ML20211E998

Proposed Tech Specs 3.7.6,separating Requirements for CR HVAC Sys Re Operation of CR Emergency Makeup Air & Filtration Sys Subsystem & CR Air Conditioning Subsystem

ML20211E998
Person / Time
Site:	Seabrook
Issue date:	09/26/1997
From:	NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
Shared Package
ML20211E968	List: ML20211E963 ML20211E976 ML20211E998
References
NUDOCS 9709300327
Download: ML20211E998 (26)

Text

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I. IN1)(ODUCTION AND SAFETY ASSMSMENT OF Pl(OPOSED CilANGM A. Introduction License Amendment Request (LAR) 97 05 proposes to separate the requiremeats for Control Room Air Conditioning from Control Room hiakeup Air and Filtration as presently contained in Technical Specification 3.7.6," Control Room IImergency hinkeup Air and Filtration " and its associated ilASlis.

Currently, Technical Specification 3.7.6 requires that each subsystem of Control Room IImergency hinkeup Air and Filtration include an OPlIRAllLl! cmcrgency Ultration unit and air conditioning unit.

The proposed change separates the requirements based on system function. The proposed change will also increase the allowed outage time (AOT) for the air conditioning portion of the Control Room Air Conditioning Subsystem (CRACS) from 7 days to 30 days.

The NRC has issued a similar license amendment to Comanche Peak 1 & 2 for the purpose of separating the air conditioning requirements from the Oltration requirements in the Technical Specifications and to estend the AOT.

H. Safety Assessment nf Proposed Changes BACKGRQUND The function of the Control Room timergency hiakeup Air and Fil, ration Subsystem (CRiih1AFS) is to remove particulate and Faseous activity from the control room mmosphere following a core damage event with subsequent release. Currently, the Technical Specincation for the CRi!MAFS also includes the cooling function of the CRACS, which is required both for habitability purposes and for maintaining an appropriate equipment service environment. The llVAC system for the conttal room is classi0ed as a safety related system and is supplied from Train A and Train !! emergency buses that are backed by the respective emergency diesel generators.

The CRiih1AFS is required to be operable during all modes of operation, except when operating within a Limiting Condition for Operation (LCO) Action statement. The current LCO Allowed Outage Times (AOTs) restrict the ability of Seabrook Station to perform scheduled preventive maintenance and normally occurring corrective maintenance. The result could be the shutdown of the plant due to unrelated failures in opposite trains of air conditioning and makeup air / Hitration. The CRiihtAl S would continue to maintain the system function by providing one train of air conditioning and one train of makeup air / Oltration. Ilowever, shutdown would be required per Technical Specincation 3.0.3 because neither train of CRiih1AFS had both subsystems operable.

A similar event to this occurred in November of 1993 and was reported to the NRC in Ll!R 93 21

" Control Room timergency hiakeup Air and Filtration Subsystem inoperability." In this event the plant entered Technical Specincation 3.0.3 due to both trains of CRiihtAFS being declared inoperable.

CRiihiAFS Train A was determined to be inoperable due to one of the two 1.8 KW heater elements, which supports the makeup air / Oltration function, being burned out. CRiihtAFS Train 11 was determined to be inoperable aner repeated air conditioning compressor trips on low oil pressure. The Control Room timergency htakeup Air and Filtration function and Control Room Air Conditioning functions remained available although supplied by different trains. There were no adserse consequences but the event resulted in the plant being in a condition prohibited by Technical Specincations due to having both trains of CRiih1 AFS inoperable.

k 9709300327 970926 PDR ADOCK 05000443: Page1 P PDR

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'the proposed license amendment will facilitate on l!ne implementation of design enhancements to the

,CRACS. Specifically, North Atlantic plans to implement design enhancements to the CRACS which will increase overall sptem availability, reliability, maintainability and enhance the performance of the system. These modifications it.clude the installation of a third ANS Safety Class 3 refrigeration compressor. This compressor has a design safety function of maintaining the refrigerant system pressure boundary, due to its commonality to both safety related condenser and evaporator units. The compressor motor will be maintained as an 11!!!!! 323 Class 11? component, and will be powered from a non safety related power supply, since the compressor has no safety function. 'the system configuration will utilire the non-safety compressor for normal plant operation with one of the two safety-related compressors aligned for standby operation. Swapping the standby status of the safety related units will require manual valve realignment locclly at the compressors. Additional modifications will enhance the performance of the existing refrigeration system during low temperature operation and system start up by providing: self contained head pressure control and hot gas bypass valves, oil migration control and a more accurate means of measuring the refrigerant charge.

The modificatione to the CRACS are substantial and will be implemented in three separate phases that remose one safety related train from service at a time. The amount of work to be completed for each phase is extenshe and an aggressive schedule will be required to restore the associated train within the current 7 day I.CO of Technical Speci0 cation 3/4.7.6. Ilowever, the proposed AOT change will allow on line implementation of the design enhancements.

'Ihe first two phases will consist of the removal of the respective air conditioning train to perform the necessary modifications. The majority of the work, which encompasses intrusive modifications to the installed system, will require refrigerant evacuation and recovery in order to modify system piping and install various system valves. The control circuits will be modined to allow manual operation of the condenser and evaporator fans. Other system modifications are planned which will increase the overall system reliability and availability. !!stimated completion time for each of the Grst two phases is approximately 17 days.

The third and final phase involves the Onal tie-in and functionality checks. The new compressor skid will be connected to the new isolation vahes and Gnal instrument calibrations and testing will be completed. l'inal functional testing will be performed by aligning the non safety compressor to each train of safety related evaporator and condenser fans. The estimated completion time for the third and final phase ofimplementation is approximately seven day s.

DI!SCRIPTION OF TECllNICAL SPECIFIC & flON Cil ANGli REQUliST Presently, the requirements for Control Ro m Emergency Makeup Air and Filtration Subsptem and Air Conditioning are combined and contained in Technical Speci0 cation 3.7.6 based on operating mode.

North Atlantic proposes to separate these requirements based on system function. Proposed Technical Speci0 cation 3.7.6.1 will address the Emergency Makeup Air and Filtration ,equirements and proposed Technical Specineation 3.7,6.2 will address Control Room Air Conditioning. Each speci0 cation will continue to be applicable in the six operating modes, during core alterations and during positive reactivity changes.

