ML18102A181

Application for Amends to Licenses DPR-70 & DPR-75,aligning TS to Reflect CR Design in Which Common Plant CR Envelope Supplied by Two 100% Capable CR Emergency Air Conditioning Sys Trains

ML18102A181
Person / Time
Site:	Salem
Issue date:	06/10/1996
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102A182	List: ML18102A181 ML18102A183
References
LCR-S95-21, LR-N96154, NUDOCS 9606180681
Download: ML18102A181 (33)

Text

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Public Service Electric and Gas Company Louis F. Storz Public SeNice Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations JUN 1 0 1996 LR-N96154 LCR S95-21 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 CHANGE TO TECHNICAL SPECIFICATIONS REVISION OF CONTROL ROOM VENTILATION SPECIFICATION.

SALEM GENERATING STATION NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 Gentlemen:

In accordance with 10CFR50.90, Public Service Electric & Gas (PSE&G) Company hereby requests a change to the Technical Specifications (TS) for the Salem Generating Station Unit Nos. 1 and 2.

In accordance with 10CFR50.91 (b) (1), a copy of this submittal has been sent to the State of New Jersey.

The proposed changes contained herein represent changes to TS 3/4.7.6 "Control Room Emergency Air Conditioning System."

These changes align the TS to reflect a control room design in which the common Salem Unit 1 and 2 Control Room Envelope (CRE) is supplied by two (2) one hundred percent capable Control Room Emergency Air Conditioning System (CREACS) trains.

The control room modifications addressed by this submittal are part of the corrective actions of Licensee Event Reports (LER) 95-006-00 and 95-017-00 aimed at restoring compliance with General Design Criterion 19 and providing an extended Allowed Outage Time (AOT) to support necessary maintenance of the system.

The proposed changes incorporate site specific information as guided by the Standard Technical Specifications (NUREG-1431, Revision 1, April 1995).

The proposed changes have been evaluated in accordance with 10CFR50.91(a) (1), using the criteria in 10CFR50.92(c), and it has been determined that this request involves no significant hazards considerations.

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Document Control Desk LR-N96154 JUN 101996 A description of the proposed changes and the basis for these changes are provided in Attachment 1.

A 10CFR50.92 evaluation with a determination of no significant hazards consideration is provided in Attachment 2.

The Technical Specification pages affected by the proposed changes are provided in Attachment 3 with pen and ink changes.

PSE&G has undertaken a substantial upgrade of the CREACS.

While the modifications are ongoing, PSE&G has requested a one-time change to permit Core Alterations of Salem Unit 2 with the CREACS inoperable in Modes 5 and 6 (Ref. Letter LR-N96091).

The one-time change requested by letter LR-N96091 provides additional time to complete the CREACS upgrade and allow for approval of this permanent TS change to reflect the upgrade of CREACS.

To allow sufficient time to complete associated administrative activities for implementation prior to Mode 4 operation, (which is scheduled to begin August 1, 1996), PSE&G requests.amendment approval by the NRC no later than July 22, 1996.

As a result of the system configuration changes, PSE&G proposes to revise the flow rates specified in the Surveillance Requirements from 7410 cfm +/- 10% to 8000 cfm +/- 10%.

Assessment of the proposed flow rate has indicated that CREACS operation

.within the flow rate range using two trains, normal accident alignment, or a single train, TS action statement alignment, will result in doses to control room personnel that are within GDC 19 limits.

However, the impact on the chilled water system's ability to support cooling coil operation in maintaining ambient temperature ~ 85°F in these configurations remains to be confirmed.

Similarly, the sensitivity value used to develop the proposed radiation detector setpoint of 1060 counts per minute remains to be confirmed.

In each instance, the additional work is planned to be completed by June 28, 1996, in support of NRC review and approval by July 22, 1996.

PSE&G will submit a letter to the NRC by June 28, 1996, confirming the proposed flow rate and radiation detector setpoint, or provide revised values for incorporation into the TS.

Should it be necessary to revise these values, the conclusion that -this-proposed license amendment involves no significant hazards consideration will be reassessed.

In addition, Control Room dose analyses have been updated for all postulated Design Basis Accidents (DBA) using updated X/Q values based on the ARCON 95 calculational methodology and the dose conversion factors published in ICRP-30.

PSE&G will submit for NRC review and approval under separate correspondence, a letter detailing the calculational methodology used to develop this amendment.

I

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,I Document Control Desk LR-N96154 JUN 1 0 1996 Should you have any questions regarding this request, we will be pleased to discuss them with you.

Affidavit Attachments (4)

Sincerely, C

Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. Olshan, Licensing Project Manager -

Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall (X24)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625

I

• r STATE OF NEW JERSEY COUNTY OF SALEM SS.

REF: LR-N96154 LCR S95-21 L. F. Storz, being duly sworn according to law deposes and says:

I am Senior Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Salem Generating Station, Units 1 and 2, are true to the best of my knowledge, information and belief.

