ML13241A188
| ML13241A188 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/2013 |
| From: | Jennifer Davis Office of Nuclear Reactor Regulation |
| To: | Joseph E Pollock Nuclear Energy Institute |
| Kratchman J, NRR/MSD 301-415-5112 | |
| Shared Package | |
| ML13241A182 | List: |
| References | |
| EA-12-104 | |
| Download: ML13241A188 (3) | |
Text
September 16, 2013 Mr. Joseph E. Pollock, Vice President Nuclear Operations Nuclear Energy Institute 1201 F Street NW, Suite 1100 Washington, DC 20004
Dear Mr. Pollock:
The U.S. Nuclear Regulatory Commission (NRC) staff has considered your request to endorse the Nuclear Energy Institute (NEI) White Paper entitled Battery Life Issue, including its addendum, made available in your letter dated August 27, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13241A186). The purpose of the White Paper is to develop an acceptable method for demonstrating that batteries will perform as specified in a plants overall integrated plan (OIP) that satisfy NRC Order EA-12-049. The NRC staff has interacted with your staff and external stakeholders during the development of this white paper.
The NRC staff agrees that the White Paper provides an acceptable approach for demonstrating that the batteries can perform as credited in the OIP and, as such, can be used to satisfy Section 11.5, Item 1, of NEI-12-06. Therefore, the NRC staff endorses the NEI White Paper with the following clarifications:
- 1. The White Paper states that industry does not believe that the Institute of Electrical and Electronics Engineers Standard 535(IEEE 535) is applicable to beyond design basis events and that battery qualification for an extended loss of ac power event is not intended. NRC staffs position is that IEEE 535 is an acceptable approach for OIPs, although the alternative described in the white paper is also acceptable provided that licensees are able to demonstrate that the manufacturer discharge curves support the duty cycle duration assumed as part of the OIPs.
- 2. The White Paper states that the current Technical Specification surveillance and safety-related maintenance practices ensure a stations safety-related batteries are maintained ready to perform their function when required. NRC staff agrees that the current surveillance and maintenance programs ensure the batteries are capable of performing their safety-related function. The need for additional testing will be evaluated during rulemaking for Station Blackout Mitigating Strategies.
The NRC staff will evaluate a licensees application of the guidance (calculations and supporting data) in its development of the final Safety Evaluation documenting compliance with NRC Order EA-12-049.
J. Pollock Licensees are strongly encouraged to follow the guidance in the NEI White Paper, Battery Life Issue, in order to improve efficiency of the NRCs review and avoid further requests for information. If a licensee deviates from the guidance, the licensee should justify the deviations and provide information that demonstrates that the batteries will perform as assumed in the OIP.
Sincerely,
/RA/
Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation
(Pkg.) ML13241A182, (NEI) ML13241A186, (Rsp.) ML13241A188 OFFICE NRR/MSPB NRR/MSPB/LA NRR/MESB NRR/MSD NRR/MSD NAME JKratchman SLent SBailey EBowman JDavis DATE 09/09/13 08/27/13 09/11/13 09/11/13 09/16/13