ML20091Q330

Application for Amend to License NPF-38 (Consisting of TS Change Request NPF-38-121) Modifying TS 3/4.8.2, DC Sources - Operating & Table 4.8-2 Re Battery Surveillance Requirements of Ts,Per Electrical Distribution Insp

ML20091Q330
Person / Time
Site:	Waterford
Issue date:	01/30/1992
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20091Q334	List: ML20091Q330 ML20091Q337
References
NUDOCS 9202040324
Download: ML20091Q330 (7)

Text

'

l

z. Ent rgy n o"< ne-Operat!ons R. P. Dark hurst 1

I l

W3F191-0819 l A4.05 QA January 30, 1992 U.S. Nuclear Regulatory Comatission .

ATTN: Document Control Desk Washington, D.C. 20555 Subject : We terford 3 SES Docket No. 50-362 License No. NPF-38 Technical Specification Chr.nge Request NPF-38-121 Gentlemen:

The attached description and safety analysis support a modification of 3/.l. A 1, D.C. Sources - Operating and Table 4.8-2, Battery Surveillance Requirements, of the Waterford 3 Technical Specificadons s These changes resulted I' rom discussions that took place during the recent electrical distribution inspection (Inspection 00-23). As indicated in the safety aimlysis, these changes do not involve a significant hazards consideration as defined by 10 CFR 50.92.

Entergy Operations, Inc. feels these plant specific changes would result in un improvement in plant safety and therefore, should be worthy of your review.

Please direct any questions or comments to Tha Gaudet on (504) 739-GGGG.

Very truly yours, b

RPil/PLC/ssf r

Attachment:

Affidavit NPF-38-121 cc: R.D. Martin, NRC Region IV D.L. Wigginton, NRC-NRR R.B. McGehee N.S. Reynolds NRC Resident luspectors Office Administrator Radiation Protection Division (State of Louisiana)

American Nuclear Insurers i

1 030103 j

I 'I l 9202040324 920130 l- PDR ADOCK 05000382 l P PDR

v UNITED STATES OF AMElllCA NUCLEAR HEGULATORY COMMISSION

-In the matter of )

)

Entergy Operations, incorporated -) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT R.P. Burkhurst, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, Incorporated; that he is duly authorivad to sign and file with the Nuclear Regulatory Commission the attrahed Teche .;al Specification Change itequest NPF-38-121; that he is familiar with the content thereof; and that the matters set forth therein are true and-correct to the best of his knowledge, information and belief.

' 3M " MV R.P. Barkhurst Vice President Operations - Waterford 3 STATE OF LOUISIANA )

) ss PARISil OF ST. CHARLES ) -

Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this 3Or* day of J o,~ u m n y - ,1992.

6~ h Sl% ~

Notary Public My Commission expires N aN 4/74 .

I k

, 4 DESCitil' TION AND SAFETY ANAL,YSIS ,

OF PROPOSED CllANGE NPF-38-121 This proposal requests a change to Waterford 3 Technical Specification (TS) 3/4.8.2, D.C. Sources - Operating, and Table 4.8-2, Battery Surveillance Requirements. The changes raise the average electrolyte temperature of a sample of battery cells from 60 F to 70PF and adjusts the limits for speelfic gravity in Table 4.8-2 to be consistent with technical specification bases and vendor information. -

Existing Specifications See Attachment A ,

Proposed Specifications ,

See Attachment B Description The changes requested in this submittal concern Waterford 3 TS 3/4.5.2 and Table 4.8-2 which discuss operability of the on-site D.C. power sources (station batteries. ) One change concerns TS d.9.2.1.b.3 which describes surveillances on the station battery electrolyte te> nerature averaged over a random sample of connected cells. Entergy Operations Inc. wishes to increase the minimum limit for this temperature from 60 F to 70 c. Another change concerns Table 4.8-2 which contains surveillance requirements for the station batteries. Entergy Operations, Inc. is requesting to raise the spceific gravity limits in this table by 0.005 to be consistent with the bases and vendor techmcal information. These two changes resulted from discussiom associated with the Waterford J electrical o distribution system functionalinspection (EDSFI) as documented in IR 50-382/00-2f I

