Text

Proposed Tech Specs,Changing SR 4.7.5.b to Run Control Room Emergency Air Cleanup Sys Every 31 Days from 10 H to 2 H & Air Flow Rate for Control Room Emergency Air Cleanup Sys AC Unit from 35,485 Cfm to 35,705 Cfm
	ML20095G865
Person / Time
Site:	San Onofre
Issue date:	12/18/1995
From:	; SOUTHERN CALIFORNIA EDISON CO.
To:	;
Shared Package
ML20095G861	List: ML20095G857; ML20095G862; ML20095G865; ML20095G870; ML20095G873;
References
	NUDOCS 9512210346
	Download: ML20095G865 (69)
	v • d • e

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l PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY AIR CLEANUP SYSTEM *

[IMITINGCONDITIONFOROPERATION 3.7.5 Two independent control room emergency air cleanup systems shall be OPERABLE.

APPLICABILITY: ALL MODES or during movement of irradiated fuel assemblies. l ACTION:

Unit 2 or 3 in MODE 1, 2, 3 or 4:

With one control room emergency air cleanup system ino)erable, restore the inoperable system to OPERABLE status within 7 days or se in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Units 2 or 3 in MODE 5 or 6; or defueled when moving irradiated fuel assemblies.

a. With one control room emergency air cleanup system inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control room emergency air cleanup system in the recirculation mode.

b. With both control room emergency air cleanup systems inoperable, or with the OPERABLE control room emergency air cleanup system required to be in the recirculation mode by ACTION (a), not capable of being powered by an OPERABLE emergency power source, suspend all o)erations involving CORE ALTERATIONS or positive reactivity c1anges; or movement of irradiated fuel assemblies.

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c. The provisions of Specification 3.0.3.are not applicable in MODE 6.

d. The provisions of Specification 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

SURVEILLANCE REQUIREMENTS 4.7.5 Each control room emergency air cleanup system shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control room air temperature is less than or equal to 110*F.

b. At least once per 31 days on a STAGGERED TEST BASIS by imitating, from the control room, flow-through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months with the heaters on.

c. At least once per 18 months or (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 with the system operating at a flow rate of 35485 cfm i 10% for the air conditioning unit, and 2050 1 150 cfm for the ventilation unit and recirculating through the respective HEPA filters and charcoal adsorbers, leakage through the system diverting valves is less than or equal to 1% air conditioning unit and 1% ventilation unit when the system is tested by admitting cold 00P at the respective intake.

Shared system with San Onofre - Unit 3.

SAN ON0FRE - UNIT 2 3/4 7-13 AMENDMENT NO. M ,123

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$.;;y!!i.(,14:! _R!OUIE!PI.9'S ( :nti ve:1

2. Verifying that t.*e : lea.-.; syste satisfies tre in cla:e testing ac:eo;arce c. iteria ard uses the test :r:cedures of l

Regulat:ry P:siti:ns C.5.a. C.5.: and C.S.d of Re;ulat:ry Guide 1.52, Revisi:n 2. March 1978, and the system flow rate is 2050 2 150 cfm f:r tne ventilati:n unit and 35,485 cfm : 1% ;

for tre air conditioning unit.

3. Verifying witnin 31 days after removal that a laterat:ry analysis of a representative carton sample Octained in accordance with Regulatory Position C.6.b of Regulat:ry Guide 1.52, Revision 2, March 1978, meets tne lacerat:ry testing criteria of Regulatory Position C.6.4 of Regulat:ry Guide 1.52, Revision 2, March 1978.

a. Verifying a system flew rate of 2050 2 150 cfm f:r the l ventilation unit and 35,a85 cfm : 10% for tne air c:nditt:nir; unit during sys*em operation wnen tested in ac::rdan:e witn ANSI N510-1975.

d. Af ter every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying witnin 31 days after rem val snat a la: oratory analysis of a re:resenta'.ive car:en sat:1e Ottained in a::ordance witn Regulat: y Position C.S.b of Regulat:ry Guide 1.52, Revision 2,. Mar:n 1973, meets the laceratory testing criteria of Regulatory Positi:n C.~5.a

-. of Regulatory Guide 1.52, Revision 2, March 1978.

e. At least once per 18 months ty: l I

1. Verifying that the pressure drop across the coe.bined HE?A t filters and charcoal adsorter banks is less than 7.0 incnes Water Gauge ventilation unit and less than 7.3 inches water Gauge air conditioning unit while operating the system at a flow rate of 2050 2 150 cfm for the ventilation unit and 35,485 cfm 2 10% for the air conditioning unit.

1

2. Verifying that on a control room isolation test signal, the systes automatically switches into the amargency mode of i operation with flow through the HEPA filters and charcoal adsorber banks.

3. Verifying that on a toxic gas isolation test signal, the system automatically switches into the isolation mode of operation with flow through the NEPA filters and charcoal adsorter banks.

4 Verifying that the system maintains the control roca at a positive pressure of greater than or equal to 1/8 inch V.G.

relative to the outside atmosphere during system operation in the energency sede.

5. Verifying u.at the heaters dissipate 4.8 kw 2 5% when tested

.) in accordance with ANSI H510-1975.

3/4 7-14 NIENCHENT No. M san Ot:0FRE-WIT 2

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Af ter each complete or' partial replacement of a HEPA filter ta..k by i

verifying that the HEPA filter banks remove greater than or equal to 99.95% of the 00P when they are tested in place in accordance witn ANSI H510-1975 while operating the system at a flew rate of 2050 2 150 cfm for the ventilation unit and 35,485 cfm : 10% for :.e l air conditioning unit.

g. Af ter each complete or partial replacement of a charcoal adscrber bank by verifying that the charcoal adsorbers remove greater nan or equal to 99.95% of a halegenated hydrocarbon refrigerant test gas when they are tested in place in accordance with ANSI 150 N510-1975 cfm for t.te while operating the system at a flow rate of 2050 : l ventilation unit and 35,485 cfm : 10% for the air conditioning unit.

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FEB 1. 8 !cM 3/4 7-15 AMENCHENT No. 14 SAN ONOFRE-UNIT 2 I

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1 PLANT SYSTEMS BASES 3/4.7.5 CONTROL ROOM EMERGENCY AIR CLEANUP SYSTEM The OPERABILITY of the control room emergancy air cleanup system ensures i that 1) the ambient air temperature does not esc'eed the allowable temocrature ;

< for continuous duty rating for the equipment anh instrumentation cooled by this system and 2) the control room will remain habitable for operations I personnel during and following al.1 credible accident conditions. The OPERABILITY of this system in conjunction with control room design provisions i is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body, or its equivalent. This limitation is i consistent with the requirements of General Design Criteria 19 of Appendix A, (

10 CFR 50. 1 l

Cumulative operation of the system with the heaters on for at least i

10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months over a 31 day period is sufficient to reduce the buildup of moisture '

on the adsorbers and HEPA filters, j

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NPF-10/15-407 ATTACHMENT "B" EXISTING SPECIFICATIONS UNIT 3

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CONTROL RCCM EME;CEN 3/4,7.5 ._

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(IMITIN7 CONDITION FOA 0FT2ATICN 1 emergency air cleanup systa=s shall te Two independent centrol ree.

3.7.5 j Ci!MSLE.

Apot!CA!!LITY: ALL HCOES il ACTICH:

N :ne I

j Unit 2 er 3 in MODES 1, 2, 3 er 4:

With one centrol rees eeergency air cleanup in at leastsystem SCT fc11 ewing inop I

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ine;erable system to CPERA3LE status within l

1 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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Units 2 and 3 in MCCFS Sroote er 5: emergency air cleanu;r -

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With ent contrer i hin system 7 days :. incpe l

restore the inoperaale system to CPIRASLE status wt LE centr:1 l

J initiate and maintain :;eration of theble,rema er l With both centrol reem emergencyi air cleanup systems inc tle of be hg

b. with the CPEMBLE centrol room emergency a r c e

ns to be in the recirculation sede by ACTICH (a), notll ca;a :; era

!. pcwered by an OPERA 3LE emergency w::E 5 ;c c.

The pr: visions of Specification 3.0.3 are not applicasle SURVEILLANCE REOUIREMENTS 4.7.5 Each c:ntrol reem emergency air cleanup system sha i

C?!M3LE:

a.

At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the c:ottel r

- temperature is less than or equal to 110*F. i b.

At least once per 31 days on a STAGGERED TEST.8 41 frca the control roca, flew through the HEPA filters and adsorbers and verifying that the system operates for a 10 bcurs with the heaters on.

c.

At least once per 18 months or (1) af ter any11:struct wing on the HEPA filter or charcoal adsorber housings, or (

painting, fire or chemical release in any ventilation zo cce=unicating with the system by:

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Verifying that with the system operating at a 150

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35485 cfm + 10% for the air condit ii systil ing ,

i HEPA filters and charcoal adsorbers t d by e unit and M ventilation unit when the system is tes e l y admitting cold 00P at the respective intake. l j l l =

Shared system with San Onofre - Unit 2. MEEE MO-

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! ! SAN CHOFRE-UNIT 3 ,

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gzgit t ANCE REOUIREVENTS (C:ntiraedi 2.

Verifying that the cleanup sys*em satisfies tne in-place testing a0:eptance Cri*eria and uses the test pr:Ctf.Wres Of

Regulat: Py E:siti:ns C.5. a. C.5.c and C.S.d of Regulat:ry Guide 1.52, Revision 2, March 1978, and the system f 6 ate is

.:t j 2050 e 150 efs for tne ventilation unit and 35,485 cf . :

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for the air c nditioning unit.

3. Verifying within 31 days af ter removal that a 14:: rat: y analysis Of a representative car::n sagle btained in I ac:ordance with Regulatory Position C.S.b of Regulat:ry Guide 1.52, Revision 2, March 1978, meets the la:: rat:ry testing criteria of Regulat:ry 7:sifien C.6.a of 8.e;uiat:ry Guide- ).52, Revision 2, March 1978 4 Verifying a system flew rate of 2050 10% 2 150 cfmair for the for:enci*.i:mir.;

the l ventilation unit and 35,485 cfm :

dnit during system cperation when tested in ac:ordar.:e wita ANSI N510-1975, d.

After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of char::a1 adsorder cperation by verifyir.g within 31 days after removal that a laboratory analysis of a representative carten sample :btained in at:crdance with tegu'at:Py P:sition C.5.b of Regulatery Guide 1.52, Revisi:n 2, Mar:n '!7!.

meets the la: rat:ry testing criteria of Regulat:ry ?:siti:s :.i.a i of Regulat:ry Guice 1.52, Revision 2, March 1973.

e. At least once per 18 m:nths by:

1. Verifying that the pressure deep across the c:mbired :'E:a filters and charcoal adscreer banks is less than 7.0 in: es i Vater Gauge ventilation unit and less than 7.3 inches Vater

) Gauge air conditioning unit while operating the system at a flew rate of 2050

150 cfm for the ventilation unit and l

35,485 cfa 2 10% for the air conditioning unit.

