bases pages are being submitted for information only and do not require issuance by the NRC. Attachment 4 provides revised Technical Specification/Bases Pages.

These proposed changes have been reviewed by the Station's Plant Operations Review Committee.

PSEG requests approval of the proposed License Amendment by April 17, 2008, with the amendments being implemented within 180 days of issuance of the approved amendment. PSEG is developing the Control Room Envelope Habitability Program 95-2168 REV. 7/99

APR 1 ZO, Document Control Desk LR-N07-0058 In accordance with 10 CFR 50.91(b)(1), a copy of this application, with attachments, is being provided to the designated state official for the State of New Jersey.

I declare under penalty of perjury that the foregoing is true and correct.

If you should have any questions regarding this submittal, please contact Mr.

Jamie Mallon at (610) 765-5507.

Executed on Sincerely,

/ (D te)

Thomas P. Joyce /

Site Vice President Salem Generating Station Attachments: 1. Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

2. Markup of the Facility Operating License and Technical Specifications
3. Markup of Technical Specification Bases pages (for information only)
4. Revised Technical Specification/Bases Pages C Mr. S. Collins, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission Mr. R. Ennis, Project Manager - Salem Unit 1 and Unit 2 and Hope Creek Mail Stop 08C2 Washington, DC 20555-0001 USNRC Senior Resident Inspector - Salem Unit 1 and Unit 2 (X24)

Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. 0. Box 415 Trenton, NJ 08625

ATTACHMENT 1 License Amendment Request Salem Generating Station Units 1 & 2 NRC Docket Nos. 50-272 and 50-311 DESCRIPTION AND ASSESSMENT

Subject:

APPLICATION TO REVISE TECHNICAL SPECIFICATIONS REGARDING CONTROL ROOM ENVELOPE HABITABILITY IN ACCORDANCE WITH TSTF-448, REVISION 3, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL EVALUATION 1

LCR S07-02

1.0 DESCRIPTION

The proposed amendment would modify technical specification (TS) requirements related to control room habitability in TS 3/4.7.6 Control Room Emergency Air Conditioning System and TS Section 6.0, Administrative Controls.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-448, Revision 3, "Control Room Habitability." The availability of this TS improvement was published in the Federal Register on January 17, 2007 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation PSEG has reviewed the safety evaluation dated January 17, 2007 as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-448. PSEG has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Salem Generating Station Unit 1 and Unit 2, and justify this amendment for the incorporation of the changes to the Salem Unit 1 and Unit 2 TS.

2.2 Optional Changes and Variations PSEG is not proposing any significant variations or deviations from the TS changes described in the TSTF-448, Revision 3, or the applicable parts of the NRC staffs model safety evaluation dated January 17, 2007. A plant specific listing of differences is provided below. These differences reflect adjustments, as needed, to account for plant specific control room habitability design, current licensing basis, or differences due to plant specific non-Standard Technical Specification wording or format.

Additionally, the parts of Section 3.0 of the model safety evaluation that are applicable for Salem Generating Station Unit 1 and Unit 2 are stated below.

A. The following proposed changes to the Salem Generating Station Unit 1 and Unit 2 TS are consistent with TSTF-448 and the Evaluations from the TSTF-448, Rev. 3, Model Safety Evaluation, Section 3.3.

2 LCR S07-02

1. PSEG is proposing to modify the TS 3.7.6.1 LCO (Unit 1) and TS 3.7.6 LCO (Unit 2) by adding a note allowing the CRE boundary to be opened intermittently under administrative controls. As stated in the LCO Bases, this Note "only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated." (Model Safety Evaluation - Evaluation 2)
2. PSEG proposes to establish new action requirements for an inoperable CRE boundary. The existing TS 3.7.6.1 (Unit 1) and TS 3.7.6 (Unit 2) Control Room Emergency Air Conditioning System (CREACS) actions are more restrictive than would be appropriate in situations for which CRE occupant implementation of compensatory measures or mitigating actions would temporarily afford adequate CRE occupant protection from postulated airborne hazards. To account for such situations in MODE 1, 2, 3, or 4, PSEG proposes to revise TS 3.7.6.1 Action c (Unit 1) and 3.7.6 Action c (Unit 2), "With the Control Room Envelope boundary inoperable." New TS 3.7.6.1 Action c.3 (Unit 1) and 3.7.6 Action c.3 (Unit 2) would allow 90 days to restore the CRE boundary to operable status, provided the mitigating actions are immediately implemented (TS 3.7.6.1 Action c.1 - Unit 1 and TS 3.7.6 Action c.1 - Unit 2) and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are verified to ensure, that in the event of a DBA, CRE occupant radiological exposures will not exceed the calculational dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke (TS 3.7.6.1 Action c.2 - Unit 1 and TS 3.7.6 Action c.2 - Unit 2). (Model Safety Evaluation -

Evaluation 2)

3. PSEG proposes a revision to TS 3.7.6.1 (Unit 1) and TS 3.7.6 (Unit
2) Action d under Applicability in Modes 5 and 6 or movement of irradiated fuel assemblies, that includes reference to the CRE boundary. The addition of the word boundary will ensure that the Actions continue to specify a condition for an inoperable CRE 3

LCR S07-02 boundary during all modes of applicability. (Model Safety Evaluation - Evaluation 4)

4. PSEG proposes to delete CRE pressurization Surveillance Requirement 4.7.6.1 .d.3 which requires verification that the system can maintain a positive pressure of at least 1/8 inches water gauge relative to the adjacent areas during system operation at a flow rate of < 2200 cfm. The deletion of this Surveillance Requirement is proposed because measurements of unfiltered air inleakage into the CRE at numerous reactor facilities has demonstrated that a basic assumption of this Surveillance Requirement, an essentially leak-tight CRE boundary, was incorrect for most facilities.

Therefore, meeting this Surveillance Requirement by achieving the required CRE pressure is not necessarily a conclusive indication of CRE boundary leak tightness (i.e., CRE boundary operability). In the PSEG response to NRC Generic Letter (GL) 2003-01, "Control Room Habitability," dated December 9, 2003, PSEG proposed to replace the existing TS control room pressurization surveillance, TS SR 4.7.6.d.3, with an inleakage measurement Surveillance Requirement and CRE Habitability Program in TS, in accordance with the approved version of TSTF-448, Revision 3. (Model Safety Evaluation - Evaluation 6)

5. In place of the pressurization Surveillance Requirement, PSEG proposes to add a new Surveillance Requirement 4.7.6.2 that will require performance of CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.

The CRE Habitability Program TS, proposed TS 6.18 (Unit 1) and TS 6.17 (Unit 2) (described below), requires that the program include requirements for determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0. This guidance references ASTM E741 as an acceptable method for ascertaining the unfiltered leakage into the CRE. PSEG proposes to follow this method. (Model Safety Evaluation - Evaluation 6)

6. PSEG proposes a new administrative controls program TS consistent with the model program TS in TSTF-448, Revision 3.

This new program is described in TS 6.18 (Unit 1) and TS 6.17 (Unit 2), "Control Room Envelope Habitability Program." In combination with the new Surveillance Requirement 4.7.6.2, this program is intended to ensure the operability of the CRE boundary, which as part of an operable Control Room Emergency Air Conditioning System will ensure that the CRE habitability is maintained such that CRE occupants can control the reactor safely 4

LCR S07-02 under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program will ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under DBA conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident. The Salem Generating Station CRE Habitability Program contains the required elements identified in TSTF-448, Revision 3.

The TSTF-448, Revision 3, Control Room Habitability Program administrative control requirement, Item d, has been revised to state that the results of the CRE pressurization tests shall be trended and used as part of the 3-year assessment of the CRE boundary. This 3-year assessment period is consistent with the Regulatory Guide 1.197 required CRE assessment period.

B. To account for Salem specific control room habitability design, current licensing basis, or differences due to plant specific non-Standard Technical Specification wording or format, the following adjustments have been incorporated into the proposed TS markups:

1. Salem Generating Station Units 1 and 2 have not adopted the Standardized Technical Specification Format. TSTF-448 has been incorporated into existing sections with new sections being added as applicable.
2. For the Control Room Habitability Program description of measurement frequency of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation given in new TS 6.18.d (Unit 1) and 6.17.d (Unit 2), the stated Salem frequency will be "36 months on a STAGGERED TEST BASIS" verses the TSTF value of 18 months. In addition, TS 6.18.d/6.17.d will state that the results will be trended and used as part of the 18 month assessment of the CRE boundary verses the TSTF value of 36 months. These variances are due to the difference between the Salem TS definition of STAGGERED TEST BASIS and the definition used by Standard Technical Specifications (STS). The Salem definition is:

"A STAGGERED TEST BASIS shall consist of a test schedule for (n) systems, subsystems, trains, or other designated components obtained by dividing the specified test interval into (n) equal subintervals. The testing of one system, subsystem, train, or other designated component at the beginning of each subinterval."

5 LCR S07-02 The STS definition is:

A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

Therefore, for Salem, in order to prescribe testing one of the subsystems every 18 months as stated in TSTF-448, the frequency must be stated as "36 months on a STAGGERED TEST BASIS".

With the exceptions identified above, the proposed TS Bases changes have been prepared to reflect applicable Bases statements from TSTF-448, Revision 3. These changes will be processed in accordance with the requirements of TS 6.18 (Unit 1) and TS 6.17 (Unit 2), "Technical Specifications (TS) Bases Control Program," which provides assurance that PSEG has established and will maintain the adequacy of the Bases.

2.3 License Condition Regarding Initial Performance of New Surveillance and Assessment Requirements PSEG proposes the following as a license condition to support implementation of the proposed TS changes (Since the referenced TS sections vary based on the plant-specific TS changes, the completed wording of the proposed license condition for each unit is provided in Attachment 2):

Upon implementation of this Amendment adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.6.2, in accordance with TS 6.18.c(i) (Unit 1) and TS 6.17.c(i) (Unit 2), the assessment of CRE habitability as required by Specifications 6.18.c(ii) (Unit 1) and 6.17.c(ii) (Unit 2), and the measurement of CRE pressure as required by Specifications 6.18.d (Unit 1) and 6.17.d (Unit 2), shall be considered met. Following implementation:

(a) The first performance of SR 4.7.6.2, in accordance with Specifications 6.18.c(i) (Unit 1) and 6.17.c(i) (Unit 2), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to 6

LCR S07-02 Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specifications 6.18.c(ii) (Unit 1) and 6.17.c(ii) (Unit 2), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specifications 6.18.d (Unit 1) and 6.17.d (Unit 2), shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from September 22, 2005, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination PSEG has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. PSEG has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Salem Generating Station Units 1 and 2, and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Commitments There are no new regulatory commitments contained in this request.

4.0 ENVIRONMENTAL EVALUATION PSEG has reviewed the environmental evaluation included in the model safety evaluation dated January 17, 2007 as part of the CLIIP. PSEG has concluded that the staffs findings presented in that evaluation are applicable to Salem Generating Station Units 1 and 2, and the evaluation is hereby incorporated by reference for this application.

