GNRO-2013/00080, License Amendment Request Revision to Battery Cell Resistances to Address Potential Non-Conservative Technical Specification Grand Gulf Nuclear Station, Unit 1

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License Amendment Request Revision to Battery Cell Resistances to Address Potential Non-Conservative Technical Specification Grand Gulf Nuclear Station, Unit 1
ML14177A270
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 06/26/2014
From: Miller O
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2013/00080
Download: ML14177A270 (12)
v • d • e


Text

Q

~Entergy GNRO-2013/00080 June 26, 2014 u.s. Nuclear Regulatory Commission Attn: Docu'ment Control Desk Washington, DC 20555-0001 Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Grand Gulf Nuclear Station Tel. (601) 437-2129 Ogden J. Miller General Manager, Operations

SUBJECT:

License Amendment Request Revision to Battery Cell Resistances to Address Potential Non-Conservative Technical Specification Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. 29

Dear Sir or Madam:

In accordance with the provisions of Section 50.90 of Title 10 Code of Federal Regulations (10 CFR), Entergy Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications (TS) for Grand Gulf Nuclear Station, Unit 1.

The proposed amendment modifies the TS Surveillance Requirements (SRs) for,safety-related batteries in TS SRs 3.8.4.2 and 3.8.4.5. This change is needed to address a potential non-conservative TS value. provides a description of the proposed change. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 shows the proposed change.

Approval of this amendment is requested within one year after the date of this submittal.

Once approved, the amendment shall be implemented within 60 days.

This letter contains no new commitments. If you have any questions or require additional information, please contact Mr. James Nadeau at (601) 437-2103.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 26, 2014.

Attachments and CC: (see next page)

GNRO-2013/00080 Page 2 of 2 Attachments:

1.

Analysis of Proposed Technical Specification Change 2.

Proposed Technical Specification Changes (mark-up) 3.

Proposed Technical Changes (clean page) cc:

U.S. Nuclear.Regulatory Commission ATTN: Mr. Mark Dapas, (w/2)

Regional Administrator, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATIN: Mr. Alan Wang, NRR/DORL (w/2)

Mail Stop OWFN 8 B1 Washington, DC 20555-0001 State Health Officer Mississippi Department of Health P.O. Box 1700 Jackson, MS 39215-1700 GNRO-2013/00080 Analysis of Proposed Technical Specification Change to GNRO-2013/00080 Page 1 of 3

1.0 DESCRIPTION

The proposed amendment modifies the Grand Gulf Nuclear Station (GGNS) Technical Specificat!ons (TS) Surveillance Requirements (SRs) for safety-related battery resistances in TS SRs 3.8.4.2 and 3.8.4.5 for batteries 1A3, 1B3, and 1C3.

2.0 BACKGROUND

Review of Operating Experience (OE) from Quad Cities identified a potential non-conservative TS value for safety-related battery inter-cell resistances. In response, administrative controls in surveillance procedure 06-EL-1 L11-R-0001, "125 Volt Battery Bank Physical Condition Check" were implemented in 2007 until the non-conservative SRs could be resolved. All surveillances performed in the past 3 years have met the more restrictive acceptance criteria.

TS SR 3.8.4.2 (page 3.8-27) and TS SR 3.8.4.5 (page 3.8-28) list battery connection resistances for inter-cell, inter-rack, inter-tier, and terminal connections to be s 1.5 E-4 ohm for Division 1 (1A3), Division 2 (1B3), and Division 3 (1C3) batteries. Institute of Electrical and Electronics Engineers (IEEE) Power Engineering Society correspondence indicates it is likely these values were inadvertently introduced into the GGNS TS from an example of nominal values provided in a draft template related to development of Standard Technical Specifications during the 1980s. Some plants implemented the s 1.5 E-4 ohm acceptance criteria as the nominal value with no further basis.

3.0 TECHNICAL ANALYSIS

To determine the new acceptance criteria, the results of each battery's performance discharge test (06-EL-1 L11-R-003) were reviewed to determine the worst case portion of the discharge profile. The difference between the minimum measured battery terminal resistance and the minimum allowable value of each was then divided by the total number of cells in the battery and the current observed at that particular moment. This resulted in the average additional connection resistance that could be tolerated by the battery.

Engineering Change (EC) 43968 concluded -the following acceptance criteria are appropriate TS SR 3.8.4.2 and TS SR 3.8.4.5 resistances for batteries 1A3, 1B3, and 1C3.

For Division 1 and Division 2 connection resistance:

s 0.5 E-4 ohm (50 IJO) for inter-cell connections and s 1.0 E-4 ohm (100 IJO) for inter-rack or inter-tier connections.

For Division 3 connection resistance:

s 1.0 E-4 ohm (100 IJO) for inter-cell and inter-tier connections.