Notary Public of New Jersey 1

DELORIS O. HADDEN Notary Public of New Jerur My Commission 000~

03-29-2 My Commission expires on

~~~~~~~~~~~~~~~~

" Document Control Desk SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 LR-N96154 LCR S95-21 CHANGE TO TECHNICAL SPECIFICATIONS REVISION OF CONTROL ROOM VENTILATION SPECIFICATION REQUESTED CHANGES AND PURPOSE The proposed changes to Technical Specifications (TS) 3/4.7.6, "Control Room Emergency Air Conditioning System" and 3/4.3.3.1, "Radiation Monitoring Instrumentation," reflect modifications to the systems being performed during the current plant outages.

These changes reflect the incorporation of site specific information as guided by the Westinghouse Standard Technical Specifications (STS}

(NUREG-1431, Revision 1, April 1995).

The system modifications addressed by these proposed TS changes are as follows: 1) conversion of the Salem Unit 1 and Unit 2 Control Room envelopes (CRE) into a single common CRE serviced by two 100% capable Control Room Emergency Air Conditioning System (CREACS) trains; 2) revision of the emergency operating mode of the CREACS during a radiological event to the pressurization mode instead of recirculation; 3) improved instrumentation and controls for CREACS initiation; 4) revision of the Surveillance Requirements to reflect the new air flow rate during operation of the upgraded CREACS trains; and 5) 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 establishment of a common CRE with two upgraded CREACS trains allows for extended Allowed Outage Times (AOT) providing for additional flexibility to allow necessary maintenance activities.

The change in operating mode during radiological events continues to provide operator protection and supports compliance to General Design Criterion (GDC) 19.

An ancillary result of incorporating these modifications into the TS is that it provides consistency between the Unit 1 and Unit 2 Limiting Conditions for Operation (LCO) and the associated Applicability and Action requirements.

BACKGROUND As described in Section 9.4.1 of the Salem Updated Final Safety

• Analysis Report (UFSAR), the Control Area Air Conditioning System (CAACS) is designed to maintain room temperatures within limits required for operation, maintenance and testing of plant controls and uninterrupted safe occupancy during post-accident conditions.

The system operates during normal or emergency conditions as required.

1 of 18

Document Control Desk Attachment l LR-N96154 LCR S95-21 Specifically, a portion of the CAACS, designated the CREACS, functions during emergency conditions.

It was originally designed to supply cooled high-efficiency particulate and charcoal filtered air to the Control Rooms.

Prior to the recent modifications, the CREACS (Ref. Figure 1) consisted of two separate trains, one associated with each Salem Unit, for cooling and treating the air supplied to their respective control room.

The Unit 1 CREACS supplied the Unit 1 control room, the shift supervisors' office, and the adjoining corridor between the Unit 1 and Unit 2 control rooms.

The Unit 2 CREACS supplied the Unit 2 control room and also the adjoining corridor.

Based upon a July 1991 interpretation regarding the leak tight integrity of the Unit 1 and Unit 2 Control Rooms, it was decided that the control rooms should be considered a single combined control room area with a common envelope.

To ensure that this revised volume continued to meet GDC 19 limits (i.e.,

5 rems whole body or its equivalent to any part of the body) administrative procedures were implemented to require concurrent operation of both Unit 1 and Unit 2 CREACS when required by either unit.

As reported in Licensee Event Report (LER) 95-006-00, dated July 14, 1995, a high radiation signal from one of the radiation monitors located in one Salem Unit may not have fully actuated CREACS into the emergency recirculation mode on the other Salem Unit.

As part of the corrective actions for this LER, design changes to the radiation monitoring instrumentation were to be evaluated.

Based on the result of analyses performed as part of the corrective actions for LER 95-006-00, it was determined that in the event of a Loss of Coolant Accident (LOCA) at Salem, the 30 rem thyroid dose limit established in GDC 19 for control room dose would have been exceeded.

The Nuclear Regulatory Commission (NRC) was notified of this assessment in LER 95-017-00, dated August 11, 1995.

Modifications to the CREACS have been initiated to address the deficiencies identified in the previously referenced LERs and to restore compliance with GDC 19.

Upon completion of the modifications to the control rooms of both Unit 1 and Unit 2, the revised CRE will encompass both control rooms, the adjoining computer rooms, a new field operators' ready room, the Senior Nuclear Shift Supervisors' office, and the emergency operations center/conference room (See Figure 2).

The CAACS, which supplies normal cooling to the CRE, will continue as presently designed to provide cooled air to the equipment rooms and relay rooms located outside the CRE during normal operation and in the event of an emergency.

2 of 18

Docliment Control Desk LR-N96154 LCR S95-21 The composite area supported by Unit specific equipment or trains necessitated that each Unit's TS reflect the overall system; thereby, creating a cross-linked CREACS Limiting Condition for Operation (LCO) for Salem Unit 1 and Salem Unit 2.

JUSTIFICATION OF REQUESTED CHANGES CREACS Modifications As designed, Salem Units 1 and 2 had separate Control Areas.

Each Unit's Control Area was served by its own safety related, Seismic Category I, Class lE CAACS and CREACS.

Modifications have redesigned the Unit 1 and 2 Control Rooms into a common CRE and reconfigured the separate Unit's CAACS and CREACS to share the duties of providing air conditioning service to this common CRE.

The modifications also upgraded the design of the Unit 1 and 2 CAACS/CREACS to meet current Salem licensing commitments and design basis requirements for serving a common CRE.

To establish the new CRE, there are additional CREACS isolation dampers which are to be installed with a failure position consistent with isolation of the CRE.

The modifications to the Unit 1 and 2 CREACS enhance safety function independence, redundancy and ability to cope with certain single failures in accordance with current Salem licensing commitments for the common CRE concept as follows (Ref. Figure 3) :

1.

2.

3.

4 0

5.

The common Unit 1 and 2 CRE is supplied by two 100% capacity CREACS filtration trains, one from each Salem Unit.

CREACS air intakes include redundant parallel supply ducts, each with redundant series air operated supply dampers and maintenance dampers.

