IR 05000333/1988011

Insp Rept 50-333/88-11 on 880501-0617.No Violations Noted. Major Areas Inspected:Plant Activities,Previous Insp Findings,Lers Review,Operational Safety Verification,Storage Battery Adequacy Audit & Physical Security Review

ML20151D834
Person / Time
Site:	FitzPatrick
Issue date:	07/12/1988
From:	Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151D830	List: IR 05000333/1988011 ML20151D827
References
50-333-88-11, NUDOCS 8807250257
Download: ML20151D834 (26)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N .50-333/88-11 Docket N License No. OPR-59 Licensee: Power Authority of the State of New York P.O. Box 41 Lycoming, New York 13093 Facility: J. A. FitzPatrick Nuclear Power Plant location: Scriba, New York i Dates: May 1, 1988 - June 17, 1988 l Inspectors: A.J. Luptak, Senior Resident Inspector R.A. Plasse,'Jr. , Resident Inspector

^;W= 7 / I blW Approved by: h.R. Jo% son, Chief, Reactor ' Da t'e

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i Projects Section 2C, ORP INSPECTION SUMMARY Areas ~ Inspected:

Routine and reactive inspection during day and backshift hours of plant activities, previous inspection findings, Licensee Event Reports review, operational safety verification, surveillance observations, maintenance observations, engineered safety feature system walkdown, storage battery adequacy audit, physical security review, and review of periodic and special reports. This involved a total of 207 inspection hours, which included 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />s-of backshift on May 5, 7, 21, June 8, and 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> of weekend / holiday inspection coverage on May 4, 15, 22, June 4, 5, 11, 198 Results:

No violations were identified during the inspection period. An unresolved item was identified concerning continuous monitoring of primary containment leakage under inerted conditions (section 4). The licensee demonstrated a conservative approach to operations by identifying and correcting concerns with the ' A' recirculation motor generator exciter brushes. In addition, the evolution of removing the motor generator from service and its return were well planned and properly controlled (section 14). One area of concern was the licensee's control of changes made to the process computer (section 3.a).

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DETAILS 1. ' Persons Contacted During-this inspection period, the inspector interviewed or held discussions with operators, technicians', maintenance, contractor, engineering, administrative, and supervisory personne . Summary of Plant Activities The inspection period began with the plant at full power. On June 11, power was reduced to 40*4 to support exciter brush replacement on the

' A' recirculation pump motor generator (MG) set. Repairs were completed and tne plant returned to full power the same day. The plant remained at full power throughout the remainder of the inspection perio . Review of Plant Events Loss of Plant Process Computer (71707, 93702)

On May 14, 1988, at 7:00 a.m., the process computer faile Following repair, the computer was returned to service at 2:00 p.m. the same day. On May 16, 1988, while reviewing the daily computer surveillances (Pls) from the weekend, the reactor-analyst supervisor discovered that the critical power ratio limit (CPRLIM) was 1.27 instead of the required value of 1.303 (per technical specification 3.1.1). The CPRLIM is dependent on core exposure and therefore increases during the fuel cycle. During troubleshooting, the computer specialist rebooted the computer with the latest backup tape available. A review of the system log indicated no changes had been made since this backup tape had been run. However, updates had been made since this tape was run but the log sheets were being reviewed and not in the log boo Therefore, the CPRLIM was based on old information from the tape and not updated with-core exposur The 1.27 CPRLIM is a less conservative value than the required value of 1.303. The potential existed that the minimum critical power ratio (MCPR) thermal limit could have been violated and not detected by the P1 core surveillanc When the problem was detected on May 16, the licensee took corrective action to update the computer with the current dat They verified that the core surveillances were correct and consistent with those prior to the computer failur In

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addition, the licensee determined that the actual value of CPRLIM l was above the required value of 1.303 during this period and therefore the actual limit was not violated.

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For long' term corrective actions, the licensee has revised the

, operating procedure for the computer to verify that the Pls, before and after a computer failure, are consistent, especially the values for the thermal limits. In addition, the procedure has been revised to ensure timely reviews of computer update logs and that the log book is up to_date. The inspector will followup licensee actions during future inspections.

l' ' Loss of Security Computers (71707, 93702)

On June 12, 1988, at 8:21 p.m., both security computers faile Initial compensatory measures were taken with the guards available on shift, and with another nine guards (the on-coming shift) on site within a half hour to supply additional compensatory measures. The failure was caused by overheating of the power supply to the concen-trator which inputs to the computer. After opening the cabinet

. housing to both the computer and the concentrator, allowing the power supply to cool, the computer systems returned to normal at 8:56 Following the loss of power, the backup computer did not fully take over the system due to interfacing problems with the

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computer that was lost and was attempting to come back on lin The licensee is reviewing this occurrence with the computer vendor for long term solution to these problems. For the short term, temporary cooling has been supplied to the cabinet. In addition, if the situation recurs in which both computers are attempting to run the-system, the licensee has been directed by the vendor to secure one of the computers. This will allow the backup to take over system monitoring. The inspector will review the licensee actions during future inspection No violations were identified during this revie . Previous Inspection Findings (92701)

