ML20115E197
| ML20115E197 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/12/1996 |
| From: | King R ENTERGY OPERATIONS, INC. |
| To: | Donahew J NRC |
| Shared Package | |
| ML20115D555 | List: |
| References | |
| NUDOCS 9607160142 | |
| Download: ML20115E197 (17) | |
Text
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General Manager's Office l
Fax Cover Sheet l
River Bend Station To: WhM Company:
dC Phone:
$1 C 5+ !&D Fax:
- bOl-h 5: 38(o, From: IM b%
Company:
Entergy/ River Bend $tation l
Phone: l
- f)' - 31'Nc% b Fax: l Pages including this cover page:
Comments:
Please call if fax is illegible.
9607160142 960712 PDR ADOCK 05000458 P
ppg
ATTACHMENT Regeest for Exercise of Enforcement Discretion L
The TS or other license con 6tions that will be violated.
L L
Entergy Operations, Inc. (EOI) has self-identified a condition which warrams j
l consideration of discretionary enforcement. During a review ofpast surveillance l
tests that were conducted during May 1994, it was discovered that the Division 1 i
station service battery test results satisfied the Technical Specification (TS) surveillance requirement (SR) 3.8.4.8 criteria fcr increased test frequency from 60 l
to 18 months. This SR requires that when a battery shows degradation the l-frequency is decreased to 18 months. The next scheduled performance of this SR l
should have been November 1995. Non-performance of this SR results in a failure to meet the associated limiting condition of operation (LCO) as required by SR 3.0.3. Specification 3.8.4 ACTIONS require that if an inoperable division ofDC power cannot be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the reactor must I
i be placed in MODE 3 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and be in MODE 4 within 36 L
hours.
Performance of the required surveillance test requires the battery to be significantly discharged. This test and the resulting recharge would result in the battery being inoperable for over 5 days which exceeds the allowed outage time permitted by TS. Additionally, TS prohibits performance of this test in Modes 1,2, and 3. EOI is requesting enforcement discretion of the reactor shutdown requirements for up to 7 days to allow sufficient time to prepare and implement the Technical Specification (TS) amendment request approved by the NRC. The amendment request will delay this surveillance requirement until the next scheduled outage, Refueling outage 7, currently scheduled to begin September 1997.~ An evaluation l
of the station service battery capacity, as discussed below, provides assurance batteries will be capable of perfonning their intended function during the period of i
discretionary enforcement. EOI has determined that a request to allow the test to be performed while operating would be inappropriate.
The condition was discovered on July 10,1996; therefore, TS Surveillance i
Requirement Api,licability 3.0.3 was entered to permit the development of this request, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, before entering with the required actions of TS 3.8.4.
2.
The circumstances surrounding the situation, including root causes, the needfor prompt action andident!fication ofany relevant historical events.
At 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> on July 10,1996, it was discovered that an increased surveillance frequency required by TS surveillance requirement (SR) 3.8.4.8 was not met. SR 3.8.4.8 requires, in part, that the test frequency be increased from 60 to 18 month intervals when the battery shows degradation. The associated TS bases defines t
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JUL-n-1996 13i53 GDERAL MANAGER '
p,e3 degradation as a drop in battery capacity by more than 10% relative to the capacity on the previous p L mance test or when it is >10% below the manufacturer's rating. A review of the previous 60 month test results indicated a greater than 10% drop in battery capacity for the Division I station service batteries. However, as required by TS and repeated in the surveillance procedure, no notification was provided to initiate the increased frequency test. This 60 month test was last performed on Division I battery during May 1994; therefore, the 18 month test requirement was not met.
A preliminary investigation found that the failure to properly increase test frequency for the Division I station service batteries was due to misinterpretation j
of the surveillance frequency criteria. The surveillance test procedure contains the i
TS criteria to increase surveillance frequency when battery performance degrades j
greater than 10% from the average of the previous tests. However, it is believed that this was interpreted to be a change of10% from the rated capacity. Due to this interpretation and the test results which were greater than 90% capacity, the 1
test frequency was not decreased to the required 18 month interval. The Division j
II station service batteries successfully met the criteria and increased frequency 4
was not warranted.