CREACS makeup air supply ducts are cross connected, such that either Unit's CREACS can take its makeup air supply from either Unit's intake.

CREACS air distribution plenums are cross connected within the common CRE such that either Unit's CREACS can supply the required air to the entire common CRE during an emergency.

Each Unit's CREACS fans are replaced with two redundant 100%

capacity fans, such that any one of the four fans is capable of providing 100% of the required CRE pressurization air to 1/8" water gauge positive pressure within the common CRE.

The CREACS filter trains (2) consist of a pre-filter, a 95%

efficient HEPA filter and a 95% efficient charcoal filter.

3 of 18

Document Control Desk LR-N96154 LCR S95-21

6.

Radiation detectors located in each CAACS supply ductwork will automatically initiate the pressurization mode in the event of a radiological emergency (High Radiation actuation signal).

Upon initiation of a Safety Injection signal from the Solid State Protection System (SSPS), CREACS will also be automatically initiated.

The control logic will automatically open the CREACS air intake dampers farthest from the radiation source or in the Unit that did not have the accident (i.e., based upon which unit's SSPS or Radiation Monitoring System (RMS) signal is received).

7.

The CREACS can be manually initiated in the pressurization mode in the event of a radiological emergency, or in the recirculation mode in the event of a fire outside the CRE or toxic chemical release.

Analysis of radiological emergencies has determined that placing the CREACS in the pressurization mode of operation will ensure that doses to control room personnel will be within GDC 19 limits.

Should a LOCA occur while operating in the recirculation mode, the system will automatically switch on a Safety Injection actuation signal to supply air from the non-accident Unit's emergency intake.

Operation in the recirculation mode will also be required for short durations during delivery of Ammonium Hydroxide in accordance with current commitments relative to Regulatory Guide 1.78.

The control area for each Salem Unit consists of the common CRE, the electrical equipment room, relay room, and work control center.

The CAACS services the control area including the CRE during normal operation in a recirculation mode with a constant amount of outside air supplied for ventilation.

CREACS is isolated.

During emergency operation, the CAACS is isolated from outside air and the CREACS supply ducts.

CAACS continues to operate in a recirculation (un-pressurized) mode for areas outside the CRE (i.e., electrical equipment room, relay room, work control center).

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 train will operate to pressurize the CRE.

In this pressurization mode, outside air is mixed with recirculated air from within the CRE, passed through each CREACS filter bank (pre-filter, HEPA filter, and charcoal filter) and cooling coil, and distributed to the 4 of 18

• Document Control Desk LR-N96154 LCR S95-21 common CRE for continued positive pressurization to 1/8" water gauge.

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.

A failure of one CREACS train requires manual actions to properly reposition damper(s) in support of single filtration train operation.

To minimize control room radiological doses and support compliance with GDC 19, the CREACS outside air is supplied from the non-accident unit's emergency air intake through the cross-connected supply duct (determined by which unit received an actuation signal).

In the event of a fire outside the CRE, a toxic chemical release or delivery of Ammonium Hydroxide, CREACS will be manually initiated in the recirculation mode whereby all outside air is isolated and the air within the CRE is recirculated through the CREACS filter bank.

In summary, operation of the CREACS in a radiological emergency is based on:

1.

CRE pressurization,

2.

Integrated control logic to automatically open the CREACS air intake dampers farthest from the radiation source.

Operation of the CREACS in a fire outside the CRE or chemical emergency is based on:

1.

CRE recirculation and isolation from the external contaminants.

Technical Specification 3/4.3.3.1, Radiation Monitoring Instrumentation The proposed Action Statement and completion times were developed utilizing the guidance of NUREG-1431 for Control Room Emergency Filtration System Actuation Instrumentation.

Each CAACS normal air intake ductwork will have an additional radiation detector channel installed for a total of two detectors per intake.

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-1/lRlB-2 and one for 2RlB-l/2RlB-2) provides a signal to 5 of 18

' Document Control Desk LR-N96154 LCR S95-21 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.

The emergency initiation function from the Control Room area radiation monitors has been removed as part of the modifications.

Therefore, in order to withstand a single failure (i.e., loss of one channel in either intake), TS Table 3.3-6, Radiation Monitoring Instrumentation, has been revised to include the requirement to have two detector channels per intake operable during All Modes, during movement of irradiated fuel and during Core Alterations.

The proposed Action Statement for Table 3.3-6 requires that with one channel in either or both intake(s) inoperable, restore the inoperable channel(s) to operable status within 7 days or initiate and maintain operation of the CREACS in the pressurization mode (or recirculation mode for periods when receiving ammonium hydroxide, fire outside the Control Room or toxic release).

With no channels operable in an intake, the Action Statement requires that the CREACS immediately, (i.e.,

without delay and in a controlled manner), be placed and maintained in the pressurization mode of operation (or recirculation mode for periods when receiving ammonium hydroxide, fire outside the Control Room or toxic release).

The CREACS outside air supply source for the pressurization mode will be selected by operators under this condition.

In the CREACS pressurization or recirculation mode, CAACS normal air intakes are isolated rendering the detectors inoperable.

However, should a Safety Injection actuation signal occur while operating in the recirculation mode, the system would automatically switch to the pressurization mode and realign the CREACS outside air dampers, as necessary, to supply air from the intake duct farthest from the accident.

If in the pressurization mode due to an inoperable RMS detector(s), one fan from each filtration train will normally be placed in operation (to accommodate single failure considerations).

