ML18102B647

Application for Amends to Licenses DPR-70 & DPR-75,modifying TS 3/4.7.7, Auxiliary Building Exhaust Air Filtration Sys & Bases

ML18102B647
Person / Time
Site:	Salem
Issue date:	10/24/1997
From:	Storz L Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18102B648	List: ML18102B647 ML18102B649
References
LCR-S95-44, LR-N97488, NUDOCS 9711050232
Download: ML18102B647 (16)

Text

Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations OCT 2 4 1997 LR-N97488 LCR S95-44 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR LICENSE AMENDMENT AUXILIARY BUILDING VENTILATION SALEM GENERATING STATION UNITS 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 In accordance with the requirements of 10CFR5-0.90, Public Service Electric and Gas Company (PSE&G) hereby requests a revision to the Technical Specifications (TS) for Salem Generating Station Units 1 and 2.

As required by 10CFR50.91(b) (1), a copy of this submittal has been sent to the State of New Jersey.

This revision modifies Technical Specification (TS) 3/4.7.7, Auxiliary Building Exhaust Air Filtration System, for both Salem units.

This proposed change will:

Require both Auxiliary Building Ventilation System (ABVS) supply fans to be OPERABLE; Require all three ABVS exhaust fans to be OPERABLE; Align ABVS TS to be consistent with current TS Bases and recently revised UFSAR system description; Assure that negative pressure is maintained in the Auxiliary Building under all postulated single-active failures; Clarify required Engineered Safeguard Feature (ESF) filter testing; Provide consistency between Unit 1 and Unit 2 TS; and

• • Remove the requirement to verify safety injection auto-start capabilities (for Unit 2).

In addition, the Technical Specification Bases for Salem Units 1 and 2 are modified as described in Attachment 3.

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Document Control Desk LR-N97488 These changes have been evaluated in accordance with OCT 2 4 1997 10CFR50.9l(a) (1), using the criteria in 10CFR50.92(c), and PSE&G has concluded that this request involves no significant hazards. of this submittal contains the bases for the requested change, Attachment 2 provides a 10CFR50.92 evaluation with a determination of no significant hazards, and Attachment 3 contains the marked up TS pages and associated Bases, as affected by the proposed changes.

Upon NRC approval of this proposed revision, PSE&G requests that the amendment be made effective on issuance, allowing a period of sixty days for implementation to provide sufficient time for associated administrative activities.

Should you have any questions regarding this request, we will be pleased to discuss them with you.

Sincerely,

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vi Affidavit Attachments (3)

C Mr. H. Miller, 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 Ms. M. Evans (X24)

USNRC Senior Resident Inspector -

Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933

Document Control Desk LR-N97488 JPP OCT 2 4 1997 BC Senior Vice President - Nuclear Engineering (N19)

General Manager -

Salem Operations (S05)

Director -

Salem Operations (S05)

Director -

Salem Unit 1 Recovery (S05)

Director -

Salem System Engineering (S02)

Director -

QA/NSR (XOl)

Director -

Licensing/Regulation & Fuels Manager -

Salem Mechanical/Civil Engineering (N51)

Supervisor -

Salem Nuclear Fuels (N20)

Program Manager - Nuclear Review Board (N38)

J. O'Connor G. Schwartz J. J. Keenan, Esq. (N21)

Records Management (N21)

Microfilm Copy Files No. 1.2.1 (Salem), and 2.3 (LCR S95-44)

STATE OF NEW JERSEY COUNTY OF SALEM SS.

REF: LR-N97488 LCR S95-44 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.

Subscribed and Sworn/)~o before me thisd9=f/1 day ofCfio/::JtuL, 1997 My Commission expires on KIMBERL y JO BROWN NOTARY PUBLIC OF f\\WW I Mi* Gem111ission Exp*

A"*.

• ER~EY ires pn! 21, 1998

Document Control LR-N97488 LCR S95-44 SALEM GENERATING STATION UNITS 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 AUXILIARY BUILDING VENTILATION SYSTEM (ABVS)

BASIS FOR REQUESTED CHANGE:

BACKGROUND The United States Nuclear Regulatory Commission (NRC) in their 10 CFR Part 50 "Final Policy Statement on Technical Specifications Improvement for Nuclear Power Reactors", regarding the four criteria used to determine if an item should be included in the Technical Specifications, stated in part, "... if a requirement meets any one of the four criteria, it should be retained or included in Technical Specifications." Under "Discussion of Criterion 3", it discusses the term "primary success path" and defines it as, "... the combination and sequences of equipment needed to operate (including consideration of the single failure criteria), so that the plant response to Design Basis Accidents and Transients limits the consequences of these events to within the appropriate acceptance criteria."