The action requirements, while in Modes I, 2,3,4, 5, and 6, remain unchanged for the emergency makeup air and ultration Ometions (Speci0 cation 3/4.7.6.1).

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l The existing action requirements, for the air conditioning function, are changed from an AOT of 7 days

,to an AOT of 30 da)s. This action requirement is relocated to a sepainte action statement for the cooling of recirculated air. The new Speci0 cation 3/4.7.6.2 includes a periodic veri 0 cation of the cooling systems' ability to maintain the control room temperature less than the limiting equipment quali0 cation temperature. This new surveillance modifies the present temperature veri 0 cation by requiring that on a I

quarterly basis the safety related compressors be aligned to the respective evaporators and condensers to verify the system will maintain the control room less than the limiting equipment quali0 cation temperature. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance run will represent typical load variations based on the daily cyclic outdoor air temperature. The current surveillance requirement, which verines the control room is maintained below the limiting equipment quali0 cation temperature every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is redundant to a similar suncillance requirement contained in Technical Specification 3.7.10, " Area Temperature Monitoring" Technical Speci0 cation Surveillance Requirement 4.7.10 requires that the control room temperature be verined less than 75 degrees F every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Furthermore, the actions specined in Technical Specincation 3.7.10, should the temperature exceed the limit, are more restrictive than the actions presently contained in Technical Speci0 cation 3.7.6. Therefore, temperature verincation on a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> basis per the Air Conditioning specification is redundant and unnecessary.

The ilASES section is revised to describe the Control Room Emergency Makeup Air and Filtration Subsystem and the Control Room Air Conditioning Subsystem.

SAFETY ASSESSMENT:

The system description and safety analysis for the control room area ventilation are provided in Sections 6.5.1 and 9.4.1 of the Updated Final Safety Analysis Report. The area ventilation senes two basic functions: (1) to protect the control room environment from external airborne concerns (e.g., radioactive gases or particulate, etc.) and (2) to maintain the temperature in the control room within a range needed to allow operators and the control room equipment to perform properly.

The first function, protecting the control room environment from external airborne problems, depends heavily on the CREMAFS. Ily ensuring proper Oltration and proper pressurization, in leakage into the control room is controlled as is the quality of the control room air. Calculations are performed based on the availability of this system to ensure that the post-event atmosphere will allow the operators to safely function in the control room.

Controlling the temperature in the control room is achieved primarily by the Control Room Air Conditioning Subsystem. This system is conservatively sized to handle the worst heat load condition postulated based on namal conditions, accident conditions and conservative meteorology. The actual load can vary greatly. Temperature chrges in the control room are gradual even under degraded conditions. Time is available to Ond alternate solutions to cool the control room, if alternative cooling methods cannot elTectively maintain control room temperature, the plant can be shutdown from the Remote Safe Shutdown Panel.

As was recognized during the development of NUREG 1431 " Standard Technical Speci0 cations Westinghouse Plants," these different functions and systems warrant different Technical Specincation requirements. In the past, these functions were combined and addressed in a single speci0 cation which established the most conservative requirements on the control room area sentilation systems. Dealing with these systems separately and establishing individual specification requirements for each system is appropriate. The proposed changes to separate the system ftmetions and to increase the AOT of the CRACS are consistent with NUREG 1431.

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The new requirements for the CRACS are consistent with its safety function. A 30 day allowed outage

' time is reasonable for a system whose full capability am y not be required at certain times of the year for any postulated design basis accident, whose complete failure will not have an inunediate, irresersible impact and whose function can possibly be restored or mitigated by plant staff actions. The 30 day allowed outage time is adequate based on the ability of the remaining OPliRAlli,li CRACS train to maintain the control room temperature wi...in limits. Ilowever, the overall reliability is reduced because a single failure in the OPliRAllt.l! CRACS train could result in a loss of CRACS function. The 30 day completion time is based on the consideration that the remaining train can provide the required protection, and that alternate safety- or non safety related cooling means are available. Operation with the non safety compressor will allow two trains of safety related CRACS to remain in the standby condition u hich will increase reliability.

The new suncillance for the CRACS is intended to periodically conGrm the capability of the system.

This new surveillance will verify that each Control Room Air Conditioning Unit (safety related) has the capability to remove the heat load in the control room on a quarterly basis. The sun eillance will align a safety related compressor for service and will remain in operation over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. This duration represents typical load sariations based on the daily cyclic widoor air temperature. This new surveillance does not create a signincant adverse impact on plant gerations and helps to detect any long

term degradation in the system.

In summary, the new l.COs, which are essentially unchanged, maintain the plant status needed to support the plant's safety analyses. The action statements have been revised to appropriately address the significance of the two systems which were previously addressed to ether and to address the plant specine air tenditioning design. The expanded applicability of t , speci0 cations and additional surveillance requirement, when taken together, enhance con 0dence in the systems' abilities to perform as designed. These new specifications provide the proper requirements for the control room ventilation systems needed to assure the desired level of safety.

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II. MARKUI OU'ROEOSI:D CILEGDi

'Itefer to the attached markup of the proposed changes to the Technical Specifications. 'T he attached markup reflects the currently issued resision of the Technical Specifications listed belew. Pending Technical Specifications or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed markup.

The following Technical Specification is included in the attached markup:

.lechnical Specification lille EagcW Index INDiiX viii, xi TS 3.7.6 Control floom limergency 3/4 716 through 18a Makeup Air and Iiltration Subsystem liases for 3/4.7.6 Control lloom Subsystems 113/474 Page 5

l INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REOUIREMENTS

.SECTION P. AGE 3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION ... 3,4 7 11 3/4.7.3 PRIMARY COMPONENT COOLING WATER SYSTEM . . . . . . . . . 3/4 7-12 3/4.7.4 SERVICE WATER SYSTEM . . . . . . . . . . . . . . . . . . 3/4 7 13

/4 7. I I E T K .

g4 y 3.6 .0f 0 MEP NCY KE AIR AfD F . T Of D- 3/4.7.7 -St ..................... .. 3/ /M 3/4.7.8 SEALED SOURCE CONTAMINATION ..,............ 3/4 7 20 3/4.7.9 -(This specification number is not used) ..... .. 3/4 7-22 3/4,7.10 AREA TEiPERATURE MONITORING .............. 3/4 7 23

-TABLE 3.7-3 AREA TEMPERATURE MONITORING ............ 3/4.7-24 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8;.1---A;C. SOURCES Operating ....................... 3/4 8 1 TABLE 4.8 l' OlESEL GENERATOR TEST SCHEDULE , . . . . . . . . . .