Postulated LOCA and non-LOCA type accidents that result in radiological releases (i.e., Fuel Handling Accident, Waste Gas Decay Tank or Volume Control Tank rupture, and all Chapter 15 accident not related to a loss of Reactor Coolant) when in this configuration will result in doses to control room personnel that are within GDC 19 limits regardless of which outside intake is selected.

However, if a single train alignment is needed in accordance with TS 3.7.6 and the operator takes manual actions to place CREACS in the pressurization mode, due to an inoperable RMS channel(s) for instance, operator actions (e.g., resetting the manual initiation signal) may be necessary to align the air intake to the opposite 6 of 18

D'ocument Control Desk LR-N96154 LCR S95-21 Unit's intake in the event of a postulated LOCA.

In light of current analyses, one filtration train cannot ensure the limits of GDC 19 would be maintained when taking intake air from the accident Unit in a single train configuration.

Therefore, should both Units be in Modes 1-4 with a single CREACS train manually selected to operate in the pressurization mode, a plant shutdown would be required.

However, it is not considered prudent for a plant shutdown due to testing based on the short testing durations and the associated increase in core damage frequency with a plant shutdown.

It should be noted that a plant shutdown would not be required if the pre-accident intake alignment is from a Unit that is in Modes 5 or 6 since CREACS would be adequately aligned in the accident configuration and capable of performing its intended safety function.

Since these conditional limitations can be intricate, plant procedures will provide sufficient details to the operators on the appropriate actions.

During operation in the recirculation mode with the RMS detector(s) inoperable, movement of irradiated fuel assemblies or Core Alterations at either Unit will not be permitted since the automatic initiation capability has been defeated for high radiation due to isolation of the detectors.

A radiological release from a non-LOCA type accident is not postulated to occur concurrent with a fire outside the CRE or toxic release that would require entering the recirculation mode.

Tanker deliveries of Ammonium Hydroxide are received infrequently throughout the year and the tankers are on-site only for short durations; approximately four hours per month.

Should a fire outside the CRE, toxic release, or delivery of Ammonium Hydroxide the operators need to manually initiate CREACS in the recirculation mode, even if operating in the pressurization mode.

The radiation detector channels are not required in response to these events.

Also, testing of the system is on an infrequent basis and may necessitate operation in the recirculation mode periodically.

Recirculation at other times is not permitted.

Therefore, operation in the recirculation mode under the above conditions for short periods of time is considered acceptable.

The Bases for TS 3/4.7.6 have been revised to include discussion of operation in the pressurization and recirculation modes.

TS Table 4.3-3, Radiation Monitoring Instrumentation Surveillance Requirements, is proposed to be revised to include the air intake radiation monitoring instrumentation.

The surveillance intervals proposed for performing Channel Checks, Source Checks, Channel Calibration and Channel Functional Testing were also developed based on the guidance of NUREG-1431 for Control Room Actuation Instrumentation since the RMS configuration and function is consistent with that presented in the NUREG.

These Surveillance 7 of 18

f Document Control Desk LR-N96154 LCR S95-21 Requirements are in addition to the 18 month actuation surveillance tests for a Safety Injection signal, High Radiation signal and manual actuation included in TS 4.7.6.1.d.

The Bases for TS 3/4.3.3.1 are also being revised to include the radiation detectors for both Unit 1 and 2.

Restricted operation in the recirculation mode is contained in TS Bases 3/4.7.6.

Technical Specification 3/4.7.6, Control Room Emergency Air Conditioning System CREACS Limiting Condition For Operation for Modes 1 -

6 The proposed Limiting Condition for Operation (LCO) states that each independent CREACS train is considered operable with the following components available:

1.

Two fans and associated outlet damper(s),

2.

One cooling coil,

3.

One charcoal adsorber and HEPA filter array,

4.

Return air isolation damper In addition, the proposed LCO specifies that the dampers required for automatic operation in the pressurization or recirculation modes and the CRE be intact to support operation of the CREACS.

Action statements related to operability of the CREACS trains, dampers and CRE integrity are proposed consistent with their safety significance and as guided by NUREG-1431, as appropriate.

The TS Bases is proposed to be revised to define the operating requirements for the system.

CREACS Action Statements for Modes 1 -

4 Each CREACS train consists of two fans that are each 100%

capacity and their associated outlet dampers, one cooling coil, one charcoal adsorber and HEPA filter array, and the return air isolation damper.

Separate Action Statements are proposed should one filtration train be inoperable, or should one fan in the remaining operable filtration train be inoperable.

The Action Statement completion times proposed are 30 days and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, respectively.

With one filtration train inoperable due to a failure of any of the required components, the Action Statement requires that the operable filtration train be aligned 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 st~tus within 30 days.

Thirty days is considered an acceptable duration to allow for continued 8 of 18

Doc~ment Control Desk LR-N96154 LCR S95-21 operation based on the following justificati,on.

Although a single failure is not required to be assumed while in the Action Statement, with the system aligned to operate with a single filtration train, two fans will be available to start in the pressurization mode (radiological emergency) or recirculation mode (toxic chemical release, fire outside the CRE, or anunonium hydroxide delivery).

Should a fan fail to start on an initiation signal in the train with two fans operable, the second fan in a standby mode will automatically start.

The possibility that both fans would fail to start is considered extremely unlikely.

Though there is a single return air isolation damper in each Unit 1 and 2 CREACS train that must open to provide return flow through the emergency filters, its failure in the closed position is unlikely, as the damper receives redundant actuation signals and fails in the open position upon loss of control air or power.

Damper operability is verified every 31 days in accordance with the Surveillance Requirements.