2. Verifying that on a control roce isolation test signal, tne systes autesatically switches it.to the emergency mode41of operation with flow through the HEPA filters and chare:

' adsorter banks. ' s

- 3.

Verifying that on a text: gas isolation test signal, the sy j automatically switches into the isolation mode of e:eratica with ficw through the NEPA filters and charcoal adsorter tanks.

4 Verifying that the system maintains the centrol re:m at a positive pressure of greater than or equal t,o the emergency mode.

5% when tested in

5. Verifying that the heaters dissipate 4.8 kw :

accordance with ANSI H510-1975.

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A."ENCHEMI MO 3 SAH ONOFRE-UNIT.3 3/4 7-15

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- SURygti.i ANCE RE0VIRE. EVTS (C:ntinued.

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Af ter each complete or ;artial replacement of a HEPA filter ban 2

verifying that the HIPA filter tanks restve grea e

99.95% of the 00P when they are tested in-place in accord while operating the system at a flow rate of -

MSI H510-1975 efs for the ventilation unit and 35,485 cfm : 10% f:- . e 2050 : 150 air c:nditioning unit.

After each cespiste or' partial replacement of a charcoal ad

g. bank by verifying 'that the charecal adsorbers rasove gre l

equal to 99.95% of a halegenated hydrocarbon ith MSI N510-1975ref rigera when they are tested in-place in accercance fw2050 2 150 cfm f:e the while emerating the syates at a flow rate o1C% for the air c:nditionin; unit.

ventilation unit and 35,485 cfm :

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MEMONENT MO. 3 3/4 7-15 SAN ONOFRE-UNIT 3 e

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PLANT SYSTEMS

! SA$ES l

3/4.7.5 CONTROL ROOM EE RGENCY AIR CLEANUP SYSTEM

! The OPERABILITY of the control' room emergency air cleanup system ensures that 1) the ambient air temperature does not exceed the allowable temperature l for continuous duty rating for the equipment and instrumentation cooled by i this system and 2) the control room will remain habitable for operations 1

personnel during and following all credible accident conditions. The

OPERA 8ILITY of this W in conjunction with control room design provisions

' is based on limiting the radiation exposure to personnel occupying the control room to 5 ren or less whole body, or its equivalent. This limitation is consistent with the requirements of General Design Criterion 19 of Appendix A,

10 CFR 50.

! Cueulative operation of the system with the heaters on for at least i 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months over a 31-day period is sufficient to reduce the buildup of moisture

on the adsorbers and HEPA filters, t

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NPF-10/15-407 ATTACHMENT "C" PROPOSED SPECIFICATIONS UNIT 2 l

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PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY AIR CLEANUP SYSTEM

LIMITING CONDITION FOR OPERATION 3.7.5 Two independent control room emergency air cleanup systems shall be OPERABLE.

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

ACTI0N:

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With one control room emergency air cleanup system ino)erable, restore the inoperable system to OPERABLE status within 7 days or )e in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Units 2 or 3 in MODE 5 or 6; or defueled when moving irradiated fuel assemblies.

a. With one control room emergency air cleanup system inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control room emergency air cleanup system in the recirculation mode.

b. With both control room emergency air cleanup systems inoperable, or with the OPERABLE control room emergency air cleanup system required to be in the recirculation mode by ACTION (a), not capable of being powered by an OPERABLE emergency power source, suspend all o)erations involving CORE ALTERATIONS or positive reactivity c1anges; or movement of irradiated fuel assemblies. -

c. The provisions of Specification 3.0.3 are not applicable in MODE 6.

d. The provisions of Specification 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

SURVEILLANCE REQUIREMENTS 4.7.5 Each control room emergency air cleanup system shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control room air temperature is less than or equal to 110*F.

b.- At least once per 31 days on a STAGGERED TEST BASIS by imitating, from the control room, flow through the HEPA filters and charcoal 2 @adsorbers w hours e and verifying tn tne neaters that4the system operates for at least l

N

c. ' At least once per 18 months or (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 h hg communicating with the system by:

3, N 1M ifying that with the system operating at a flow rate of 3 r '

'e h "

cfm + 10% for the air conditioning unit, and 2050 + 150 cfm JfortheveEtilationunitandrecirculatingthroughtherespective 1

HEPA filters and charcoal adsorbers, leakage through the system diverting valves is less than or equal to 1% air conditioning unit and 1% ventilation unit when the system is tested by admitting cold DOP at the respective intake. f

Shared system with San Onofre - Unit 3.

SAN ON0FRE - UNIT 2 3/4 7-13 AMENDMENT NO. M ,123

PLAT SYSTDt5

$URVEll.LM;E REQUIREMENTS (Continued) 2.

Verifying that the cleanup system satisfies the in place testing acceptance criteria and uses the test procedures of Regulatory Positions C.5.a. C.S.c and C.S.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is t 2050 1 150 cfm for the ventilation unit arid u5,489cfm 210%

for the air conditioning unit.

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Verifying within 31 days af ter removal that a laboratory l analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory 1 testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.

4 Verifying a system flo ate307efof 2050 2 150 cfm for the ventilation unit andos.453 cfm 210% for the air conditioning g, unit during system operation when tested in accordance with ANSI N510-1975.

d. 1 Af ter every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying '

within 31 days after removal that a laboratory analysis of a i representative carbon sarr.ple obtained in a::ordance with Regulatory '

Position C.6.b of Regulatory Guide 1.52. Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.

e. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA !

filters and charcoal adsorber banks is less than 7.0 inches Water Gauge ventilation unit and less than 7.3 inches Water i Gauge air conditioning unit while operating the system at a l

i flow rate of 2050 2 150 cfm for the ventilation unit and q

' (3:s,48S cfm i 10% for the air conditioning unit.

JF 7b5 L

2. Verlfying that on a control room isolation test signal, the

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system automatically switches into the emergency mode of i

operation with flow through the HEPA filters and charcoal ;

adsorber banks.

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3. l Verifying that on a toxic gas isolation test signal, the system i automatically switches into the isolation mode of operation '

with flow through the HEPA filters and charcoal adsorber banks.

4. Verifying that the system maintains the control room at a i

positive pressure of greater than or equal to 1/8' inch W.G.

relative to the outside atmosphere during system operation in the emergency mode.

fL

) ( 5. Verifyingthattheheatersdissipate4.8kwt5%whentesth

( in accordance with ANSI N510-1975.J l

SAN O!!OFRE-UNIT 2 3/4 7-14 AMENOMENT NO. 14 k

PLANT SYSTEMS 1

]_FVEI'.'**j~. ~EO?!E.E.IN'~ f:r .i?ued) f.

After each complete or' partial repla' cement of a HEPAy filter bank 99.95% of the DOP when they are tested in p(

ANSI N510-1975 while operating the system at a flow rate of air conditioning unit.2050 i 150 cfm for the ventilation unit and(Js, I('

g. pr 3g 7p3r After each complete or -partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater tha equal to 99.95% of a halogenated hydrocarbon refrigerant t tes' gas when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 2050 ventilation unit andtso.485]hfm t 10% for the 150 cfm for the air conditioning unity2 Y 3(7pf . l I

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SAN ONOFRE-UNIT 2 FEB18!aR1 3/4 7-15 AMENDMENT NO. 14

PLANT SYSTEMS BASES 1 3/4.7.5 CONTROL ROOM EMERGENCY AIR CLEANUP SYSTEM The CREACUS provides a arotecte'd environment from which operators can control the plant follow ng an uncontrolled release of radioactivity, or toxic gas.

The CREACUS consists of two independent, redundant trains that recirculate and filter the control room air. Each train consists of a prefilter, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodine), and a fan. A second bank of HEPA filter follows the adsorber section (for emergency air conditioning unit only) and is used to retain carbon fines downstream of carbon adsorber. Each emergency ventilation air supply unit Ductwork, includes prefilter, HEPA filter, charcoal adsorber, and fan.

motor-operated dampers, and instrumentation also form part of the system.

Air and motor-operated dampers are provided for air volume control and system isolation purposes.

Upon receipt of the actuating signal, normal air supply to the control room is isolated, and the stream of ventilation air is recirculated through the system's filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 15 minutes per month verifies proper system operation.

There are two CREACUS operational modes. Emergency mode is an operational mode when the control room is isolated to prevent operation personnel from the radioactive exposure through the duration of any one of the postulated limiting faults discussed in FSAR, Chapter 15. . , . Isolation mode is an operational mode when control room is isolated to protect operation personnel from toxic gases and smoke.

Actuation of the CREACUS places the system into either of two separate states of the operation, depending on the initiation signal. Actuation of the system to the emergency mode of operation closes the unfil'tered-outside-air intake and exhaust dampers and aligns the system for recirculation of control room air through the redundant trains of HEPA and charcoal filters. The emergency mode initiates pressurization of the control room. Outside air is added to the air being recirculated from the control room.

Pressurization of the control room prevents infiltration of infiltered air from the surrounding areas of the building.

The actions taken in the toxic gas isolation mode are the same, except that the signal switches control room ventilation to an isolation mode, preventing outside air from entering the control room.

SAN ON0FRE-UNIT 2 B 3/4.7-4

4 PLAfiTSYSTEMS BASES 3/4.7.5 CONTROL ROCH EMERGENCY AIR CLEANUP SYSTEM (continued) i The control room supply and the outside air supply of the normal control room HVAC is monitored by radiation and toxic-gas detectors respectively.

One detector output above the setpoint will cause actuation of the emergency mode or isolaticn mode as required. The actions of the toxic gas isolation mode are more restrictive, and will override the actions of the emergency radiaticn mode. However, toxic gas and radiation events are not considered to occur concurrently.

A single train will pressurize the control room to at least 0.125 inches

- water gauge, and provides an air exchange rate in excess of 45% per hour.

Redundant recirculation trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally open isolation dampers are arranged in series pairs so that the failure.cf one damper to shut will not result in a breach of isolation. The CREACUS is designed in accordance with Seismic Category 1 requirements.

t The CREACUS is designed to maintain the control room environment. for 30 days of continuous occupancy after a Design Basis Accident (CSA) without

' exceeding a 5 rem ahole body dose.