(Closed) UNRESOLVED ITEM (87-03-01): Evaluate presence of elastic material and localized rust on drywell head flange face and tongues; also, procedural inconsistencies regarding drywell head torquing. The inspector reviewed the licensee's followup report (JMD-87-026) and procedural changes, finding them to be acequate. The licensee has added a prerequisite step to the vessel assembly procedure MP- requiring head flange cleaning. Clarification was also added to the bolt torque requirements by the licensee. This item is close (Closed) INSPECTION FOLLOWUP ITEM (82-15-15): Review licensee developinent and implementation of preventive nintenance program. The licensee has developed a detailed preventive maintenance plan. The first phase of the plan (the Master Equipment Jst) has been completed. The licensee has staffed a grr a which 6 cerrently L , -

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verifying vendor manuals ~and has procedures in place to complete the preventive maintenance program requirements. The inspector has reviewed these procedures and held discussions with the task force leader and considers this item closed based on the licensee planned action . Licensee Event Report'(LER) Review (90712)

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-The inspector revkwed LERs to verify that the details of the events were clearly' reported. The' inspector determined that each report was adequate to assess the event, the cause appeared accurate and was supported by details, corrective actions appeared appropriate to

' correct.the cause, and generic' applicability to other plants was not in questio During this inspection period, the following LERs were reviewed:

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LER 88-03, reported the isolation of the Reactor Water Cleanup, '

Containment Atmosphere Dilution, and Reactor Building Ventilation systems, and the start of Standby Gas Treatment system due to the loss of the 'A' Reactor Protection System Motor Generator. Followup of this event is discussed in section 3 of Inspection Report 50-333/88-0 LER 88-04, reported the as-found, out-of-tolerance setpoints on three eleven L outoffiveTargetRocksafetyreliefvalvesremovedfortesting(vendor are installed). At the time this LER was written, the licensee s had not completed testing, refurbishing, and recertification of the valves in question. The licensee has committed to submit an updated LER to include additional information relative to the cause of the setpoint drift. Additional NRr. review will be performed upon receipt of this updated LE ,

No violations were identifie . Emergency Notification System Reports (92700)

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The inspector reviewed the following events which were reported to the NRC via the Emergency Notification System as required by 10 CFR 50.7 The review included a determination that the reporting requirenents were met, that appropriate corrective actions had been taken, and that the event had been evaluated for possible generic implication The following reports were reviewed:

Event Date Subject June 12, 1988 Loss of security computers. Followup of this event is discussed in section No violations were identified, t

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7. Operational Safety Verification (71707) Control Room Observations Daily the inspector verified selected plant parameters and equipment availability to ensure compliance with Technical Specifications limiting conditions for operation. Selected lit annunciators were discussed with control room operators to verify that the reasons for them were understood and corrective action, if required, was being taken. The inspector observed shift turnovers biweekly to ensure proper control room and shif t

. manning. The inspector directly observed the operations listed below to ensure adherence to approved procedures:

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Routine power operation Power reduction, transfer to single loop to perform maintenance on the A recirculation motor generator, and return to two loop operatio Issuance of Radiation Work Permits and Work

Request / Event / Deficiency form No violations were identifie Shif t Logs and Operating Records Selected shift logs and operating records were reviewed to obtain information on plant problems and operations, detect changes and trends in performance, detect possible conflicts with Technical Specifications or regulatory requirements, determine that records are being maintained and reviewed as required, and assess the effectiveness of the communications provided by the log No violations were identifie Plant Tours During the inspection period, the inspector made tours of control rooms and accessible plant areas to monitor station activities and to make an independent assessment of equipment status, radiological conditions, safety and adherence to regulatory requirement While conducting a tour of the diesel generator rooms, the inspector identified a few minor housekeeping items which were brought to the attention of licensee management. The inspector subsequently verified that these items were corrected. In general, overall plant cleanliness and housekeeping has been very good. Continued station employee and licensee management

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attehtion is needed'to maintain this level of cleanliness and I material conditions, especially in areas where existing-maintenance is underwa No violations were identifie Tagout Verification The inspector reviewed the following' safety-related protective tagout records (PTRs).to verify that breakers, switches and/or valves were in the. required position ,

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PTR 881080 'A' Residual Heat Removal (RHR) sys+e PTR 881085 'A' RHR hydrostatic tes PTR 881101 'A' Recirculation MG Se No violations were identifie , Emergency System Operability The inspector verified operability of the following systems by ensuring that each accessible valve in the primary. flow path was ,

in the correct position, by confirming that power supplies and  !

breakers were properly aligned for ccmponents that must activate >

upon an initiation signal, and by visual! inspection of the major  :

components which might prevent. fulfillment of their functional '

requirements:

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Emergency Diesel Generator 'B' Core Spray syste 'A' Residual Heat Removal syste No violations'were identifie i 8. Surveillance Observations (61726)

-The inspector observed portions of the surveillance procedures listed ,

below to verify that the test instrumentation was properly calibrated, j approved- procedures were used, the work was performed by qualified j; personnel, limiting conditions for operations were met, and the system was correctly restored following the testin F-ST-35A, Containment Spray / Cooling Systes Logic System Functional Test, Rev. 16, dated December 22, 1987, performed May

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.F-ST-2C, Residual Hea bv al Motor Operated Valve Operability Test,-Rev. 21, dated December-22,_1987, performed June 5, 198 :

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F-ST-26K, Recirculation Pump Start-up Check of the Differential Temperature Between-the Reactor Coolant in the Idle loop to the

1. Reactor _ Vessel, Revi_5, dated March 7,1984, performed June 11, -

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The inspector also witnessed all aspects of the following surveillance test to verify th'.t the surveillance procedure conformed to specification re4uirements and had been properly, approved, limiting conditions for operation for removing equipment from service were met, testing was per formed by qualified personnel, test results met technical specification requirements, the surveillance test documentation was' reviewed, and equipment was properly restored to

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service following the test:

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F-ST-34B, Reactor Building Exhaust Monitors Instrument / Isolation Logic System Functional and Simulated Automatic Actuation Test, Re . 21, dated February 24, 1988, performed May 19, 1988; No violations were identified.