For additional assurance of flow while in single train alignment, the return air isolation damper will be administratively controlled in the open position when operating in this configuration.

Failure of the charcoal adsorber/HEPA filter array is extremely unlikely since these components do not perform an active function.

Support systems to the cooling coil (i.e., chilled water) will be administratively controlled to ensure operability is maintained.

CREACS air intakes include redundant parallel supply ducts to ensure an air flow path is available and each with redundant series air operated supply dampers to ensure isolation during a chemical release.

A separate Action Statement time of 7 days is proposed for inoperable emergency air intake dampers.

Based on the above discussion, 30 days is considered an acceptable duration to allow for continued operation when operating in a single train configuration.

The proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Action Statement completion time for one fan inoperable while aligned for single filtration train operation is also considered an acceptable duration based on safety significance.

While aligned for single filtration train operation with only one operable 100% capacity fan available, the available equipment has the capability to pressurize the control room to 1/8" water gauge in the event of a radiological emergency or initiate recirculation in the event of a fire outside the CRE, toxic chemical release or anunonium hydroxide delivery.

New dampers resulting from the cross-ties and split intake ducts increased the number of dampers required to function properly for CREACS, to be considered operable.

In addition to providing the 9 of 18

Document Control Desk LR-N96154 LCR S95-21 proper flowpaths, some of these dampers now perform a CRE boundary function.

To apply the correct Action Statement allowed outage time to an inoperable damper, t~e LCOs have been revised to address specific damper safety functions and redundancy.

The dampers now required for CREACS operability (see Table 1 and Figure 3) are added to the BASES by this submittal.

The proposed Action Statement for one or both isolation damper(s) on an outside emergency air conditioning air intake duct inoperable requires that the affected duct be closed 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 requires the damper(s) to be restored to operable status within 7 days.

An alternate intake path remains available.

The associated CAACS of each CREACS train isolates their respective outside air intakes during a radiological emergency and isolates the dampers between CAACS and CREACS ductwork.

Proposed Action Statements require that if these dampers are inoperable, then they are to be placed 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 />.

The Action Statement completion time is considered reasonable in light of field actions necessary to place the inoperable dampers in the closed position in support of CREACS operation.

CREACS Action Statements for Modes 5, 6 and During Movement of Irradiated Fuel Assemblies and During Core Alterations During Modes 5 and 6 or during movement of irradiated fuel assemblies and during Core Alterations, Action Statement allowed outage times have been specified for inoperable filtration trains and dampers based on safety significance and as guided by NUREG-1431.

The Action Statements require, under certain operating conditions, that the system be aligned for single filtration train operation, or requires that movement of irradiated fuel assemblies or Core Alterations changes be suspended if the Action Statements are not satisfied within the required time frame.

For operation of either Unit or both Units in Modes 5 and 6 or during movement of irradiated fuel assemblies and during Core Alterations, operation of a single CREACS train or both CREACS trains in the pressurization mode is acceptable as discussed above.

If pressurization cannot be maintained (e.g., loss of CRE integrity or failure of both CREACS trains) or the system is placed in recirculation (for periods when receiving ammonium hydroxide, fire outside the Control Room or toxic release),

movement of irradiated fuel assemblies and Core Alterations will be suspended.

Movement of irradiated fuel assemblies and Core 10 of 18

• Docliment Control Desk LR-N96154 LCR S95-21 Alterations will also be suspended due to inoperable damper(s) until the damper(s) can be placed in its safe operating configuration.

Should a fire outside the CRE or toxic release occur, the operators will need to isolate the CRE from outside air by manually initiating CREACS in the recirculation mode.

Operation in the recirculation mode is also necessary during each tanker delivery of Ammonium Hydroxide.

During operation in the recirculation mode, movement of irradiated fuel assemblies and Core Alterations at either Unit will not be permitted.

The Bases for TS 3/4.7.6 has been revised to include discussion of operation in the pressurization and recirculation modes.

CREACS Surveillance Requirements The changes to the filter testing Surveillance Requirements reflect the new operating configuration and flowrates, with the following exceptions.

All 18 month surveillance tests, with the exception of those related to filter testing, will be performed to demonstrate the acceptance of both Unit 1 CREACS train and Unit 2 CREACS train concurrently.

PSE&G proposes to add a new 18 month Surveillance Requirement for verifying that on a manual actuation signal, CREACS will actuate to the required operating mode including proper damper alignment.

Control Room personnel are required to manually initiate CREACS in the recirculation mode in the event of a fire outside the control area or toxic chemical release, and may manually initiate CREACS in the pressurization mode in the event of a radiological emergency.

This Surveillance Requirement is consistent with NUREG-1431 for actuation instrumentation.

TS Surveillance Requirement 4.7.6.1.a is revised to eliminate verification that the CRE air temperature will be maintained

~120°F and to eliminate the minimum one hour train operation time.

The current temperature requirement does not provide adequate verification that the system is capable of performing its intended heat removal function and is, therefore, being replaced with an 18 month surveillance that will identify unacceptable degradation of the system's cooling capability.

The requirement to operate each fan for at least 15 minutes is being retained since it is felt that system operational deficiencies can be identified during that time and that prolonged system operation in the emergency configuration is not warranted.

These changes are consistent with the recommendations of NUREG-1431.