6l b Cantade$ive oferab'en f kke JfC&

2 Aows over a 3/ dg pen'or 4 mf/<h<kd 4 M*

.4re du<Wep of mi s6,e on 4fa adsorfees e*<a'

//gPA (<WerS. 2dours ,4:ee fr**s is fated o>r

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SAN ON0FRE-UNIT 2 3 3/4.7-4a j .,....._

NPF-10/15-407 ATTACHMENT "D" PROPOSED SPECIFICATIONS UNIT 3 1

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PLANT SYSTEMS 3/4.7.5 CONTROL ROOM EMERGENCY AIR CLEANUP SYSTEMo LIMITING CONDITION FOR OPERATION 3.7.5 Two independent control room emergency air cleanup systems shall be OPERABLE.

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

AC &d &YfM & gg '

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Unit 2 or 3 in MODES 1, 2, 3 or 4: '

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With one control room emergency air cleanup system ino)erable, restore the inoperable system to OPERABLE status within 7 days or ae in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Units 2 or 3 in MODES 5 or 6; or defueled when moving irradiated fuel assemblies.

a. With one control room emergency air cleanup system inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control room emergency air cleanup system in the recirculation mode.

b. With both control room emergency air cleanup systems inoperable, or with the OPERABLE control room emergency air cleanup system required to be in the recirculation mode by ACTION (a), not capable of being powered by an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes, or movement of irradiated fuel assemblies.

t

c. The provisions of Specification 3.0.3 are not applicable in MODE 6.

d. The provisions of Specification 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

SURVEILLANCE REQUIREMENTS 4.7.5 Each control room emergency air cleanup system shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control room air temperature is less than or equal to 110*F.

b. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 51 2 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months (yntn tne neaters om 7 %

c. At least once per 18 months or (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 communicapingwiththesystemby: _g,

1. Verifying that with the system operating at a flow rate of 35485 cfm i 10% for the air conditioning unit, and 2050 150 cfm for the ventilation unit and recirculating through the respective HEPA filters and charcoal adsorbers, leakage through the system j diverting valves is less than or equal to 1% air conditioning '

unit and 1% ventilation unit when the system is tested by admitting cold D0P at the respective intake j L

.* Shared system with San Onofre - Unit 2.

SAN ON0FRE-UNIT 3 3/4 7-14 AMENDMENT N0. 3,112 l

l l

PLANT SYSTEM 5 1

j 5URVEILkANCE REQUIREMENTS (Continued)

2. Verifying that the cleanup system satisfies the in place j testing acceptance. criteria and uses the test procedures of Regulatory Positions C.S.a. C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is '

, 2050 1 150 cfm for the ventilation unit and g efm 210% \Q f

for the air conditioning unit. 74g

3. Verifying within 31 days after removal that a laboratory i analysis of a representative carbon sample ibtained in accordance with Regulatory Position C.6.b of Regulatory i Guide 1.52. Revision 2, March 1978, meets the laboratory

. testing criteria of Regulatory Position C.6.a of Regulatory j

4.

Guide 1.52, Revision 2; March g 9

Verifying a system flow d o1 1050 2 150 cfm for the l

! ventilation unit an 4 cfm i 10% for the air conditioning Nl j unit during system oper on when tested in accordance with I ANSI N510-1975. l

]

i d. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation by verifying l within 31 days after removal that a laboratory analysis of a

representative carbon sample obtained in accordance with Regulatory j Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, -

meets the laboratory testing criteria of Regulatory Position C.6.a

. i of Regulatory Guide 1.52, Revision 2, March 1978.

l l e. At least once per 18 months by:

l 1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 7.0 inches i Water Gauge ventilation unit and less than 7.3 inches Water l Gauge air conditioning unit ~while operating'the system at a 3595 flow rate of 2050 t 150 cfm for the ventilation unit and lg l

8 s,4sgefs

105 for the air conditioning unit.

l ~2 . . Verifying that on a control room isolation test signal, the j system automatically switches irito the emergency mode of i operation with flow through the HEPA filters and charcoal i adsorber banks.

! 3. Verifying that on a toxic gas isolation test signal, the system i automatically switches into the isolation mode of operation l with flow through the HEPA filters and charcoal adsorber banks.

l 4. Verifying that the system maintains the control room at a j positive pressure of greater than or equal to 1/8 inch W.C.

! relative to the outside atmosphere during system operation in the eneroenev mode.

5. Verifying that the heaters dissipate 4.8 kw 5% when teste !

accordance with ANSI N510-1975 - 4 W

i l Y >

Jeleded] mais m j SAN ON0FRE-UNIT.3 3/4 7-15 AMENDMENT NO. 3 j __.

PLANT SYSTE!!S

'~x SURVEIILANCE REQUIREMENTS (Continued'.

l f. After each complete or partial replacement of a HEPA filter bank by

verifying that the HEPA filter banks remove greater than or equal to j

99.95% of the 00P when they are tested in piace in accordance with ANSI N510-1975 while operating the system a'; a low rate of 2050 t 150 cfm for the ventilation unit and ,48 cfm i 10% for the lq air conditioning unit. pp

g. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of'a halogenated h drocarbon refrigerant test gas when they are tested in. place in accordance with ANSI N510-1975 while operating the system at a flow rate of 2050 t 150 cfm for the lg ventilation unit andLJs,4s:gefm i 10% for the air conditioning unit.

f 35;70f J

SAN ONOFRE-UNIT 3 3/4 7-16 AMENOMENT NO. 3

I l

r PLANT SYSTEMS BASES 3/4.7.5 CONTROL ROOM EMERGENCY AIR CLEANUP SYSTEM The CREACUS provides a protected environment from which operators can control the plant following an uncontrolled release of radioactivity, or toxic gas.

The CREACUS consists of two independent, redundant trains that recirculate Each train consists of a prefilter, a and filter the control room air. filter, an activated charcoal high efficiency particulate air (HEPA)adsorber section for removal a fan. A second bank of HEPA filter follows the adsorber section (for emergency air conditioning unit only) and is used to retain carbon fines downstream of carbon adsorber. Each emergency ventilation air supply unit Ductwork, includes prefilter, HEPA filter, charcoal adsorber, and fan.

motor-operated dampers, and instrumentation also form part of the system.

Air and motor-operated dampers are provided for air volume control and system isolation purposes.

Upon receipt of the actuating signal, nonnal air supply to the control room is isolated, and the stream ofThe ventilation air is recirculated prefilters remove any large through the system's filter trains. ;

particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operat4cn of each train for at least 15 minutes per month verifies proper system operation.

There are two CREACUS operational modes. Emergency mode is an operational mode when the control room is isolated to prevent operation personnel from ,

the radioactive exposure through the duration of any one of the postulated limiting faults discussed in FSAR, Chapter 15, .

Isolation mode is an operational mode when control room is isolated to protect operation personnel from toxic gases and smoke.

Actuation of the CREACUS places the system into either of two separate states of the operation, depending on the initiation signal. Actuation of the system to the emergency mode of operation closes the unfiltered-outside-air intake and exhaust dampers and aligns the system for recirculation of control room air through the redundant trains of HEPA and charcoal filters. The emergency mode initiates pressurization of the control room. Outside air is added to the air being recirculated from the l control room, Pressurization of the control room prevents infiltration of infiltered air from the surrounding areas of the building.

The actions taken in the toxic gas isolation mode are the same, except that the signal switches control room ventilation to an isolation mode, preventing outside air from entering the control room.

4 SAN ON0FRE-UNIT 3 B 3/4.7-4

7 PLANT SYSTEMS 4

BASES )

3/4.7.S CONTROL ROOM EMERGENCY h al control AIR The control room supply and the outside air supply of t e norm room HVAC is monitored by radiation and cause actuation of the toxic-gas One detector output above the setpoint will The actions of the toxic emergency mode or isolation mode as required. d the actions of gas isolation mode are more restrictive, diation andevents areoverri e will.

the emergency radiation mode. However, toxic gas and ra not considered to occur concurrently.

least 0.125 inches A single train will pressurize the control room to atin excess of water gauge, and provides an air exchange rate tion should an Redundant recirculation trains provide thetrain. Normally required filtra excessive pressure drop develop across the h t the failure other of filter i The CREACUS open isolation dampers are arranged inl series pairs so t a one damper to shut will not result int a for 30 breach The CREACUS is designed to maintain the control ) without room days of continuous occupancy after a Design Basis exceeding a 5 rem whole body dose.

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d

- . . ~ . . . . . ... - . . - . . . - - .-. . . . . . . . . .

NPF-10/15-407 ATTACHMENT "E" Proposed Under Technical Specifications Improvement Program (TSIP) Specifications (not changed per PCN-407) s UNIT 2 4

4 1

4 j

a.

1

CREACUS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

LCO 3.7.11 Two CREACUS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

ACTIONS --------------------------NOTE-------- ---------------------

The provisions of LC0 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

CONDITION REQUIRED ACTION COMPLETION TIME A. One CREACUS train A.1 Restore CREACUS train 7 days inoperable. to OPERABLE status.

9 B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion -

Time of Condition A AND not met in MODE 1, 2, 3, or 4. B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. Required Action and C.1 Place OPERABLE Immediately associated Completion CREACUS train in Time of Condition A emergency radiation not met in MODES 5 protection mode.

or 6, or during movement of irradiated OR fuel assemblies.

(continued)

SAN ON0FRE--UNIT 2 3.7-24 Amendment No. 11/03/95

CREACUS 3.7.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 4

C. (continued) C.2.1 Suspend CORE Immediately 4 ALTERATIONS,

)

AND C.2.2 Suspend movement of Immediately 3

irradiated fuel

assemblies.

1 D. Two CREACUS trains D.1 Enter LC0 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4.

j 3

E. Two CREACUS trains E.1 Suspend CORE Immediately

inoperable in MODES 5 ALTERATIONS.

or 6, or during movement of irradiated AND fuel assemblies. '

E.2 Suspend movement of Immediately irradiated' fuel

, assemblies.

}

j SURVEILLANCE REQUIREMENTS i

SURVEILLANCE FREQUENCY SR 3.7.11.1 Operate each CREACUS train for a 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months 31 days with the heaters on.

SR 3.7.11.2 Perform required CREACUS filter testing in In accordance accordance with Ventilation Filter Testing with the VFTP Program (VFTP).

(continued)

SAN ON0FRE--UNIT 2 3.7-25 Amendment No. 11/03/95 1

1 CREACUS 3.7.11 SURVEILLANCE REQUIREMENTS (continued)-

SURVEILLANCE FREQUENCY SR 3.7.11.3 Verify that with the system operating at a 18 months or flow rate of 35485 cfm 10% for the air (1) after any conditioning unit, and 2050 150 cfm for structural the ventilation unit and recirculating maintenance on through the respective HEPA filters and the HEPA filter charcoal adsorbers, leakage through the or charcoal system diverting valves is less than or adsorber equal to 1% air conditioning unit and 1% housings, or ventilation unit when the system is tested (2) following by admitting cold D0P at the respective painting, fire intake. or chemical release in any ventilation zone communicating with the system SR 3.7.11.4 Verify that the heaters dissipate 4.8 kw 18 months 1 5% when tested in accordance with ANSI -

N510-1975.