7

ATTACHMENT 2 License Amendment Request Salem Generating Station Units 1 & 2 NRC Docket Nos. 50-272 and 50-311 TSTF-448 Control Room Envelope Habitability Proposed Technical Specification Changes (Mark-up)

MARKED UP TECHNICAL SPECIFICATION PAGES Salem Generatina Station. Unit 1 Facility Operating License Page 5

Technical Specification Pages 3/4 7-18 3/4 7-19 3/4 7-20 3/4 7-21 6-31

D. Paragraph 2.D. has been combined with paragraph 2.E. per Amendment No.

86, June 27, 1988.

E. The licensees shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to 5 4 the authority of 10 CFR 50.90 and 10 CFR 0.5 (p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Salem-Hope Creek Nuclear Generating Station Security Plan,"

with revisions submitted through December 17, 2001; "Salem-Hope Creek Nuclear Generating Station Security Training and Qualification Plan,"

with revisions submitted through December 17, 2001; and "Salem-Hope Creek Nuclear Generating Station Security Contingency Plan," with revisions submitted through June 2, 1998. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.

F. In accordance with the requirement imposed by the October 8, 1976, order of the United States Court of Appeals for the District of Columbia Circuit in Natural Resources Defense Council v. Nuclear Regulatory Commission, No. 74-1385 and 74-1586, that the Nuclear Regulatory Commission "shall make any licenses granted between July 21, 1976 and such time when the mandate is issued subject to the outcome of the proceedings herein," the license amendment issued herein shall be subject to the outcome of such proceedings.

G. Prior to startup following the first regularly scheduled refueling outage, Public Service Electric and Gas Company shall install, to the satisfaction of the Commission, a long-term means of protection against reactor coolant system over-pressurization when water-solid.

H. This amended license is effective as of the date of its issuance.

Facility Operating License No. DPR-70, as amended, shall expire at midnight, August 13, 2016.

Amendment No. 1-2-5, 2-3-3, 250

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 The common control room emergency air conditioning system (CREACS)*

shall be OPERABLE with:

a. Two independent air conditioning filtration trains (one from each unit) consisting of:
1. Two fans and associated outlet dampers,
2. One cooling coil,
3. One charcoal adsorber and HEPA filter array,
4. Return air isolation damper.
b. All other automatic dampers required for operation in the pressurization or recirculation modes.

Sc. The control room envelope intact.

APPLICABILITY: ALL MODES and during movement of irradiated fuel assemblies.

ACTION: MODES 1, 2, 3, and 4

a. With one filtration train inoperable, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and restore the inoperable filtration train to OPERABLE status within 30 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 CREACS aligned for single filtration train operation and with one of the two remaining fans or associated outlet damper inoperable, restore the inoperable fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 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 />.
  • *' } *c. With the Control Room Envelop~'~rablexetr h oto
  • --o-o ve ope o*!s 'uis or be -in.at *east]

-_*_HOT *ANDBY wit n the next 6 *rs and in *LD SHUTDOWN ithin{

"~~t followin /0 hours. --- ///_

d. With one or both series isolation damper(s) on a normal Control Area Air Conditioning System (CAACS) outside air intake or exhaust duct inoperable, close the affected duct within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one isolation damper secured in the closed position 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 />. (Refer to ACTION 25 of Table 3.3-6.)

The CREACS is a shared system with Salem Unit 2 SALEM - UNIT 1 3/4 7-18 Amendment No.263

Insert 1 (16) Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.6.2, in accordance with TS 6.18.c.(i), the assessment of CRE habitability as required by Specification 6.18.c.(ii), and the measurement of CRE pressure as required by Specification 6.18.d, shall be considered met. Following implementation:

a. The first performance of SR 4.7.6.2, in accordance with Specification 6.18.c.(i), shall be within the specified frequency of 6 years, plus the 18 month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
b. The first performance of the periodic assessment of CRE habitability, Specification 6.18.c(ii), shall be 3 years, plus the 9 month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
c. The first performance of the periodic measurement of CRE pressure, Specification 6.18.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from September 22, 2005, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

Insert 2 NOTE: The control room envelope (CRE) boundary may be opened intermittently under administrative control.

Insert 3

1. Immediately, initiate action to implement mitigating actions, and
2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits, and
3. Within 90 days, restore the Control Room Envelope boundary to OPERABLE status, 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 />.

PLANT SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

e. With one or both isolation damper(s) on an outside emergency air conditioning air intake duct inoperable, close the affected duct within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one isolation damper secured in the closed position and restore the damper(s) to OPERABLE status within 7 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 />.
f. With any isolation damper between the normal CAACS and the CREACS inoperable, secure the damper in the closed position within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 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 />.

MODES 5 and 6 or during movement of irradiated fuel assemblies

a. With one filtration train inoperable, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or suspend movement of irradiated fuel assemblies.
b. With CREACS aligned for single filtration train operation with one of the two remaining fans or associated outlet damper inoperable, restore the fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or suspend movement of irradiated fuel assemblies.
c. With two filtration trains inoperable, immediately suspend movement of irradiated fuel assemblies.
d. With the Control Room Envelop rinoprable, immediately suspend movement of irradiated fuel assemblies.
e. With one or both series isolation damper(s) on a normal CAACS outside air intake or exhaust duct inoperable, immediately suspend movement of irradiated fuel assemblies until the affected duct is closed by use of at least one isolation damper secured in the closed position. (Refer to ACTION 25 of Table 3.3-6.)
f. With one or both series isolation damper(s) on an outside emergency air conditioning air intake duct inoperable, immediately suspend movement of irradiated fuel assemblies until the affected duct is closed by use of at least one isolation damper secured in the closed position. To resume movement of irradiated fuel assemblies, at least one emergency air intake duct must be operable on each unit.
g. With any isolation damper between the CAACS and the CREACS inoperable, immediately suspend movement of irradiated fuel assemblies until the damper is closed and secured in the closed position.

SALEM - UNIT 1 3/4 7-19 Amendment No.263

SURVEILLANCE REQUIREMENTS 4.7.6.lEach control room emergency air conditioning system filtration train shall be demonstrated OPERABLE:

a. At least once per 31 days by initiating flow through the HEPA filter and charcoal adsorber train(s) and verifying that the train(s) operates with each fan operating for at least 15 minutes.
b. At least once per 18 months or prior to return to service (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system, by:
1. Verifying that the charcoal adsorbers remove Ž99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place while operating the ventilation system at a flow rate of 8000 cfm 10%.
2. Verifying that the HEPA filter banks remove Ž99% of the DOP when they are tested in-place while operating the ventilation system at a flow rate of 8000 cfm +/- 10%.
3. Verifying within 31 days after removal from the CREACS unit, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5%

when tested in accordance with ASTM D3803-1989 at a temperature of 30 C an6 a relative humidity of 95%.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 dayE after removal from the CREACS unit, that a laboratory analysis of a representative carbon sample, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows a methyl iodide penetration less than 2.5% when tested in accordance with ASTM D3803-1985 at a temperature of 30 C and a relative humidity of 95%.
d. At least once per 18 months by:
1. Verifying that the pressure drop across the combined HEPA filter and charcoal adsorber bank is
  • 3.5 inches water gauge while operating the ventilation system at a flow rate of 8000 cfm +/- 10%. 1 2.* Verifying that on a safety injection test signal or control room intake high radiation test signal, the system automatically actuates in the pressurization mode by opening the outside air supply and diverting air flow through the HEPA filter and charcoal adsorber bank.
3. Verifying that the system can maintain the control room at a positive pressure > 1/8" water gauge relative to the adjacent areas during system operation with makeup air being supplied through the HEPA filters and charc al ads at the design makeup flow rate of < 2200 cfm.

A one time extension to this surveillance requirement which is satisfied by performance of the Manual SI test is granted during fuel cycle thirteen allowinc Unit 1 operations to continue to the thirteenth refueling outage (1R13). The surveillance testing is to be completed at the appropriate time during the 1R13 outage, prior to the unit returning to Mode 4 upon outage completion.

SALEM - UNIT 1 3/4 7-20 Amendment No. 245

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

4. Verifying that on a manual actuation signal, the system will actuate to the required pressurization or recirculation operating mode.
5. Verify each CREACS train has the capability to remove the assumed heat load.
e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove Ž 99% of the DOP when they are tested in-place while operating the filter system at a flow rate of 8000 cfm +/- 10%.
f. After each complete or partial replacement of a charcoal absorber bank by verifying that the charcoal absorbers remove Ž 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place while operating the filter system at a flow rate of 8000 cfm +/- 10%.

~ Perform required CpE .4.mfLJtercd& ai.r Ludea~kae- testin3 L'n aeco-nda~¶-m4- WLf the. C.ovtroI Rc~om HUabI'tab&ýt Y Prog-rd, VA, (Refe . to 75 (P. 1?)

SALEM - UNIT 1 3/4 7-21 Amendment No. 190

ADMINISTRATIVE CONTROLS

c. Proposed changes to the Bases that require either condition of Specification 6.17.b above shall be reviewed and approved by the NRC prior to Implementation.
d. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e).
e. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.

6.18 CONTROL ROO )M ENVELOPE HABITABILITY PROGR A~M A Control Room Envelope (CRE) Habitability Program shall be established and 1 implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Air Conditioning System (CREACS),

can control the reactor safely under normal conditions and maintain it in a CRE occupants safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.
b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

The following are exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREACS, operating at the flow rate required by the Surveillance Requirements, at a frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.
e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph
c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

juirements 4.0.2 are applicable to the Frequencies for assessing CRE habJ itability, determining CRE unfiltered inleakage, and measuring CRE pres*3ure and assessing the CRE boundary as required by paragraphs c and d, r* espectively.

f. The provisions of Surveillance Re SALEM - UNIT 1 6- Amendment No. xxx

MARKED UP TECHNICAL SPECIFICATION PAGES Salem Generating Station, Unit 2 Facility Operating License Page 22b Technical Specification Pages 3/4 7-15 3/4 7-16 3/4 7-17 3/4 7-17a 6-31

22a (30) The decommissioning trust agreement for Salem, Unit 2, shall be subject to the following:

(a) The decommissioning trust agreement must be in a form acceptable to the NRC.

(b) With respect to the decommissioning trust fund, investments in the securities or other obligations of Exelon Corporation or affiliates thereof, or their successors or assigns are prohibited. Except for investments tied to market indexes or other non-nuclear sector mutual funds, investments in any entity owning one or more nuclear power plants are prohibited.

(c The decommissioning trust agreement for Salem, Unit 2, must provide that no disbursements or payments from the trust shall be made by the trustee unless the trustee has first given the Director, Office of Nuclear Reactor Regulation, 30 days prior written notice of payment. The decommissiong trust agreement shall further contain a provision that no disbursements or payments from the trust shall be make if the trustee receives prior written notice of objection from the NRC.

(d) The decommissioning trust agreement must provide that the agreement can not be amended in any material respect without prior written consent of the Director, Office of Nuclear Reactor Regulation.

(e) The appropriate section of the decommissioning trust agreement shall state that the trustee, investment advisor, or anyone else directing the investments made in the trust shall adhere to a "prudent investor" standard, as specified in 18 CFR 35.32 (a) (3) of the Federal Energy Regulatory Commission's regulations.