3/4 8 10 Shutdown . . . . . . . . . . . . . . . . . . . . . . . . 3/4 8 11 3/4.8.2 D.C. SOURCES Operating ..........,. .,...... 3/4 8 12 TABLE 4.8 2 BATTERY SURVEILLANCE RE0b1REMEkn> ........ 3/4 8-14 Shutdown . . . . . ... . . . . . . . . . . . . . . . . 3/4 8-15 3/4.8.3 ONSITE POWER DISTRIBUTION 0)erating ................... 3/4 8 16 Slutdown . . . ... . . . . . . . . . . . . . . . . . . .

Trip Circuit for inverter 1-2A . . . . . . . . . .

.... 3/4 8-18

.. 3/4 8 19-3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES A.C, Circuits Inside Primary Containment . . . . . . . . 3/4 8-20 Containment Penetration Conductor Overcurrent Protective Devices and Protective Devices for Class 1E Power Sources Connected to Non-Class-1E Circuits ......... ... ........ 3/4 8-21 Motor-Operated Valves Thermal Overload Protection .. 3/4 8-24 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION . ...... .... . . . 3/4 9-1 3/4.9.2 INSTRUMENTATION ......... ... 3/4 9 2 3/4.9.3 DECAY TIME . . . . . . . . . . . . . . . . . . . . . . .. . 3/4 9-3 SEABROOK - UNIT'1 viii

Insert C

, 3/4.7.6 CON 1ROl, ROOh! SUllSYSTiihtS Emergency Makeup Air and Filtration 3/4716 Air Conditioning 3/4 7.lBa

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INDEX BASES I

• SECTl'ON PRiE TABLE B 3/4.4-1 REACTOR VESSEL TOUGHNESS . . . . .... B 3/4 4-11 3/4.4.10 STRUCTURAL INTEGRITY . . . . . . . . . ... ... B 3/4 4-16 3/4.4.11 REACTOR COOLANT SYSTEM VENTS . . ... .. . B 3/4 4 16 3/4 5 EMERGENCY CORE COOLING SYSTEMS 3/4.5.1 ACCUMULATORS . . . . . . . . . . ... ... B 3/4 6 1 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS .............. B 3/4 5-1 3/4.5.4 REFUELING WATER STORAGE TANK ..... ... ... B 3/4 6 2 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT ............ . . B 3/4 6-1 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS .... ... B 3/4 6 3 3/4.6.3 CONTAINMENT ISOLATION VALVES . . . . . . . . . . . . . . B 3/4 6-3 3/4.6.4 COMBUSTIBLE GAS CONTROL .... ..... . ... B 3/4 6-3 3/4.6.5 CONTAINMENT ENCLOSURE BUILDING . . . . . . . ..... B 3/4 6-4 3/4 7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE .................. .. B 3/4 7-1 3/4.7.2 STEAM GENERATOR PRESSURE /TEMPERATURL LIMITATION ... B 3/4 7-3 3/4.7.3 PRIMARY COMPONENT COOLING WATER SYSTEM . ... .. B 3/4 7-3 3/4.7.4 SERVICE WATER SYSTEM . . . . . ............ B 3/4 7-3 3/4,7.5 ULTIMATE HEAT SINK . ... ..

. B 3/4 7-3 3/4.7.6 CONTROL ROOM [ EMF.RGENCY MEU, PAIR AWPTJWRAJJdf 3 SUBSYSTEM $

3/4.7.7 SNUBBERS .. ......

B3/47-/d B 3/4 7-4 3/4.7.8 SEALED SOURCE CONTAMINATION .... . . ..... B 3/4 7 5 3/4.7.9 (This saecification number is not used) ..,,.... B 3/4 7-5 3/4.7.10 AREA TEiPERATURE MONITORING ..... .. ...., 8 3/4 7-5 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1, 3/4.8.2 and 3/4.8.3 A.C. SOURCES D.C. SOURCES, and ONSITE POWER DISTRIBUTION ..... ........ B 3/4 8 1 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES .. .. B 3/4 8-3 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION .......... .. ... B 3/4 9-1 3/4.9.2 INSTRUMENTATION ..... .... ... B 3/4 9-1 3/4.9.3 DECAY TIME . . . . . . . . . . . . . . . . . . . . B 3/4 9-1 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS .. .. . B 3/4 9-1 3/4.9.5 COMMUNICATIONS . . . . . ..... ... B 3/4 9-1 3/4.9.6 REFUELING MACHINE ................. B 3/4 9-1 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE BUILDING ... B 3/4 9-2 SEABROOK - UNIT 1 xi

PLANT SYSTEMS 3/4.7.6 CONTROL RDOM NCY M A AIRANDFILTRATbSUBSYSTEM1 4

LIMITING CONDITION FOR OPERATION

.i 3.7.6[Two inde endent Control Room Emergency Makeup Air and Filtration Subsystems shal be OPERABLE.

APPLICABILITY: All MODES ACTION.

MODES 1. 2. 3 and 4:

With one Control Room Emergency Makeup Air and Filtration Subsystem inoperable, restore the ino)erable system to OPERABLE status within 7 days or be in at least HOT STAND 3Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODES 5 and 6:

a. With one Control Room Emergency Makeup Air and Filtration Subsystem inoperable restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE Control Room Emergency Makeup Air and Filtration Subsystem in the filtration / recirculation mode.

b. With both Control Room Emergency Makeu) Air and Filtration Subsystems inoperable or with the OPERABLE Control Room Emergency Makeup Air and Filtration Subsystem. required to be in the filtration / 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 clanges.