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9. Maintenance Observations (62703) The inspector observed portions of various safety-related maintenance activities to determine that redundan' components were operable, that these activities dia not violate the limiting conditions' for operation, that required administrative approvals and tagouts were obtained prior to initiating the work, that approved procedures were used or the activity was within the

"skills of the trade," that appropriate radiological controls were properly implemented, that ignition / fire prevention controls

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were properly implemented, and that equipment was properly tested prior to returning it to service, During this inspection period, the following activities were observed:

-- WR 10/45477, 'A' RHR system hydrostatic tes WR 10/05235, Change oil RHR service water pum WR 08/52273, Remove irradiated material from fuel poo WR 02/54837, Replace brushes on the ' A' recirculation pump excite _No violations were identified.

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1 Enaineered; Safety Feature (ESF) System Walkdown (71710)

~The' inspector verified the operability of the selected ESF system by ,

. performing a complete walkdown of accessible portions of the system to  :

confirm that system lineup procedures match plant. drawings and the

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as-built configuration,-to identify equipment conditions that might degrade performance,.to determine that instrumentation is calibrated and-functioning, and to verify that valves are properly positioned'and locked as appropriate:

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Standby Gas Treatment system No violations were-identifie . Physical Security Review (71709)

The inspector made observations to verify that selected aspects of the 4 station physical security program were in accordance with regulatory requirements, physical security plan and approved procedure The inspector walked down. the perimeter fence to verify that there were no obstructions in the vicinity of the fence or other fence impairments that could aid the unauthorized entry of an individual into the plan No unacceptable conditions were identifie '1 Review of Technical Specifications for Continuous Monitoring of

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PrimaryContainment{71707)

Technical Specificatto,n (TS) 4.7.A.3, requires that when the primary containment is inerted, it shall be continuously monitored for gross leakage by review of the inerting system makeup requirement Following discussion with the licensee and review of ST-400, Daily Surveillance and Instrument Check, the inspector found that although

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the inerting system makeup is recorded once o day, there is no specified acceptable value.

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The inspector determined that this specific requirement was based on the premise that when the plant was constructed, the containment would be inerted and any additional make-up would be added to account for leakage over time. However, subsequent requirements to maintain greater than a 1.7 psi differential pressure between the suppression chamber and the drywell necessitates periodic makeup to the drywell and venting of the suppression chamber. Therefore, monitoring of the inerting makeup alone is not an accurate indication of system leakag (Additionally, NRC standard BWR TS do not require any continuous monitoring of containment leakage).

Since this item was identified, the licensee has been actively pursuing more accurate methods of identifying gross leakage and attempting to determine a suitable criteri In addition, the

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.e- licensee is considering submitting a technical specification change-request eliminating this requirement. This-item is unresolved pending further rev'ew of the licensee's actions (333/88-11-01).

' 1 Review o_f Battery Conditions (71707, 61726)

In.accordance with the Region I Temporary Instruction'(TI) 87-07,

Storage Battery Adequacy Audit", the inspector reviewed the existing condition and control of the storage-batteries at FitzPatric '

The scope of the inspection was to assess the adequacy of control over n stcrage battery operability and compliance with existing NRC requirements. Appendix 1 was provided to assist the licensee in providing information to support this inspection. The inspector reviewed the licensee's response to Appendix 1 (memorandum JTS-88-0203, dated May 20, 1988), and performed an independent review of battery conditions and the procedures utilized to maintain the batteries. The inspector also accompanied an auxiliary operator on a rout.ine daily tour in the LPCI battery rooms, as required by' Procedure No. 17, Auxiliary. Plant Tour and Operating Log The following batteries which provide vital DC loads were inspected:

Designation Power Supplied Station Battery 71SB-1 Various vital DC loads (125V DC)

Station Battery 715B-2 Various vital DC loads (125V DC)

'A' LPCI Battery 71 BAT-3A LPCI bus MOVs

'B' LPCI Battery 71 BAT-38 LPCI bus MOVs The following safety significant batteries were also inspected:

Nuclear Instrument Batteries Power Supplied ,

71-IB-1; 71-IB-2 Nuclear Instrumentation and 71-IB-3; 71-IB-4 Radiation Monitoring Instrumentation Diesel Fire Pump Batteries Diesel Fire Pump [

(4-12V automotive type batteries to make 2-24V batteries)

The inspector visually inspected the condition of the batteries for .