(31) Exelon Generation Company shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application for approval of the transfer of its ownership interest in Salem, Unit 2, license and the requirementsof the Order approving the transfer, and consistent with the safety evaluation supporting the Order.

FPT ON K)IF Amendment No. 222

CTHISPA INTENTIO ALLY B PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6 The common control room emergency air conditioning system (CREACS)*

shall be OPERABLE with:

a. Two independent air conditioning filtration trains (one from each unit) consisting of:
1. Two fans and associated outlet dampers,
2. One cooling coil,
3. One charcoal adsorber and HEPA filter array,
4. Return air isolation damper.
b. All other automatic dampers required for operation in the pressurization or recirculation modes.

The control room envelope intact.

APPLICABILITY: ALL MODES and during movement of irradiated fuel assemblies.

ACTION: MODES 1, 2, 3, and 4

a. With one filtration train inoperable, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and restore the inoperable filtration train to OPERABLE status within 30 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 CREACS aligned for single filtration train operation and with one of the two remaining fans or associated outlet damper inoperable, restore the inoperable fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 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 />.
c. With the Control Room Envelop'ehin rable* rEesor he-Copfriol*= R nv o RABL tatus L r ;; in at_-east*T 1 (STTDBY wi*i n tý; nex't 61ho s and- D SHUTDOWN -ithn'h OL*

f'lowing' 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />

d. With one or both series isolation damper(s) on a normal Control Area Air Conditioning System (CAACS) outside air intake or exhaust duct inoperable, close the affected duct within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one isolation damper secured in the closed position 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 />. (Refer to ACTION 28 of Table 3.3-6.)
  • The CREACS is a shared system with Salem Unit 1 SALEM - UNIT 2 3/4 7-15 Amendment No.245

Insert 1 (16) Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.6.2, in accordance with TS 6.17.c.(i), the assessment of CRE habitability as required by Specification 6.17.c.(ii), and the measurement of CRE pressure as required by Specification 6.17.d, shall be considered met. Following implementation:

a. The first performance of SR 4.7.6.2, in accordance with Specification 6.17.c.(i), shall be within the specified frequency of 6 years, plus the 18 month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
b. The first performance of the periodic assessment of CRE habitability, Specification 6.17.c(ii), shall be 3 years, plus the 9 month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
c. The first performance of the periodic measurement of CRE pressure, Specification 6.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from September 22, 2005, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

Insert 2 NOTE: The control room envelope (CRE) boundary may be opened intermittently under administrative control.

Insert 3

1. Immediately, initiate action to implement mitigating actions, and
2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits, and
3. Within 90 days, restore the Control Room Envelope boundary to OPERABLE status, 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 />.

PLANT SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

e. With one or both isolation damper(s) on an outside emergency air conditioning air intake duct inoperable, close the affected duct within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one isolation damper secured in the closed position and restore the damper(s) to OPERABLE status within 7 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 />.
f. With any isolation damper between the normal CAACS and the CREACS inoperable, secure the damper in the closed position within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 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 />.

MODES 5 and 6 or during movement of irradiated fuel assemblies

a. With one filtration train inoperable, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or suspend movement of irradiated fuel assemblies.
b. With CREACS aligned for single filtration train operation with one of the two remaining fans or associated outlet damper inoperable, restore the fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or suspend movement of irradiated fuel assemblies.
c. With two filtration trains inoperable, immediately suspend movement of irradiated fuel assemblies.
d. With the Control Room Envelope inoperablie, immediately suspend movement of irradiated fuel assemblies.
e. With, one or both series isolation damper(s) on a normal CAACS outside air intake or exhaust duct inoperable, immediately suspend movement of irradiated fuel assemblies until the affected duct is closed by use of at least one isolation damper secured in the closed position. (Refer to ACTION 28 of Table 3.3-6.)
f. With one or both series isolation damper(s) on an outside emergency air conditioning air intake duct inoperable, immediately suspend movement of irradiated fuel assemblies until the affected duct is closed by use of at least one isolation damper secured in the closed position. To resume movement of irradiated fuel assemblies, at least one emergency air intake duct must be operable on each unit.
g. With any isolation damper between the CAACS and the CREACS inoperable, immediately suspend movement of irradiated fuel assemblies until the damper is closed and secured in the closed position.

SALEM - UNIT 2 3/4 7-16 Amendment No.245

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS 4.7.6.1 The control room emergency air conditioning system shall be demonstrated OPERABLE:

a. At least once per 31 days by initiating flow through the HEPA filter and charcoal adsorber train(s) and verifying that the train(s) operates with each fan operating for at least 15 minutes.
b. At least once per 18 months or prior to return to service (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system, by:
1. Verifying that the charcoal adsorbers remove > 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place while operating the ventilation system at a flow rate of 8000 cfm +/- 10%.
2. Verifying that the HEPA filter banks remove > 99% of the DOP when they are tested in-place while operating the ventilation system at a flow rate of 8000 cfm +/- 10%.
3. Verifying within 31 days after removal from the CREACS unit, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30'C and a relative humidity of 95%.
c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal from the CREACS unit, that a laboratory analysis of a representative carbon sample, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows a methyl iodine penetration less than 2.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30 0 C and a relative humidity of 95%.
d. At least once per 18 months by:
1. Verifying that the pressure drop across the combined HEPA filter and charcoal adsorber bank is < 3.5 inches Water Gauge while operating the ventilation system at a flow rate of 8000 cfm +/- 10%.
2. Verifying that on a safety injection test signal or control room intake high radiation test signal, the system automatically actuates in the pressurization mode by opening the outside air supply and diverting air flow through the HEPA filter and charcoal adsorber bank.
3. Ve**ry ta the system can maintain the control room a f posiye pressure > 8" water gauge ative to the acent ar as during sy em operation wit akeup air bein supplied t rough flowrate makeu the A of filters f 2200and ch coal adsorbers1 the de 6 gn SALE

- UNT2 / -1 mndetNo 2 SALEM - UNIT 2 3/4 7-17 Amendment No. 226

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

4. Verifying that on a manual actuation signal, the system will actuate to the required pressurization or recirculation operating mode.
5. Verify each CREACS train has the capability to remove the assumed heat load.
e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove > 99% of the DOP when they are tested in-place while operating the filter system at a flow rate of 8000 cfm +/- 10%.
f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove > 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place while operating the filter system at a flow rate of 8000 cfm +/- 10%.

Sorfti. ROOM, Hwb~t..bliIhe Ctro Roow Pror (Aefe-r t T5 6,17)

SALEM - UNIT 2 3/4 7-17a Amendment No. 173

6.17 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Air Conditioning System (CREACS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.
b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

The following are exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREACS, operating at the flow rate required by the Surveillance Requirements, at a frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.
e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph
c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
f. The provisions of Surveillance Requirement 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

SALEM - UNIT 2 6-31 Amendment No. xxx

ATTACHMENT 3 License Amendment Request Salem Generating Station Units 1 & 2 NRC Docket Nos. 50-272 and 50-311 TSTF-448 Control Room Envelope Habitability Proposed Changes To Technical Specification Bases Pages (Mark-up)

(For information only)

REVISED TECHNICAL SPECIFICATION BASES PAGES Salem Generating Station, Unit 1 Pages B 3/4 7-5 B 3/4 7-5b B 3/4 7-5c

PLANT SYSTEMS BASES 3/4.7.5 FLOOD PROTECTION The limitation on flood protection ensures that facility protective actions will be taken and operation will be terminated in the event of flood conditions.

The limit of elevation 10.51 Mean Sea Level is based on the elevation above which facility flood control measures are required to provide protection to safety related equipment.

3/4.7.6 CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM The OPERABILITY of the "oroAr emer ency co itiong -ir stý 4CREACSý ensures that 1) the a-iinT-t air tempera dcs not exceed -the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions.

  • [ The CREACS is a shared system between Unit 1 and 2 supplying a common
  • XhveloTRE,. During emergency operation following receipt of a Safety Ihject on or High Radiation actuation signal, for areas inside the CRE, one 100% capacity fan in each Unit's CREACS will operate in a pressurization mode with a constant amount of outs'de air supplied for continued CRE pressurization /81wa r 9g9 One fan from each train will automatically start upon receipt o an initiation signal, with one fan in each train in standby. A failure of one fan will result in the standby fan automatically starting.

Each CREACS train has two 100%6 capacity fans, such that any one of the four fans is sized to provide the required flow for CRE pressurizationtt 18'*wate*..

ge *essr within the common CRE during an emergency.

A failure of one CREACS filtration train requires manual actions to properly reposition dampers in support of single filtration train operation.

To minimize control room radiological doses, the CREACS outside air is supplied from the non-accident unit's emergency air intake through the cross-connected supply duct (as determined by which unit received an accident signal). Outside air is mixed with recirculated air, passed through each CREACS filter bank (pre-filter, HEPA filter, and charcoal -44ýý and cooling coil, and distributed to the common CRE. .4 a CREACS will be manually initiated in the recirculation mode only in the event of a fire outside the CRE, a toxic chemical release, delivery of Ammonium 7

  • Hydroxide or testing.

SALEM - UNIT 1 B 3/4 7-5 Amendment No. 190

PLANT SYSTEMS BASES CAACS and CREACS interface isolation dampers: I(2)CAAl4 and I(2)CAA20 These two dampers are normally open and do not have associated redundant dampers. These dampers serve a boundary function by isolating the CREACS from the CAACS during emergency operation of the CREACS.

Note: Dampers l(2)CAA5, CAACS recirculation damper will receive an accident alignment signal to ensure proper accident configuration of CAACS. This damper, however, is not required for the OPERABILITY of CREACS as defined in the LCO.

tofg I operation of the CREACS when the emergency air conditioning system is capable maintaining a 1/8" water gauge positive pressure with the control room bound door(s) closed.

Fil er testing will be in accordance with the applicable section of ANSI N510 (1975 with the exception that laboratory testing of activated arbon will be in accord ce with ASTM D3803 (1989). The acceptance criteria or the laboratory test ig of the carbon adsorbe i determined by applying a minimum safety factor of 2 to the charcoal 4-1-* moval efficiency eredited in the design basis dose an Jysis as specified in Generic Letter 9,5-02.

TS Surveillance Req irement verifies that each faen is capable of operating for at least 15 minutes by itiating flow through e HEPA filter and charcoal adsorbers train(s) to ensure at the system is a ilable in a standby mode.

Each CAACS normal air intake uctwork w 1 have an additional radiation detector channel installed for a tot of t detectors per intake. The two detector channels from Unit 1 and Unit CS air intake provide input to common radiation monitor processors. E radiation monitor processor (one for IRlB-I/IRIB-2 and one for 2RlB-l/2RlB- ) pr ides a signal to initiate CREACS in the pressurization mode should high adiation e detected. A minimum of one out of two detectors in either intake ill initiate he pressurization mode. With two detector channels inoperable on a Unit, operat in may continue as long as CREACS is placed inservice in e pressurization or circulation mode.

Pressurization mode will be itiated after 7 days with e inoperable detector.