SURVEILLANCE REQUIREMENTS el 4.7.6{Each Control Room Emergency Makeup Air and Filtration Subsystem shall be demonstrated OPERABLE:

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a. At (ast once 12 hotrdy verif ifig that t[controJ-room is ntained ow the iting egt ent qttatificationdemperature in the cont ol room area. -

d. g At least once per 31 days on a STAGGERED TEST BASIS by initiating, f' the control room, flow through the HEPA filters and charcml au .:rs and verifying that the system operates for at least l's cont c:!ous hours with the heaters operating:

SEABROOK - UNIT 1 3/4 7-16

PLANT SYSTEMS Correct Room SuGSYSTEA%

4 EMEEfocMc{ WWEOP AIR MD f~lLT1?AT ch SURVEILLANCE REOUfREMENTS (Continued) hg. At least once per 18 months or (1) af ter any structural maintenance on the HEPA filter or charcoal adsorber housings or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:

1) Verifying that the filtration system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than .05% and uses the test procedure guidance in Regulatory Position C.5.a. C.5.c. and C.S.d of Regulatory Guide 1.52. Revision 2. March 1978* and the system flow rate is 1100 cfm 10%:

2) Verifying, within 31 days after removal, that a laboratory analysis of a re)resentative carbon sample obtained in accordance 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* for a methyl iodide penetration of less than 1.0%: and

3) Verifying a system flow rats of 1100 cfm 10% during system operation when tested in accordance with ANSI N510 1980.

($g. Af ter every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying.

within 31 days after removal, that a laboratory 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 testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52. Revision 2. March 1978* for a methyl iodide penetration of less than 1.0%:

d/ At least once per 18 months by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks, for filter CBA-F-38, is less than 2.8 inches Water Gauge while operating the system at a flow rate of 1100 cfm 10% and verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks, for filter CBA-F-8038. is less than 6.3 inches Water Gauge while operating the system at a flow rate of 1100 cfm 10%.

2) Verifying that upon generation of an 'S' test signal, the following automatic system functions occur:

a. The normal makeup air fan (s) trip off and the normal makeup air isolation damper (s) close:

• ANSI N510-1980 shall be used in place of ANSI N510-1975 as referenced in Regulatory Guide 1.52. Revision 2.

SEABROOK - UNIT 1 3/4 7-17

' , PLANT SYSTEMS Cor0TRotToo M Su&SV.57 EMS f W%Wy MECP Alk AMD FiL7RASA SURVEILLANCE REOUIREMENTS (Continued)

b. The control room exhaust subsystem isolation damper (s) close, and the exhaust fan trips off:

c. The control room emergency makeup air and filtration subsystem actuates with flows through the HEPA filters and charcoal adsorber banks:

3) Verifying that upon generation of Remote intake High Radiation test signal, the following automatic system functions occur:

a. The normal makeup air fan (s) trip off and the normal makeup air isolation damper (s) close:

b. The control room exhaust subsystem isolation damper (s) close, and the exhaust fan trips off:

c. The control room emergency makeup air and filtration subsystem actuates with flows through the HEPA filters and charcoal adsorber banks:

4) Verifying that the Control Room Emergency Makeup Air and filtration Subsystem maintains the control room at a positive pressure of greater than or equal to 1/8 inch Water Gauge at less than or equal to a pressurization flow of 600 cfm relative to adjacent areas during system operation; and

5) Verifying that the heaters dissipate 3.6 0.36 kW when tested in accordance with ANSI N510-1980.

6[ Af ter each com31ete or partial replacement of a HEPA filter bank, by verifying tlat the filtration system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than .05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 1100 cfm 10%: and JA

/

After each complete or partial replacement of a charcoal adsorber bank, by verifying that the filtration system satisfies the in-place 3enetration and bypass leakage testing acceptance criteria of less tlan .05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 1100 cfm 10%.

SEABROOK - UNIT 1 3/4 7-18

INSERT A M.A!JT SYSTEMS

,3/4.7.6 CONTROL ROOM SUBSYSTEMS AIR CO!JDIT10111tJG LIMITI!JG CO!JDIT1011 EOR OPERATIOli 3.7.6.2 Two independent Control Room Air Conditioning Subsystems shall be OPERABLE.

APPLICABILITY: All MODES ACTIO!Jt MODES 1, 2, 3 and 4:

With one Control Room Air Conditioning Subsystem ineperable, restore the inoperable system to OPERABLE status within 30 days or be in at least 110T STA!JDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOW!1 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODES 5 and 6

a. With one Control Room Air Conditioning Subsystem inoperable, restore the inoperable system to OPERABLE status within 30 days or initiate and maintain operation of the remaining OPERABLE Control Room Air Conditioning Subsystem or immediately suspend all operations involving CORE ALTERAT1014S or positive reactivity changes,

b. With both Control Room Air Conditioning Subsystems inoperable, or with the OPERABLE Control Room Air Conditioning Subsystem unable to maintain temperature below the limiting equipment qualification temperature in the control room area, suspend all operations involving CORE ALTERATIO!4S or positive reactivity changes.

SURVEILLA!JCE REQUIREMENTS _

4.7.6.2 Each Control Room Air Conditioning Subsystem shall be demonstrated OPERABLE at least once per 92 days by verif ying the ability to maintain temperature in the control room area below the limiting equipment qualification temperature for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SEABROOK - UNIT 1 3/4 7-18a

ao *

• PLANT SYSTEMS BASES 3/4 7.6 CONTROL R00 MIL -UBSYSTEM$

The OPERABIL11Y of the Control Room Emergency Makeup Air and Filtration Subsystem ensures that;I(lythe allowabye tempefure r Ior continusus-cuty yig 10p the3ujpment afd instrument / tion cochd by this systo/ u nnt expeded/ and (/1rone control ruum will remain tidbitable for opefations Tiersonnel duririg and following credible accident conditions. Cumulative operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

Heaters run continuously to maintain the relative humidity below 70%. The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rems or less whole body, or its equivalent. This limitation is consistent with the requirements of General Design Criterion 19 of Appendix A. 10 CFR Part IfW'p 50.