The pressure drop across the combined HEPA filter and charcoal adsorber bank is revised to ~ 3.5" water gauge at a flow rate of 8000 cfm +/- 10% before replacement is required.

11 of 18

• Docllinent Control Desk LR-N96154 LCR S95-21 PSE&G also proposes to ~elete the repetitive references to system flows, and revise the charcoal lab testing temperature to 30°C based on the ASTM Standard D 3803 (1989).

DESIGN/LICENSING BASIS In support of the CREACS modifications, the change in CREACS operation, and the changes to supporting surveillances, the following information delineates Salem Units 1 and 2 CAACS/CREACS compliance with current Salem licensing commitments:

Single Failure Criterion The modifications made to the Control Room enhance the ability for the Salem Units to cope with the affects of a single active component failure through the addition of dampers, redundant controls, and circuitry modifications.

However, some dampers that are required to change position such as CAA14, (normal supply air isolation), CAA17, (CREACS return air isolation) and

CAA20, (normal return air isolation) maintain the original design and do not have redundancy within each train.

PSE&G took the position that the damper motors were spring loaded to their fail-safe positions in addition to the manual operators provided for backup and considered this acceptable in light of the design criteria established at the time Salem was constructed and licensed.

This position was recognized in the Safety Evaluation Report for Salem.

For these dampers, Salem continues to rely on the ability to take manual short-term actions to ensure operability of the system.

General Design Criterion 2, Design Bases for Protection Against Natural Phenomena The proposed modification is designed in accordance with the Salem CAACS/CREACS design bases to withstand the effects of or to be protected against the effects of natural phenomena.

General Design Criterion 4, Environmental and Missile Design Bases The proposed modification is designed in accordance with the Salem CAACS/CREACS design bases to be protected against the dynamic effects of internally and externally generated missiles and the effects of pipe whip and jet impingement.

The CAACS/CREACS is designed for mild environment conditions which is consistent with those found at the 120' elevation of the Auxiliary Building.

12 of 18

Document Control Desk LR-N96154 LCR S95-21 General Design Criterion 5, Sharing of Structures, Systems and Components The Control Rooms for Salem Unit 1 and 2 are within a common envelope.

The ability of CREACS to perform its safety functions in support of maintaining post accident habitability and ambient air temperatures is accounted for in the proposed LCO, including the ability to shutdown and cooldown a unit in the event of an accident on the other unit.

The Unit 1 and 2 CAACS are separate systems except that each CAACS utilizes a common air distribution plenum for normal air supply to the CRE.

The Unit 1 and 2 CREACS are completely separate systems, except that each CREACS air intake plenum and each CREACS air distribution plenum is cross-connected so that either CREACS, operating alone, can receive its outside air supply from either Unit's CREACS air intake plenum and can distribute filtered air to the entire control room envelope during a radiological emergency.

The actuation circuitry is also considered shared components within the system.

The shared air supply and distribution cross-connect duct work or circuitry do not impair the ability of either CREACS to perform its safety function, nor do they impair either unit from performing an orderly shutdown and cooldown, in the event of an accident in the other Salem Unit.

General Design Criterion 19, Control Room The proposed modification enhances the Salem CREACS independence, redundancy and single failure design features in order to meet control room habitability requirements for compliance with GDC 19.

Control room dose analyses have been updated for all postulated Design Basis Accidents (DBA), using updated input parameters (X/Q values based on the ARCON 95 calculational methodology, ESF leakages, containment spray coverage).

The updated control room dose analyses were based on the modified control room envelope arrangement, the upgraded CREACS design and performance parameters, selective air intake logic, and HEPA removal efficiency of 95% and charcoal efficiency for radioiodine of 95% and the ability of the Fuel Handling 13 of 18

Document Control Desk LR-N96154 LCR 895-21 Building filtration system to mitigate fuel handling accidents.

The control room dose analyses demonstrate that, for the worst case accident for control room habitability, a single CREACS unit is capable of maintaining control room doses below GDC 19 limits; provided air intake from the non-accident Unit, which the system has adequate redundancy to ensure.

As stated previously in this request, certain limited operating and testing configurations and certain single failures combined with specific accident scenarios may result in the control room doses exceeding GDC 19 limits.

These include:

CREACS operating in the recirculation mode for a fire outside the CRE, toxic release, or ammonium hydroxide tanker delivery; CREACS manually selected to operate in the pressurization mode with a single filtration train alignment; during CREACS system re-alignment, (i.e., four hours), due to an inoperable train; and single failure of non-redundant dampers without manual repositioning.

Though administrative controls will ensure limited operation in these configurations and will provide.guidance on compensatory actions, these stated scenarios are considered unlikely to occur.

Regulatory Guide 1.29, Seismic Design Classification The CREACS modification was designed in accordance with Salem Seismic Category I requirements and is located within a Seismic Category I structure.

Regulatory Guide 1.52, Design, Testing, and Maintenance Criteria for Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants The original design of the system met the intent of RG 1.52 Revision 1 as noted in Appendix 3A to the UFSAR.

This section of the UFSAR will be revised to reflect the design modification and previous exceptions will be updated as applicable.

System testing is to Revision 2 as clarified in Generic Letter 83-13.

The CREACS filters will continue to be tested for the post-modification airflow using a higher acceptance criteria in order to confirm charcoal filter efficiency at 95%.

Regulatory Guide 1.78, Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room 14 of 18

• Document Control Desk LR-N96154 LCR S95-21 During a Postulated Hazardous Chemical Release The modified CREACS does not change the Salem licensing commitment to Regulatory Guide 1.78.

The CREACS response to postulated hazardous chemical releases is the same as the current system design basis.