SR 3.7.11.5 Verify each CREACUS train actuates on an 24 months actual or simulated actuation signal.

SR 3.7.11.6 Verify each CREACUS train can maintain a 24 months positive pressure of a 0.125 inches water gauge, relative to the atmosphere during the emergency radiation state of the emergency mode of operation.

l SAN ON0FRE--UNIT 2 3.7-26 Amendment No. 11/03/95

j CREACUS ;

B 3.7.11 i B 3.7 PLANT SYSTEMS

~

B 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

BASES BACKGROUND The CREACUS provides a protected environment from which i operators can control the plant following an uncontrolled l release of radioactivity. l The CREACUS consists of two independent, redundant trains that recirculate and filter the control room air. Each CREACUS train consists of emergency air conditioning unit, emergency ventilation air supply unit, emergency isolation dampers, and cooling coils and two cabinet coolers per Unit.

Each emergency air conditioning unit includes a prefilter, a high efficiency particulate air (HEPA) filter, an activated carbon adsorber section for removal of gaseous activity .

(principally iodine), and a fan. A second bank of HEPA filters follows the adsorber section to collect carbon fines. Each emergency ventilation air supply unit includes prefilter, HEPA filter, carbon adsorber and fan. Ductwork, motor-operated dampers, and instrumentation also form part of the system. Air and motor-operated dampers are provided for air volume control and system isolation purposes.

Upon receipt of the actuating signal, normal air supply to the control room is isolated, and the stream of ventilation air is recirculated through the system's filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 15 minutes per month verifies proper system operability.

There are two CREACUS operational modes. Emergency mode is an operational mode when the control room is isolated to protect operational personnel from radioactive exposure through the duration of any one of the postulated limiting faults discussed in Chapter 15 UFSAR (Ref. 2). Isolation mode is an operational mode when the control room is isolated to protect operational personnel from toxic gasses and smoke.

Actuation of the CREACUS places the system into either of two separate states of operation, depending on the initiation signal. Actuation of the system to the emergency mode of operation closes the unfiltered-outside-air intake (continued)

SAN ONOFRE--UNIT 2 B 3.7-56 Amendment No. 11/03/95 l l

CREACUS B 3.7.11 BASES BACKGROUND and unfiltered exhaust dampers, and aligns the system for (continued) recirculation of control room air through the redundant trains of HEPA and charcoal filters. The emergency mode initiates pressurizat. ion of the control room. !

Outside air is added to the air being recirculated from the control room. Pressurization of the control room prevents infiltration of unfiltered air from the surrounding areas of the building.

The control room supply and the outside air supply of the normal control room HVAC are monitored by radiation and toxic-gas detectors respectively. One detector output above the setpoint will cause actuation of the emergency mode or l isolation mode as required. The actions of the isolation !

mode are more restrictive, and will override the actions of l the emergency mode of operation. However, toxic gas and I radiation events are not considered to occur concurrently.

A single train will pressurize the control room to at least 0.125 inches water gauge, and provides an air exchange rate in excess of 45% per hour. The CREACUS operation in maintaining the control room habitable is discussed in l

,. Reference 1.

Redundant recirculation trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally-open isolation dampers are arranged in series pairs so that one damper's failure to shut will not r'esult in a breach of isolation. The CREACUS i is designed in accordance with Seismic Category I requirements.

The CREACUS is designed to maintain the control room environment for 30 days of continuous occupancy after a ,

Design Basis Accident (DBA) without exceeding a 5-rem ;

whole-body dose. j APPLICABLE The CREACUS components are arranged in redundant safety i SAFETY ANALYSES related ventilation trains. The location of components and 1 ducting within the control room envelope ensures an adequate supply of filtered air to all areas requiring access. j l

i I

(continued) I SAN ON0FRE--UNIT 2 B 3.7-57 Amendment No. 11/03/95

~

l CREACUS B 3.7.11 BASES APPLICABLE The CREACUS provides airborne radiological protection for {

SAFETY ANALYSES the control room operators, as demonstrated by the control (continued) room accident dose analyses for the most limiting design basis loss of coolant accident fission product release presented in the UFSAR, Chapter 15 (Ref. 2).

1 The analysis of toxic gas releases demonstrates that the l toxicity limits are not exceeded in the control room '

following a toxic chemical release, as presented in Reference 1.

The worst case single active failure of a component of the CREACUS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

' The CREACUS satisfies Criterion 3 of the NRC Policy Statement.

LCO Two independent and redundant trains of the CREACUS are required to be OPERABLE to ensure that at least one is available, assuming that a single failure disables the other train. Total system failure could result in a control room operator receiving a dose in excess of 5 rem in the event of a large radioactive release.,

The CREACUS is considered OPERABLE when the individual 4

components necessary to control operator exposure are OPERABLE in both trains. A CREACUS train is considered OPERABLE when the associated:

a. Fan is OPERABLE;

b. 'M PA filters and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functions; and

c. Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In addition, the control room boundary must be maintained, or administratively controlled, including the integrity of the walls, floors, ceilings, ductwork, and access doors.

(continued)

SAN ON0FRE--UNIT 2 B 3.7-58 Amendment No. 11/03/95

l CREACUS B 3.7.11 BASES APPLICABILITY In MODES 1, 2, 3, and 4, the CREACUS must be OPERABLE to limit operator exposure during and following a DBA.

In MODES 5 and 6, the CREACUS is required to cope with the release from a rupture of a waste gas tank.

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

ACTIONS ACTION statements are modified by NOTE "The provisions of LCO 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration." Therefore, since CREACUS can be inoperable during each individual MODE, it should not be required to have two OPERABLE CREACUS trains before MODE change from defueled from MODE 6 to defueled configuration, and from MODE 4 to MODE 5.

Specification 3.0.4 establishes that entry into an operational mode or other specified condition shall not be made unless the conditions of the LC0 are met.

Applicability statement "During movement of irradiated fuel assemblies" ensures the OPERABILITY of both CREACUS trains prior to the start of movement of irradiated fuel ,

assemblies. l Ad l

With one CREACUS train inoperable, action must be taken to I restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREACUS subsystem is adequate to perform control room radiation protection function.

However, the overall reliability is reduced because a single failure in the OPERABLE CREACUS train could result in loss of CREACUS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and the ability of the remaining train to provide the required capability.

l 1

l SAN ON0FRE--UNIT 2 I B 3.7-59 Amendment No. 11/03/95 !

4 CREACUS B 3.7.11 BASES l 5

ACTIONS B.1 and B.2 (continued) i If the inoperable CREACUS cannot be restored.to OPERABLE status within the re' quired Completion Time in MODE 1, 2, 3, ,

or 4, the unit must be placed in a MODE that minimizes the l accident risk. To achieve this status, the unit must be l 1

placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 )

i within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the <

required unit conditions from full power conditions in an

! orderly manner and without challenging unit systems.

i i

J C.l. C.2.1. and C.2.2 i

In MODE 5 or 6, or during movement of irradiated fuel

! assemblies,'if Required Action A.1 cannot be completed i

within the required Completion Time, the OPERABLE CREACUS

train must be immediately placed in the emergency mode of operation. This action ensures that the remaining train is l OPERABLE, that no failures preventing automatic actuation i will occur, and that any active failure will be readily l detected.

l An alternative to Required Action C.1 is to immediately ;

suspend activities that could result in a release of

! radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies to a safe position.

j D_.d '

i

! If both CREACUS trains are inoperable in MODE 1, 2, 3, or 4, i the CREACUS may not be capable of performing the intended 4

function and the unit'is in a condition outside the accident i l analyses. Therefore, LC0 3.0.3 must be entered immediately.

E.1 and E.2 i

When in MODES 5 or 6, or during movement of irradiated fuel 1 assemblies with two trains inoperable, action must be taken ,

immediately to suspend activities that could result in a '

release of radioactivity that might enter the control room.

SAN ON0FRE--UNIT 2 B 3.7-60 Amendment No. 11/03/95

'CREACUS B 3.7.11 S

BASES 1

ACTIONS This places the unit in a condition that minimizes the (continued) accident risk. This does not preclude the movement of fuel to a safe position.

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and ,

normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system.

Systems with heaters must be operated for a 10 continuous l hours with the heaters energized. This is sufficient to ,

J. reduce the buildup of mositure on the adsorbers and HEPA j filters. The 31 day Frequency is based on the known 3 reliability of the equipment, and the two train redundancy available.

4 SR 3.7.11.2 l

This SR verifies that the required CREACUS testing is

performed in accordance with the Ventilation Filter Testing i

Program (VFTP). The CREACUS' filter tests are based on i

Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing l HEPA filter performance,' charcoal adsorber efficiency, 4 minimum system-flow rate, and the physical properties of the

activated charcoal (general use and following specific j

operations). Specific test frequencies and additional j information are discussed in detail in the VFTP.

1 1

i SR 3.7.11.3

)

This SR verifies that with the system operating at a flow rate of 35485 cfm 110% for the air conditioning unit, and i 2050 1150 cfm for the ventilation unit and recirculating

through the respective HEPA filters and charcoal adsorbers, leakage through the system diverting valves is i less than or equal to 1% air conditioning unit and 1%

~

ventilation unit when the system is tested by admitting cold DOP at the respective intake. The frequency of this 4

(continued)

SAN ONOFRE--UNIT 2 8 3.7-61 Amendment No. 11/03/95 4

i CREACUS B 3.7.11 4

BASES

, . SURVEILLANCE SR 3.7.11.3 (continued)

REQUIREMENTS (continued) SR is 18 month or (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.

) ;

SR 3.7.11.4 '

i This SR verifies that the heaters dissipate 4.8 kw 5% when tested in accordance with ANSI N510-1975. The frequency of i

this SR is 18 months.

4 j- SR 3.7.11.5 This SR verifies each CREACUS train starts and operates on

an actual or simulated actuation signal. The Frequency of l 24 months is consistent with that.specified in Reference 3. :

l SR 3.7.11.6 0

This SR verifies the integrity of the control room enclosure and the assumed inleakage rates of potentially contaminated i air. The control room positive pressure, with respect to i

potentially contaminated atmosphere, is periodically tested to verify proper function of the CREACUS. During the i emergency radiation state of the emergency mode of i

operation, the CREACUS is designed to pressurize the control i

i room = 0.125 inches water gauge positive pressure with respect to the atmosphere in order to prevent unfiltered inleakage. The CREACUS is designed to maintain this

, positive pressure with one train.

i j REFERENCES 1. UFSAR, Section 9.4.

i 2. UFSAR, Chapter 15.