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- Correct cell' electrolyte level Battery caps in place with no thermometer installe Adequate Battery Room ventilation in operatio Elimination of combustibles and loose equipmen .No cracked cells, electrolyte leakag No-localized heat sources (steam piping, local heaters).

The. inspector also noted that the auxiliary operator checked the general condition of the battery rooms (i.e. cleanliness, electrolyte levels, cracked cells, etc.) as required, and documented in the-Routine Auxiliary Operation Logs Piocedure No.1 This'is performed every shift in addition to the weekly battery surveillance tests. 'Any

' discrepancies noted on these logs is brought to the immediate attention of_the shift supervisor so that corrective action car be taken if necessar The following procedures were reviewed by.the inspector:

MP-71-10, LPCI Battery Weekly Surveillance Test MP-71-11, LPCI Battery Quarterly Surveillance Test MP-71-12,125V. Station Battery Weekly Surveillance Test MP-71-13,125V Station Battery Quarterly Surveillance Test MP-71-20,125V Station Battery Service Test and Charger Performance Test (once per operating cycle)

F-ST-2F, LPCI Battery Service Test (once per operating cycle)

F-ST-160, 125V DC Station Battery Performance Discharge and Charger Test (every 5 years)

F-ST-16H, LPCI. Independent Power Supply Performance Discharge Test (every 5 years)

F-ST-16G, LPCI Battery Monthly Test F-ST-19, Battery Room Ventilation Equipment Operability Test (weekly)

F-ST-76C, Diesel Fire Pump Operational Check The inspector found the condition of the batteries acceptabl Battery rooms were found to be clean and well maintaine Overall, the licensee's battery controls are adequate. Battery checks performed by the auxiliary operators every shif t during their daily plant tours exemplify the licensee safety perspective towards the batteries. This check is performed in addition to the weekly surveillance check by technicians cognizant over the batterie No violations were identified.

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14. AssuranceofQuality(71707) ,

This section is-included to provide assessment of the licensee's i oversight'and effectiveness in ensuring activities are conducted-in a ;

manner which assures qualit The licensee's actions in detecting and replacing the 'A'  !

recirculation MG set exciter brushes were noteworthy. The identification of the problem and management decision to reduce power *

and. replace the brushes demonstrate a conservative approach to

' operations. The evolution of reducing power, transfer to single loop and back, and replacement of the brushes, was properly preplanned and ;

executed in a controlled manner. This is an example where the t licensee took corrective actions prior to an equipment failure which i had the potential to cause a plant transien The inspectors have also noted that while overall-cleanliness and housekeeping have been very good, continued attention to this area y from all licensee personnel is necessary to maintain this level of r cleanliness, especially in ongoing maintenance area '

The inspectors noted some concerns with the control of the plant's precess computer (see section 3). Although no actual tharmal limits '

were violated, the potential existed. The root cause was inadequate control of data for and ch:nges to the process computer. The liceasee needs to assure quality in this area as they do for other equipment'

, important to safety, t 1 Review of Periodic and Special Reports (90713)

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Upon rt.ceipt, the inspector reviewed periodic and special report ' *

The review included the following: inclusion of information required i by the NRC; test results and/or supporting information consistent with .

design predictions and performance specifications; planned corrective [

action for resolution of problems, and the repertability and validity i of report information. The following periodic reports were reviewed: !

--' April 1988, Operating Status Report, dated May 9, 198 May 1988, Operating Status Report, dated June 7, 198 l

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No unacceptable conditions were note . Annual Emergency Preparedness Exercise l

.On May 17, 1988, an announced annual emergency preparedness exercise "

was conducted. This was a partial participation exercis The State i of New York and the County of Oswego participated with the licensee at the EOF and Joint News Center. FEMA did not observe these activitie The licensee's activities were observed by a team from Region I and the resident inspector. No significant deficiencie's were observed by I the NRC during the exercise. It was concluded that the New York Power ;

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~. Authority demonstrated their ability to protect the health.and safety

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of,the' public in the event <of an emergency. Details of the

, observatio'ns made during the exercise will-be discussed in Inspection Report 50-333/88-0 ~17. . Meeting With Local Official (94600)

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N' " 0n May 13,.1988;. the Nine Mile Point and FitzPatrick' resident

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inspectors met with the Mayor of the City of Oswego. The purpose of the. meeting.was to familiarize the Mayor with the role of the NRC-resident-inspectors. Topics discussed -included . resident . inspector coverage of routine and off-normal plant events, NRC and licensee Emergency Plans, the NRC Inspection Program and the Systematic Assessment ~of Licensee Performance process. No additional concerns were identified during tiu , meetin . Exit-Interview (30703)

At pericdicl intervals during the course of this inspection, meetings were held with sento, facility management to discuss inspection scope and findings. In addition, at the eno' of the period, the inspector met with licensee representatives and summarized the scope and findings of the inspection as they are described in this repor Based on the. NRC Region I review.of this report and discussions held with-NYPA representatives during the exit meeting, it was determined

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that this report does not contain information subject to 10 CFR 2.790 restriction .