Further, it says, "Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function."

The Auxiliary Building Ventilation System (ABVS), which controls Auxiliary Building environment, is necessary to ensure the availability of primary success path equipment to perform their design basis functions, thus is required under Criterion 3 to be in Technical Specifications (TS).

Furthermore, the ABVS contains Auxiliary Building exhaust air to ensure that it is filtered and released from the plant through a monitored vent during a Loss of Coolant Accident (LOCA).

This prevents the uncontrolled release of radioactive gaseous and particulate contamination that could leak from ECCS equipment located in the Auxiliary Building, as required by 10 CFR Part 20 and Part 100 considerations.

During review of ABVS TS, PSE&G decided to revise the TS for both units to update surveillance requirements, create consistency between the TS for both units, and change the Limiting Condition for Operation (LCO) to require all ABVS fans to be OPERABLE.

The only change to the exhaust fans is to require them to be OPERABLE.

The number of fans operating at any one time, under Page 1 of 9

Document Control LR-N97488 LCR S95-44 normal conditions, will depend on ambient temperature and pressure conditions.

REQUESTED CHANGE AND PURPOSE This revision modifies Technical Specification (TS)3/4.7.7, Auxiliary Building Exhaust Air Filtration System, for both Salem Units.

The proposed change will modify the TS to:

1.

Require two ABVS supply fans to be OPERABLE.

2.

Require three ABVS exhaust fans to be OPERABLE.

3.

Require that Auxiliary Building pressure be negative with respect to atmospheric pressure.

4.

Clarify required filter testing.

5.

Provide consistency between Unit 1 and 2 TS.

6.

Remove redundant testing associated with Safety Injection auto-start capabilities of the fans for Unit 2.

In addition, the Technical Specification Bases for Salem Units 1 and 2 are modified as described in Attachment 3.

The purpose of this change is to provide explicit operability requirements for the ABVS that are consistent with current Salem Technical Specification Bases and revised UFSAR system description, assure that any Auxiliary Building airborne contamination is contained, and assure that ABVS maintains Auxiliary Building temperatures within design limits.

JUSTIFICATION FOR REQUESTED CHANGES Bases The existing accident analysis in Salem Updated Final Safety Analysis Report (UFSAR), Chapter 15, credits ABVS for mitigating a Loss of Coolant Accident (LOCA).

For the system to perform its safety function as provided in the UFSAR, Post LOCA Auxiliary Building pressure must be maintained slightly negative with respect to ambient atmospheric pressure, air flow must be adequate to control temperature within allowable levels during Page 2 of 9

Document Control LR-N97488 LCR 895-44 normal and emergency modes of operation, and air flow from the emergency ECCS areas must be able to be directed through the carbon adsorber to control release of particulate and gaseous contamination from the building in accordance with 10CFR20.

System Description

The Salem ABVS is a once through ventilation and exhaust filtration system that maintains a slight negative pressure within the building, delivering outside air in sufficient volume to maintain Auxiliary Building temperatures within design limits.

The supply system consists of two fans, each of 100% capacity, powered from vital buses, that deliver outside air via duct work distribution throughout the building.

Supply fan start circuits are administratively controlled to prevent more than one supply fan from operating at any time, avoiding pressurization of the Auxiliary Building.

The system normally operates with one supply fan running; however, given a sufficiently low ambient temperature, there may b no supply fans in operation.

The exhaust system consists of three fans, each of 50% capacity, taking exhaust from a common plenum, three High Efficiency Particulate Air (HEPA) filters, and one High Efficiency Carbon Adsorber (HECA).

The HEPA filters receive air from the exhaust system duct work, and discharge it to the common plenum.

The carbon adsorber can be aligned interchangeably between either of two of the three HEPA filters and the common plenum.

The third HEPA filter cannot be aligned to the carbon adsorber.