) 3. Regulatory Guide 1.52 (Rev. 2).

i i

SAN ON0FRE--UNIT 2 B 3.7-62 Amendment No. 11/03/95 n-____________

NPF-10/15-407 ATTACHMENT "F" Proposed Under Technical Specifications Improvement Program (TSIP) Specifications (notchangedperPCN-407)

UNIT 3 i l

I

CREACUS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

LC0 3.7.11 Two CREACUS trains shall be OPERA 3LE.

1 APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

ACTIONS --------------------------NOTE------------------------------

The provisions of LCO 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

CONDITION REQUIRED ACTION COMPLETION TIME A. One CREACUS train A.1 Restore CREACUS train 7 days inoperable. to OPERABLE status.

~

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A AND not met in MODE 1, 2, 3, or 4. B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 1

C. Required Action and C.1 Place OPERABLE Immediately {

associated Completion CREACUS train in Time of Condition A emergency radiation l not met in MODES 5 protection mode.

3 or 6, or during movement of irradiated OB fuel assemblies.

4 (continued) d l

SAN ON0FRE--UNIT 3 3.7-24 Amendment No. 11/03/95

CREACUS !

3.7.11 l l

ACTIONS CONDITION REQUIRED ACTION. COMPLETION TIME C. (continued) C.2.1 Suspend CORE Immediately ALTERATIONS.

E C.2.2 Suspend movement of Immediately :

irradiated fuel assemblies.

D. Two CREACUS trains D.1 Enter LC0 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4. l 1

E. Two CREACUS trains E.1 Suspend CORE Immediately i inoperable in MODES 5 ALTERATIONS.

or 6, or during '

movement of irradiated M l fuel assemblies. o- l E.2 Suspend movement of Immediately irradiated fuel assemblies.

1 1

SURVEILLANCE REQUIREMENTS .

SURVEILLANCE FREQUENCY SR 3.7.11.1 Operate each CREACUS train for 2: 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months 31 days with the heaters on.

l l

SR 3.7.11.2 Perform required CREACUS filter testing in In accordance accordance with Ventilation Filter Testing with the VFTP Program (VFTP).

(continued)

SAN ON0FRE--UNIT 3 3.7-25 Amendment No. 11/03/95

i CREACUS t

3.7.11 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.11.3 Verify that with the system operating at a 18 months or flow rate of 35485 cfm 110% for the air (1) after any conditioning unit, and 2050 1150 cfm for structural

the ventilation unit and recirculating maintenance on

! through the respective HEPA filters and the HEPA filter charcoal adsorbers, leakage through the or charcoal

~j system diverting valves is less than or adsorber equal to 1% air conditioning unit and 1% housings, or ventilation unit when the system is tested (2) following

! by admitting cold DOP at the respective painting, fire

intake. or chemical 4

e release in any ventilation.

zone communicating with the system i

i SR 3.7.11.4 Verify that the heaters dissipate 4.8 kw 18 months i'

5% when tested in accordance with ANSI N510-1975.

i .)

I SR 3.7.11.5 Verify each CREACUS train actuates on an 24 months !

actual or simulated actuation signal. 1 1

SR 3.7.11.6 Verify each CREACUS train can maintain a 24 months positive pressure of a 0.125 inches water gauge, relative to the atmosphere during

'the emergency radiation state of the emergency mode of operation.

i .

l f

4

? l 1

l SAN ONOFRE--UNIT 3 3.7-26 Amendment No. 11/03/95 l

l

I

~

+

1 CREACUS B 3.7.11 B 3.7 PLANT SYSTEMS B 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

BASES BACKGROUND The CREACUS provides a protected environment from which operators can control the plant following an uncontrolled release of radioactivity.

The CREACUS consists of two independent, redundant trains that recirculate and filter the control room air. Each CREACUS train consists of emergency air conditioning unit, emergency ventilation air supply unit, emergency isolation dampers, and cooling coils and two cabinet coolers per Unit.

Each emergency air conditioning unit includes a prefilter, a high efficiency particulate air carbon adsorber section for remov(HEPA) filter, an al of gaseous activated activity (principally iodine), and a fan. A second bank of HEPA filters follows the adsorber section to collect carbon fines. Each emergency ventilation air supply unit includes prefilter, HEPA filter, carbon adsorber and fan. Ductwork, motor-operated dampers, and instrumentation also form part of the system. Air and motor-operated dampers are provided for air volume control and system isolation purposes. ,

Upon receipt of the actuating signal, normal air supply to the control room is isolated, and the stream of ventilation air is recirculated through the system's filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 15 minutes per month verifies proper system operability.

There are two CREACUS operational modes. Emergency mode is an operational mode ~when the control room is isolated to protect operational personnel from radioactive exposure through the duration of.any one of the postulated limiting faults discussed in Chapter 15 UFSAR (Ref. 2). Isolation mode is an operational mode when the control room is isolated to protect operational personnel from toxic gasses and smoke.

Actuation of the CREACUS places the system into either of two separate states of operation, depending on the initiation signal. Actuation of the system to the emergency mode of operation closes the unfiltered-outside-air intake (continued) j SAN ON0FRE--UNIT 3 8 3.7-56 Amendment No. 11/03/95 V

CREACUS B 3.7.11 BASES BACKGROUND and unfiltered exhaust dampers, and aligns the system for (continued) recirculation of control room air through the redundant trains of HEPA and charcoal filters. The emergency mode initiates pressurization of the control room.

Outside air is added to the air being recirculated from' the control room. Pressurization of the control room prevents infiltration of unfiltered: air from the surrounding areas of the building.

The control room supply and the outside air supply of the normal control room HVAC are monitored by radiation and toxic-gas detectors respectively. One detector output above the setpoint will cause actuation of the emergency mode or isolation mode as required. The actions of the isolation mode are more restrictive, and will override the actions of the emergency mode of operation. However, toxic gas and radiation events are not considered to occur concurrently.

A single train will pressurize the control room to at least 0.125 inches water gauge, and provides an air exchange rate in excess of 45% per hour. The CREACUS operation in maintaining the control room habitable is discussed in

. Reference 1.

Redundant recirculation trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally-open isolation dampers are arranged in series pairs so that one damper's failure to shut will not result in a breach of isolation. The CREACUS is designed in accordance with Seismic Category I requirements.

The CREACUS is designed to maintain the control room environment for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5-rem whole-body dose.

APPLICABLE The CREACUS components are arranged in redundant safety SAFETY ANALYSES related ventilation trains. The location of components and i ducting within the control room envelope ensures an adequate !

supply of filtered air to all areas requiring access.

(continued)

SAN ON0FRE--UNIT 3 B 3.7-57 Amendment No. 11/03/95

_. .. _ _~ _ __ -

CREACUS B 3.7.11 BASES APPLICABLE The CREACUS provides airborne radiological protection for SAFETY ANALYSES the control room operators, as demonstrated by the control )

(continued) room accident dose analyses for the most limiting design l basis loss of coolant . accident fission product release :

presented in the UFSAR, Chapter 15 (Ref. 2).

1 The analysis of toxic gas releases demonstrates that the i toxicity limits are not exceeded in the control room following a toxic chemical release, as presented in Reference 1.

The worst case single active failure of a component of the ,

CREACUS, assuming a loss of offsite power, does not impair l the ability of the system to perform its design function. ;

The CREACUS satisfies Criterion 3 of the NRC Policy Statement.

LC0 Two independent and redundant trains of the CREACUS are required to be OPERABLE to ensure that at least one is available, assuming that a single failure disables the other _

train. Total system failure could result in a control room operator receiving a dose in excess of 5 rem in the event of a large radioactive release.

The CREACUS is considered OPERABLE when the individual components necessary to control operator exposure are OPERABLE in both trains. A CREACUS train is considered OPERABLE when the associated:

a. Fan is OPERABLE;

b. HEPA filters and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functions; and

c. Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In addition, the control room boundary must be maintained, or administrative 1y controlled, including the integrity of the walls, floors, ceilings, ductwork, and access doors.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-5B Amendment No. 11/03/95

CREACUS B 3.7.11 BASES APPLICABILITY In MODES 1, 2, 3, and 4, the CREACUS must be OPERABLE to limit operator exposure during and following a DBA.

In MODES 5 and 6, the.CREACUS is required to cope with the release from a rupture of a waste gas tank.

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

ACTIONS ACTION statements are modified by NOTE "The provisions of LC0 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration." Therefore, since CREACUS can be inoperable during each individual MODE, it should not be required to have two OPERABLE CREACUS trains before MODE change from defueled from MODE 6 to defueled configuration, and from MODE 4 to MODE 5.

Specification 3.0.4 establishes that entry into an operational mode or other specified condition shall not be made unless the conditions of the LCO are met.

Applicability statement "During movement of irradiated fuel assemblies" ensures the OPERABILITY of both CREACUS trains prior to the start of movement of irradiated fuel assemblies.

Ad With one CREACUS train inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREACUS subsystem is adequate to perform control room radiation protection function.

However, the overall reliability is reduced because a single failure in the OPERABLE.CREACUS train could result in loss of CREACUS function. The 7 day Completion Time is based on the low probability of a DBA occurring during this time period, and the ability of the remaining train to provide the required capability.

(continued)

SAN ON0FRE--UNIT 3 8 3.7-59 Amendment No. 11/03/95

CREACUS B 3.7.11 BASES ACTIONS B.1 and B.2

(continued)

If the inoperable CREACUS cannot be restored to OPERABLE status within the required Completion Time in MODE 1, 2, 3, or.4, the unit must be placed in a MODE that minimizes the 4

accident. risk. To achieve this status, the unit must be placed in at..least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an j orderly manner and without challenging unit systems.

i

C.1. C.2.1. and C.2.2 i

In MODE 5 or 6, or during movement of irradiated fuel i

assemblies, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CREACUS train must be immediately placed in the emergency mode of s operation. This action ensures that the remaining train is j OPERABLE, that no failures preventing automatic' actuation I

will occur, and that any active failure will be readily detected.

An alternative to Required Action C.1 is to immediately

suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places'the unit in a condition that minimizes i the accident risk. This does not preclude the movement of

] fuel assemblies to a safe position.

D.J If both CREACUS trains are inoperable in MODE 1, '2, 3, or 4, the CREACUS may not be capable of performing the intended 1

function and the unit is in a condition outside the accident analyses. Therefore, LC0 3.0.3 must be entered immediately.

{' E.1 and E.2 When in MODES 5 or 6, or during movement of irradiated fuel

assemblies with two trains inoperable, action must be taken i immediately to suspend activities that could result in a

release of radioactivity that might enter the control room.