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J',, APPENDIX 1 NRC Inspection' Report

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No. 50-333/88-11 TI 88-07 ATTACHMENT >

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STORAiE BATTERY INSPECTION SAMPLE The following identifies'the wet cell battery Inspection sampl It may be provided to the licensee for more efficient identification of data relevant to assessing compliance with.the. current licensing basi , General Battery Information

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Document the below information for batteries which carry vital load (1) Qualified, or design, seismic lif (2) Qualified, or design, electrical lif (3) Ag (4) Time in servic (5) Plans for replacemen . Previous Licensee Actions Identify actions takenRon theofollowing IE Information Notices: 83-11, Possible Seismic ' Vulnerability of Old Lead Storage Batteries; 84-83, Various Battery Problems;-85-74, Station Battery Problems; and 86-37, Degradation. of Station Batterie . Seismic Lifetime and Qualification For batteries supplying vital' loads, identify the following informatio (1) = Licensee and/or manufacturer's establishment of seismic lifetim This n.aybe through documentation allowing verification by competent personnel other than the qualifiers and containing design specifica-tions, the qualification method, results, and justifications (ref:

IEEE 535-1986).

(2) Seismic qualification maintenance. Identify how the criteria for assuring that the battery and rack will maintain seismic aualifica-tion are defined, available, and used for periodic inspections and cell replacements. Identify the criteria for determination of seismic end of life based upon the in-service condition of the batter .

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1 '4. Electrical Sizing and Qualification For batteries supplying vital loads, identify the following informatio (1) Confirmation that the battery size is sufficient to handle the load profile with a suitable margi (2) 'The means of tracking .d control of battery loads such that the batteries and their replacements will have sufficient capacity throughout design. life, if worst case electrolyte temperature and other worst case conditions exist when the battery is called upon to perform its design functio (3) The provisions for consideration of the effect of jumpered out cells upon the ability of a battery to perform under worst case condition . Battery Ventilation and Protection From Ignition Hazards For batteries carrying vital loads, identify the followin (1) The provisions for assuring adequacy battery ventilation during normal operation, outages, charging, and discharg (2) AcRquacy of checks of battery ventilation flo (3) Adequacy of controls over battery ventilation impediments such as enclosing the battery space or its ventilation with plastic sheeting, or any other ventilation obstructions, during outages and other period (4) Adequacy of hydrogen detection equipment and its calibration and use, or of the technical justification for not using such equipmen (5)' Knowledge of the hydrogen hazard on the part of plant management, operating shift management, and personnel who access the battery space (6) Prohibition of hot work and smoking in battery spaces, including checking the spaces for the residue of such activit (7) Assurance that battery cells are secured, with post-to-case and top-to-jar seals tight. Thermometers should not be left in cells after temperatures are measured. Caps on the filler openings should be properly secured when not required to be off. (Cells should be vented only through the flash arrestors.)

(8) The means of assuring proper elimination of water-carrying pipes (e.g.,

, HVAC lines) from battery spaces, especially those which may carry salt wate A2-2 i-

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J (9) The means of positive control'over.the quality of water added to the batteries to assure that the manufacturer's recommendations or an appropriate licensee standard are met or exceede (10) The assurance of elimination of combustibles, and loose equipment and conductors, from battery space .6.- Electrolyte Temperature Control For batteries supplying vital loads, identify the adequacy of the-followin (1) Avoidance of localized heat sources such as direct sunlight, radiatsrs, steam pipes,.and space heater (2) That the location / arrangement provides for no more than a SF difference in cell temperature, as confirmed by measurements representative of operating conditions. If this is not the case, then the licensee and manufacturer should have identified the consequent impact on expected battery and individual cell capacity and life,-and surveillance procedures should reflect the additional allowable temperature variatio . Charging For batteries carrying vital loads, identify the adequacy of the followin (1) Provision for a freshening charge after more than 3 months of being on open circuit, unless determined by the manufacturer to be unnecessary to assure rated capacity throughout lif (2) Accc.tplishment of equalizing charges at 18 month intervals, and when the corrected specified gravity (SG) of an individual cell is more than 10 point (0.010) below the average of all the cells, and when the average corrected SG of all cells drop more thar, 10 points below the average installation value, and if any cell voltage is below 2.13 (Specific manufacturer's provisions and assessment may allow the non-performance of some of these recommended charges, or may provide different criteria.)

(3) Control over battery water quality such that specified purity is confirmed before addition, that water added just prior to charging is added only to bring the electrolyte up to the prescribed minimum (to prevent overflow during charging), and that water added after and between charges not bring the level above the prescribed maximum (unless manufacturer's instructions provide for other water addition

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measures).

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p (4) That routine float and final end of charge,SGs_not be caken before 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of float operation after completion of the charge and the last water _ addition, unless-the manufacturer's instructions provided othe rwi se. (The need is for measurement of reprcsentative cell

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(5) Establishment and maintenance of float voltage on accordance with the manufacturer's. instruction (6) Assurance that single-cell charger use does not violate Class 1E independence from non-class 1E equipmen EL Performance Tests and Replacement Criteria For batteries carrying vital loads, identify the followin (1) Initial acceptance testing which demonstrates the ability of the batteries to meet the manufacturer's ratin (2) Service testing which demonstrates the ability to carry the load profile with an appropriate margin for worst case conditions, including _end of life loss of capacity under the worst case electrolyte temperatur (3) -Accomplishment of a performance test (capacity test discharge)

.within the first two years of service and at 5 year intervals until signs of degradation are evident or 85% of the qualified service life is reache (4) Annual performance testing of batteries which show signs of degradation or which have reached 85% of the qualified service life is reache (5) End of electrical life criteria which consider the rapid end of life drop-off in capacity, worst case state of charge during float service, worst case electrolyte temperature, current DC loads, and the time needed to replace the battery while it can still handle worst case condition . Other Safety-Significant Wet Cell Batteries

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For safety-significant wet cell batteries not used for vital loads, show how the maintenance program periodic.-11y determines the ability to perform the design function and provides for timely replacement of

batteries and for maintaining associated equipment (e.g., chargers).