The Waterford 3125 Volt D.C. System is designed to provide a Class IE sourco of reliable continuous power for the Plant Protection System control and instrumentation and other loads for start-up, operation, and shutdown under normal and emergency conditions. It consists of three, sixty cell,125 volt batteries, each with its own battery chargers, load centers and distribution panels. These three banks of batteries, designated 3A-S, 3B-S and 3AB-S and their associated load centers and' distribution panels, are arranged to feed the safety related redundant de loads and the non-s' r ety related loads associated

~ with divisions A, B and AB. Batteries 3A-S and 3B-S are rated at twelvo hundred ampere-hours for an eight hour rate of discharge or six hundred ampere-hours for a one hour rate of discharge to 1.75 volts per cell at 250C (77 F.) The 3AB-S battery is rated 2400 ampere-hours for an eight hour rate of

= discharge to 1.75 volts per cell at 25 C.

Section 2.G.3.1 of IR 50-382/90-23 discusses existing battery capacity. During the inspection, the team was given some battery sizing worksheets. They noticed the worksheets identified a minimum electrolyte temperature of 77 F (the standard -

rating used by IEEE-485). This was inconsistent with a phint TS that identifies a minimum temperature _of 60 F. As such, either a new calculation supporting 60 F

< should be supplied or the specification should be changed.

1

Unable ' mpport the 600F temperature. Design Engineering performed cale J c e, tar % a minimum specification temperature Hmit which would incluf wquate desig'. argin. Engineering revealed that the heaters in the

VA' yatem ar- % ety Class 3 while the heating col.s for the battery rooms are

"/7:' W. Juring a design ') asis event, at least one llVAC heater is

b. . ' ../ " vent the othee heaters should fall, heat would continue to be to the roo by various sources and laat transmission from adjacent areas.

".h, coom temperature would start to drop due to the cooler air supply, y s . temperatures of the electrolyte will start to decrease, although this will

.e. i y 'l too contains heat. Calculations show that th ' electrolyte o a. ' rop to t i lov. as 73.3 F in a 24-hour period, erefore, a of .6 -

s Ls 'ac.zd . evaluation. Calculation L' -E91-052 shows

. 4t 70 f , eleci Mytt till contains sufficient capacity such that the a carry

• ro W3 u.n2s, cc F .alation requires a specification change to define the tainimum electrolyte v v as 70 F. Increasing the minimum average electrolyte temperature

,- F o 700F eepresents an increase in the minimum battery capacity and, -

3 aceh. , the minimum storW energy allowed by the specification. This means an

( wnase :n protection; honey T more conservative specification. As such, this

• nange doca not represent a reduction in safety.

\

iR 50-382/99-M idennfied anuner concern stating that the TS surveillances of battery electrolyto cecific gravity were inecasistent with manufacturer requirements documt... ad ir. the vendor technical manual. TS Table 4.8-2 contains sur e llance requirements for the station batteries. In the bases for this i

specifier. tion, maximum difference per_ 'u for the electrolyte from the i manufe *urer's fully charged specift gruity is specified. As stated in Bases 3/4.8 fable 4.8-2 speufles the normal limits for each designated pilot cell and each connected cell for . . . specific gravity. The limits for the designated pin cells . . . specific gravity, 0.015 beh.,w the trenafacturer's full charge wecific gravity, is characteristic of a charged ecil with adequate capacity.

The normal limits for eacb connected cell f- . . specific gravity, not more than 0.020 bedow the manufacturer's i charge specific gravity with an average specific gravity cf all the connected cells nct more than 0.010

• below the manufacturer's f ull charge specific gravity, ensums 4 s operability and capability of the battery.

" Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8-2 is permitted for up to 7 days. Daring this 7-day period: . . . (2) the allowable value for the average specific gravity of all the cells, not more than 0.020 below the manufacturer's recommended fuU charge specific gravity, ensures that the decrease in rating will be less than the safety margin provided in sizing

. . . ; (3) the allowable value for an individual cell's specific gravity will not be more than 0.040 below the manufacturer's full charge specific gravity and that the overall capability of the battery will be maintained within an acceptable limit; . . ."