The carbon adsorber is placed in the exhaust stream only during post LOCA conditions to remove radioactive iodine which may be introduced to the Auxiliary Building through ECCS equipment. The exhaust fans are powered from vital buses and are designed for continuous operation.

The exhaust fans maintain Auxiliary Building pressure slightly negative with respect to ambient atmospheric pressure.

The system is normally operated with two exhaust fans, and the remaining exhaust fan in stand-by.

UFSAR Section 9.4.2.2.2, System Operation, states that in the event of a LOCA, one of the two supply air units modulates air to the building in response to exhaust air temperature and two of the three exhaust fans modulate effluent to the plant vent in response to building negative pressure.

This statement is correct except that it does not characterize the necessary manual alignment steps.

On a Safety Injection (SI) signal the non-operating exhaust fan will automatically start to maximize flow.

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Document Control

e. LR-N97488 LCR 895-44 Alteration of this default configuration to optimize system performance requires manual intervention.

In addition, dampers that normally direct effluent from the emergency vent duct through the HEPA filters are manually shifted during accident conditions to include air flow through the carbon adsorber unit.

Justification The current ABVS TS LCO does not provide sufficient control for ABVS configurations such that the postulated post-accident response of the ABVS, assuming a single failure of the fans or their support systems, is in accordance with UFSAR descriptions.

This LCR is intended to correct the situation by including the supply and exhaust fan alignment and configuration in TS LCO 3.7.7.

This change provides explicit requirements for the ABVS to be OPERABLE such that a single failure can be accommodated (or continued operation conservatively restricted via Technical Specification Action Statements when failures can not be tolerated) and assures that negative Auxiliary Building pressure and equipment cooling are maintained.

The current TS 3/4.7.7 requires that at least one Auxiliary Building exhaust air HEPA filter train, associated with the one carbon adsorber bank, and at least two exhaust fans shall be OPERABLE.

With only one exhaust fan OPERABLE, the TS requires that at least two exhaust fans be made OPERABLE within 7 days or be in 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 />.

The third exhaust and both supply fans are not required to maintain the ABVS in an OPERABLE status, and can be removed from service with no limitations imposed by the TS.

Without limitations for those components, single failure criteria would require that the system must be able to perform its safety function in the presence of the most limiting single failure for the remaining components covered by the TS LCO.

However, applying the single failure criterion to ABVS can result in a configuration where supply fan capacity exceeds exhaust fan capability or post-LOCA temperatures can not be maintained.

This could cause either:

1) Auxiliary Building pressure to be greater than ambient atmospheric, which could result in the uncontrolled release of radioactive material during LOCA conditions; or 2) overheating of ESF equipment required to mitigate the consequences of design basis accidents.

The proposed changes contained in this submittal would eliminate this potential system configuration by requiring all fans to be OPERABLE and conservatively limiting the time allowed to operate in a degraded condition.

Although the application of the single Page 4 of 9

Document Control LR-N97488 LCR 895-44 failure criterion would be effectively relaxed for the limited time allowed by the LCO action statement, the proposed LCO and corresponding action statements provide more restrictive controls on plant configurations than are currently in place within the ABVS TS.

Specifically, the proposed LCO action statements for the supply and exhaust fans would allow:

1) one supply fan or one exhaust fan to be inoperable for 14 days; and 2) two or three exhaust fans to be inoperable for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Probabilistic Safety Analyses (PSA) of the proposed equipment outage times have been performed and demonstrated that equipment outage times more than twice as long as the proposed allowed outage times would not result in a significant increase in conditional core damage probability.

Specifically, the most limiting supply or exhaust fan outage resulted in a conditional core damage probability of 1.2E-7 for a 30 day period.

For the conditions where two or three exhaust fans are inoperable, uncontrolled releases of particulate and gaseous contamination from the Auxiliary Building could occur under post LOCA conditions due to the inability to maintain negative Auxiliary Building pressure.

However, PSE&G believes that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time is appropriately conservative due to:

1) the low probability of events resulting in core damage that would require ABVS filtration; and 2) the proposed outage time is commensurate with the existing 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time for an inoperable carbon adsorber unit, which would also result in diminished radioactive iodine removal under the unlikely post LOCA conditions.