ANSI N510-1980 will be used as-a procedural guide for surveillance testing.

p 3/T 7 7 SNUBBERS All snubbers are required OPERABLE to ensure that the structural integrity of the Reactor Coolant System and all other safety related systems is maintained during and following a seismic or other event initiating dynamic loads.

Snubbers are classtfied and grouped by design and manufacturer but not by size. Forexample,mechanicalsnubbersutilizingthesamedesignfeaturesof the 2-kip. 10 kip and 100 kip capacity manufactured by Company 'A" are of the same type. The same design mechanical snubbers manufactured by Company "B" for the purposes of this Technical Specification would be of a different type, as would hydraulic snubbers from either manufacturer.

A list of individual snubbers with detailed information of snubber location and size and of system affected shall be available at the plant in accordance with Section 50.71(c) of 10 CFR Part 50. The accessibility of each snubber shall be determined and approved by the Station Operation Review Committee (SORC). The determination shall be based upon the existing radiation levels and the expected time to perform a visual inspection in each snubber location as well as other factors associated with accessibility during plant operations (e.g., temperature, atmosphere, location, etc.) and the recommendations of Regulatory Guides 8.8 and 8.10. The addition or deletion of any hydraulic or mechanical snubber shall be made in accordance with Section 50.59 of 10 CFP Part 50.

Surveillance to demonstrate OPERABILITY is by performance of the require-ments of an approved inservice inspection program.

Permanent or other exemptions from the surveillance program for individual snubbers may be granted by the Commission if a justifiable basis for exemption is presented and, if applicable, snubber life destructive testing was performed to qualify the snubbers for the applicable design conditions at either the com-pletion of their fabrication or at a subsequent date. Snubbers so exempted SEABROOK - UNIT 1 B 3/4 7-4 Amendment No. 18

INSERT B The OlikABI',ITY of the Control Room Air Conditioning Subsystem ensures that the allowable temperature for continuous-duty rating for the equipment and instrumentation cooled by this system is not exceeded. The Control i<oom Air Conditioning Subsystem ccnsists of two independent and redundant trains that provide coaling of recirculated control room air. The design basis of the Cont rol koom Air Conditioning Subsystem is to maintain the control room t aperature for 30 days of continued occupancy. Surveillance to demonstrate OlFRABIh17Y will ver if y each subsystem has the capability to n,aint ain the cont rol room area ten:perature less than the limiting oquipment qualification t en pe r a t u r e . The operational surveillance will be performed on a quarterly basis, requiring the safety related comprestar to operate over a twenty-four hour period. ' Ibis will ensure the safety related subsystem can remove the heat load based on daily cyclic outdoor air temperature.

Ii1. RE1XEE OEl'ROEOSLILCilANUl:S liefer to the attached rety pe of the proposed clianges to the Technical Speci0 cations. The attached rety pe reuccts the currently issued sersion of the Technical Speci0 cations. Pending Technical Speci0 cation changes or Technical Speci0 cation changes issued Subsequent to this subinittal are not renected in the enclosed retype. The enclosed retype should be checked for continuity with Technical Speci0 cations prior to issuance.

Page 6

'* ** 1NDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS

. SECTION PAGF, 3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION .... 3/4 7-11 3/4.7.3 PRIMARY COMPONENT COOLING WATER SYSTEM . . . . . . . . . 3/4 7-12 3/4.7.4 SERVICE WATER SYSTEM ................. 3/4 7-13 3/4.7.5 ULTidATE HEAT SINK , . . . . . . . . . . . . . . . . . . 3/4 7 14 3/4.7.6 CONTROL R00M SUBSYSTEMS Emergency Makeup Air and Filtration .. ..... 3/4 7-16 Air Conditioning . . . . . . . . . . . . . . . . . . . 3/4 7-18a 3/4.7.7 SNUBBERS . . . . . . . . . . . . . . . . . . . . . . . 3/4 7 19 3/4.7.8 SEALED SOURCE CONTAMINATION ......... .... 3/4 7-20 3/4.7.9 (This s)ecification number is not used) ........ 3/4 7 22 3/4.7.10 AREA TEiPERATURE MONITORING .......... ... 3/4 7-23 TABLE 3.7-3 AREA TEMPERATURE MONITORING . .... ..... 3/4 7 24 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES Operating . . . . . .........-....... 3/4 8 1 TABLE-4.8-1 DIESEL GENERATOR TEST SCHEDULE . . . ...... -3/4 8 10 Shutdown . . . . . . . . . . . . . . . . . . . . . . . . 3/4 8-11 3/4.8.2 D.C. SOURCES Operating ................... ... 3/4 8-12 TABLE 4.8-2 BATTERY SURVEILLANCE REQUIREMENTS . . . . . . . . . . 3/4 8 14 Shutdown . . . . . . . . . . . . . . . . . . , .... 3/4 8-15 3/4,8.3 ONSITE POWER DISTRIBUTION 0)erating ....

................. 3/4 8-16 Slutdown . . . . . . . . . . . . . .......... 3/4 8 18 Trip Circuit for Inverter 1-2A . . . . . . . . . . . . . 3/4 8-19 3/4,8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES A.C. Circuits inside Primary Containment . . . . . . . . 3/4 8 20 Containment Penetration Conductor Overcurrent Protective Devices and Protective Devices for Class 1E Power Sources Connected to Non Class lE Circuits ..............,...... 3/4 8-21 Motor-Operated Valves Thermal Overload Protection ... 3/4 8-24 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION .. ...,.... ... .. 3/4 9-1 3/4.9.2 INSTRUMENTATION . ... ..... ....... 3/4 9-2 3/4.9.3 DECAY T!ME , . . ,,. ...... ...... 3/4 9 3 SEABROOK - UNIT 1 viii

'o '

INDEX BASES SEC110N E62.