Radiological releases dun g a fuel handling accident whi operating in the recirculation mode could t in unacceptable radiation leve in the CRE since the automatic initation capability has been defeated for h radiation due to isolation of th detectors. Therefore, movement of irradiate fuel assemblies or Core A erations at either Unit will not be permitted whe in the recirculation mode.

Immediate a tion(s), in accordance with the LCO Action Statements, means that the required action should be pursued without delay and in a controlled mannaer.

SALEM - UNIT 1 B 3/4 7-5b Amendment No. 245

PLANT SYSTEMS BASES e 0 RABILITY of t's system in conjunctin with control room design prov sions is based o limiting the radiatýon exposure to personw1 occupyin the control room to 5 rem or less whole b dy, or its equivalent. This 1 iitation is consi'ent with the requir ents of General Des"gn Criterion 9 o* Appendix "A", 1CFR 50 except for t e Fuel Handling Acci ent, where t e a lowable doses t Control Room person el are provided by 1 CFR 50.67 and RG 1.183, Alternative Source Term.

3/4.7.7 AUXILIARY BUILDING EXHAUST AIR FILTRATION SYSTEM The Auxiliary Building Ventilation System (ABVS) consists of two major subsystems. They are designed to control Auxiliary Building temperature during normal and emergency modes of operation, and to maintain slightly negative pressure in the building to prevent unmonitored leakage out of the building and, to contain Auxiliary Building airborne contamination (by maintaining slightly negative pressure) during Loss of Coolant Accidents (LOCA).

The two subsystems are:

1. A once through filtration exhaust system, designed to contain particulate and gaseous contamination and prevent it from being released from the building in accordance with 10CFR20, and
2. A once through air supply system, designed to deliver outside air into the building to maintain building temperatures within acceptable limits. For the purposes of satisfying the Technical Specification LCO, one supply fan must be administratively removed from service such that the fan will not auto-start on an actuation signal; however, the supply fan must be OPERABLE with the exception of this administrative control.

These systems operate during normal and emergency plant modes. Additionally, the system provides a flow path for containment purge supply and exhaust during Modes 5 and 6. Either the Containment Purge system or the Auxiliary Building Ventilation System with suction from the containment atmosphere, with associated radiation monitoring will be available whenever movement of irradiated fuel is in progress in the containment building and the equipment hatch is open. If for any reason, this ventilation requirement can not be met, movement of fuel assemblies within the containment building shall be discontinued until the flow path(s) can be reestablished or close the equipment hatch and personnel airlocks.

Appropriate filtration surveillances are contained in the UFSAR Section 9.4.2.4, Test and Inspections. Auxiliary Building exhaust air filtration system functionality is not required to meet LCO 3.7.7.1.

The ventilation exhaust consists of three 50% capacity fans that are powered from vital buses. The fans are designed for continuous operation, to control the Auxiliary Building pressure at -0.10" Water Gauge with respect to atmosphere.

The ventilation supply consists of two 100% capacity fans that are powered from vital buses, and distribute outdoor air to the general areas and corridors of the building through associated ductwork.

SALEM - UNIT 1 B 3/4 7-5c TSBC SCN 06-015

Insert 4 BACKGROUND:

The control room emergency air conditioning system (CREACS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

Insert 5 The CREACS consists of two independent, redundant trains, one from each unit that re-circulate and filter the air in the Control Room Envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air. Each CREACS train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines),

and fans. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system.

Insert 6 The CREACS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding 5 Rem total effective dose equivalent (TEDE).

Insert 7 The CREACS is an emergency system, parts of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of the actuating signal(s), normal air supply to the CRE is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Pressurization of the CRE minimizes infiltration of

unfiltered air through the CRE boundary from all the surrounding areas adjacent to the CRE boundary.

j Insert 8 The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room and other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

APPLICABLE SAFETY ANALYSES The CREACS components are arranged in redundant, safety related ventilation trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. The CREACS provides airborne radiological protection for the CRE occupants, as demonstrated by the CRE occupant dose analyses for the most limiting design basis accident, fission product release presented in the UFSAR, Chapter 15.

The CREACS provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release, as described in UFSAR, Section 6.4. The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels, as described in UFSAR, Section 9.5.

LCO Two independent and redundant CREACS trains are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other train. Total system failure, such as from a loss of all ventilation trains or from an inoperable CRE boundary could result in exceeding a dose of 5 rem TEDE to the CRE occupants in the event of a large radioactive release.

In order for the CREACS trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area.

For other openings, these controls are proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition, when a need for CRE isolation is indicated.

Insert 9 APPLICABILITY In all MODES and during movement of irradiated fuel assemblies, the CREACS must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

During movement of irradiated fuel assemblies, the CREACS must be OPERABLE to cope with the release from a fuel handling accident, involving handling irradiated fuel.

ACTIONS When one CREACS train is inoperable, for reasons other than an inoperable CRE boundary, action must be taken to align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and restore the inoperable filtration train to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREACS train is adequate to perform the CRE occupant protection function. With CREACS aligned for single filtration train operation and with one of the two remaining fans or associated outlet damper inoperable, restore the inoperable fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. However, the overall reliability is reduced because a failure in the OPERABLE CREACS train could result in loss of CREACS function. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train components to provide the required capability.

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24-hour completion time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day completion time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day completion time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

In MODE 1, 2, 3, or 4, if the inoperable CREACS train or the CRE boundary cannot be restored to OPERABLE status within the required completion time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed completion times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 5 or 6, or during movement of irradiated fuel assemblies, if the inoperable CREACS train cannot be restored to OPERABLE status, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or suspend movement of irradiated fuel assemblies. With CREACS aligned for single filtration train operation with one of the two remaining fans or associated outlet damper inoperable, restore the fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is based on the ability of the remaining train components to provide the required capability.

In MODE 5 or 6, or during movement of irradiated fuel assemblies, with two CREACS trains inoperable or with one or more CREACS trains inoperable due to an inoperable CRE boundary, action must be taken

immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

Immediate action(s), in accordance with the LCO Action Statements, means that the required action should be pursued without delay and in a controlled manner.

SURVEILLANCE REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. The 31-day Frequency is based on the reliability of the equipment and the two-train redundancy. TS Surveillance Requirement verifies that each fan is capable of operating for at least 15 minutes by initiating flow through the HEPA filter and charcoal adsorbers train(s) to ensure that the system is available in a standby mode.

Filter testing verifies that the required CREACS testing is performed in accordance with the surveillance requirements. The surveillance requirements include testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the surveillance requirements. Filter testing will be in accordance with the applicable sections of ANSI N510 (1975) with the exception that laboratory testing of activated carbon will be in accordance with ASTM D3803 (1989). The acceptance criteria for the laboratory testing of the carbon adsorber is determined by applying a minimum safety 'factor of 2 to the charcoal adsorber removal efficiency credited in the design basis dose analysis as specified in Generic Letter 99-02.

Actuation testing verifies that each CREACS train starts and operates on an actual or simulated actuation signal. The Frequency of 18-months is based on industry operating experience and is consistent with the typical refueling cycle.

The control room envelope is considered intact and able to support operation of the CREACS when the emergency air conditioning system is capable of maintaining positive pressure with the control room boundary door(s) closed. Unfiltered air inleakage testing verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

Each CAACS normal air intake ductwork has two radiation detector channels. The two detector channels from Unit 1 and Unit 2 CAACS air intake provide input to common radiation monitor processors. Each radiation monitor processor (one for 1RIB-1/lRlB-2 and one for 2RlB-l/2R1B-2) provides a signal to initiate CREACS in the pressurization mode should high radiation be detected. A minimum of one out of two detectors in either intake will initiate the pressurization mode. With two detector channels inoperable on a Unit, operation may continue as long as CREACS is placed in-service in the pressurization or recirculation mode. Pressurization mode will be initiated after 7 days with one inoperable detector. Radiological releases during a fuel handling accident while operating in the recirculation mode could result in unacceptable radiation levels in the CRE since the automatic initiation capability has been defeated for high radiation due to isolation of the detectors. Therefore, movement of irradiated fuel assemblies or Core Alterations at either Unit will not be permitted when in the recirculation mode.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. The testing verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, CRE boundary is inoperable. Required action allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F. These compensatory measures may also be used as required mitigating actions. Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

REVISED TECHNICAL SPECIFICATION BASES PAGES Salem Generating Station, Unit 2 Pages B 3/4 7-5 B 3/4 7-5b B 3/4 7-5c

PLANT SYSTEMS BASES 3/4.7.5 FLOOD PROTECTION The limitation on flood protection ensures that facility protective actions will be taken and operation will be terminated in the event of flood conditions. The limit of elevation 10.5? Mean Sea Level is based on the elevation above which facility flood control measures are required to provide protection to safety-related equipment.

3/4.7.6 CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM S-->The OPERABILITY of the corol roop emergence air con~tionin sys em (CREACS) ensures that 1) the aiiient 3air- temperature does not exce-d the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions.

JWcEA-T--5 The CREACS is a shared system between Unit 1 and 2 supplying a common

<o~jtrol Rbom Env... ý(CRE). During emergency operation following receipt of a Safety Injection or High Radiation actuation signal, for areas inside the CRE, one 100% capacity fan in each Unit's CREACS will operate in a pressurization mode with a constant amount of outside air supplied for continued CRE pressurization q_1 a ga4 .One fan from each train will automatically start upon receipt of an initia ion signal, with one fan in each train in standby. A failure of one fan will result in the standby fan automatically starting.

Each CREACS train has two 100% capacity fans, such that any one o_ the

,0 four fans is sized to provide the required flow for CRE pressurization*t7l/1??I

-er gaug pos0 ive essM within the common CRE during an emergency.

A failure of one CREACS filtration train requires manual actions to properly reposition dampers in support of single filtration train operation.

To minimize control room radiological doses, the CREACS outside air is supplied from the non-accident unit's emergency air intake through the cross-connected supply duct (as determined by which unit received an accident signal). Outside air is mixed with recirculated air, passed through each CREACS filter bank (pre-filter, HEPA filter, and charcoal *f*, and cooling coil, and distributed to the common CRE.

CREACS will be manually initiated in the recirculation mode only i*rithe

  • Jevnt of a fire outside the CRE, a toxic chemical release, delivery of Ammonium Hydroxide or testing.

SALEM - UNIT 2 B 3/4 7-5 Amendment No. 173

PLANT SYSTEMS BASES CAACS and CREACS interface isolation dampers: l(2)CAAI4 and l(2)CAA20 These two dampers are normally open and do not have associated redundant dampers. These dampers serve a boundary function by isolating the CREACS from the CAACS during emergency operation of the CREACS.

Note: Dampers 1(2)CAA5, CAACS recirculation damper will receive an accident alignment signal to ensure proper accident configuration of CAACS. This damper, however, is not required for the OPERABILITY of CREACS as defined in the LCO.

The-ontrol room enve ope is considered intact and able to support operation f the CREACS when the ergency air conditioning system is capable o maintaini g a 1/81 water gauge po itive pressure with the control room bounda door(s) osed.