For the case where two supply fans are inoperable, the proposed action statement would require that the unit be placed in HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> since post-accident design basis temperatures cannot be assured in the Auxiliary Building.

This proposed action statement is appropriate since it is more restrictive in the time required to reach a safe shutdown condition than is currently specified using the provisions of TS 3.0.3.

For the other ABVS components, PSE&G is proposing that:

1) a 7 day allowed outage time be established for one inoperable HEPA filter train; 2) a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time be established when a HEPA filter train cannot be aligned to a carbon adsorber unit; 3) a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time be established when Auxiliary Building pressure is no longer negative with respect to atmospheric pressure; and 4) the existing 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage Page 5 of 9

Document Control LR-N97488 LCR 895-44 time for one inoperable carbon adsorber unit be retained.

For the proposed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage times, the ABVS will not effectively remove post-LOCA radioactive iodine or particulates.

However, PSE&G believes that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time is appropriately conservative because:

1) the low probability of events resulting in core damage that would require ABVS filtration and iodine removal; and 2) the proposed outage times are commensurate with the existing 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time for an inoperable carbon adsorber unit, which would also result in diminished radioactive iodine removal under the unlikely post LOCA conditions.

For the 7 day allowed outage time proposed for one inoperable HEPA filter train, PSE&G believes that this period is sufficiently conservative since:

1) the remaining HEPA filtration capability is sufficient to mitigate the consequences of design basis accidents; and 2) the 7 day allowed outage time is commensurate with the length of time established in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants,"

when ventilation systems can no longer tolerate an additional failure.

For the changes contained in the proposed Surveillance Requirement 4.7.7.1.a, PSE&G is specifying that flow through both HEPA filter trains communicating with the carbon adsorber is required.

The change will ensure that dampers and other airflow directional devices are operating properly and will function as required in response to control room actuation. The original requirement for the 15 minute test duration has not changed.

For the changes contained in the proposed Surveillance Requirements 4.7.7.1.b.1 and 4.7.7.1.b.2, PSE&G altered the manner in which the 18 month test is performed.

Specifically, PSE&G would like to replace DOP with halogenated hydrocarbon refrigerant as the challenge agent when determining total system bypass.

The use of DOP as a challenge agent for total system bypass does not completely represent the bypass that may be present within the system and would require that the results of the carbon adsorber bed inplace leak test be utilized to determine the total system bypass.

The proposed halogenated hydrocarbon refrigerant is not affected by HEPA filters and comparisons of upstream and downstream concentrations truly represents total system bypass.

The use of this agent eliminates intensive labor activities involving the invasive practice of removing and reinstalling HEPA filters to ensure that they do not bias the test results by removing DOP prior to reaching areas of potential bypass.

These proposed surveillances also address the two specific flow paths communicating with the carbon adsorber Page 6 of 9

Document Control LR-N97488 LCR 895-44 unit to ensure that bypass testing occurs in the possible system configurations.

For the changes contained in the proposed Surveillance Requirements 4.7.7.1.b.3 and 4.7.7.1.b.4, PSE&G is providing additional details of how the tests are being performed with specific references to USNRC Regulatory Guide 1.52.

For Surveillance Requirement 4.7.7.1.b.4, specific references to the HEPA filter bank trains are being added.

For the changes contained in the proposed Surveillance Requirement 4.7.7.1.b.5, PSE&G is proposing several changes to the current 4.7.7.1.b.4 requirements.

ANSI N510 and USNRC Regulatory Guide 1.52 require cyclic laboratory testing of carbon samples drawn from existing beds.

These samples need to be tested under conditions that represent in-service system conditions.

This test requires that the sample be tested at 130°C and 95% relative humidity (RH); however, these parameters are not representative of the conditions expected in the Auxiliary Building during a design basis accident.

Therefore, PSE&G is proposing that the more appropriate test at 30°C and 95%

RH be utilized when testing iodine removal capability.

This criteria is consistent with the currently accepted test standard ANSI D3803, Revision 1989, that prescribes an appropriate test methodology of carbon adsorber samples.

In addition, the requirement for the ABVS to remove methyl iodide has been removed since the current site dose analysis does not credit the ABVS with methyl iodide removal.