1 (continued)

SAN ON0FRE--UNIT 3 B 3.7-60 Amendment No. 11/03/95 4

CREACUS I B 3.7.11 l i

BASES I ACTIONS This places the unit in a condition that minimizes the (continued) accident risk. This does not preclude the movement of fuel 4

to a safe position.

l 1

SURVEILLANCE SR 3.7.11.1 I j REQUIREMENTS l Standby systems should be checked periodically to ensure '

l that they function properly. Since the environment and ;

normal operating conditions on this system are not severe, l l testing each train once every month provides an adequate check on this system.

Systems with heaters must be operated for a 10 continuous l hours with the heaters energized. This is sufficient to i reduce the buildup of mositure on the adsorbers and HEPA filters. The 31 day Frequency is based on the known ,

reliability of the equipment, and the two train redundancy 1 available.

i i SR 3.7.11.2 l

. This SR verifies that the required CREACUS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREACUS filter tests are based on Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing l HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

)

3 SR 3.7.11.3 This SR verifies that with the system operating at a flow ,

i~

rate of 35485 cfm 110% for the air conditioning unit, and 2050 1150 cfm for the ventilation unit and recirculating through the respective HEPA filters and charcoal adsorbers, leakage through the system diverting valves is 4

less than or equal to 1% air conditioning unit and 1%

ventilation unit when the system is tested by admitting cold 00P at the respective intake. The frequency of this (continued)

SAN ON0FRE--UNIT 3 B 3.7-61 Amendment No. 11/03/95 4

)

l

CREACUS B 3.7.11 EASES SURVEILLANCE SR 3.7.11.3 (continued)

REQUIREMENTS (continued) SR is 18 month or (1) after any structural maintenance on the HEPA filter or cha_rcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system.

SR 3.7.11.4 This SR verifies that the heaters dissipate 4.8 kw

5% when tested in accordance with ANSI N510-1975. The frequency of this SR is 18 months.

SR 3.7.11.5 This SR verifies each CREACUS train starts and operates on an actual or simulated actuation signal. The Frequency of 24 months is consistent with that specified in Reference 3.

SR 3.7.11.6 '

4 This SR verifies the integrity of the control room enclosure l

and the assumed inleakage rates of potentially contaminated I air. The control room positive pressure, with respect to I potentially contaminated atmosphere, is periodically tested to verify proper function of the CREACUS. During the emergency radiation state of the emergency mode of l operation, the CREACUS is designed to pressurize the control room t 0.125 inches water gauge positive pressure with respect to the atmosphere in order to prevent unfiltered inleakage. The CREACUS is designed to maintain this positive pressure with one train.

REFERENCES 1. UFSAR, Section 9.4.

2. UFSAR, Chapter 15.

3. Regulatory Guide 1.52 (Rev. 2).

SAN ON0FRE--UNIT 3 B 3.7-62 Amendment No. 11/03/95 i

NPF-10/15-407

)

ATTACHMENT "G" Proposed Under Technical Specifications Improvement Program (TSIP) Specifications (changed per PCN-407)

UNIT 2 l

i l

l b

w -

CREACUS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

LCO 3.7.11 Two CREACUS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies.

l ACTIONS

NOTE 5-----------------------------

I. The provisions of LC0 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

2. g -

CONDITION REQUIRED ACTION COMPLETION TIME A. One CREACUS train A.1 Restore CREACUS train 7 days inoperable. to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion s Time of Condition A MQ not met in MODE 1, 2, 3, or 4. B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. Required Action and C.1 Place OPERABLE Immediately associated Completion CREACUS train in s

Time of Condition A emergency radiation

' not met in MODES 5 protection mode.

or 6, or during

.' movement of irradiated 08 fuel assemblies.

(continued)

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SAN ON0FRE--UNIT 2 3.7-24 Amendment No. 11/03/95

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CREACUS 3.7.11 l ACTIONS CONDITION REQUIRED ACTION. COMPLETION TIME C. (continued) C.2.1 Suspend CORE

- Immediately ALTERATIONS.

AND C.2.2 Suspend movement of Immediately irradiated fuel assemblies.

1 D. Two CREACUS trains D.1 Enter LC0 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4.

E. Two CREACUS trains E.1 Suspend CORE inoperable in MODES 5 Immediately ALTERATIONS.

or 6, or during _

movement of irradiated

' ANJ fuel assemblies. ,

..J' E.2 Suspend movement of Immediately l irradiated' fuel assemblies. <

l SURVEILLANCE REQUIREMENTS SURVEILLANCE '

FREQUENCY SR 3.7.11.1 ,_

0perate e,ach CREACUS train for a ours 31 days 7 . ., ... ,, m m o e .

SR 3.7.11.2 Perform required CREACUS filter testing in In accordance accordance with Ventilation Filter Testing with the VFTP Program (VFTP).

(continued)

SAN ON0FRE--UNIT 2 3.7-25 Amendment No. 11/03/95

CREACUS l 3.7.11 l I

l SURVEILLANCE REQUIREMENTS (continued) i

, 1 SURVEILLANCE '

FREQUENCY I w -

SR 3.7.11.3 Verify that with the system operating at a 18 months or i

flow rate of 35485 cfm 10% for the air (1) after any conditioning unit, and 2050 150 cfm for structural i the ventilation unit and recirculating maintenance on through the respective HEPA filters and the HEPA filter i

charcoal adsorbers, leakage through the or charcoal i

system diverting valves is less than or adsorber equal to 1% air conditioning unit and 1% housings, or ventilation unit when the system is tested (2) following i

4 ' by admitting cold D0P at the respective painting, fire intake. or chemical

)

release in any 3 ventilation j zone i communicating l N with the syst '

[ SR 3.7.11.4 Verify that the heaters dissipate 4.8 kw 18 months 1

5% when tested in accordance with ANSI

( N510-1975.

SR 3.7.11 erify each CREACUS train actuates on an 24 months actual or simulated actuation signal.

SR 3.7.11 erify each CREACUS train can maintain a 24 months positive pressure of 2: 0.125 inches water gauge, relative to the atmosphere during the emergency radiation state of the emergency mode of operation.

SAN ONOFRE--UNIT 2 3.7-26 Amendment No. 11/03/95

CREACUS B 3.7.11 l

B 3.7 PLANT SYSTEMS B 3.7.11 Control Room Emergency Air Cleanup System'(CREACUS)

BASES BACKGROUND The CREACUS provides a protected environment from which I operators can control the plant following an uncontrolled release of radioactivity.

The CREACUS consists of two independent, redundant trains that recirculate and filter the control room air. Each CREACUS train consists of emergency air conditioning unit, emergency ventilation air supply unit, emergency isolation 1 dampers, and cooling coils and two cabinet coolers per Unit. !

Each emergency air conditioning unit includes a prefilter, a high efficiency particulate air (HEPA) filter, an activated l carbon adsorber section for removal of gaseous activity l (principally iodine), and a fan. A second bank of HEPA l filters follows the adsorber section to collect carbon i fines. Each emergency ventilation air supply unit includes prefilter, HEPA filter, carbon adsorber and fan. Ductwork, l t

motor-operated dampers, and instrumentation also form part of the system. Air and motor-operated dampers are provided for air volume control and system isolation purposes.

Upon receipt of the actuating signal, normal air supply to the control room is isolated, and the stream of ventilation air is recirculated through the system's filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 15 minutes per month verifies proper system operability.

There are two CREACUS operational modes. Emergency mode is an operational mode when the control room is isolated to protect operational personnel from radioactive exposure through the duration of any one of the postulated limiting faults discussed in Chapter 15 UFSAR (Ref. 2). Isolation mode is an operational mode when the control room is isolated to protect operational personnel from toxic gasses and smoke.

Actuation of the CREACUS places the system into either of two separate states of operation, depending on the initiation signal. Actuation of the system to the emergency mode of operation closes the unfiltered.outside-air intake I

(continued)

SAN ON0FRE--UNIT 2 B 3.7-56 Amendment No. 11/03/95

.Aha

CREACUS I

l B 3.7.11

BASES BACKGROUND and unfiltered exhaust dampers, and aligns the system for (continued) recirculation of control room air through the redundant trains of HEPA and charcoal filters. The emergency mode initiates pressurizat. ion of the control room.

Outside air is added to'the air being recirculated from the control room. Pressurization of the control room prevents ,

infiltration of unfiltered air from the surrounding areas of i the building.

{

The control room supply and the outside air supply of. the normal control room HVAC are monitored by radiation and toxic-gas detectors respectively. One' detector output above the setpoint will cause actuation of the emergency mode or isolation mode as required. The actions of the isolation mode are more restrictive, and will override the actions of the emergency mode of operation. However, toxic gas and radiation events are not considered to occur concurrently.

A single train will pressurize the control room to at least 0.125 inches water gauge, and provides an air exchange rate in excess of 45% per hour. The CREACUS operation in maintaining the control room habitable is discussed in

. . Reference 1.

Reduadant recirculation trains provide the required filtration should an excessive pressure drop develop across the other filter train. Normally-open isolation dampers are arranged in series pairs so that one damper's failure to shut will not result in a breach of isolation. The CREACUS is designed in accordance with Seismic Category I requirements.

The CREACUS is designed to maintain the control room environment for 30 days of continuous occupancy after a D W m Basis Accident (DBA) without exceeding a 5-rem vm -body dose.

APPLICABLE The CREACUS components are arranged in redundant safety SAFETY ANALYSES related ventilation trains. The location of components and ducting within the control room envelope ensures an adequate .

supply of filtered air to all areas requiring access.

T (continued) l SAN ONOFRE--UNIT 2 B 3.7-57 Amendment No. 11/03/95 u .. .

r CREACUS B 3.7.11 BASES l

l APPLICABLE The CREACUS provides airborne radiological protection for SAFETY ANALYSES the control room operators, as demonstrated by the control .

(continued) room accident dose analyses for the most limiting design basis loss of coolant accident fission product release presented in the UFSAR, Chapter 15 (Ref. 2).

The analysis of toxic gas releases demonstrates that the toxicity limits are not exceeded in the control room

- following a toxic chemical release, as presented in Reference 1.

The worst case single active failure of a component of the CREACUS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

The CREACUS satisfies Criterion 3 of the NRC Policy 5tatement.

LCO Two independent and redundant trains of the CREACUS are required to be OPERABLE to ensure that at least one is available, assuming that a single failure disables the other train. Total system failure could result in a control room operator receiving a dose in excess of 5 rem in the event of a large radioactive release.,

The CREACUS is considered OPERABLE when the individual components necessary to control operator exposure are OPERABLE in both trains. A CREACUS train is considered OPERABLE when the associated:

a. Fan is OPERABLE;

b. HEPA filters and charcoal adsorber are not excessisely restricting flow, and are capable of perfcrming their filtration functions; and

c. Ductwork, valves, and dampers are OPERABLE, and air circulation can be maintained.