.ilter testing will be i accordance with the pplicable sections of ANSI N510 1975) with the exceptio that laboratory test g of activated carbon will be i accordance with ASTM D/803 (1989). The accep ance criteria for the la ratory testing of the carbon adsorber is dete mined by applying a minimum s ety factor of 2 to the 6harcoal filter removal efficiency credited in the esign basis dose analysi? as specified in Generc Letter 99-02.

TS Surveillance Requirement verifies tha each fan is capable of op ating

-for at least 15 minutes by initiating flow th ugh the HEPA filter and c rcoal adsorber train(s) to ensure that the system s available in a standby m e.

Each CAACS n* al air intake ductwor will have an additional r diation detector channel

  • stalled for a total of two detectors per intake. The two detector channel from Unit 1 and Unit 2 CAACS air intake provide 'put to common radiation monitor processors. E ch radiation monitor proc ssor (one for IRIB-l/IRIB-2 Ad one for 2RlB-I/2RlB- ) provides a signal to initiate CREACS in the pressuriz ion mode should high r diation be detected. A minimum of one out of two detect rs in either intake wi 1 initiate the pressuriz ion mode. With two detector channels inoperable on a Unit, operation may co inue as long as CREACS is p aced inservice in the ressurization or recircu ation mode.

Pressuriza ion mode will be initi ted after 7 days with on inoperable detecto Radiologi al releases during a uel handling accide7ntwhle operating in the recircula ion mode could result in unacceptable radiatio levels in the CRE since the( automatic initiation capability has been defe ed for high radiat n due to isolation of the detec ors. Therefore, movemen of irradiated fuel assemblies or Core Alteratio at either Unit will no be permitted when the recirculation mode.

Immediate action(s), n accordance with the LCO Action Statements; means that the required action should be pursued without delay and in a controlled manner.

SALEM - UNIT 2 B 3/4 7-5b Amendment No. 226

PLANT SYSTEMS BASES The ILITY of this system in onjunction with ontrol room design provisi s is based n limiting the r diation exposure o personnel cupying the c trol room to 5 rem or less who e body, or its e ivalent. Thi imitati n is onsistent wi the requiremen s of General De gn Criterion (GDC) 19 of Ap endix "A", 10 CFR Part 50. Th re-analysis of e Fuel Handling Accide is b sed on the cr teria of 10 CF 50.67 and Reg. iide 1.183, Al ernative , ource Term, which replace GDC 19 for Control Room dose 3/4.7.7 AUXILIARY BUILDING EXHAUST AIR FILTRATION SYSTEM The Auxiliary Building Ventilation System (ABVS) consists of two major subsystems. They are designed to control Auxiliary Building temperature during normal and emergency modes of operation, and to contain Auxiliary Building airborne contamination (by maintaining slightly negative pressure) during Loss of Coolant Accidents (LOCA). The two subsystems are:

1. A once through filtration exhaust system, designed to contain particulate and gaseous contamination and prevent it from being released from the building in accordance with 10CFR20, and
2. A once through air supply system, designed to deliver outside air into the building to maintain building temperatures within acceptable limits. For the purposes of satisfying the Technical Specification LCO, one supply fan must be administratively removed from service such that the fan will not auto-start on an actuation signal; however, the supply fan must be OPERABLE with the exception of this administrative control.

These systems operate during normal and emergency plant modes. Additionally, the system provides a flow path for containment purge supply and exhaust during Modes 5 and 6. Either the Containment Purge system or the Auxiliary Building Ventilation System with suction from the containment atmosphere, with associated radiation monitoring will be available whenever movement of irradiated fuel is in progress in the containment building and the equipment hatch is open. If for any reason, this ventilation requirement can not be met, movement of fuel assemblies within the containment building shall be discontinued until the flow path(s) can be reestablished or close the equipment hatch and personnel airlocks.

Appropriate filtration surveillances are contained in the Updated Final Safety Analysis Report (UFSAR) Section 9.4.2.4, Test and Inspections. Auxiliary Building exhaust air filtration system functionality is not required to meet LCO 3.7.7.

The ventilation exhaust consists of three 50% capacity fans that are powered from vital buses. The fans are designed for continuous operation, to control the Auxiliary Building pressure at -0.10" Water Gauge with respect to atmosphere.

The ventilation supply consists of two 100% capacity fans that are powered from vital buses, and distribute outdoor air to the general areas and corridors of the building through associated ductwork.

SALEM - UNIT 2 B 3/4 7-5c TSBC SCN 06-015

Insert 4 BACKGROUND:

The control room emergency air conditioning system (CREACS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

Insert 5 The CREACS consists of two independent, redundant trains, one from each unit that re-circulate and filter the air in the Control Room Envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air. Each CREACS train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines),

and fans. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system.

Insert 6 The CREACS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding 5 Rem total effective dose equivalent (TEDE).

Insert 7 The CREACS is an emergency system, parts of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of the actuating signal(s), normal air supply to the CRE is isolated, and the stream of ventilation air is recirculated through the system filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Pressurization of the CRE minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas adjacent to the CRE boundary.

Insert 8 The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room and other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

APPLICABLE SAFETY ANALYSES The CREACS components are arranged in redundant, safety related ventilation trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. The CREACS provides airborne radiological protection for the CRE occupants, as demonstrated by the CRE occupant dose analyses for the most limiting design basis accident, fission product release presented in the UFSAR, Chapter 15.

The CREACS provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release, as described in UFSAR, Section 6.4. The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels, as described in UFSAR, Section 9.5.

LCO Two independent and redundant CREACS trains are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other train. Total system failure, such as from a loss of all ventilation trains or from an inoperable CRE boundary could result in exceeding a dose of 5 rem TEDE to the CRE occupants in the event of a large radioactive release.

In order for the CREACS trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area.

For other openings, these controls are proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition, when a need for CRE isolation is indicated.

Insert 9 APPLICABILITY In all MODES and during movement of irradiated fuel assemblies, the CREACS must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

During movement of irradiated fuel assemblies, the CREACS must be OPERABLE to cope with the release from a fuel handling accident, involving handling irradiated fuel.

ACTIONS When one CREACS train is inoperable, for reasons other than an inoperable CRE boundary, action must be taken to align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and restore the inoperable filtration train to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREACS train is adequate to perform the CRE occupant protection function. With CREACS aligned for single filtration train operation and with one of the two remaining fans or associated outlet damper inoperable, restore the inoperable fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. However, the overall reliability is reduced because a failure in the OPERABLE CREACS train could result in loss of CREACS function. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train components to provide the required capability.

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the

effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24-hour completion time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day completion time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day completion time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

In MODE 1, 2, 3, or 4, if the inoperable CREACS train or the CRE boundary cannot be restored to OPERABLE status within the required completion time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed completion times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

In MODE 5 or 6, or during movement of irradiated fuel assemblies, if the inoperable CREACS train cannot be restored to OPERABLE status, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or suspend movement of irradiated fuel assemblies. With CREACS aligned for single filtration train operation with one of the two remaining fans or associated outlet damper inoperable, restore the fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is based on the ability of the remaining train components to provide the required capability.

In MODE 5 or 6, or during movement of irradiated fuel assemblies, with two CREACS trains inoperable or with one or more CREACS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

Immediate action(s), in accordance with the LCO Action Statements, means that the required action should be pursued without delay and in a controlled manner.

SURVEILLANCE REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. The 31-day Frequency is based on the reliability of the equipment and the two-train redundancy. TS Surveillance Requirement verifies that each fan is capable of operating for at least 15 minutes by initiating flow through the HEPA filter and charcoal adsorbers train(s) to ensure that the system is available in a standby mode.

Filter testing verifies that the required CREACS testing is performed in accordance with the surveillance requirements. The surveillance requirements include testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the surveillance requirements. Filter testing will be in accordance with the applicable sections of ANSI N510 (1975) with the exception that laboratory testing of activated carbon will be in accordance with ASTM D3803 (1989). The acceptance criteria for the laboratory testing of the carbon adsorber is determined by applying a minimum safety factor of 2 to the charcoal adsorber removal efficiency credited in the design basis dose analysis as specified in Generic Letter 99-02.

Actuation testing verifies that each CREACS train starts and operates on an actual or simulated actuation signal. The Frequency of 18-months is based on industry operating experience and is consistent with the typical refueling cycle.

'j The control room envelope is considered intact and able to support operation of the CREACS when the emergency air conditioning system is capable of maintaining positive pressure with the control room boundary door(s) closed. Unfiltered air inleakage testing verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

Each CAACS normal air intake ductwork has two radiation detector channels. The two detector channels from Unit 1 and Unit 2 CAACS air intake provide input to common radiation monitor processors. Each radiation monitor processor (one for IRlB-I/1R1B-2 and one for 2RIB-1/2R1B-2) provides a signal to initiate CREACS in the pressurization mode should high radiation be detected. A minimum of one out of two detectors in either intake will initiate the pressurization mode. With two detector channels inoperable on a Unit, operation may continue as long as CREACS is placed in-service in the pressurization or recirculation mode. Pressurization mode will be initiated after 7 days with one inoperable detector. Radiological releases during a fuel handling accident while operating in the

recirculation mode could result in unacceptable radiation levels in the CRE since the automatic initiation capability has been defeated for high radiation due to isolation of the detectors. Therefore, movement of irradiated fuel assemblies or Core Alterations at either Unit will not be permitted when in the recirculation mode.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. The testing verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, CRE boundary is inoperable. Required action allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F. These compensatory measures may also be used as required mitigating actions. Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

ATTACHMENT 4 License Amendment Request Salem Generating Station Units 1 & 2 NRC Docket Nos. 50-272 and 50-311 TSTF-448 Control Room Envelope Habitability Revised Technical Specification/Bases Pages

REVISED TECHNICAL SPECIFICATION/BASES PAGES Salem Generating Station, Unit 1 Facility Operating License Page 5

Technical Specification Pages 3/4 7-18 3/4 7-19 3/4 7-20 3/4 7-21 6-31 Technical Specification Bases Pages B 3/4 7-5 B 3/4 7-5a B 3/4 7-5b B 3/4 7-5c B 3/4 7-5d B 3/4 7-5e B 3/4 7-5f

(16)Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.6.2, in accordance with TS 6.18.c. (i),

the assessment of CRE habitability as required by Specification 6.18.c. (ii), and the measurement of CRE pressure as required by Specification 6.18.d, shall be considered met. Following implementation:

a. The first performance of SR 4.7.6.2, in accordance with Specification 6.18.c. (i), shall be within the specified frequency of 6 years, plus the 18 month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
b. The first performance of the periodic assessment of CRE habitability, Specification 6.18.c(ii), shall be 3 years, plus the 9 month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
c. The first performance of the periodic measurement of CRE pressure, Specification 6.18.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from September 22, 2005, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

D. Paragraph 2.D. has been combined with paragraph 2.E. per Amendment No.

86, June 27, 1988.

E. The licensees shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Salem-Hope Creek Nuclear Generating Station Security Plan,"

with revisions submitted through December 17, 2001; "Salem-Hope Creek Nuclear Generating Station Security Training and Qualification Plan,"

with revisions submitted through December 17, 2001; and "Salem-Hope Creek Nuclear Generating Station Security Contingency Plan," with revisions submitted through June 2, 1998. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.