These criteria are identical with those established in the Combustion Engineering (CE) standard TSs which assume a manufacturer's recommended full charge specific cravity of 1.213. Operating within specific gravity limits based on these allowance s ensures operability of the battery and its capability to perform its design function. Consistent with the CE standr 7d TSs, batteries at Waterford 3 have a nominal fully charged specific gravity o' 1.215 (at 77 F. ) When applying the allowances from the ases to the manufacturer's full charge specific gravity, 2 j l

L the limits in Table 4.8-2 are all too low by 0.005. Engineering investigated this l '

and could _not find any supporting basis for the_ discrepancy. Consequently, this change is being requested to correct these limits based on the allowances from the TS bases as' applied to the vendor specifications.

Table 4.8-2 identifies three different kinds of requirements for specific gravity. <

The left column, Category A, establishes limits for the pliot cells. The middle and right columns identify normal and allowable values for the connected cells. .

Normal limits for th connected celle are established for everyday oreration while outsi'le normal limits or allowable values are established for unusual situations.

These " allowable values" permit operation to continue provided it is not for more ,

than seven days. . Most of these limits are based on the manufacturer's full chargo specific gravity,1.215. To bring them into agreement with design, they must be increased by 0.005. Raising these limits creates a more limiting TS since un increased minimum specific gravity means the limiting condition allowed by the TS establishes more stored energy in the battery. Ilence, the change is more conservative and does not represent a reduction in safety.

Safety Analysis The proposed changes described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:

1. Will the operation of the facility in accordance with these propost d changes involve a significant increase in the probability or consequence of any accident ureviously evaluated? -

Response: No Previously analyzed accidents that are potentially affected by this change are those that require operation of the station batteries. This would include all accidents that postulate the loss of offsite power (LOOP) concurrent with tite accident (e.g. , a loss of coolant accident with a LOOP. ) For these accidents, the batteries provide field flash and power to the control system to start the EDGs. Additionally, the station batteries

! are needed for the station blackout event to carry essential loads. This proposal requests changes to Waterford 3 specifications that increase the -

minircum amount ' Mored er.ergy that can be contained in the batteries.

These changes .c e negative impact on the reliability or perforn.ance of the station batt - .id, therefore, have no actual impact on any previously analyze . accident in the Final Safety Analysis Report. As such, the operation of Waterford 3 in accordance with the proposed changes does not involve a significant increase in the probability or consequence of any accident previously evalurted.

2. Will the operation of the facility in accordance with these proposed changes create the possibility of a new or different kind of accident from any

[ accident previously evaluated?

Response: Na To create a new or different kind of accident, -these changes will have to introduce a new failure path. Only surveillances for the station batteries are affected. No design requirements for the station batteries or power ,

distribution syatems are altered. Because the proposed amendment would not change the design, configuration or method of operation of the plant, it j, 3

would not create the possibility of a new or different bind of accident.

3. Will the operation of the facility in accordance with these proposed changes involve a significant reduction. in the margin of safety?

Response: No increasing the minimum average electrolyte temperature and specific gravity allowed by TSs means-the minimum stored energy that can be  ;

contained in the batteries is increased. This represents a general improvement in safety. The modification does not change the design basis for any equipment in the plant. Since existing TS operability and surveillance requirements are not reduced by the proposed changes, the operation of Waterford 3 in accordance with these changes does not involve a reduction in any margin of safety.

The Commis.non has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by previding certain examples (48 FR 14870) of amendments that are considered not likely to

. involve significant hazards considerations. The changes identified in this .

submittal closely. match example (11):

"(li) . A change that constitutes an additional limitation, restriction or control not presently included in the technical specifications; for '

example, a more stringent so-veillance requirement."

Although the proposed changes represent increased restriction on existing surveillances rather than the introdr tion of new surveil.'acces to the TSs, they most closely res;mble exampic (ii) sin e they are quite clearly, "a more stringent surveillance raquiremont."

Safety and Significant flazards Determinatbn

-Ilased on the above Safety Analysis, it is concluded that: (1) the proposed changes do not constitute a significant hazards consideration as defined by 10 CFR 50.92; and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed changes; and (3) this action will not result in~a condition that significantly alters the impact of the station on

, the environment as described in the NRC Final Environmental Statement.

l(

'r r

1 4

lL . _ .. -.

is s t

t

, 4 r

i

i l A ?.-- t-

!!) i' -

c-1

% -V .-:9::

+

NPF-38-121 i-ATTACllMENT A ,

4 o

g 1

i -

h T

4 h

h

'* - ' w o e v e,v - m . ....<,c,,,,e y ., ,. _, ,. ,, . , , ,