In addition, the control room boundary must be maintained, or administratively controlled, including the integrity of the walls, floors, ceilings, ductwork, and access doors.

(continued)

SAN ON0FRE--UNIT 2 B 3.7-58 Amendment No. I 11/03/95

,-% ~ m

l CREACUS B 3.7.11 l

BASES APPLICABILITY In MODES I, 2, 3, and 4, the CREACUS must be OPERABLE to limit operator exposure during and following a DBA.

In MODES 5 and 6, the CREACUS is required to cope with the release from a rupture of a waste gas tank.

I During movement of ;rradiated fuel assemblies, the CREACUS I must be OPERABLE to cope with the release from a fuel l handling accident.

l n e r / en ws .' \

ACTIONS ACTION statements are modified TFS provisions of LC0 3.0.4 are not hpplicable when entering MODES 5, 6, or defueled configuration." Therefore, since CREACUS can be inoperable during each individual MODE, it should not be required to have two OPERABLE CREACUS trains before MODE change from defueled from MODE 6 to defueled configuration, and from MODE 4 to MODE 5.

Specification 3.0.4 establishes that entry into an operational mode or other specified condition shall not be made unless the conditions of the LC0 are met.

Applicability statement "During movement of irradiated fuel assemblies" ensures the OPERABILITY of both CREACUS trains prior to the start of movement of irradiated fuel assemblies.

I With one CREACUS train inoperable, action must be taken to i

restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREACUS subsystem is adequate to perform control room radiation protection function.

i However, the overall reliability is reduced because a single failure in the OPERABLE CREACUS train could result in loss of CREACUS function. The 7 day Completion Time is based on i

the low probability of a DBA occurring during this time period, and the ability of the remaining train to provide the required capability.

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! SAN ON0FRE--UNI"2 = Ja./-59 Amendment No. 11/03/95

CREACUS B 3.7.11 BASES ACTIONS B.1 and B.2 (continued)

If the inoperable CREACUS cannot be restored to OPERABLE status within the re. quired Completion Time in MODE 1, 2, 3, or 4, the unit must be placed in a MODE that minimizes the accident risk. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

C.I. C.2.1. and C.2.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CREACUS train must be immediately placed in the emergency mode of operation. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure will be readily detected.

An alternative to Required Action C.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes

' the accident risk. This does not preclude the movement of fuel assemblies to a safe position.

If both CREACUS trains are inoperable in MODE 1, 2, 3, or 4 the CREACUS may not be capable of performing the intended function and the unit'is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

E.1 and E.2 When in MODES 5 or 6, or during movement of irradiated fuel assemblies with two trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the control room.

SAN ON0FRE--UNIT 2 B 3.7-60 Amendment No. 11/03/95

CREACUS B 3.7.11 BASES ACTIONS This places the unit in a condition that minimizes the (continued) accident risk. This does not preclude the movement of fuel to a safe position.

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS l

Standby systems should be checked periodically to ensure l that they function properly. Since the environment and i H

normal operating conditions on this system are not severe, i testing each train once every month provides an adequate 7MSN = {

check on this system.

1 l

stems with heaters must be operated for a 10 continuous i hours with the heaters energized. This is sufficient to I (reduce tha h"4'd"? ^# mnciture nn +': 2 rhare 'M :'5 .

l Lij.tarr J The 31 day Frequency is based on the known :

reliability of the equipment, and the two train redundancy available.

I SR 3.7.11.2 This SR verifies that the required CREACUS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREACUS711ter tests are based on Regulatory Guide 1.52 (Ref. 3). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system' flow rate, and the physical propertie: of the activated charcoal (general use and following specific operations). Specific test frequencies and additionai information are discussed in detail in the VFTP.

s SR 3.7.11.3 This SR verifies that with the system operating at a flo rate of 35485 cfm 210% for the air conditioning unit, and 2050 2150 cfm for the ventilation unit and recirculating through the respective HEPA filters and charcoal adsorbers, leakage through the system diverting valves is less than or equal to 1% air conditioning unit and 1%

ventilation unit when the system is tested by admitting cold DOP at the respective intake. The frequency of- this

, (continued)

SAN ONOFRE--UNIT 2 8 3.7-61 Amendment No. 11/03/95

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CREACUS B 3.7.11 BASES SURVEILLANCE f SR 3.7.11.3 (continued)l' REQUIREMENTS

{

(continued) SR is 18 month or (1) after any structural maintenance the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system.

SR 3.7.11.4 This SR verifies that the heaters dissipate 4.8 kw 5% when tested in accordance with ANSI N510-1975. The frequency of SR is 18 months. '

SR 3.7.11 3 This SR verifies each CREACUS train starts and operates on an actual or simulated actuation signal. The Frequency of 24 months is consistent with that specified in Reference 3.

SR 3.7.11 [

y; This SR verifies the integrity of the control room enclosure and the assumed inleakage rates of potentially contaminated air. The control room positive pressure, with respect to potentially contaminated atmosphere, is periodically tested to verify proper function of the CREACUS. During the emergency radiition state of the emergency mode of operation, the CREACUS is designed to pressurize the control room a 0.125 inches water gauge positive pressure with respect to the atmosphere in order to prevent unfiltered inleakage. The CREACUS is designed to maintain this positive pressure with one train.

REFERENCES 1. UFSAR, Section 9.4.

2. UFSAR, Chapter 15.

3. Regulatory Guide 1.52 (Rev. 2).

SAN ON0FRE--UNIT 2 B 3.7-62 Amendment No. 11/03/95

._.. ._ _ _ __ _ _ _ . . _ . _ _ _ _ . _ _ . _ _ _ _ . . .. ._ _ ~ . . . . . _ . . . . _ . .

1 3

0 m, l

NPF-10/15-407 1

1 i l i

l 1

ATTACHMENT "H" Proposed Under ' Technical Specifications Improvement Program

, (TSIP) Specifications (changed per PCN-407)

UNIT 3 i

4 i

i i

. 1 a

i -

4

CREACUS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

LC0 3.7.11 Two CREACUS trains shall be OPERABLE.

1 APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies. '

ACTIONS

NOTES-----------------------------

1. The provisions of LC0 3.0.4 are not applicable when entering

_HODES 5, 6, or defueled configuration.

CONDITION REQUIRED ACTION . COMPLETION TIME l l

A. One CREACUS train A.1 Restore CREACUS train 7 days inoperable. to OPERABLE status. '

B. Required Action and B.1 Be in MODE 3.

associated Completion 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Time of Condition A MQ not met in MODE 1, 2, 3, or 4. B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months C. Required Action and C.1 Place OPERABLE Immediately 4 associated Completion CREACUS train in -

Time of Condition A emergency radiation

{ not met in MODES 5 prot.ection mode.

or 6, or during '

movement of irradiated E fuel assemblies.

(continued) sd 2. $ach (fm) $h00 * "f Yl #

ACT4Ws sepamkly SAN ON0FRE--UNIT 3 3.7-24 Amendment No. 11/03/95 i

CREACUS l 3.7.11 !

ACTIO!IS CONDIT10ll REQUIRED ACTION : COMPLETION TIME C. (continued) C.2.1 Suspend CORE Immediately ALTERATIONS.

l M

C.2.2 Suspend movement of Immediately irradiated fuel assemblies.

D. Two CREACUS trains 0.1 inoperable in MODE 1, Enter LC0 3.0.3. Immediately 2, 3, or 4. -

E. Two CREACUS trains E.1 Suspend CORE Immediately inoperable in MODES 5 ALTERATIONS.

or 6, or during movement of irradiated M fuel assemblies.

E.2 Suspend movement of Immediately irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS

SURVEILLANCE '.

FREQUENCY 2Amh SR 3.7.11.1 Operate each CREACUS train for 31 daysahr')[

@_iin tne uudeT*i3pt. !

y < --

J' '

SR 3.7.11.2 Perform required CREACUS filter testing in i In accordance accordance with Ventilation Filter Testing with the VFTP l Program (VFTP).

i (continued) I l

SAN ONOFRE--UNIT 3 3.7-25 Amendment No. 11/03/95

.E . &

, CREACUS

3.7.11 SURVEILLANCE REQUIREMENTS (continued) '

SURVEILLANCE FREQUENCY SR 3.7.11.3 Verify that with the system operating at a 18 months or flow rate of 35485 cfm 110% for the air (1)afterany conditioning unit, and 2050 1150 cfm for structural the ventilation unit and recirculating maintenance on through the respective HEPA filters and the HEPA filter charcoal adsorbers, leakage through the or charcoal system diverting valves is less than or adsorber equal to 1% air conditioning unit and 1% housings, or i

ventilation unit when the system is tested (2) following i

by admitting cold DOP at the respective painting, fire intake. ;

or chemical release in any ventilation. I zone communicating

__with the system o

/ SR 3.7.11.4 Verify that the heaters dissipate 4.8 kw 18 months t 5% when tested in accordance with ANSI

_ N510-1975.

SR 3.7.11.[VerifyeachCREACUStrainactuatesonan 24 months actual or simulated actuation signal. ;

SR 3.7.11 Verify each CREACUS train can maintain a 24 months posi'tive pressure of a 0.125 inches water gauge, relative to the atmosphere during

'the emergency radiation state of the ,

emergency mode of operation.

i a::::= ' ' ' '

SAN ONOFRE--UNIT 3 3.7-26 Amendment No. 11/03/95

,.e,

CREACUS B 3.7.11

~

B 3.7 PLANT SYSTEMS '

i B 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

BASES i BACKGROUND The CREACUS provides a protected environment from which I i

operators can control the plant following an uncontrolled release of radioactivity.

The CREACUS consists of two independent, redundant trains that recirculate and filter the control room air. .Each

. CREACUS train consists of emergency air conditioning unit, i

emergency ventilation air supply unit, emergency isolation dampers, and cooling coils and two cabinet coolers per Unit.

Each emergency air conditioning unit includes a prefilter, a.

high efficiency particulate air i carbon adsorber section for remov(HEPA) filter, an al of gaseous activated activity (principally iodine), and a fan. A second bank of HEPA fines. follows filters the adsorber section to collect carbon Each emergency ventilation air supply unit includes

prefilter, HEPA filter carbon adsorber and fan. Ductwork,

i. motor-operated dampers,, and instrumentation also form part -

of the system. Air and motor-operated dampers are provided for air volume control and system isolation purposes.

i U)on receipt of the actuating signal, normal air supply to

' tie control room is isolated,'and the stream of ventilation air is recirculated through the system's filter trains. The 4

prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 15 minutes per month verifies proper system operability.