F. In accordance with the requirement imposed by the October 8, 1976, order of the United States Court of Appeals for the District of Columbia Circuit in Natural Resources Defense Council v. Nuclear Regulatory Commission, No. 74-1385 and 74-1586, that the Nuclear Regulatory Commission "shall make any licenses granted between July 21, 1976 and such time when the mandate is issued subject to the outcome of the proceedings herein," the license amendment issued herein shall be subject to the outcome of such proceedings.

Amendment No. , , 250, xxx

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 The common control room emergency air conditioning system (CREACS)*

shall be OPERABLE with:

a. Two independent air conditioning filtration trains (one from each unit) consisting of:
1. Two fans and associated outlet dampers,
2. One cooling coil,
3. One charcoal adsorber and HEPA filter array,
4. Return air isolation damper.
b. All other automatic dampers required for operation in the pressurization or recirculation modes.
c. The control room envelope intact.

NOTE: The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: ALL MODES and during movement of irradiated fuel assemblies.

ACTION: MODES 1, 2, 3, and 4

a. With one filtration train inoperable, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and restore the inoperable filtration train to OPERABLE status within 30 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 CREACS aligned for single filtration train operation and with one of the two remaining fans or associated outlet damper inoperable, restore the inoperable fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 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 />.
c. With the Control Room Envelope boundary inoperable:
1. Immediately, initiate action to implement mitigating actions, and
2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits, and
3. Within 90 days, Rrestore the Control Room Envelope boundary to OPERABLE status, 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 />.

The CREACS is a shared system with Salem Unit 2 SALEM - UNIT 1 3/4 7-18 Amendment No.xxx

PLANT SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

d. With one or both series isolation damper(s) on a normal Control Area Air Conditioning System (CAACS) outside air intake or exhaust duct inoperable, close the affected duct within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one isolation damper secured in the closed position 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 />. (Refer to ACTION 25 of Table 3.3-6.)
e. With one or both isolation damper(s) on an outside emergency air conditioning air intake duct inoperable, close the affected duct within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one isolation damper secured in the closed position and restore the damper(s) to OPERABLE status within 7 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 />.
f. With any isolation damper between the normal CAACS and the CREACS inoperable, secure the damper in the closed position within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 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 />.

MODES 5 and 6 or during movement of irradiated fuel assemblies

a. With one filtration train inoperable, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or suspend movement of irradiated fuel assemblies.
b. With CREACS aligned for single filtration train operation with one of the two remaining fans or associated outlet damper inoperable, restore the fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or suspend movement of irradiated fuel assemblies.
c. With two filtration trains inoperable, immediately suspend movement of irradiated fuel assemblies.
d. With the Control Room Envelope boundary inoperable, immediately suspend movement of irradiated fuel assemblies.
e. With one or both series isolation damper(s) on a normal CAACS outside air intake or exhaust duct inoperable, immediately suspend movement of irradiated fuel assemblies until the affected duct is closed by use of at least one isolation damper secured in the closed position. (Refer to ACTION 25 of Table 3.3-6.)
f. With one or both series isolation damper(s) on an outside emergency air conditioning air intake duct inoperable, immediately suspend movement of irradiated fuel assemblies until the affected duct is closed by use of at least one isolation damper secured in the closed position. To resume movement of irradiated fuel assemblies, at least one emergency air intake duct must be operable on each unit.
g. With any isolation damper between the CAACS and the CREACS inoperable, immediately suspend movement of irradiated fuel assemblies until the damper is closed and secured in the closed position.

SALEM - UNIT 1 3/4 7-19 Amendment No.xxx

SURVEILLANCE REQUIREMENTS 4.7.6.1 Each control room emergency air conditioning system filtration train shall be demonstrated OPERABLE:

a. At least once per 31 days by initiating flow through the HEPA filter and charcoal adsorber train(s) and verifying that the train(s) operates with each fan operating for at least 15 minutes.
b. At least once per 18 months or prior to return to service (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system, by:
1. Verifying that the charcoal adsorbers remove Ž99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place while operating the ventilation system at a flow rate of 8000 cfm +/-10%.
2. Verifying that the HEPA filter banks remove Ž99% of the DOP when they are tested in-place while operating the ventilation system at a flow rate of 8000 cfm +/-10%.
3. Verifying within 31 days after removal from the CREACS unit, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5%

when tested in accordance with ASTM D3803-1989 at a temperature of 30 0 C and a relative humidity of 95%.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 dayE after removal from the CREACS unit, that a laboratory analysis of a representative carbon sample, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows a methyl iodide penetration less than 2.5% when tested in accordance with ASTM D3803-198(

at a temperature of 30'C and a relative humidity of 95%.

d. At least once per 18 months by:
1. Verifying that the pressure drop across the combined HEPA filter and charcoal adsorber bank is
  • 3.5 inches water gauge while operating the ventilation system at a flow rate of 8000 cfm +/- 10%.

2.* Verifying that on a safety injection test signal or control room intake high radiation test signal, the system automatically actuates in the pressurization mode by opening the outside air supply and diverting air flow through the HEPA filter and charcoal adsorber bank.

3. Deleted.
  • A one time extension to this surveillance requirement which is satisfied by performance of the Manual SI test is granted during fuel cycle thirteen allowing Unit 1 operations to continue to the thirteenth refueling outage (IR13). The surveillance testing is to be completed at the appropriate time during the 1R13 outage, prior to the unit returning to Mode 4 upon outage completion.

SALEM - UNIT 1 347-20 Amendment No. xxx

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

4. Verifying that on a manual actuation signal, the system will actuate to the required pressurization or recirculation operating mode.
5. Verify each CREACS train has the capability to remove the assumed heat load.
e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove Ž 99% of the DOP when they are tested in-place while operating the filter system at a flow rate of 8000 cfm +/- 10%.
f. After each complete or partial replacement of a charcoal absorber bank by verifying that the charcoal absorbers remove Ž 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place while operating the filter system at a flow rate of 8000 cfm +/- 10%.

4.7.6.2 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program (Refer to T.S. 6.18).

SALEM - UNIT 1 3/4 7-21 Amendment No. xxx

ADMINISTRATIVE CONTROLS

c. Proposed changes to the Bases that require either condition of Specification 6.17.b above shall be reviewed and approved by the NRC prior to Implementation.
d. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e).
e. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.

6.18 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Air Conditioning System (CREACS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.
b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for (i) determining the unfiltered air inleakage past tine CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

The following are exceptions to Sections C.1 and C.2 of Regulatory Guide 1-197, Revision 0:

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREACS, operating at the flow rate required by the Surveillance Requirements, at a frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.
e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph
c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
f. The provisions of Surveillance Requirements 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

SALEM - UNIT 1 6-31 Amendment No. xxx

3/4.7 PLANT SYSTEMS BASES 3/4.7.6 CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM BACKGROUND:

The control room emergency air conditioning system (CREACS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The OPERABILITY of the CREACS ensures that 1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions.

The CREACS consists of two independent, redundant trains, one from each unit that re-circulate and filter the air in the Control Room Envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air. Each CREACS train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and fans. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system. The CREACS is a shared system between Unit 1 and 2 supplying a common CRE. During emergency operation following receipt of a Safety Injection or High Radiation actuation signal, for areas inside the CRE, one 100% capacity fan in each Unit's CREACS will operate in a pressurization mode with a constant amount of outside air supplied for continued CRE pressurization. One fan from each train will automatically start upon receipt of an initiation signal, with one fan in each train in standby. A failure of one fan will result in the standby fan automatically starting.

Each CREACS train has two 100% capacity fans, such that any one of the four fans is sized to provide the required flow for CRE pressurization within the common CRE during an emergency.

A failure of one CREACS filtration train requires manual actions to properly reposition dampers in support of single filtration train operation.

To minimize control room radiological doses, the CREACS outside air is supplied from the non-accident unit's emergency air intake through the cross-connected supply duct (as determined by which unit received an accident signal). Outside air is mixed with recirculated air, passed through each CREACS filter bank (pre-filter, HEPA filter, and charcoal adsorber) and cooling coil, and distributed to the common CRE. The CREACS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding 5 Rem total effective dose equivalent (TEDE).

SALEM - UNIT 1 B 3/4 7-5 Amendment No. XXX

3/4.7 PLANT SYSTEMS BASES The CREACS is an emergency system, parts of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of the actuating signal(s), normal air supply to the CRE is isolated, and the stream of ventilation air is recirculated through the system filter trains.

The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Pressurization of the CRE minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas adjacent to the CRE boundary. CREACS will be manually initiated in the recirculation mode only in the event of a fire outside the CRE, a toxic chemical release, delivery of Ammonium Hydroxide or testing.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room and other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

APPLICABLE SAFETY ANALYSES The CREACS components are arranged in redundant, safety related ventilation trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. The CREACS provides airborne radiological protection for the CRE occupants, as demonstrated by the CRE occupant dose analyses for the most limiting design basis accident, fission product release presented in the UFSAR, Chapter 15.

The CREACS provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release, as described in UFSAR, Section 6.4. The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels, as described in UFSAR, Section 9.5.

SALEM - UNIT 1 B 3/4 7-5a Amendment No. XXX

3/4.7 PLANT SYSTEMS BASES LCO Two independent and redundant CREACS trains are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other train. Total system failure, such as from a loss of all ventilation trains or from an inoperable CRE boundary could result in exceeding a dose of 5 rem TEDE to the CRE occupants in the event of a large radioactive release.

In order for the CREACS trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls are proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition, when a need for CRE isolation is indicated.

A significant contributor to this system's OPERABILITY are the dampers, which are required to actuate to their correct positions. The following dampers are associated with the respective LCO*:

a.l Fan outlet dampers: l(2)CAAI5 and I(2)CAAI6 These dampers ensure that the flow path for CREACS is operable and are required to open upon CREACS initiation. The associated fan outlet damper will open on fan operation.

a.4 Return air isolation damper: I(2)CAAl7 When aligned for single train operation, the associated air return isolation damper will be administratively controlled in the open position.

b. Other dampers required for automatic operation in the pressurization or recirculation modes:

Control Area Air Conditioning System (CAACS) outside air intake isolation dampers: I(2)CAA40, l(2)CAA41, I(2)CAA43 and I(2)CAA45 The normally open outside air intake dampers I(2)CAA40 and inlet plenum isolation dampers l(2)CAA43 will be closed under emergency conditions.

The normally closed outside air intake dampers l(2)CAA41 and inlet plenum isolation dampers I(2)CAA45 are normally closed and remain closed under emergency conditions.

  • Operability of the CREACS requires that each of the Unit 2 dampers are also operable SALEM - UNIT 1 B 3/4 7-5b Amendment No. XXX

3/4.7 PLANT SYSTEMS BASES Control Area Air Conditioning System (CAACS) exhaust isolation dampers:

I(2)CAAI8 and I(2)CAAI9.

These dampers are normally closed and are required to remain closed to prevent inleakage from the outside environment in the event of a toxic release.