Regulatory Guide 1.95, Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chlorine Release The modified CREACS does not change the Salem licensing commitment to Regulatory Guide 1.95.

The CREACS response to postulated accidental chlorine releases is the same as the original system design basis.

Per UFSAR Section 6.4, there is no on-site chlorine hazard.

CONCLUSIONS Based on the modifications to the Salem Control Room HVAC boundary establishing a single CRE, the new radiological assessments for control room doses indicating a reduced dose by operating the CREACS in the pressurization mode, the upgrading of the Salem CREACS to two 100% capable supply/filtration trains, and the guidance provided by the STS (NUREG-1431), PSE&G has determined that the changes to the TS outlined here meet the current licensing basis and provide the necessary protection to the operators to support operation of Salem Units 1 and 2 in accordance with GDC 19.

15 of 18

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Document Control Desk Attachment l LR-N96154 LCR 895-21 Table 1 Salem Unit 1 & 2 CREACS Required Damper Positions During Accident Condition Description Unit 1 Unit 2 Dampers Required to Stay in Closed Position Outside Air Intake Dampers 1CAA41

• 2CAA41

• CAACS Filter Inlet Plenum Isolation 1CAA45*

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Dampers Exhaust Dampers lCAAlB,19 2CAA18,19 Dampers Required to Open CREACS Outside Air Intake Dampers (ll 1CAA4 8*, 4 9*

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and/or and/or 1CAA50*, 51

• 2CAA50*, 51*

CREACS Fan Outlet Dampers 1CAA15 or 2CAA15 or (Depending on Fan Operation) 1CAA16 2CAA16 CREACS Return Air Isolation Dampers 1CAA17 2CAA17 Dampers Required to Close Control Room Normal Supply Air 1CAA14 2CAA14 Isolation Dampers Control Room Normal Return Air 1CAA20 2CAA20 Isolation Dampers CAACS Filter Inlet Plenum Isolation 1CAA43*

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Dampers and Outside Air Intake Dampers and and 1CAA40*

2CAA40 New Dampers Note 1: Dampers at Unit which had accident will remain closed.

Dampers at Unit which did not have accident will open.

18 of 18

Document Control Desk LR-N96154 LCR S95-21 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS REVISION OF CONTROL ROOM VENTILATION SPECIFICATION 10CFR50.92 EVALUATION Public Service Electric & Gas has concluded that the proposed changes to the Salem Generating Station Unit Nos. 1 and 2 Technical Specifications (TS) do not involve a significant hazards consideration.

In support of this determination, an evaluation of each of the three standards set forth in 10CFR50.92 is provided below.

Proposed Changes The proposed TS changes align the TS to reflect the control room design in which the common Salem Unit 1 and 2 control ~oom envelope (CRE) is supplied by two one hundred percent capable trains and revises the emergency operating mode of the Control Room Emergency Air Conditioning Systems (CREACS) during a radiological event including instrumentation and controls for CREACS initiation.

This license amendment application will also correct Unit 1 and Unit 2 TS differences by incorporating the guidance provided by the Westinghouse Standard Technical Specifications (STS)

(NUREG-1431) while satisfying a corrective action for Licensee Event Report (LER) 95-006-00.

Basis

1.

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

CREACS ensures adequate protection after an accident and is not an accident initiator.

The changes to the emergency operating mode and configuration of the CREACS, while modifying the control room dose assessment, do not affect the probability of an accident.

The proposed operation of the CREACS in the pressurization mode at the initiation of an accident will reduce overall operator doses from such an event and will ensure that the requirements of General Design Criterion (GDC) 19 will be met.

Operation in the recirculation mode to mitigate the consequences of a fire or a toxic release, if necessary, or as a compensatory measure when receiving ammonium hydroxide does not significantly increase the consequences of other 1 of 3

• Document Control Desk LR-N96154 LCR S95-21 accidents due to the short duration of these events, the ability to re-align the system to the pressurization mode manually, and the suspension of Core Alterations or fuel movement.

The CREACS as modified satisfies TS Bases 3.7.6.

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

The proposed changes reflect the commonality of the Salem Unit 1 and Unit 2 CRE and the supporting CREACS trains by adopting the guidance for required actions, allowed outage times, and testing provided in the STS.

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

2.

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

The establishment of the CREACS as a shared system for both Units 1 and 2 will not result in a new accident release scenario.

The upgraded CREACS reflected by this submittal revises the emergency operating mode from the original recirculation mode to a pressurization mode in the event of a radiological emergency.

This change in CREACS operating philosophy is in support of compliance with the limits of GDC 19.

Modifications to the Salem control rooms regarding the controlled atmospheric boundary configuration and how the configuration is maintained cannot result in new accident scenarios.

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

3.

The proposed change does not involve a significant reduction in a margin of safety.

The proposed changes support modifications to the CREACS as part of corrective actions identified in Licensee Event Reports with the intent of compliance with General Design Criterion 19 limits.

The changes do no impact the existing safety analyses while retaining and meeting current 2 of 3

~ Document Control Desk LR-N96154 LCR S95-21 requirements and General Design Criteria limitations and gaining a redundancy in the affected system.

The modified CREACS meets the TS Bases 3.7.6 requirements.

CREACS ensures that (1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for equipment and instrumentation cooled by the CREACS and (2) the Control Room will remain habitable for operations personnel during and following all credible accident conditions.

This clarification of the CREACS operability requirements and the application of more conservative requirements to Unit 1 will result in a net increase to operator safety.

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

Conclusion Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.

3 of 3

(1 I