This change will impose more restrictive allowance values than s 1.5 E-4 ohm (150 IJO) for all connections in all three divisions.

to GNRO-2013/00080 Page 2 of 3 4.0 REGULATORY SAFETY ANALYSIS 4.1 No Significant Hazards Consideration Determination Entergy Operations, Inc. (Entergy) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in Title 10 Code of Federal Regulations (10 CFR) 50.92, "lssuance of amendment, II as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises the TS SRs for safety-related battery resistances in TS SRs 3.8.4.2 and 3.8.4.5. This change addresses a potential non-conservative TS value. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change revises the TS SRs for safety-related battery resistances in TS SRs 3.8.4.2 and 3.8.4.5. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operations. The change does not alter assumptions made in the safety analysis.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change revises the TS SRs for safety-related battery resistances in TS SRs 3.8.4.2 and 3.8.4.5. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. This change addresses a potential non-conservative TS value. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of "no significant hazards consideration" is justified.

to GNRO-2013/00080 Page 3 of 3 4.2 Applicable Regulatory Requirements/Criteria The direct current (DC) electrical power system is required by 10 CFR 50, Appendix A, General Design Criteria (GDC) 17. According to the GGNS TS Bases, the resistance measurements required by TS SRs 3.8.4.2 and 3.8.4.5 provide an indication of physical damage or abnormal deterioration that could potentially degrade battery performance, and do not state resistance measurement acceptance criteria. As this revision addresses a potentially non-conservative value, these two TS SRs will continue to meet the intent described in the TS Bases and meet the requirements of 10 CFR 50, Appendix A, GDC 17.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a TS SR. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 CONCLUSION

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the NRC's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

GNRO-2013/00080 Proposed Technical Specification Changes (mark-up)

Note, markup deletions identified by strikethrough (aetete) and additions identified by underline (addition).

DC Sources-Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Division 3 DC D.1 Declare High Pressure Immediately electrical power Core Spray System subsystem inoperable inoperable.

for reasons other than Condition A.

E.

Required Action and E.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition C or AND D not met.

E.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SR 3.8.4.1 SR 3.8.4.2 GRAND GULF SURVEILLANCE Verify battery terminal voltage is

~ 129 V on float charge.

Verify no visible corrosion at battery terminals and connectors.

Verify Division 1 and 2 batter~ connection resistance is

~ 1.5 [ 4 ohm for inter cell connections,

~ 1.5 [ 4 ohm for inter rack connections,

~ 1.5 [ 4 ohm for inter tier connections, and

~ 1.5 [ 4 ohm for terminal connections.

< 0.5 E-4 ohm for inter-cell connections and < 1.0 E-4 ohm for inter-rack or inter-tier connections.

Verify Division 3 connection resistance is

< 1.0 E-4 ohm per inter-cell and inter-tier connection.

3.8-27 FREQUENCY 7 days 92 days (continued)

Amendment No. Ire

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.3 SR 3.8.4.4 SR 3.8.4.5 SR 3.8.4.6 SURVEILLANCE Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance.

Remove visible corrosion and verify battery cell to cell and terminal connections are coated with anti-corrosion material.

Verify Division 1 and 2 battery connection resistance is

~ 1.5 [ 4 ohm for inter cell connections,

~ 1.5 [ 4 ohm for inter rack connections,

~ 1.5 [ 4 ohm for inter tier connections, and

~ 1.5 [ 4 ohm for terminal connections.

< 0.5 E-4 ohm for inter-cell connections and < 1.0 E-4 ohm for inter-rack or inter-tier connections.

Verify Division 3 connection resistance is

< 1.0 E-4 ohm per inter-cell and inter-tier connection.

Verify each Division 1 and 2 required battery charger supplies

~ 400 amps at

~ 125 V for

~ 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />; and the Division 3 battery charger supplies

~ SO amps at

~ 125 V for

~ 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

FREQUENCY 24 months 24 months 24 months 24 months (continued)

GRAND GULF 3.8-28 Amendment No. +/-re ~

GNRO-2013/00080 Proposed Technical Specification Changes (clean page)

DC Sources-Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Division 3 DC D.1 Declare High Pressure Immediately electrical power Core Spray System subsystem inoperable inoperable.

for reasons other than Condition A.

E.

Required Action and E.1 Be in MODE 3.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition C or AND D not met.

E.2 Be in MODE 4.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SR 3.8.4.1 SR 3.8.4.2 GRAND GULF SURVEILLANCE Verify battery terminal voltage is

~ 129 V on float charge.

Verify no visible corrosion at battery terminals and connectors.

Verify Division 1 and 2 connection resistance is

~ 0.5 E-4 ohm for inter-cell connections and

~ 1.0 E-4 ohm for inter-rack or inter-tier connections.

AND Verify Division 3 connection resistance is

~ 1.0 E-4 ohm per inter-cell and inter-tier connection.

3.8-27 FREQUENCY 7 days 92 days (continued)

Amendment No. ___

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.3 SR 3.8.4.4 SR 3.8.4.5 Verify battery cells, cell plates, and 24 months racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance.

Remove visible corrosion and verify battery 24 months cell to cell and terminal connections are coated with anti-corrosion material.

Verify Division 1 and 2 connection 24 months resistance is

~ 0.5 E-4 ohm for inter-cell connections and

~. 1.0 E-4 ohm for inter-rack or inter-tier connections.

AND Verify Division 3 connection resistance is

~ 1.0 E-4 ohm per inter-cell and inter-tier connection.

SR 3.8.4.6 GRAND GULF Verify each Division 1 and 2 required battery charger supplies

~ 400 amps at

~ 125 V for

~ 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />; and the Division 3 battery charger supplies

~ 50 amps at

~ 125 V for

~ 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

3.8-28 24 months (continued)

Amendment No. ___

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