TABLE B 3/4.4 1 REACTOR VESSEL TOUGHNESS . . . . . . . . ... B 3/4 4-11 3/4.4.10 STRUCTURAL INTEGRITY . . . . . . . . . . . , . . . . . . B 3/4 4-16 3/4.4.11 REACTOR COOLANT SYSTEM VENTS . . . . . . . . . . . .. B 3/4 4-16 3/4.5 FMERGENCY CORE COOLING SYSTEMS 3/4.5.1 ACCUMULATORS . . . . . . . . . . . . . . . . . . . . . . B 3/4 6-1 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS ... .......... B 3/4 6-1 3/4.5.4 REFUEllNG WATER STORAGE TANK . . . . . . . . . . . . . . B 3/4 5-2 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT .......... ... ,. , . B 3/4 6-1 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS . . . . . . . . . . B 3/4 6 3 3/4.6.3 CONTAINMENT ISOLAY10N VALVES . .......... . B 3/4 6 3 3/4.6.4 COMBUSTIBLE GAS CONTROL ................ B 3/4 6 3 3/4.6.5 CONTAINMENT ENCLOSURE BUILDING ......., ... B 3/4 6-4 3/4.7 PLANT SYSTEMS 3/4.7,1 TURBlNE CYCLE ..................... B 3,; 7-1 3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE LlHITATION , .. . B 3/4 7 3 ,

3/4.7.3 PRIMARY COMPONENT COOLING WATER SYSTEM . . . . . . . . B 3/4 7 3 3/4.7.4 SERVICE WATER SYSTEM . , . . . . . . . . . . . . .. . B 3/4 7-3 3/4.7.5 ULTIMATE HEAT SINK . . . . . . . . . . . . . . . . . . . B 3/4 7 3 3/4.7.6 CONTROL R00M SUBSYSTEMS ,,..... B 3/4 7-4 l

3/4.7.7 SNUBBERS . . . . . . . . . . . . . . . . . ,. . . . . . .

... B 3/4 7 4 3/4.7.8 SEALED SOURCE CONTAMINATION .............. B 3/4 7-5 3/4.7.9 (This s)ecification number is not used) . ...... . B 3/4 7 5 3/4.7.10 AREA TEiPERATURE MONITORING .............. B 3/4 7-5 3/4.8 ELECTRICAL POWER SYSTEKS 3/4.8.1, 3/4,8.2. and 3/4.8.3 A.C. SOURCES. C.c SOUR;.R. and DNSITE POWER DISTRIBUTION ......... ... . B 3/4 8-1 3/4.8.4 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES . . . . . . . B 3/4 8 3 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION ,.......... .. ... B 3/4 9-1 3/4.9.2 INSTRUMENTATION B 3/4 9-1 3/4'.9.3 DECAY TIME . . . . . . . . . .. . B 3*A 9 1 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS .... .... . B 3/4 9 1

-3/4.9.5 COMMUNICATIONS . . . . . . . . . . . . . . . . , , . . . B 3/4 9 1 3/4.9.6 REFUELING MACHINE ................ . . B 3/4 9 1 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE BUILDING , . . . . B 3/4 9-2 SEABROOK - UNIT 1 xi

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM SUBSYSTEMS l EMERGENCY MAKEUP AIR AND FILTRATION LIMITING CONDITION FOR OPERATION 3.7.6.1 Two inde)endent Control Room Emergency Makeup Air and Filtration l Subsystems shall )e OPERABLE.

APPLICABILITY: All MODES ACTION:

MODES 1, 2, 3 and 4:

With one Control Room Emergency Makeup Air and Filtration Subsystem inoperable, restore the ino)erable system to OPERABLE status within 7 days or be in at least HOT STAND 3Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the

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

MODES 5 and 6:

a. With one Control Room Emergency Makeup Air and Filtration Subsystem inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE Control Room Emergency Makeup Air and Filtration Subsystem in the filtration / recirculation mode,

b. With both Control Room Emergency Makeu) Air and filtration Subsystems inoperable, or with the OPERABLE Control Room Emergency Makeup Air and Filtration cibsystem, required to be in the filtration / recirculation 6 7 3 by ACTION a., not capable of being powered by an OPERABLE emergency power source, suspend all 0)erations involving CORE ALTERATIONS or positive reactivity clanges.

SURVEILLANCE REOUIREMENTS 4.7.6.1 Each Control Room Emergency Makeup Air and Filtration Subsystem shall be demonstrated OPERABLE: l

a. 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 10 continuous hours with the heaters operating:

SEABROOK - UNIT 1 3/4 7-16

1 Il @T SYSTEMS CONTROL ROOM SUBSYSTEMS LMERGENCY MAKEUP AIR AND FILTRATION

, SURVElELANCE REOUIREMENTS (Continued)

b. At least once per 18 months or (1) after any structural maintenance l on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone conmunicating with the system by:

1) Verifying that the filtration system satisfies the in place penetration and bypass leakage testing acceptance criteria of less than .05% and uses the test Regulatory Position C.5.a. C.5.c. procedure and C.S.d guidance in of Regulatory Guide 1.52. Revision 2. March 1978*, and the system flow rate is 1100 cfm 10%:

2) Verifying, within 31 days after removal, that a laboratory analysis of a re)resentative carbon sample obtained in accordance 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*. for a met'yl iodide penetration of less than 1.0%: and

3) Verifying a system flow rate of 1100 cfm i 10% during system operation when tested in accordance with ANSI N5101980,

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying. l within 31 days after removal, that a laboratory 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 testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52. Revision 2, March 1978*, for a methyl iodide penetration of less than 1.0%:

d, At least once per 18 months by:

l

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks, for filter CBA-F-38. is less than 2.8 inches Water Gauge while operating the system at a flow rate of 1100 cfm i 10%: and verifying that the pressure dro) across the combined HEPA filters and charcoal adsorber bancs for filter CBA-F-8038. is less than 6.3 inches Water Gauge while operating-the system at a flow rate of 1100 cfm 10%.

2) Verifying that upon generation of an 'S' test signal, the following automatic system functions occur:

a. The normal makeup air fan (s) trip off and the normal makeup air isolation damper (s) close:

• ANSI N510-1980 shall be used in plate of ANSI N510-1975 as referenced in Regulatory Guide 1.52. Revision 2.