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i ENCLOSURE (2) APPENDIX 2

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., JAF Battery Response to NRC Storags *

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_ Battery Inspoction Sample GENERAL This enclosure provides a response to questions contained in the Battery Inspection Sample for storage batteries supplying vital loads at the James A. FitzPatrick Nuclear Power Plant. The two station batteries addressed are: a) the 125 VDC station bat-teries,-Plant ID Nos. 71SB-1 and -2 (Gould NCX-2400), and b) the LPCI batteries,. Plant ID Nos. 71 BAT-3A and -3? (Exide EC-19). General Battery Information Document the below information for batteries which carry vital load ) Qualified, or design, seismic lif ) Qualified, or design, electrical lif ) Age 4) Time in servic ) Plans for replacemen JAF Response 1) Both JAF safety-related batteries are qualified for seismic per IEEE 323-1974, 344-19/5, and 535-1979 as documented in References 1 and 14 of Enclosure (2).

For the station battery, a seismic qualified life of 10 years is established based on the qualification of 10 year old naturally aged batteries. The LPUI battery was thermally aged prior to seismic testing. Qualified life is 18 year ) Both JAF safety-related batteries are qualified to IEEE 323-1974 and 535-1979 as documented in References 1 and 1 The qualified life based on these programs are as follows:

a) 125V Station Battery - Qualified Life is 10 years per Reference 14 of Enclosure (2).

b) LPCI Battery - Qualified Life is 18.1 years per Reference 1 of Enclosure (2).

3) Age a) 125V Station Battery - 4 year Batteries were installed in 198 b) LPCI Battery - 3 year Batteries were installed in 1984/1985.

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.. 4 ). Time in service is assumed to be the sama as battery ag . 5) The batteries will be replaced before the end of y qualified life unless existing qualification programs ;

are able to extend the qualified life through addition-al testin Replacement is also dependent upon perfor-mance during surveillance testing (capacity tests, performance test, physical condition, etc.).

2. _P_revious Licensee Actions Identify actions taken on the following IE Information Notices: 83-11, Possible Seismic Vulnerability of Old Lead Storage Batteries: 84-83, Various Battery Problems. 85-74, Station Battery Problems and 86-37, Degradation of Station Batterie JAF Response NYPA's actions to battery-related IE Notices are documented in the following memorandums:

IE 83-11 -

JAF Memorandum TS-83-181 IE 84-83 -

JAF Memorandum OER 0494 IE 85-74 -

JAF Memorandum OER 850331 IE 86-37 -

JAF Memorandum OER 860147 3. Seismic Lifetime and Qualification For batteries supplying vital loads, identify the following in forma tion:

1) Licensee and/or manufacturer's establishment of seismic lifetim This may be through documentation allowing verification by competent personnel other than the qualifiers and containing design specifications, the qualification method, results, and justifications (Reference IEEE 535-1986).

2) Seismic qualification maintenanc Identify how the criteria for assuring that the battery and rack will maintain seismic qualification are defined, available, and used for periodic inspections and cell replace-ment Identify the criteria for determination of seismic end-of-life based upon the in-service condition of the batter JAF Response 1) Refer to NYPA response to 1(1).

2) Quarterly surveillance tests, References 2 and 3, require inspection of battery racks and battery rack fastener Maintenance Procedure 57.6 specifies Page -2-

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F ENCLOSURE (2)

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(Continued)

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corroctiva maintenance steps for battery rack Based

on satisfactory battery performance testing and the above inspections and maintenance, the seismic end of life is the same as the battery qualified Itf l

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4 Elec tr_i__ca l___ Sizing _ and Qualification For batteries supplying vital loads, identify the following information:

1) Confirmation that the battery size is sufficient to handle the load profile with a suitable margi ) The means of tracking and control of battery loads such that the batteries and their replacements will have sufficient capacity throughout design life, if worst case electrolyte temperature and other worst case conditions exisc when the battery is called upon to perform its design functio ) The provisions for consideration of the effect of jumpered out cells upon the ability of a battery to perform under worst case condition JAF Response 1) Load analyses available in NYPA design file Refer to Reference (4) for station batteries and Modification F1-77-009 for LPCI batterie ) All changes to plant configurations are controlled by Work Activity Control Procedure 10.1.6 and checked per Engineering and Design Procedures EDP-1 and EDP- ) Evaluated on a per case basis in accordance with WACP 10.1.3 and WACP 10. . Batterv Ventilation and Protection from Ignition Hazards _

For batteries carrying vital loads, identify the following:

1) The provisions for assuring adequate battery ventila-tion during normal operation, outages, charging, and discharg ) Adequacy of checks of battery ventilation flo ) Adequacy of controls over battery ventilation impedi-ments such as enclosing the battery space or its ventilation with plastic sheeting, or any other ven-tilation obstructions, during outages or other period ) Adequacy of hydrogen detection equipment and its calibration and use, or of the technical justification for not using such equipmen Page -3-

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5)

.. Knowledge of tho hydrogon hazerd on the part of plart mcnagsmant,

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oporating shift management, and personnal who access the battery space )

Prohibition of hot work and smoking in batterv spaces, including checking the spaces for the residue of such activit )

Assuring that battery cells are secured, with post-to-case and top-to-jar seals tight. Thermometers should not be left in cells after temperatures are measured. Caps on the filler openings should be properly secured when not required to be off. (Cells should be vented only through the flash arrestors.)