Control Room Emergency Air Conditioning System (CREACS) air intake dampers: I(2)CAA48, I(2)CAA49, l(2)CAA5O and I(2)CAA51 CREACS outside air intake dampers are maintained closed during normal and recirculation operation and are opened automatically upon initiation of CREACS pressurization. The control logic will automatically open the CREACS air intake dampers farthest from the radiation source based upon which Unit's Solid State Protection System (SSPS) or Radiation Monitoring System (RMS) signal is received.

CAACS and CREACS interface isolation dampers: I(2)CAAI4 and I(2)CAA20 These two dampers are normally open and do not have associated redundant dampers. These dampers serve a boundary function by isolating the CREACS from the CAACS during emergency operation of the CREACS.

Note: Dampers I(2)CAAS, CAACS recirculation damper will receive an accident alignment signal to ensure proper accident configuration of CAACS. This damper, however, is not required for the OPERABILITY of CREACS as defined in the LCO.

APPLICABILITY In all MODES and during movement of irradiated fuel assemblies, the CREACS must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

During movement of irradiated fuel assemblies, the CREACS must be OPERABLE to cope with the release from a fuel handling accident, involving handling irradiated fuel.

SALEM - UNIT 1 B 3/4 7-5c Amendment No. XXX

3/4.7 PLANT SYSTEMS BASES ACTIONS When one CREACS train is inoperable, for reasons other than an inoperable CRE boundary, action must be taken to align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and restore the inoperable filtration train to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREACS train is adequate to perform the CRE occupant protection function. With CREACS aligned for single filtration train operation and with one of the two remaining fans or associated outlet damper inoperable, restore the inoperable fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

However, the overall reliability is reduced because a failure in the OPERABLE CREACS train could result in loss of CREACS function. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train components to provide the required capability.

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e.,

actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24-hour completion time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day completion time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day completion time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

In MODE 1, 2, 3, or 4, if the inoperable CREACS train or the CRE boundary cannot be restored to OPERABLE status within the required completion time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed completion times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SALEM - UNIT 1 B 3/4 7-5d Amendment No. XXX

3/4.7 PLANT SYSTEMS BASES In MODE 5 or 6, or during movement of irradiated fuel assemblies, if the inoperable CREACS train cannot be restored to OPERABLE status, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or suspend movement of irradiated fuel assemblies. With CREACS aligned for single filtration train operation with one of the two remaining fans or associated outlet damper inoperable, restore the fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is based on the ability of the remaining train components to provide the required capability.

Immediate action(s), in accordance with the LCO Action Statements, means that the required action should be pursued without delay and in a controlled manner.

SURVEILLANCE REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, tes.ting each train once every month provides an adequate check of this system. The 31-day Frequency is based on the reliability of the equipment and the two-train redundancy. TS Surveillance Requirement verifies that each fan is capable of operating for at least 15 minutes by initiating flow through the HEPA filter and charcoal adsorbers train(s) to ensure that the system is available in a standby mode.

Filter testing verifies that the required CREACS testing is performed in accordance with the surveillance requirements. The surveillance requirements include testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the surveillance requirements. Filter testing will be in accordance with the applicable sections of ANSI N510 (1975) with the exception that laboratory testing of activated carbon will be in accordance with ASTM D3803 (1989). The acceptance criteria for the laboratory testing of the carbon adsorber is determined by applying a minimum safety factor of 2 to the charcoal adsorber removal efficiency credited in the design basis dose analysis as specified in Generic Letter 99-02.

Actuation testing verifies that each CREACS train starts and operates on an actual or simulated actuation signal. The Frequency of 18-months is based on industry operating experience and is consistent with the typical refueling cycle.

SALEM - UNIT I B 3/4 7-5e Amendment No. XXX

3/4.7 PLANT SYSTEMS BASES The control room envelope is considered intact and able to support operation of the CREACS when the emergency air conditioning system is capable of maintaining positive pressure with the control room boundary door(s) closed.

Unfiltered air inleakage testing verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

Each CAACS normal air intake ductwork has two radiation detector channels.

The two detector channels from Unit 1 and Unit 2 CAACS air intake provide input to common radiation monitor processors. Each radiation monitor processor (one for IRIB-l/lRIB-2 and one for 2RIB-I/2RlB-2) provides a signal to initiate CREACS in the pressurization mode should high radiation be detected. A minimum of one out of two detectors in either intake will initiate the pressurization mode. With two detector channels inoperable on a Unit, operation may continue as long as CREACS is placed in-service in the pressurization or recirculation mode. Pressurization mode will be initiated after 7 days with one inoperable detector. Radiological releases during a fuel handling accident while operating in the recirculation mode could result in unacceptable radiation levels in the CRE since the automatic initiation capability has been defeated for high radiation due to isolation of the detectors. Therefore, movement of irradiated fuel assemblies or Core Alterations at either Unit will not be permitted when in the recirculation mode.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. The testing verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, CRE boundary is inoperable. Required action allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F. These compensatory measures may also be used as required mitigating actions.

Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

SALEM - UNIT 1 B 3/4 7-5f Amendment No. XXX

REVISED TECHNICAL SPECIFICATION PAGES Salem Generating Station, Unit 2 Facility Operating License Page 22b Technical Specification Pages 3/4 7-15 3/4 7-16 3/4 7-17 3/4 7-17a 6-31 Technical Specification Bases Pages B 3/4 7-5 B 3/4 7-5a B 3/4 7-5b B 3/4 7-5c B 3/4 7-5d B 3/4 7-5e B 3/4 7-5f

-22b-(32) Upon implementation of Amendment No. xxx adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 4.7.6.2, in accordance with TS 6.17.c. (i), the assessment of CRE habitability as required by Specification 6.18.c. (ii), and the measurement of CRE pressure as required by Specification 6.18.d, shall be considered met. Following implementation:

a. The first performance of SR 4.7.6.2, in accordance with Specification 6.17.c.(i), shall be within the specified frequency of 6 years, plus the 18 month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
b. The first performance of the periodic assessment of CRE habitability, Specification 6.17.c(ii), shall be 3 years, plus the 9 month allowance of SR 4.0.2, as measured from June 4, 2003, the date of the most recent successful tracer gas test, as stated in the December 9, 2003 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
c. The first performance of the periodic measurement of CRE pressure, Specification 6.18.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from September 22, 2005, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

Amendment No. XXX

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6 The common control room emergency air conditioning system (CREACS)*

shall be OPERABLE with:

a. Two independent air conditioning filtration trains (one from each unit) consisting of:
1. Two fans and associated outlet dampers,
2. One cooling coil,
3. One charcoal adsorber and HEPA filter array,
4. Return air isolation damper.
b. All other automatic dampers required for operation in the pressurization or recirculation modes.
c. The control room envelope intact.

NOTE: The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: ALL MODES and during movement of irradiated fuel assemblies.

ACTION: MODES 1, 2, 3, and 4

a. With one filtration train inoperable, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and restore the inoperable filtration train to OPERABLE status within 30 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 CREACS aligned for single filtration train operation and with one of the two remaining fans or associated outlet damper inoperable, restore the inoperable fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 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 />.
c. With the Control Room Envelope boundary inoperable:
1. Immediately, initiate action to implement mitigating actions, and
2. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, verify mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits, and
3. Within 90 days, restore the Control Room Envelope boundary to OPERABLE status, 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 />.
  • The CREACS is a shared system with Salem Unit 1 SALEM - UNIT 2 3/4 7-15 Amendment No.xxx

PLANT SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

d. With one or both series isolation damper(s) on a normal Control Area Air Conditioning System (CAACS) outside air intake or exhaust duct inoperable, close the affected duct within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one isolation damper secured in the closed position 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 />. (Refer to ACTION 28 of Table 3.3-6.)
e. With one or both isolation damper(s) on an outside emergency air conditioning air intake duct inoperable, close the affected duct within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one isolation damper secured in the closed position and restore the damper(s) to OPERABLE status within 7 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 />.
f. With any isolation damper between the normal CAACS and the CREACS inoperable, secure the damper in the closed position within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 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 />.

MODES 5 and 6 or during movement of irradiated fuel assemblies

a. With one filtration train inoperable, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or suspend movement of irradiated fuel assemblies.
b. With CREACS aligned for single filtration train operation with one of the two remaining fans or associated outlet damper inoperable, restore the fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or suspend movement of irradiated fuel assemblies.
c. With two filtration trains inoperable, immediately suspend movement of irradiated fuel assemblies.
d. With the Control Room Envelope boundary inoperable, immediately suspend movement of irradiated fuel assemblies.
e. With one or both series isolation damper(s) on a normal CAACS outside air intake or exhaust duct inoperable, immediately suspend movement of irradiated fuel assemblies until the affected duct is closed by use of at least one isolation damper secured in the closed position. (Refer to ACTION 28 of Table 3.3-6.)
f. With one or both series isolation damper(s) on an outside emergency air conditioning air intake duct inoperable, immediately suspend movement of irradiated fuel assemblies until the affected duct is closed by use of at least one isolation damper secured in the closed position. To resume movement of irradiated fuel assemblies, at least one emergency air intake duct must be operable on each unit.
g. With any isolation damper between the CAACS and the CREACS inoperable, immediately suspend movement of irradiated fuel assemblies until the damper is closed and secured in the closed position.

SALEM - UNIT 2 3/4 7-16 Amendment No.xxx

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS 4.7.6.1 Each control room emergency air conditioning system filtration train shall be demonstrated OPERABLE:

a. At least once per 31 days by initiating flow through the HEPA filter and charcoal adsorber train(s) and verifying that the train(s) operates with each fan operating for at least 15 minutes.
b. At least once per 18 months or prior to return to service (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system, by:
1. Verifying that the charcoal adsorbers remove >99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place while operating the ventilation system at a flow rate of 8000 cfm

+/-10%.

2. Verifying that the HEPA filter banks remove >99% of the DOP when they are tested in-place while operating the ventilation system at a flow rate of 8000 cfm +/-10%.
3. Verifying within 31 days after removal from the CREACS unit, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than 2.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30'C and a relative humidity of 95%.
c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal from the CREACS unit, that a laboratory analysis of a representative carbon sample, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows a methyl iodide penetration less than 2.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30'C and a relative humidity of 95%.
d. At least once per 18 months by:
1. Verifying that the pressure drop across the combined HEPA filter and charcoal adsorber bank is *3.5 inches water gauge while operating the ventilation system at a flow rate of 8000 cfm +/- 10%.
2. Verifying that on a safety injection test signal or control room intake high radiation test signal, the system automatically actuates in the pressurization mode by opening the outside air supply and diverting air flow through the HEPA filter and charcoal adsorber bank.
3. Deleted.

SALEM - UNIT 2 3/4 7-17 Amendment No. xxx

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

4. Verifying that on a manual actuation signal, the system will actuate to the required pressurization or recirculation operating mode.
5. Verify each CREACS train has the capability to remove the assumed heat load.
e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove Ž 99% of the DOP when they are tested in-place while operating the filter system at a flow rate of 8000 cfm +/- 10%.
f. After each complete or partial replacement of a charcoal absorber bank by verifying that the charcoal absorbers remove Ž 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place while operating the filter system at a flow rate of 8000 cfm +/- 10%.