SEABROOK - UNIT 1 3/4 7-17

PLANT SYSTEMS CONTROL ROOM SUBSYSTEMS EMERGENCY MAKEUP AIR AND FILTRATION EURVEILLANCE REOUIREMENTS (Continued)

b. The control room exhaust subsystem isolation damper (s) close, and the exhaust fan trips off:

c. The control room emergency makeup air and filtration subsystem actuates with flows through the HEPA filters and charcoal adsorber banks:

3) Verifying that upon generation of Remote intake High Radiation test signal, the following automatic system functions occur:

a. The normal makeup air fan (s) trip off and the normal makeup air isolation damper (s) close;

b. The control room exhaust subsystem isolation damper (s) close. and the exhaust fan trips off:

c. The control room emergency makeup air and filtration subsystem actuates with flows through the HEPA filters and charcoal adsorber banks:

4) Verifying that the Control Room Emergency Makeup Air and Filtration Subsystem maintains the control room at a positive pressure of greater than or equal to 1/8 inch Water Gauge at

, less than or equal to a pressurization flow of 600 cfm relative to adjacent areas during system operation: and

5) Verifying that the heaters dissipate 3.6 0.36 kW when tested in accordance with ANSI Na10-1980.

e. After each com)lete or partial replacement of a HEPA filter bank. l by verifying tlat the filtration system satisfies the in place penetration and bypass leakage testing acceptance criteria of less than .05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 1100 cfm 10%: and

f. After each complete or partial replacement of a charcoal adsorber {

bank, by verifying that the filtration system satisfies the in-place 3enetration and bypass leakage testing acceptance criteria of less t1an .05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 1100 cfm 10%.

SEABROOK - UNIT 1 3/4 7-18 i

_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . . _ _ - - _ _ i

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM SUBSYSTEMS

, AIR CONDITIONING LlHITING CONDITION FOR OPERATION 3.7.6.2 Two independent Control Room Air Conditioning Subsystems shall be OPERABLE.

APPLICABlllTY: All MODES ACTION:

MODES 1. 2. 3 and 4:

With one Control Room Air Conditioning Subsystem inoperable, restore the ino)erable system to OPERABLE status within 30 days or be in at least HOT STA1DBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

__ MODES 5 and 6:

a. With one Control Room Air Conditioning Subsystem ino)erable, restore the inoperable system to OPERABLE status wit 11n 30 days or initiate and maintain operation of the remaining OPERABLE Control Room Air Conditioning Subsystem or immediately suspend all o)erations involving CORE ALTERA110NS or positive reactivity clanges,

b. With both Control Room Air Conditioning Subsystems inoperable, or with the OPERABLE Control Room Air Conditioning Subsystem unable to maintain temperature below the limiting equipment qualification temperature in the control rooii) area, suspend all o)erations involving CORE ALTERATIONS or positive reactivity c1anges.

SURVEILLANCE REOUIREMENTS 4.7.6.2 Each Control Room Air Conditioning Subsystem shall be demonstrated OPERABLE at least once per 92 days by verifying the ability to maintain temperature in the control room area below the limiting equipment qualification temperature for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SEABROOK - UNIT 1 3/4 7-18a

PLANT SYSTEMS BASES 3/4.7.6 CONTR0l_ ROOM SUBSYSTEMS l

The OPERABilllY of the Control Room Emergency Makeup Air and Filtration Subsystem ensures that the control room will remain habitable for operations l personnel during and following credible accident conditions. Cumulative operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

Heaters run continuously to maintain the relative humidity below 70%. The OPERABILITY of this system in conjunction with control room design provisions is ,

based on limiting the radiation exposure to personnel occu.. .ng the control room to 5 rems or less whole body, or its equivalent. This limitation is consistent with the requirements of General Design Criterion 19 of Appendix A.10 CFR Part

50. ANSI N510-1980 will be used as a procedural guide for surveillance testing.

The OPERABillTY of the Control Room Air Conditioning Subsystem ensures that the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system is not exceeded. The Control Room Air Conditioning Subsystem consists of two independent and redundant trains that provide cooling of recirculated control room air. The design basis of the Control Room Air Conditioning Subsystem is to maintain the control room -

tem)erature for 30 days of continued occupancy. Surveillance to demonstrate OPERABILITY will verify each subsystem has the capability to maintain the control room area temperature less than the limiting equipment qualification temperature. The o)erational surveillance will be performed on a quarterly basis, requiring t1e safety related compressor to operate over a twenty-four hour aeriod. This will ensure the safety related subsystem can remove the heat load )ased on daily cyclic outdoor air temperature.

3/4.7 7 SNUBBERS All snubbers are required OPERABLE to ensure that the structural integrity of the Reactor Coolant System and all other safety-related systems is maintained during and followirg a seismic or other event initiating dynamic loads.

Snubbers are classified and grouped by design and manufacturer but not by sice. For example, mechanical snubbers utilizing the same design features of the 2-kip. 10 kip and 100 kip capacity manufactured by Company "A" are of the same type. The same design mechanical snubbers manufactured by Company "B" for the pur oses of this Technical Specification would be of a different type, as would h draulic snubbers from either manufacturer.

A list of individual snubbers with detailed information of snubber location and size and of system affected shall be available at the plant in accordance with Section 50.71(c) of 10 CFR Part 50. The accessibility of each snubber shall be determined and approved by the Station Operation Review Committee (SORC). The determination shall be based upon the existing radiation levels and the expected time to perform a visual inspection in each snubber location as well as other factors associated with accessibility during plant operations (e.g. , temperature, atmosphere, location, etc. ), and the recommendations of Regulatory Guides 8.8 and 8.10. The addition or deletion of any hydraulic or mechanical snubber shall be made in accordance with Section 50.59 of 10 CFR Part 50.

SEABROOK - UNIT 1 B 3/4 7-4 Amendment i;o. M

_ l

)* ' *'

PLANT SYSTEMS BASES 3/4.7.7 -SNUBBERS (Continued)

Surveillance to demonstrate OPERABILITY is by performance of the require-ments of an approved inservice inspection program.

Permanent or other exemptions from the surveillance program for individual snubbers may be granted by the Commission if a justifiable basis for exemption is presented and, if applicable, snubber life destructive testing was performed to qualify the snubbers for the applicable design conditions at either the com-pletion of their fabrication or at a subsequent date. Snubbers so exempted shall be listed in the list of individual snubbers indicating the extent uf the

-exemptions.

