ML20247J848

Requests Util Address Encl Concerns Re 890321 Application for Amend to License NPF-38.Amend Would Replace Tech Spec on Control Room Air Conditioning Sys W/Four Specs on Air Filtration,Air Temp & Isolation & Pressurization

ML20247J848
Person / Time
Site:	Waterford
Issue date:	07/27/1989
From:	Wigginton D Office of Nuclear Reactor Regulation
To:	Dewease J LOUISIANA POWER & LIGHT CO.
References
NUDOCS 8907310346
Download: ML20247J848 (6)

Text

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? [ *~ . #  : July - 27,1989 y T* j{ '

a Docket 1NoV 50-382 t- . ' iMr. J. G. Dewease .

f Senior 3 Vice PresidentL- Nuclear Operations

'-Louisiana Power.and Light Company

?"' iPost Office Box'60340- . ,

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.New Orleans, Louisiana.170160h

SUBJECT:

' CONTROL ROOM VENTILATION - TECHNICAL SPECIFICATION CHANGE

'NPF-38 '

• ' By letter dated March 21,'1989,- the Louisiana Power an'd' Light Company. (LP&L) .

r submfited-a proposed amendment to the . license for' the Waterford Steam Electric ..

W; Station, Unit 3. The proposed change would replace the Technical Specification.

on control room air conditioning system with four specifications on air filtration,

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air temperature, and isolation and' pressurization The LP&L submittal represents!

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J an attempt to upgrade the current contro1~ room technical specifications lto-k ' accurately reflect the required functions and operational capabilities of the ventilation components.

'In our review of the March 21, 1989 submittal, we have developed questions which we have enclosed for LP&L's consideration. It is-requested that LP&L-respond to the issues;to assure that all concerns are appropriately addressed.

If you wish to meet or discuss the issues, please let us know. The reporting-and/or.recordkeeping requirements contained in this-letter affect fewer than ten respondents; therefore OMB clearance.is not required under P.L.'96-511.

Sincerely,

/s/

Dev'id L. Wigginton, Project Manager

. Project' Directorate - IV Division of Reactor Projects - III, i

.IV, V and Special Projects Office of Nuclear Reactor Regulation  ;

Enclosure:

.As stated 4 1

cc w/ enclosure:

See next page M l

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+ July 27, 1989 '

Docket No. 50-382 J

Mr. J. G. Dewease Senior Vice President - Nuclear Operations  !

Louisiana Power and Light Company i Post Office Box'60340 i New Orleans, Louisiana 70160 j l

Dear Mr. Dewease:

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SUBJECT:

CONTROL ROOM VENTILATION - TECHNICAL SPECIFICATION CHANGE NPF-38-95  :

By letter dated March 21, 1989, the Louisiana Power and Light Company (LP&L) submitted a proposed amendment to the license for the Waterford Steam Electric Station, Unit'3. The proposed r.hange would replace the Technical Specification on control room air conditioning system with four specifications on air filtration, air temperature, and isolation and pressurization. The LP&L submittal represents an attempt to upgrade the current control room technical specifications to accurately reflect the required functions and operational capabilities of the ventilation components.

In our review of the March 21, 1989 submittal, we have developed questions which we have enclosed for LP&L's consideration. It is requested that LP&L respond to the issues to assure that all concerns are appropriately addressed.

If you wish to meet or discuss the issues, please let us know. The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, s

David L. W nton, Project Manager i Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

See next page

.o. .

-i Mr. Jerrold G. Dewease Waterford 3 Louisiana Power & Light Company  !

CC:

W. Malcolm Stevenson, Esq. Regional Administrator, Region IV Monrce & Leman U.S. Nuclear Regulatory Commission 201.St. Charles Avenue, Suite 3300 Office of Executive Director for New Orleans, Louisiana 70170-3300 Operations 611 Ryan Plaza Drive, Suite 1000 Mr. E. Blake Arlington, Texas 76011 Shaw, Pittraan, Potts & Trowbridge 2300 N Street, NW Mr. William H. Spell, Administrator i Washington, D.C. 20037 Nuclear , Energy Division Office of Environmental Affairs Resident Inspector /Waterford NPS Post Office Box 14690 ,

Post Office Box 822 Baton Rouge, Louisiana 70898 '

K111ona, Louisiana 70066 Mr. Ralph T. Lally President, Police Jury Manager of Quality Assurance St. Charles Parish ,

Middle South Services, Inc. Hahnville, Louisiana 70057 Post Office Box 61000 New Orleans, Louisiana 70161 Chairman William A. Cross Louisiana Public Service Commission Bethesda Licensing Office One American Place, Suite 1630- 3 Metro Center Baton Rouge, Louisiana 70825-1697 Suite 610 Bethesda, Maryland 20814 Mr. R. F. Burski i Nuclear Safety and Regulatory Affairs Manager Louisiana Power & Light Company 317 Baronne Street New Orleans, Louisiana 70112 1 I

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LL ' Enclosure REQUEST FOR ADDITIONAL INFORMATION l TECHNICAL SPECIFICATION CHANGE C0HTROL ROOM HVAC OPERABLE CRITERIA WATERFORD STEAM ELECTRIC STATION, UNIT NO. 3 i DOCKET NO. 50-382 General The proposed changes would replace TS 3.7.6 with four separate TS's 3.7.6.1, 3.7.6.2, 3.7.6.3, and 3.7.6.4 This is based an the independence, in the -

Waterford design, of the trains associated with the following control room

-safety-related systems / functions: (1) emergency air filtration, (2) air i temperature,and(3)isolationandpressurization. A further basis should be that, with one emergency diesel generator inoperable, it is assured that at-least one of the trains, for each of these systems / functions that depend on the operable diesel generator, is operable. )

Q 1. Clarify how each train of the above three systems / functions is independent of each of the other five trains.