4.7.6.2 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program (Refer to T.S. 6.17).

SALEM - UNIT 2 3/4 7-17a Amendment No. xxx

ADMINISTRATIVE CONTROLS 6.17 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Air Conditioning System (CREACS), CRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge. The program shall ensure that adequate radiation protection is provided to permit access and occupancy of the CRE under design basis accident (DBA) conditions without personnel receiving radiation exposures in excess of 5 rem total effective dose equivalent (TEDE) for the duration of the accident.

The program shall include the following elements:

a. The definition of the CRE and the CRE boundary.
b. Requirements for maintaining the CRE boundary in its design condition including configuration control and preventive maintenance.
c. Requirements for (i) determining the unfiltered air inleakage past the CRE boundary into the CRE in accordance with the testing methods and at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear Power Reactors," Revision 0, May 2003, and (ii) assessing CRE habitability at the Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

The following are exceptions to Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0:

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one train of the CREACS, operating at the flow rate required by the Surveillance Requirements, at a frequency of 36 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 18 month assessment of the CRE boundary.
e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph
c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.
f. The provisions of Surveillance Requirement 4.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

SALEM - UNIT 2 6-31 Amendment No. xxx

PLANT SYSTEMS BASES 3/4.7.6 CONTROL ROOM EMERGENCY AIR CONDITIONING SYSTEM BACKGROUND:

The control room emergency air conditioning system (CREACS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The OPERABILITY of the CREACS ensures that 1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions.

The CREACS consists of two independent, redundant trains, one from each unit that re-circulate and filter the air in the Control Room Envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air. Each CREACS train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and fans. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system. The CREACS is a shared system between Unit 1 and 2 supplying a common CRE. During emergency operation following receipt of a Safety Injection or High Radiation actuation signal, for areas inside the CRE, one 100% capacity fan in each Unit's CREACS will operate in a pressurization mode with a constant amount of outside air supplied for continued CRE pressurization. One fan from each train will automatically start upon receipt of an initiation signal, with one fan in each train in standby. A failure of one fan will result in the standby fan automatically starting.

Each CREACS train has two 100% capacity fans, such that any one of the four fans is sized to provide the required flow for CRE within the common CRE during an emergency.

A failure of one CREACS filtration train requires manual actions to properly reposition dampers in support of single filtration train operation.

To minimize control room radiological doses, the CREACS outside air is supplied from the non-accident unit's emergency air intake through the cross-connected supply duct (as determined by which unit received an accident signal). Outside air is mixed with recirculated air, passed through each CREACS filter bank (pre-filter, HEPA filter, and charcoal adsorber) and cooling coil, and distributed to the common CRE. The CREACS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding 5 Rem total effective dose equivalent (TEDE).

SALEM - UNIT 2 B 3/4 7-5 Amendment No. XXX

PLANT SYSTEMS BASES The CREACS is an emergency system, parts of which may also operate during normal unit operations in the standby mode of operation. Upon receipt of the actuating signal(s), normal air supply to the CRE is isolated, and the stream of ventilation air is recirculated through the system filter trains.

The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Pressurization of the CRE minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas adjacent to the CRE boundary. CREACS will be manually initiated in the recirculation mode only in the event of a fire outside the CRE, a toxic chemical release, delivery of Ammonium Hydroxide or testing.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions. This area encompasses the control room and other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE. The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analysis of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

APPLICABLE SAFETY ANALYSES The CREACS components are arranged in redundant, safety related ventilation trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access. The CREACS provides airborne radiological protection for the CRE occupants, as demonstrated by the CRE occupant dose analyses for the most limiting design basis accident, fission product release presented in the UFSAR, Chapter 15.

The CREACS provides protection from smoke and hazardous chemicals to the CRE occupants. The analysis of hazardous chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release, as described in UFSAR, Section 6.4. The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels, as described in UFSAR, Section 9.5.

SALEM - UNIT 2 B 3/4 7-5a Amendment No. XXX

PLANT SYSTEMS BASES LCO Two independent and redundant CREACS trains are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other train. Total system failure, such as from a loss of all ventilation trains or from an inoperable CRE boundary could result in exceeding a dose of 5 rem TEDE to the CRE occupants in the event of a large radioactive release.

In order for the CREACS trains to be considered OPERABLE, the CRE boundary must be maintained such that the CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous.chemicals and smoke.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls. This Note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls are proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition, when a need for CRE isolation is indicated.

A significant contributor to this system's OPERABILITY are the dampers, which are required to actuate to their correct positions. The following dampers are associated with the respective LCO*:

a.l Fan outlet dampers: I(2)CAAI5 and l(2)CAAl6 These dampers ensure that the flow path for CREACS is operable and are required to open upon CREACS initiation. The associated fan outlet damper will open on fan operation.

a.4 Return air isolation damper: I(2)CAAl7 When aligned for single train operation, the associated air return isolation damper will be administratively controlled in the open position.

b. Other dampers required for automatic operation in the pressurization or recirculation modes:

Control Area Air Conditioning System (CAACS) outside air intake isolation dampers: I(2)CAA40, I(2)CAA41, I(2)CAA43 and I(2)CAA45 The normally open outside air intake dampers I(2)CAA40 and inlet plenum isolation dampers I(2)CAA43 will be closed under emergency conditions.

The normally closed outside air intake dampers I(2)CAA41 and inlet plenum isolation dampers I(2)CAA45 are normally closed and remain closed under emergency conditions.

  • Operability of the CREACS requires that each of the Unit 1 dampers are also operable SALEM - UNIT 2 B 3/4 7-5b Amendment No. XXX

PLANT SYSTEMS BASES Control Area Air Conditioning System (CAACS) exhaust isolation dampers:

I(2)CAAI8 and I(2)CAAl9.

These dampers are normally closed and are required to remain closed to prevent inleakage from the outside environment in the event of a toxic release.

Control Room Emergency Air Conditioning System (CREACS) air intake dampers: I(2)CAA48, I(2)CAA49, I(2)CAA50 and l(2)CAA51 CREACS outside air intake dampers are maintained closed during normal and recirculation operation and are opened automatically upon initiation of CREACS pressurization. The control logic will automatically open the CREACS air intake dampers farthest from the radiation source based upon which Unit's Solid State Protection System (SSPS) or Radiation Monitoring System (RMS) signal is received.

CAACS and CREACS interface isolation dampers: l(2)CAAI4 and I(2)CAA20 These two dampers are normally open and do not have associated redundant dampers. These dampers serve a boundary function by isolating the CREACS from the CAACS during emergency operation of the CREACS.

Note: Dampers I(2)CAA5, CAACS recirculation damper will receive an accident alignment signal to ensure proper accident configuration of CAACS. This damper, however, is not required for the OPERABILITY of CREACS as defined in the LCO.

APPLICABILITY In all MODES and during movement of irradiated fuel assemblies, the CREACS must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

During movement of irradiated fuel assemblies, the CREACS must be OPERABLE to cope with the release from a fuel handling accident, involving handling irradiated fuel.

SALEM - UNIT 2 B 3/4 7-5c Amendment No. XXX

PLANT SYSTEMS BASES ACTIONS When one CREACS train is inoperable, for reasons other than an inoperable CRE boundary, action must be taken to align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and restore the inoperable filtration train to OPERABLE status within 30 days. In this Condition, the remaining OPERABLE CREACS train is adequate to perform the CRE occupant protection function. With CREACS aligned for single filtration train operation and with one of the two remaining fans or associated outlet damper inoperable, restore the inoperable fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

However, the overall reliability is reduced because a failure in the OPERABLE CREACS train could result in loss of CREACS function. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is based on the low probability of a DBA occurring during this time period, and ability of the remaining train components to provide the required capability.

If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

During the period that the CRE boundary is considered inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e.,

actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional. The 24-hour completion time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day completion time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day completion time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

In MODE 1, 2, 3, or 4, if the inoperable CREACS train or the CRE boundary cannot be restored to OPERABLE status within the required completion time, the unit must be placed in a MODE that minimizes accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The allowed completion times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SALEM - UNIT 2 B 3/4 7-5d Amendment No. XXX

PLANT SYSTEMS BASES In MODE 5 or 6, or during movement of irradiated fuel assemblies, if the inoperable CREACS train cannot be restored to OPERABLE status, align CREACS for single filtration train operation within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or suspend movement of irradiated fuel assemblies. With CREACS aligned for single filtration train operation with one of the two remaining fans or associated outlet damper inoperable, restore the fan or damper to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time is based on the ability of the remaining train components to provide the required capability.

Immediate action(s), in accordance with the LCO Action Statements, means that the required action should be pursued without delay and in a controlled manner.

SURVEILLANCE REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not too severe, testing each train once every month provides an adequate check of this system. The 31-day Frequency is based on the reliability of the equipment and the two-train redundancy. TS Surveillance Requirement verifies that each fan is capable of operating for at least 15 minutes by initiating flow through the HEPA filter and charcoal adsorbers train(s) to ensure that the system is available in a standby mode.

Filter testing verifies that the required CREACS testing is performed in accordance with the surveillance requirements. The surveillance requirements include testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the surveillance requirements. Filter testing will be in accordance with the applicable sections of ANSI N510 (1975) with the exception that laboratory testing of activated carbon will be in accordance with ASTM D3803 (1989). The acceptance criteria for the laboratory testing of the carbon adsorber is determined by applying a minimum safety factor of 2 to the charcoal adsorber removal efficiency credited in the design basis dose analysis as specified in Generic Letter 99-02.

Actuation testing verifies that each CREACS train starts and operates on an actual or simulated actuation signal. The Frequency of 18-months is based on industry operating experience and is consistent with the typical refueling cycle.

SALEM - UNIT 2 B 3/4 7-5e Amendment No. XXX

PLANT SYSTEMS BASES The control room envelope is considered intact and able to support operation of the CREACS when the emergency air conditioning system is capable of maintaining positive pressure with the control room boundary door(s) closed.

Unfiltered air inleakage testing verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

Each CAACS normal air intake ductwork has two radiation detector channels.

The two detector channels from Unit 1 and Unit 2 CAACS air intake provide input to common radiation monitor processors. Each radiation monitor processor (one for lRlB-l/lRlB-2 and one for 2RlB-l/2RIB-2) provides a signal to initiate CREACS in the pressurization mode should high radiation be detected. A minimum of one out of two detectors in either intake will initiate the pressurization mode. With two detector channels inoperable on a Unit, operation may continue as long as CREACS is placed in-service in the pressurization or recirculation mode. Pressurization mode will be initiated after 7 days with one inoperable detector. Radiological releases during a fuel handling accident while operating in the recirculation mode could result in unacceptable radiation levels in the CRE since the automatic initiation capability has been defeated for high radiation due to isolation of the detectors. Therefore, movement of irradiated fuel assemblies or Core Alterations at either Unit will not be permitted when in the recirculation mode.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. The testing verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, CRE boundary is inoperable. Required action allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F. These compensatory measures may also be used as required mitigating actions.

Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

SALEM - UNIT 2 B 3/4 7-5f Amendment No. XXX