For the changes contained in the proposed Surveillance Requirements 4.7.7.1.b.6, PSE&G is proposing that editorial modifications be made to more specifically describe the lineup for the surveillance test.

In addition, system flowrate acceptance criteria currently contained in Surveillance Requirement 4.7.7.1.b.5 is being modified to only specify the upper flowrate limit of 21,400 cfm + 10%.

This change is necessary since the winter mode of operation throttles the ABVS flow to approximately 66% of the full flow value.

At this "winter mode" flowrate, filtration and elemental iodine removal capability is enhanced with the lower flow.

Actual filter testing will, however, still be performed at 21,400 cfm +/- 10% to ensure filtration and elemental iodine removal capabilities under the design basis flowrates.

For the changes contained in the proposed Surveillance Requirements 4.7.7.1.b.7.a and 4.7.7.1.b.7.b, PSE&G is establishing the same acceptance criteria currently contained in Surveillance Requirement 4.7.7.1.d.1.

The specific lineups to Page 7 of 9

Document Control LR-N97488 LCR 895-44 perform the pressure drop test of the HEPA filter trains are being added to the surveillance requirements.

For the changes contained in the proposed Surveillance Requirement 4.7.7.1.b.8, PSE&G is adding the requirements to verify that the normal ABVS configuration is capable of maintaining the Auxiliary Building at a negative pressure with respect to the outside ambient pressure.

The ability to maintain negative pressure is a primary ABVS function as described in the UFSAR and this test has been added to the TS to ensure that unfiltered leakage paths are not present in the Auxiliary Building pressure boundary and to provide an indication of possible pressure boundary degradation.

For the changes contained in the proposed Surveillance Requirement 4.7.7.1.c, PSE&G is proposing several changes to the current requirements as discussed previously for the changes contained in the new Surveillance Requirement 4.7.7.1.b.5.

Specifically, the criteria contained in test standard ANSI D3803, Revision 1989, will be used to test for iodine removal capability in lieu of the method currently described in Surveillance Requirement 4.7.7.1.c.

For the changes contained in the proposed Surveillance Requirement 4.7.7.1.d, PSE&G is adding new requirements to ensure that airflow distribution is verified after modifications that could impact the ABVS flow patterns.

This requirement will provide more consistent test results and ensures that equal distribution of the_ challenge gases occurs during testing.

For the changes contained in the proposed Surveillance Requirement 4.7.7.1.e, PSE&G is providing the same requirement that currently exists in Surveillance Requirement 4.7.7.1.b.

The specific reference to the new Surveillance Requirements 4.7.7.1.b.3 and 4.7.7.1.b.4 ensures that the appropriate leakage testing is performed whenever structural maintenance is performed on the HEPA or carbon adsorber mounting frames or housing.

For the changes contained in the proposed Surveillance Requirements 4.7.7.1.f and 4.7.7.1.g, PSE&G is providing requirements to ensure proper testing of the carbon adsorber unit after flow from the normal areas of the Auxiliary Building or the containment purge has been directed through the carbon adsorber.

The airflows from these areas exceed the capacity of the carbon filter and therefore verification of the carbon adsorber operability is required.

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Document Control LR-N97488 LCR S95-44 PSE&G is also proposing that the current Unit 2 Surveillance Requirement 4.7.7.d.2 be eliminated.

Verifying that the ABVS system starts on a Safety Injection Test Signal is already accomplished by performing the 18 month emergency diesel generator surveillances 4.8.1.1.2.d.3 & 6.

In summary, this submittal provides explicit requirements for the ABVS to be considered OPERABLE consistent with current Salem Technical Specification Bases and UFSAR system description, and assures that:

1) negative Auxiliary Building pressure is maintained under all postulated single-active failures; and 2) the ABVS is capable of performing its design basis functions.

CONCLUSIONS The changes proposed herein enhance the TS by providing specific criteria that must be met in order to consider the system OPERABLE.

These criteria are directly related to the design basis as provided in the UFSAR, and will enhance the system's ability to respond to and mitigate design basis accidents as required.

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Document Control LR-N97488 LCR S95-44 SALEM GENERATING STATION UNITS 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 AUXILIARY BUILDING VENTILATION SYSTEM (ABVS) 10CFR50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the proposed changes to the Salem Generating Station Units 1 and 2 TS do not involve a significant hazard.