Q 2. Clarify how, with one diesel generator inoperable, it is assured that each of the trains that depend on the operable diesel generator (s) is operable.

Air Filtration In proposed TS 3.7.6.1 a new action has been added for the case of both control room emergency air filtration trains inoperable. This situation is alrehdy addressed by TS 3.0.3 and, therefore, does not appear to be i necessary. Furthermore, it appears to be nonconservative since it would l allow entry into the situation where no emergency air filtration train is l operable without the requirement for a Licensee Event Report or consideration of an enforcement action.

Q 3. Justify or delete the addition of Action (b) to TS 3.7.6.1.

Air Temperature The proposed change would assure the operability of the control room air handling units (AH-12 units) by verifying their operation and by verifying that th'e control room air temperature is within specified limits. This i differs from the existing TS in that in the proposal there is no specific requirement to demonstrate a system or train operable and an action is required when the control room air temperature exceeds the specified limit.

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\, l The Bases for the existing TS states that the operability of the control room I i air conditioning system ensures that (1) the ambient air temperature does not )

exceed the allowable temperature for the continuous duty rating for the l equipment and instrumentation cooled by this system and (2) the control room will remain habitable for operations personnel during and following all credible accident conditions. The Bases for the proposed TS is similar except that maintaining the control room air temperature to less than 80 F ensures )

that (1) (same as existing TS) and (2) the control room will remain habitable fer operations personnel during plant operations. The staff interpretation is 1 that, included in the meaning of the above, each Bases is to ensure that the control room ambient air temperature will be suitably controlled in consideration of equipment and instrumentation allowable temperatures and  ;

habitability for operating personnel during normal operations and during all  ;

credible accident conditions. ]

It is not clear that operability under the existing TS or the proposed TS ensures this function of the control room air conditioning system. Relying l cnly on surveillance of control room air temperatures and operation of the safety-related %H-12 units during operation in the normal mode may not be j sufficient because: ,

(1) During normal operation, the non-safety-related AH-31 supplemental air handling units may be in operation and carry part of the cooling load; (2) The flow rate of cool outside air is greater in the normal mode than in the emergency mode; (3) The outside air temperatures may be higher during emergency operation; and 1

(a) One, or possibly two, ESF air filtration unit heaters will be operating during emergency operation.

A further concept for revised TS in this area would provide two separate TS. I One TS would address the control room emergency air temperature control (HVAC) )

system and would require two trains to be operable. The surveillance would I periodically verify that each train removes an average of at least [ ] l Btu /hr from the control room air when operated for [ ] hour. The Btu /hr {

criterion would be established based on a prior analysis such that the surveil- J 1ance will verify that each train is capable of attaining in [ ] hour, )

starting from a specified initial control room air temperature, a specified I final control room air temperature assumed to be maintained during emergencies, in each emergency protection mode, with assumed adverse environmental air tem-peratures. The other of the two TS's would address control room air temperatures ,

for normal operation and would require that the control room air temperatures 4 not exceed specified limits based on short-term and long-term time spans for habitability and for equipment and instrumentation. Action items would be i provided for each of the specified temperature lir.its. The surveillance would  !

periodically determine the control room ambient air temperature. The initial I control room air temperature and the final control room air temperature specified in the one TS would correspond, respectively, to the long-term equipment and instrument temperature limit and the long-term habitability temperature limit j specified in the other TS.

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e l' i Q 4s Clarify, and amend as appropriate, the submittal with supporting rationale, based on the above.

Isolation and Pressurization The proposed TS require that the control room envelope isolation and pressurization boundaries be operable. This differs from the existing TS in that there in no specific requirement to have two trains operable. The proposed TS provides actions with either or both control room envelope l 1 solation valves in a normal outside air flow path inoperable or any control l room emergency filter unit outside air intake valve inoperable. However, I the action for failure to maintain a positive pressure in the control room l e relative to adjacent areas does not appear to address the case of one j envelop train (pressurization fan) inoperable.

The actions regarding the control room envelope isolation valves are j open-ended in that they allow the affected flow paths to be isolated for an  !

indefinite period. Rationale supporting this is not provided. Clearly,  !

isolation of emergency intake air paths may affect operator protection in radiological emergencies. Similarly, the action regarding positive pressure in the control room is open-ended in that it allows immediate initiation of actions to restore the boundaries operable, but no requirement specific to completion of actions. Again, no supporting rationale is provided.

The surveillance requirements do not appear to address the operability of.the emergency filter outside air intake valves.

Q 5. Clarify, and amend as appropriate, the submittal including supporting rationale, based on the above.

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