ML20078N445
| ML20078N445 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/02/1994 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-94-0191, W3F1-94-191, NUDOCS 9412060285 | |
| Download: ML20078N445 (3) | |
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W3F1-94-0191 A4.05 PR December 2, 1994 U.S. Nuclear Regulatory Commission ATIN:
Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Request for Additional Information of Technical Specification Change Request NPF-38-116 Gentlemen:
By letter dated July 18, 1991, as supplemented by letter dated March 16, 1994, Waterford 3 proposed a change to Technical Specification (TS) 3/4.7.6, " Control Room Air Conditioning System." Proposed Action c.2.a. of Limiting Condition for Operation (LCO) 3.7.6.4, allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to identify the cause of an inoperable control room envelope, when the cause of inoperability is other than that addressed by LC0 3.7.6.4 Actions 'a' and/or 'b' (i.e., an inoperable control room envelope isolation valve or an inoperable Control Room Emergency Filter Outside Air Intake valve).
The NRC review staff requested additional information in support of the allowed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period of Action c.2.a.
In a discussion with the review staff Waterford 3 agreed that the proposed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> may not be necessary and that an allowed time would be proposed based on a justified need.
Waterford 3 has performed an evaluation to determine the time necessary to identify the cause of a failure in the Control Room Envelope pressure boundary pursuant to proposed Action c.2.a.
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o Clarification of Technical Specification Change Request NPF-38-ll6 W3F1-94-0191 Page 2 December 2,1994 The Control Room Envelope pressure boundary is subjected to a pressurization test at least once every 18 months. This pressurization test is performed separately by each train of the Control Room Ventilation System (HVC). An established plant procedure contains specific instructions to restore the envelope to an operable status should both trains of the HVC fail to satisfy the pressurization test acceptance criteria (maintain a positive pressure in the Control Room of 2 0.125 inwg with an outside air intake flowrate of.C 200 cfm).
These instructions include the inspection of Control Room air-lock doors and pipe and conduit penetrations and verification of actual make-up air flow through an emergency outside air intake path.
Other items to consider include floor drains and plumbing traps, electrical and duct penetrations and joint cracks at the seams of boundary wallt and where the boundary walls and ceilings meet.
Additionally, it may be necessary to isolate or perform separate pressure tests on certain portions of the Control Room Envelope to precisely determine the area where the majority of air leakage is occurring.
The evaluation identified the following troubleshooting tasks that would be performed as necessary should the integrity of the Control Room Envelope pressure boundary fall into question.
Estimated times associated with each task are based on sound engineering judgment:
2 Hrs.
Inspection and testing of Control Room air-lock doors.
6 Hrs.
Inspection and testing of pipe / conduit / duct penetrations.
4 Hrs.
Inspection and testing of floor drains and plumbing traps.
24 Hrs.
Inspection and testing of dry grout cracks at the seams of l
boundary walls and where the boundary walls meet the ceiling.
48 Hrs.
Inspection and testing of electrical penetrations.
4 Hrs.
Verification of actual make-up air flow through an emergency outside air intake path by the performance of a duct traverse.
36 Hrs.
Isolation or performance of separate pressure tests on certain porti]ns of the Control Room Envelope.
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Clar-ification of Technical Specification Change Request NPF-38-ll6 W3F1-94-0191 Page 3 December 2,1994 This breakdown illustrates that if these troubleshooting tasks were performed in parallel the maximum identification period would be 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Thus, the current 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of proposed TS 3.7.6.4 Action c.2.a. will be acceptable when modified to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
This will have no impact on the safety and significant hazards determination provided with the original submittal.
If you should have any questions concerning the above, please contact Paul Caropino at (504) 739-6692.
Very truly yours, 4
R.F. Burski i
Director Nuclear Safety RFB/PLC/ssf Attachment cc:
L.J. Callan, NRC Region IV C.P. Patel, NRC-NRR j
R.B. McGehee N.S. Reynolds i
NRC Resident Inspectors Office Administrator Radiation Protection Division (State of Louisiana)
American Nuclear Insurers j
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