8) The means of assuring proper elimination of water-carrying pipes (e.g., HVAC lines) from battery spaces, especially those which may carry salt wate ) The means of positive control over the quality of water added to the batteries to assure that the manufactur-er's recommendations or an appropriate licensee stan-dard are met or exceede ) The assurance of elimination of combustibles, and loose equipment and conductors, from battery space JAF Respon_s_e 1) Technical Specification, Section 3.11.C, and Operating Procedure F-OP-43A (125VDC Power System), state that battery room ventilation shall be operable on a con-tinuing basis whenever the station satteries and associated chargers are in servic ) Battery scheduleroom ventilation5.systems are tested on a weekly per Reference 3) Batteries are located in separate rooms which are vented directly to the outside environment. All work activities in these areas are controlled by WACP 10. ) Hydrogen detection equipment is not installed. Ven-tilation system is sized to keep H concentration below explosive limits during worst case2condition ) Procedures include use of open flames. precautions against Warning signs are smoking posted onandthethe doors into the Battery Room ) All maintenance and test procedures contain precautions against introduction of sparks, open flames, or burning material into battery rooms. Battery Rooms are checked weekly for cleanliness, see References 6 and Page -4-

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7)

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Maintenanco procedurec include stops to assure that '

filler caps are installed, seo References 2, 3, 6, and ) There are no water pipes in the battery room ) Maintenance procedures require the use of distilled or demineralized water for filling battery cells, References 2 and see 10)

Battery rooms are not used for storage of equipment or materia There tre weekly checks for cleanlines Refer to Referencas 6 and . Electrolyte Temperature Control Forthe of batteries supplying vital loads, identify the adequacy following:

1)

Avoidance of localized heat sources such as direct sunlight, radiators, steam pipes, and space heater ) That the location / arrangement provides for no more than a 5'F difference in cell temperature, as confirmed by measurements representative of operating condition If this is not the case, then the licensee and manufac-turer should have identified the consequent impact on expected battery and individal cell capacity and life, and surveillance procedures should reflect the addi-tional allowable temperature variatio JAF Response 1) There are no heat sources in the battery rooms, other than the battery room ventilation system ) Cell temperature measurements made on a quarterly basis during plant life confirm the adecuacy of battery location / arrangement as well as adequacy of Battery Room Ventilation Systems. Refer to References 2 and . Charging For batteries carrying vital loads, identify the adequacy of the following:

1) Provision for a freshening charge after more than 3 months of being on open circuit, unless determined by the manufacturer to be unnecessary to assure rated capacity throughout lif ) Accomplishment of equalizing charges at 18 month intervals, and when the corrected specified gravity (SC) of an individual cell is more than 10 point (0.010) below the average of all the cells, and when Page -5-

EN$LoSURE (2)

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,. th2 cycrage corrected SG of all collo drop more than 10 *

points below the average installation value, and if any cell voltage is below 2.13 (Specific manufacturer's provisions and assessments m6y allow the non-perform-ance of some of these recommended charges, or may provide different criteria.)

3) Control over battery water quality such that specified purity is confirmed before addition, that water added just prior to charging is added cnly to bring the electrolyte up to the prescribed minimum (to prevent overflow during charging), and that water added after and between charges not bring the level above the prescribed maximum (unless manufacturer's instructions provide for other water addition menaures).

4) That routine float and final end-of-charge SG's not be taken before 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of float operation after comple-tion of the charge and the last water addition, unless the manufacturer s instructions provided otherwis (The need is for measurement of representative cell levels and average them.)

5) Establishment and maintenance of float voltage in accordance with the manufacturer's instruction ) Assurance that single-cell charger does not violate Class lE independence from non-class IE equipmen JAF Response 1) Not applicable to NYP Batteries are always connected and on float charge except for short down-times for charger / inverter maintenanc Replacement cells always receive the vendor recommended freshening charge before installatio ) References 8 and 9 require that an equalizing charge be applied at 18 month interval Equalizing charges are also required whenever a single cell voltage drops below 2.13 VDC, or specific gravity is less than 1.20 Refer to References 2 and ) Procedures specify that only distilled or domineralized water may be used to replenish electrolyt Also, water is not added prior to special charging cycle Refer to References 2 and 3 for 1cvel adjustment requirements when adding wate ) Procedures require a delay of one week (168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />)

l before measurement of the final post-charge specific gravity measurement Refer to References 8, 9, 10, I and 11.