The service life of a snubber is established via manufacturer input and information through consideration of the snubber service conditions and I

associated installation and maintenance records (newly installed snubbers, seal replaced, spring replaced, in high radiation area, in high temperature area.

etc.), The requirement to monitor the snubber service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age and operating conditions. These records will provide statistical bases for future consideration of snubber service life.

3/4 7.8 SEALED SOURCE CONTAMINATION The limitations on removable contamination for sources requiring leak tating. including alpha emitters, is based on 10 CFR 70.39(a)(3) limits for plutonium. This limitation will ensure that leakage from Byproduct. Source, and Special Nuclear Ma.terial sources will not exceed allowable intake values.

Sealed sources are classified into three groups according to their use, with Surveil k oce Requirements commensurate with the probahility of damage to a source in that group. Those sources which are frequently handled are required to be tested more often than those which are not. Sealed sources which are continuously enclosed within a shielded mechanism (i.e., sealed sources within radiation monitoring or boron .neasuring devices) are considered to be stored and need not be tested unless they are removed from the shielded mechanism.

3/4.7.9 (This specification number is not used.)

3/4.7.10' AREA TEMPERATURE MONITORING The area temperature limitations ensure that safety-related equipment will nX asubjected to temperatures 1.7 excess of their environmental qualification temperatures. Exposure to excessive temperatures may degrade equipment and can cause a loss of its OPERABILITY. The temperature limits include an allowance for instrument error of 4.5 F.

SEABROOK - UNIT 1 B 3/4 7-5 Amendment No. M

IV. ETEllAllNAHQ10131GNIElCANT IJAZARib101dROPOSI ACj l AS Gl:S License Amendment itequest (LAlt) 97-05 proposes 'o separate the requirements for Control Room Makeup Air and Filtration from Control Room Air Conditioning presently contained in Technical Speci0 cation 3.7.6, " Control Room Emergency Makeup Air and Filtration," and its associated ilASES.

T he proposed change will prevent potential plant shutdowns due to unrelated failures in air conditioning and makeup air / Ghration systems, and increase the AOT to support preventative and corrective maintenance on the air conditioning systems.

~

In accordance with 10 CFR 50.92, North Atlantic has reviewed the attached proposed change and has concluded that it does not involve a signincant hazards consideration (SilC). The basis for the conclusion that the proposed change does not involve a SilC is as follows:

1.

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

lae proposed changes have no impact on the probability of an accident. The control room ventilation systems are support systems which have a role in the detection and mitigation of accidents but do not contribute to the initiation of any accident previously evcluated.

The administrative changes (e g., reorganizing the Technical Specifications by function) have nu impact on the course of any accidents previously evaluated.

Specifying an allowed outage time ( AOT) of 30 days for the cooling of recirculated air while one train is inoperable represents an increase in AOT (from 7 days) and thus an increase in the probability that the air conditioning functions could be unavailable. The increase in AOT does not atTect the availability of the second trah of air conditioning or the actions required should both trains of air conditioning become unavailable. Similar to the existing Technical Speci0 cations, one train of air conditioning will always be available to assist in the mitigation of an accident. Additionally, if the second train of air conditioning becomes unavailable, a shutdown would be required in accordance with Technical Speci0 cation 3.0.3. While the increase in AOT may affect system availability on a per train basis, it does not affect overall system availability. In addition, tais increase in unavailability of one train of air conditioning is not considered signineant based on several factors including: the system design is based on the worst postulated meteorological condition; generally, less than design cooling is required; an unavailability condition does not create an immediate irreversible impact (i.e., temperature will increase slowly over a period of time); the system could possibly be restored or its loss mitigated without any impact on the course of whatever accident is being considered; and the extended AOT would allow more opportunity to perform maintenance and thus may provide oserall improvement in equipment reliability.

Overall, the net effect of the increase in AOT is not significant and, as a result, does not involve signincant increase in the consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or ahferent k:nd of accidentfrom anypreviously analy:ed.

Page 7

ae -,s The proposed changes separate the requirements for Control Room Makeup Air and Filtration from Control Room Air Conditioning. They also increase the AOT of the Control Room Air Conditioning Subsystem from 7 to 30 days. These changes do not involve any hardware or setpoint changes nor do they affect the way the system operates during accident conditions.

They also do not alter the environmental conditions in the Control Room during normal or accident conditions. Separating the two functions of this system in the Technical Specification is administrative in inture and does not create the possibility of a new or difTerent accident. The increase in AUT in no way affects the availability of the second train of air conditioning or the octions required should both trains of air conditioning become unavailable. Therefore, these danges do not create the possibility of a new or different accident from any previously evaluated.

3. 7'he proposed change does not mvolve a sigma emt reduction in the margin ofsakty.

The changes being proposed do not alte: the environmental conditions which are to be '

maintained in the control roc.m during normai operation and following an accident.- As a result, the margin of safety for these functions remains the same. The only potential impact is the air conditioning system's postulated unavailability, as discussed in the response to question I above.

As noted in the above response, there is no significant impact on the accident analyses. Thus, the proposed changes do not involve a significant reduction in the margin of safety.

flased on the above evaluation, North Atlantie > oncludes that the activities associated with the proposed changes satisfy the no significant hazards ( s , sideration of 10CFR50.92(c) and, accordingly, a no significant hazards consideration finding isjustified.

Page 8

o e '. b6 V. PROfOSEllSCllEDULE 11)ltLLCENSI: AMENDalENLjSSibuCI: AND EEEEC11 YEN 13S North Atlantic requests NI(C review of LAR 97 05 and issuance of a license amendment by November 7, 1997, hasing immediate effectiveness and implementation required within 60 days. This will support modifications to the CRACS. North Atlantic is currently operating at 100 percent power and plans to make these enhancements to the CRACS on line.

t Page 9

04 'o D4 V1. ENY11tOSA113LR.1311%CT ASSESSMI:NT North Atlantic has reviewed the proposed license amendment against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not insohe a significant hazards consideration, nor increase the types and amounts of effluent that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing. North Atlantic concludes that the proposed change meets the criteria delineated in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

Page 10

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