GNRO-2003/00044, Supplement to Amendment Request Removal of Mode Restrictions for Surveillance Testing of the Division 3 Battery

Supplement to Amendment Request Removal of Mode Restrictions for Surveillance Testing of the Division 3 Battery

ML032310412
Person / Time
Site:	Grand Gulf
Issue date:	08/07/2003
From:	Roberts J Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2003/00044, TAC MB8938
Download: ML032310412 (7)

Text

Entergy Operations, Inc.

Waterloo Road Ad-~ Entergy PO. Box 756 Port Gibson, MS 39150 Tel 601 437 6470 Jerry C. Roberts Director Nuclear Safety Assurance GNRO-2003/00044 August 7, 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Supplement to Amendment Request Removal of MODE Restrictions for Surveillance Testing of the Division 3 Battery (TAC No. MB8938)

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCE:

Letter GNRO-2003/00033 from J. C. Roberts to USNRC, uLicense Amendment Request - Removal of MODE Restrictions for Surveillance Testing of the Division 3 Battery" dated May 12, 2003 (ADAMS Accession No. ML031420552)

Dear Sir or Madam:

By letter (Reference 1), Entergy Operations, Inc. (Entergy) proposed a change to the Grand Gulf Nuclear Station, Unit 1 (GGNS) Technical Specifications (TS) to remove the MODE restrictions for performance of Surveillance Requirements (SR) 3.8.4.7 and 3.8.4.8 for the Division 3 DC electrical power subsystem.

On June 25, 2003, Entergy and members of your staff held a call to discuss the current TS Bases definition of mdegradation" for SR 3.8.4.8. SR 3.8.4.8 requires a battery performance test every 60 months to determine overall battery degradation due to age and usage. The surveillance is required to be performed more frequently if the battery shows degradation" or reaches 85% of the expected life. The current TS Bases defines "degradation" as when battery capacity drops by more than 10% of rated capacity from the average of previous tests or is below 90% of the manufacturer's rating. The NRC staff reviewer expressed concern over the effectiveness of determining battery condition by comparing measured capacity to the average capacity of previous tests. After discussion and review of IEEE Standard 450 and NUREG 1434, Entergy agreed to revise the TS Bases for SR 3.8.4.8 such that future performance tests will compare battery capacity with the previous performance test rather than the average of the previous performance tests.

A'boj

August 7, 2003 GNRO-2003/00044 Page 2 of 3 The definition of "degradation" is taken from IEEE Standard 450, IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications. Early editions of the IEEE standard defined degradation in relation to a change in capacity from the average of previous tests. However, newer editions of the standard define degradation in relation to the change in capacity from only the previous performance test. NUREG 1434, Standard Technical Specifications General Electric Plants, BWRI6, also defines degradation in relation to the previous test rather than the average of the previous tests.

The TS Bases will be revised in accordance with TS 5.5.11, 'Technical Specification (TS) Bases Control Program,"from:

"Degradation is indicated when the battery capacity drops by more than 10% of rated capacity from its average on previous performance tests or is below 90% of the manufacturers rating" to:

"Degradation is indicated when the battery capacity drops by more than 10% of rated capacity relative to its capacity on the previous performance test or is below 90% of the manufacturers rating."

A mark-up of TS Bases page B 3.8-59 was provided with Reference 1 for your information. A revised mark-up of TS Bases page B 3.8-59 showing the above additional changes is provided in Attachment 1 for your information. As discussed in Reference 1, the TS Bases changes will be implemented within 60 days of amendment issuance. The original no significant hazards consideration included in Reference 1 is not affected by any information contained in the supplemental letter. There is one new commitment contained in this letter.

If you have any questions or require additional information, please contact Ron Byrd at 601-368-5792.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 7, 2003.

Sincerely, JCRIRWB/amt Attachments:

1. Revised Markup of Technical Specification Bases Pages

2. List of Regulatory Commitments cc: (See Next Page)

August 7, 2003 GNRO-2003/00044 Page 3 of 3 cc: Mr. Thomas P. Gwynn Acting Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 U. S. Nuclear Regulatory Commission Attn: Mr. B. K. Vaidya MS OWFNI7D-1 Washington, DC 20555-0001 Mr. Brian W. Amy, MD, MHA, MPH Mississippi Department of Health P. 0. Box 1700 Jackson, MS 39215-1700 Mr. T. L. Hoeg, GGNS Senior Resident Mr. D. E. Levanway (Wise Carter)

Mr. L. J. Smith (Wise Carter)

Mr. N. S. Reynolds Mr. H. L. Thomas

Attachment I To GNRO-2003100044 Revised Markup of Technical Specification Bases Pages to GNRO-2003/00044 Page 1 of 1 DC Sources- Shutdown B 3.8.4 BASES SURVEILLANCE SR 3.8.4. (continued)

REOUIREMENTS The Surveillance Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85X of Its expected life and capacity is

< 100iof the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However, if the battery r /re,shows no degradation but has reached 851 of its expected

( L3 C sWA lca life, the Surveillance Frequency -5 only reduced to Add V"on I c _24 months for batteries that retain capacity i 1001 of the manufacturer's rating. Degradation Is indicated when the battery capacity drops by more than 103 of rated capacity 7/ie- hcv'zswo,-'o3 901 -z- itc - z previous performance testp'or is below of the manufacturer's rating. These Frequencies are

+Cist m sy 6 e. based on the recommendations in IEEE-450 (Ref. 8).

10 This SR is modified by a Note. The reason for the Note is IF W t that performing the Surveillance would remove a required DC C¢4IC A16o ov t#A electrical power subsystem from service, perturb the HsANcs 8 {Cow J _electrical distribution system, and challenge safety OY ,

/5 X systems. Credit may be taken for unplanned events that w~ old e i. / satisfy the Surveillance.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. Regulatory Guide 1.6, March 10, 1971.

3. IEEE Standard 308, 1978.

4. UFSAR, Section 8.3.2.

5. UFSAR, Chapter 6.

6. UFSAR, Chapter 15.

7. Regulatory Guide 1.93, December 1974.

i. IEEE Standard 450, 1987.

9. Regulatory Guide 1.32, February 1977.

10. Regulatory Guide 1.129, December 1974.

11. IEEE Standard 485.

GRAND GULF B 3.8-59 LDC 97070

Attachment 2 To GNRO-2003100044 List of Regulatory Commitments to GNRO-2003/00044 Page I of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

Entergy agreed to revise the TS Bases for SR X Within 60 3.8.4.8 such that future performance tests will days of compare battery capacity with the previous amendment performance test rather than the average of the issuance previous performance tests.