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5) Operating procedures, Roferencos 12 and 13, specify *

flost voltages which agree with manufacturers' rec-ommendations. These values are verified weekly per

, References 6 and ) The question of separation of Class 1E and Non-Class 1E equipment during single cell charging has not been addresse . Performance Tests and Replacement Criteria For batteries carrying vital loads, identify the following:

1) Initial acceptance testing which demonstrates the ability of the batteries to meet the manufacturer's ratin ) Service testing which demonstrates the ability to carry the load profile with an appropriate margin for worst case conditions, including end-of-life loss of capacity under the worst case electrolyte temperatur ) Accomplishment of a performance test (capacity test discharge) within the first two years of service and at 5 year intervals until signs of degradation are evident of 85% of the qualified service life is reache ) Annual performance testing of batteries which show signs of degradation or which have reached 85% of the qualified service life is reache ) End of electrical life criteria which consider the

. rapid end-of-life drop off in capacity, worst case state of charge during float service, worst case electrolyte temperature, current DC loads, and the time needed to replace the battery while it can still handle worst case condition JAF Response 1) For the 12SV station batteries, a capacity test was performed by the vendor prior to delivery and a service test was performed after installation. For the LPCI batteries, a capacity test, per Reference 11, was performed after installatio ) Service tests are designed to demonstrate ability to carry design load in conformance to IEEE Standard 450-1980. Refer to References 8 and ) Performance tests are performed on a S year schedule as required by Technical Specification Refer to Refer-ences 10 and 1 Page -7-

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4 ). More frequsnt test schedules as a function of measured '

bettery capacity is not Refer

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to References 10 and 11.part of testdegraded However, procedure test !

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capacities would be addressed if a battery capacity were found to be less than 100%.

i 5) End-of-life criteria is not part of test procedure Refer to References 10 and 11  !

l 9. Other Safety-Significant Wet Cell Batteries l For safety-significant wet cell batteries not used for vital loads, show how the maintenance program periodically deter-mines the ability to perform the design function and pro-vides for timely replacement of batteries and for maintain-ing associated equipment (e.g., chargers).

Other safety-significant batteries not carrying vital loads in the JAF Plant are:

a) Four 24 volt nuclear instrument batteries (non-safety related)

b) Two 24 volt diesel fire pump batteries a) Nuclear Instrument Batteries There are four instrument batteries which are located in the two Station Battery Rooms, two to each roo Each battery is supplied with a separate battery charger. These batteries were upgraded and replaced in 1985 after 12 years of servic Maintenance Procedure MP-71.14 is performed weekly, and records temperature, level, and specific gravity of the pilot cells, and the panel readings of the associated battery charge Maintenance Procedure MP-71.16 is performed quarterly and requires documentation of the following checks:

1) Voltage, temperature, level and specific gravity of each cel ) Overall battery voltag ) Visual inspection of batteries and battery rack ) Area cleanlines b) Diesel Fire Pump _ Batteries There are four 12 volt automotive type batteries connected to make two 24 volt batteries located in the Diesel Fire Pump Room off the screenwel Page -8-

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Survaillcnco Test Procedure F-ST-76C requires wackly

• chseks of battery voltage end cloctrolyte leval plus weekly start of diesel fire pump to verify opera,bilit *

Maintenance Procedure 76.10 is performed quarterly and records temperature, electrolyte level, and specific gravity of each cel Visual inspection of batteries and battery rack is also performe REFERENCES

EQ Reference 280, Final Report on the Evaluation of the

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Exide EC-19 Storage Batteries MP-71.13, 12SV Station Battery Quarterly Surveillance Test MP-71.11, LPCI Battery Quarterly Surveillance Test Report No. EDA-JAF-87-B01, Evaluation Report for Battery

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Design Duty Cycle (125V Station Battery) ) F-ST-19, Battery Room Ventilation Equipment Operability Test MP-71.12, 125V Station Battery Weekly Surveillance Test MP-71.10, LPCI Battery Weekly Surveillance Test MP-71.20, 125V Station Battery Service Test and Charger Performance Test F-ST-2F, LPCI and LPCI MOV Power Supply Simulated Automatic Actuation Test and LPCI Battery Service Test 1 F-ST-16D, Charger 125V DC Station Battery Performance Discharge and Test 1 F-ST-16H, LPCI Independent Power Supply Performance Dis-charge Test 1 F-OP-43A, 125V DC Power System 1 F-OP-43C, LPCI Independent Power Supply System 1 EQ Reference 176, Environmental Qualification Report for i

Gould NCX-2400 Station Batteries and Racks Page -9-l

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ENCLOSURE (3)

, , Ganarel Bnttery Information

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1. 125 VDC Station Battery

. Plant Identification Numbers: 71SB-1 and 715B-2 Manufacturer: Gould in Model No.: NCX 2400 (2400 Amp Hours)

Function: Provide electrical power for plant vital DC loads (125 Volts).

Purchase Order No.: 83-4564 *

September, 1983

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Installation Date:

2. LPCI Battery Plant Identification Numbers: 71 BAT-3A and 71 BAT-3B Manufacturer: Exide Corporation Model No.: EC-19 (800 Amp-Hour)

Function: Provide independent electrical power for valves in the Low Pressure Coolant Injection system (419 Volts).

Purchase Order No.: 84-3465 Installation Dates: 71 BAT-3A - December, 1984 71 BAT-3B -

June, 1985 l

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