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

REQUESTED CHANGE This submittal provides explicit requirements for the ABVS to be considered OPERABLE, consistent with "Standard Technical Specifications Westinghouse Plants" NUREG 1431, Revision 1 (ITS) and applicable Bases.

Filter testing requirements are standardized using more current testing standards, and clarification is added to the Bases.

Specifically, it will:

Require two Auxiliary Building Ventilation System (ABVS) supply fans to be OPERABLE.

Require three ABVS exhaust fans to be OPERABLE.

Clarify required filter testing.

Provide consistency between Unit 1 and 2 TS.

Remove redundant testing associated with Safety Injection auto-start capabilities of the fans for Unit 2.

BASIS

1.

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

The proposed change alters the number of fans which must be OPERABLE to ensure that a sufficient number of supply and exhaust fans will be operable, following a most limiting single failure, to mitigate the consequences of design basis accidents.

The changes to the ABVS surveillance requirements still provide an appropriate means for demonstrating the operability of the ABVS.

Page 1 of 3

Document Control LR-N97488 LCR 895-44 The ABVS cannot initiate or otherwise cause any accident or operational transient evaluated in the UFSAR.

Consequently, the probability of such events is not increased.

The ABVS cannot increase the consequences of a design basis LOCA unless:

1)

Auxiliary Building negative pressure is lost, resulting in uncontrolled, ground level release of radioactive material; 2)

ABVS carbon adsorbers are bypassed, resulting in uncontrolled release of radioactive iodine from the plant vent; or 3)

Auxiliary Building temperatures are not controlled, resulting in failure of accident mitigating equipment.

By requiring OPERABILITY of all ABVS supply and exhaust fans, the proposed changes contained in this submittal assures Auxiliary Building negative pressure is maintained under all postulated post-accident, single-failure scenarios.

The proposed changes to ABVS will not affect the elemental iodine adsorption capability of the system.

Finally, engineering analyses conclude that these fan combinations, with single-active failures of the fans or their support systems considered, provide sufficient Auxiliary Building ventilation.

Under the most limiting temperature conditions, the fans will maintain room temperatures within design limits.

Accordingly, the consequences of a design basis LOCA, hence applicable design basis accidents or operational transients, are not increased.

Therefore, the proposed amendment 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.

ABVS supply fans are not considered essential to the primary safety-function of preventing or mitigating radioactive releases, nor are they currently required to be OPERABLE.

Similarly, accident analyses take no credit for operation of supply fans.

Accordingly, malfunctions of vital buses and ABVS exhaust fans are the only malfunctions of active ABVS related equipment important to safety that are previously evaluated.

The probability of failure of a vital bus is not increased by this proposal since the proposal has no direct effect on electrical power.

Neither is the probability of exhaust fan failure increased by the proposal, since exhaust fans are not Page 2 of 3

Document Control LR-N97488 LCR 895-44 affected by this proposal, except that the number that must be OPERABLE is increased from two to three.

By requiring additional supply fans and exhaust fans to be OPERABLE, no single failure of either a vital bus or ABVS fan prevents (1) maintenance of negative Auxiliary Building pressure or (2) maintenance of temperatures within design limits.

Since ABVS supply and exhaust fans cannot initiate accidents, increasing the number of fans required to be OPERABLE cannot create the possibility of a new or different kind of accident from any accident previously evaluated.

In addition, the proposed changes to the ABVS surveillance testing concern ABVS leakage, HEPA filter and carbon adsorber capabilities, and laboratory test methods.

Therefore, the proposed surveillance requirement changes would have no impact on the initiation of accidents.

Thus, the proposed changes do 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 margin of safety is dependent upon the maintenance of specific operating parameters within designated design limits.

Since iodine removal capability is not affected by the proposed changes, and negative Auxiliary Building pressures and temperatures will continue to be maintained within existing design limits under post-accident conditions, including consideration of the most limiting single active failure, the margin of safety is not reduced.

By imposing new restrictions on the allowed outage times of ABVS components, the margin of safety is increased with the proposed changes to the ABVS Technical Specification Limiting Condition for Operation (LCO).

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

Public Service Electric & Gas has concluded that the proposed changes to the Salem Generating Station Technical Specifications do not involve a significant hazards consideration.

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