~ There are two CREACUS operational modes. Emergency mode is an operational mode'when the control room is isolated to i

protect operational personnel from radioactive exposure i through the duration of,any one of the postulated limiting .

faults discussed in Chapter 15 UFSAR Ref. 2). Isolation i

mode is an operational mode when the c(ontrol room is isolated to protect operational personnel from toxic gasses and smoke.

'AcTu'ation of the CREACUS places the system into either of e[ two separate states of operation, depending on the initiation signal. Actuation of the system to the emergency I

mode of operation closes the unfiltered-outside-air intake (continued) j_ SAN ONOFRE--UNIT 3 8 3.7-56 Amendment No. 11/03/95 5-

. -. -_ _ -__ _ a

CREACUS B 3.7.11 BASES BACKGROUND and unfiltered exhaust dampers, and aligns the system for -

(continued) recirculation of control room air through the redundant trains of HEPA and charcoal filters. The emergency mode initiates pressurizatipn of the control room.

Outside air is added to the air being recirculated from the control room. Pressurization of the control room prevents infiltration of unfiltered air from the surrounding areas of the building.

The control room supply and the outside air supply of the normal control room HVAC are monitored by radiation and toxic-gas detectors respectively. One detector output above the setpoint will cause actuation of the emergency mode or isolation mode as required. The actions of the isolation mode are more restrictive, and will override the actions of the emergency mode of operation. However, toxic gas and radiation events are not considered to occur concurrently.

A single train will pressurize the control room to at least 0.125 inches water gauge, and provides an air exchange rate

- in excess of 45% per hour. The CREACUS operation in j

maintaining the control room habitable is discussed in Reference 1.

Redundant recirculation trains, provide the required filtration should an excessive pressure drop develop across the other filter train. Normally-open isolation dampers are arranged in series pairs so that one damper's failure to shut will not risult in a breach of isolation. The CREACUS is designed in accordance with Seismic Category I requirements.

The CREACUS is designed to maintain the control room 1 environment for 30 days of continuous occupancy. after a Design Basis Accident (DBA) without exceeding a 5-rem whole-body dose. -

l APPLICABLE The CREACUS components are arranged in redundant safety l l

SAFETY ANALYSES , re).ated ventilation trains. The location of components and e'y " ducting within the control room envelope ensures an adequate supply of filtered air to all areas requiring access.

(continued)

SAN ON0FRE--UNIT 3 8 3.7-57 Amendment No. 11/03/95 {

s

.========

_ . . . _ _ - _ _ _ _ _ _ _ ~ . _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ - _ _ - _ - _ _ _ - _ - _ _ _ _

- - - . _~ - - . - - - - . - -. - _..- - . - _ - - _ - . - - -

CREACUS

?

B 3.7.11 BASES 4

APPLICABLE t

The CREACUS provides airborne radiological protection for -

SAFETY ANALYSES the control room operators, as demonstrated by the control (continued) room accident dose analyses for the most limiting design basis loss of coolant: accident fission product release presented in the UFSAR, Chapter 15 (Ref. 2).

i The analysis of toxic gas releases demonstrates that the toxicity limits are not exceeded in the control room following a toxic chemical release, as presented in j Reference 1.

i The worst case single active failure of a component of the CREACUS, assuming a loss of offsite power, does not impair

' the ability of the system to perform its design function.

The CREACUS satisfies Criterion 3 of the NRC Policy Statement.

t LC0 Two independent and redundant trains of the CREACUS are i

required to be OPERABLE to ensure that at least one is available, assuming that a single failure disables the other train. Total system failure could result in a control room .

operator receiving a dose in excess of 5 rem in the event of -

i a large radioactive release.

j

The CREACUS is considered OPERABLE when the individual f components necessary to control operator exposure are

OPERABLE in both trains. A CREACUS train is considered 1 OPERABLE when the associated

a. Fan is OPERABLE; i b.

i HEPA filters arid charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functions; and

c. Ductwork, valves, and dampers are OPERABLE, and air

. circulation can be maintained.

In d =="or'pddition, the control room boundary must be main w j

] the walls, floors, ceilings, ductwork, and access doors. i i

i i

l (continued)

SAN ONOFRE--UNIT 3 B 3.7-58 Amendment No. 11/03/95 k

4 m 2,. ...

CREACUS 1

B 3.7.11

BASES I

APPLICABILITY In MODES 1, 2, 3, and 4, the CREACUS must be OPERABLE to

limit operator exposure during and following a DBA.

In MODES 5 and 6, the CREACUS is required to cope with the I t

release from a rupture'of a waste gas tank.

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

j%TEIs*rs.'

ACTION statements are modified y 0TE .'The provisions of LCO 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration." Therefore, since CREACUS can be inoperable during each individual MODE, it should not be required to have two OPERABLE CREACUS trains before MODE change from defueled from MODE 6 to defueled configuration, and from MODE 4 to MODE 5.

Specification 3.0.4 establishes that entry into an operational mode or other specified condition shall not be i made unless the conditions of the LC0 are met.

- - Applicability statement "During movement of irradiated fuel <

assemblies" ensures the OPERABILITY of both CREACUS trains prior to the start of movement of irradiated fuel assemblies. '

F aa .

With one CREACUS train inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, the remaining OPERABLE CREACUS subsystem is adequate to perform control room radiation protection function.

However, the overall reliability is reduced because a single l

failure in the OPERABLE.CREACUS train could result in loss of CREACUS function. The 7 day Completion Time is based on i~ the low probability of a DBA occurring during this time period, and the ability of the remaining train to provide the required capability.

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.n p & 4/W )* $ltd $$ W 44~

AQ" Less 9y dxth E s e;g y ~D % % ,4 &$*$$$$$k.E n *>f kd rr A

~

(/98I/dM.SShM M N M M Vf (continued)

SAN ON0FRE--UNIT 3 B 3.7-59 Amendment No. 11/03/95 4

=======

CREACUS l

B 3.7.11 '

i BASES ACTIONS B.1 and B.2 -

(continued)

If the inoperable CREACUS cannot be restored to OPERABLE

status within the requ. ired Completion Time in MODE 1, 2, 3, i or 4, the unit must be' placed in a MODE that minimizes the i accident risk. To achieve this status, the unit must be i placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 '

within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are

reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

l

, C.1. C.2.1. and C.2.2 i

In MODE 5 or 6, or during movement of irradiated fuel assemblies, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CREACUS train must be immediately placed in the emergency mode of operation. This action ensures that the remaining train is i

1 OPERABLE, that no failures preventing automatic actuation

! will occur, and that any active failure will be readily detected. :

l i

An alternative to Required Action C.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the control ,

l s

room. This places the unit in a condition that minimizes i the accident risk. This does not preclude the movement of fuel assemblies to a safe position.

)

i l 4

~ '

If both CREACUS trains are inoperable in MODE 1, 2, 3, or 4, the CREACUS may not be capable of performing the intended I

function and the unit is in a condition outside the accident !

analyses. Therefore, LCO 3.0.3 must be entered immediately.

i E.1 and E.2 4

'"r" #When in MODES 5 or 6, or during movement of irradiated fuel assemblies with two trains inoperable, action must be taken

immediately to suspend activities that could result in a

release of radioactivity that might enter the control room.

(continued)

SAN ON0FRE--UNIT 3 8 3.7-60 Amendment No. 11/03/95

lesear "A

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6u h4n/ /o redaee de Ae/Wap ofo on'.corters erd #EM/We,s f4ers on de lasey on ene.sen ra/<We-h:we e d ectalaa/km w/ukA caAa& der egaee #a-f,)ne reeusuet 4 uup2a4

& N' "'N b" f psoislate. eskhd A insM 4e caenc4 S su'a/ ~P*)" *r y l

c/taccoaf feds. ~

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4 CREACUS B 3.7.11 i

BASES t .

ACTIONS This places the unit in a condition that minimizes the (continued) accident risk. This does not preclude the movement of fuel to a safe position.

l SURVEILLANCE SR 3.7.11.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and normal operating conditions on this system are not severe, pgg testing each train once every month provides an adequate check on this system.

b gystems with heaters must be operated for a: 10 continuous i

I hours with the heaters energized. This is sufficient to 4

(reduce filters r ine the 31 builduo of mndture cay Frequency is based on onthetha adsorbers and HE Known res tability of the equipment, and the two train redundancy available.

SR 3.7.11.2 This SR verifies that the required CREACUS testing is performed in accordance with the Ventilation Filter Testing

Program (VFTP). The CREACUS filter tests are based on

Regulatory Guide 1.52 HEPA filter performance (Ref. 3). adsorber

, charcoal The VFTP includes testing efficiency, '

i minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and aciditional information are discussed in detail in the VFTP.

1 3.7.11.3 1

i; This SR verifies that with the system operating at a i rate of 35485 cfm 10% for the air conditioning unit, and 2050 2150 cfm for the ventilation unit and recirculating

' l through the respective HEPA filters and charcoal adgorbers, leakage through the system diverting valves is J r **9ess than or equal to 1% air conditioning unit and 1%

<* ventilation unit when the system is tested by admitting cold D0P at the respective intake. The frequency of this (continued)

SAN ON0FRE--UNIT 3 8 3.7-61 Amendment No. 11/03/95 s

w

CREACUS B 3.7.11 BASES I

SURVEILLANCE REQUIREMENTS

[SR 3.7.11.3 (continued)

(continued) SR is 18 month or the HEPA filter or(charcoal adsorber housings, or (2)1) a i following painting fi're or chemical release in any ventilation zone co,mmunicating with the system. '

SR 3.7.11.4 This SR verifies that the heaters dissipate 4.8 kw i 5% when tested in accordance with ANSI N510-1975. The frequency of Qhis SR is 18 months. p SR 3.7.11 3 This SR verifies each CREACUS train starts and operates on an actual or simulated actuation signal. The Frequency of 24 months is consistent with that specified in Reference 3.

SR 3.7.11 y This SR verifies the integrity of the control room enclosure '

and the assumed inleakage rates of potentially contaminated air. The control room positive pressure, with respect to potentially contaminated atmosphere, is periodically tested to verify proper function of the CREACUS. During the emergency radiation state of the emergency mode of operation, the CREACUS is designed to pressurize the control

- room a: 0.125 inches water gauge positive pressure with respect to the atmosphere in order to prevent unfiltered inleakage. The CREACUS is designed to maintain this positive pressure with one_ train.

REFERENCES 1. UFSAR, Section 9.4.

2. UFSAR, Chapter 15.

r,. *9. ' egulatory Guide 1.52 (Rev. 2).

e l l

4 SAN ON0FRE--UNIT 3 8 3.7-62 Amendment No. 11/03/95 !

i 1

i NPF-10/15-407 ATTACHMENT "I" Additional Information 1

j

)

ML20095G865

Text

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