. T Document Control Desk SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 LR-N96154 LCR S95-21 CHANGE TO TECHNICAL SPECIFICATIONS REVISION OF CONTROL ROOM VENTILATION SPECIFICATION TECHNICAL SPECIFICATION PAGES WITH PEN AND INK CHANGES The following Technical Specifications for Facility Operating License No. DPR-70 are affected by this change request:

Technical Specification Page Table 3.3-6 3/4 3-36a, 37 Table 4.3-3 3/4 3-38a 3/4.7.6.1 3/4 7-18 thru 3/4 7-21 B 3/4.3.3.1 B 3/4 3-2 B 3/4.7.6 B 3/4 7-5 The following Technical Specifications for Facility Operating License No. DPR-75 are affected by this change request:

Technical SEecification Page Table 3.3-6 3/4 3-39a, 40 Table 4.3-3 3/4 3-4la 3/4.7.6 3/4 7-15 thru 3/4 7-17 B 3/4.3.3.1 B 3/4 3-2 B 3/4.7.6 B 3/4 7-5 1 of 25

Document Control Desk INSERT 1 LR-N96154 LCR S95-21 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.

INSERT 2 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 inoperable, restore the Control Room Envelope to OPERABLE status 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 />.

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 24 (27 for Unit 2) 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 2 of 25

Document Control Desk LR-N96154 LCR S95-21 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 and during CORE ALTERATIONS.

a.

b.

c.

d.

e.

f.

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 CORE ALTERATIONS and 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 />, or suspend CORE ALTERATIONS and movement of irradiated fuel assemblies.

With two filtration trains inoperable, immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies.

With the Control Room Envelope inoperable, immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies.

With one or both series isolation damper(s) on a normal CAACS outside air intake or exhaust duct inoperable, immediately suspend CORE ALTERATIONS and 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 24 (27 for Unit 2) of Table 3.3-6.)

With one or both series isolation damper(s) on an outside emergency air conditioning air intake duct inoperable, immediately suspend CORE ALTERATIONS and 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 CORE ALTERATIONS or movement of irradiated fuel assemblies, at least one emergency air intake duct must be operable on each unit.

3 of 25

Document Control Desk LR-N96154 LCR 895-21

g.

With any isolation damper between the CAACS and the CREACS inoperable, immediately suspend CORE ALTERATIONS and movement of irradiated fuel assemblies until the damper is closed and secured in the closed position.

INSERT 3 The CREACS is a shared system with Salem Unit 2(1).

INSERT 4

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 that a laboratory analysis of a carbon sample from one of the charcoal adsorbers demonstrates a removal efficiency of ~ 99% for radioactive methyl iodide when the sample is tested at 30°C, 95% relative humidity.

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 either:

d.

1. Verifying within 31 days after removal that a laboratory analysis of a carbon sample obtained from a test canister demonstrates a removal efficiency of ~ 99% for radioactive methyl iodide when the sample is tested at 30°C, 95% relative humidity; or 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 4 of 25

Document Control Desk LR-N96154 LCR 895-21 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. 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 charcoal adsorbers at the design makeup flow rate of ~ 2500 cfm.

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%.

INSERT 5 The CREACS is a shared system between Unit 1 and 2 supplying a common Control Room Envelope (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 to 1/8" water gauge.

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 5 of 25

Document Control Desk LR-N96154 LCR S95-21 pressurization to 1/8" water gauge positive pressure 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 filter) and cooling coil, and distributed to the common CRE.

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.

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.1 Fan outlet dampers:

1(2)CAA15 and 1(2)CAA16 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:

1(2)CAA17 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:

1(2)CAA40, 1(2)CAA41, 1(2)CAA43 and 1(2)CAA45 The normally open outside air intake dampers 1(2)CAA40 and inlet plenum isolation dampers 1(2)CAA43 will be closed under emergency conditions.

The normally closed outside air intake dampers 1(2)CAA41 and inlet plenum isolation dampers 1(2)CAA45 are normally closed and remain closed under emergency conditions.

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

1(2)CAA18 and 1(2)CAA19 6 of 25

Document Control Desk LR-N96154 LCR S95-21 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: 1(2)CAA48, 1(2)CAA49, 1(2)CAA50 and 1(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: 1(2)CAA14 and 1(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 control room envelope is considered intact and able to support operation of the CREACS when the emergency air conditioning system is capable of maintaining a 1/8 water gauge positive pressure with the control room boundary door(s) closed.

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).

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 adsorber train(s) to ensure that the system is available in a standby mode.

Each CAACS normal air intake ductwork will have an additional radiation detector channel installed for a total of two detectors per intake.

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-1/lRlB-2 and one for 2RlB-1/2RlB-2) provides a signal to initiate CREACS in the pressurization mode should high radiation 7 of 25

Document Control Desk LR-N96154 LCR S95-21 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 inservice 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.

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.

INSERT 6 Operability of the CREACS requires that each of the Unit 2(1) dampers are also operable.

INSERT 7 ACTION 24 (27) -

With the number of channels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, restore the inoperable channel(s) to OPERABLE status within 7 days or initiate and maintain operation of the Control Room Emergency Air Conditioning System (CREACS) in the pressurization or recirculation mode of operation.

CORE ALTERATIONS and movement of irradiated fuel assemblies will be suspended during operation in the recirculation mode.

INSERT 8 With no channels OPERABLE in a Control Room air intake, immediately initiate and maintain operation of the CREACS in the pressurization or recirculation mode of operation.

CORE ALTERATIONS and movement of irradiated fuel assemblies will be suspended during operation in the recirculation mode.

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.

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