I TS SR 3.0.3 allows that when a surveillance is not performed within its specified t
frequency, then declaration of not meeting the LCO may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the specified frequency, whichever is less. Failure j
to increase the Division I station service battery capacity test from 60 months to 18 months meets this criteria. As 4 result, SR 3.0.3 LCO was entered which allows time to permit completion of the surveillance or remedial measures that might preclude completion of the surveillance. In this case, enforcement discretion is being requested to allow for development of a TS change that will extend required completion of the surveillance until a time when it can be performed without imposing unnecessary transients on the plant (refer to item 9 below).
A delay in enforcement discretion past the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3,0.3 LCO will result in entering TS 3.8.4 Condition A, inoperable Division I electrical power subsystem.
The TS Action requires the subsystem to be returned to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in Mode 3, Hot Shutdown, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in Mode 4, Cold Shutdown, within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Prompt action is required to prevent an unnecessary plant shutdown.
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i JUL-11-1996 13:54-GEtERAL MANAGER P.04 l
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t 3.
The safety basisfor the request, includdg an enxtuation of the safety signifcance andpotentialconsequences ofthepropoordcourse ofaction. This evaluation shouldinclude at least a qualitative risk assessment derivedfrom the licensee's PRA.
l Battery Performance Discharge Tests are performed at 5 year intervals to monitor battery aging until degradation is observed. Once age-related degradation is indicated, the testing frequency is increased to monitor the battery as it approaches its end oflife. Per IEEE Standard 450-1980 and IEEE Standard 450-1987, the battery is recommended to be replaced within one year after reaching a battery i
capacity of 80%. The problem being evaluated is that the first performance test that should have been performed as a resuk of detecting possible age-related battery capacity degradation was not performed.
I The last Division 1 battery Performance Discharge Test, performed on May 1994 (RF-05), indicated that the Division 1 battery capacity was 97% of the manufacturers rating. This capacity indicates a drop of >10% from the average of previous performance tests, indicating possible age-related degradation. The next battery Performance Discharge Test should have been performed by January 1996 (RF-06) to monitor the battery capacity. This test was not performed.
.j It is expected that the battery capacity decreases at an increasing rate as the battery end-of-life is approached. To provide a cantervative indication of battery aging, j
. IEEE 450-1980 recommneds an increased frequency of testing when the battery capacity drops more than 10% of the average of previous Performance Discharge Tests or the battery reaches 90% ofits rated capacity. Although the Performance i
Discharge Test was not performed during RF-06, reasonable basis exists to show
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that the battery capacity is adequate to perform its specified safety function.
Alarge margin exists to the established battery replacement criteria. No reason exists to suspect that any battery replacanum criteria will be reached prior to the next scheduled refuel outage (RF-07). The previous battery Performance j
Discharge Test will be three years old at RF-07, while this is longer than the 18 j
month frequency in Tech Spec, it is still a reduction in the suiveillance frequency L
for this test from 60 months to 36 months. The last performance test indicated a 4
i capacity of 97%, which is substantially greater than the 90% capacity indication of age-related degradation.
A review of the last Performance Discharge Test show that no cell reversals occurred. This indicates that any battery aging degradation is uniform. As part of the Performance Discharge Test, the battery may receive an equalizing battery charge from 3-7 days prior to the test. This is to assure that a consistent reference condition exists for the capacity measurement This equalizing battery charge was L
not performed, thus additional variance in the capacity measurement was introduced by the initial battery conditions. A review of the initial terminal voltage l
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JUL-H-8996 13:54
. GENERAL. MANAGER P.05 data point (approximately 10 Ininutes into the test) from the Performance Discharge Tests, show that the initial voltage for the 1989 test was higher than the initial vohage for the 1994 test indicating a substantial difference in the initial state af charge of the battery. It was not until the battery had been under load for greater than 30 minutes in the 1989 Performance Discharge Test that the battery tenninal vohage dropped to the initial loaded tenninal voltage (10 minute reading) in the 1994 Performance Discharge Test. A review of the final terminal voltages l
from all of the battery service tests show that no substantial battery degradation has occurred. Thus h is reasonable to conclude that no substantial battery degradation has occurred.
Design Basis:
nere are three independent physically and electrically separated Class IE 125V de distribution systems at RBS. These systerra each include a battery charger, a lead acid battery bank, a 125V de distribution panel, local and control room i
instnamentation and alarm facilities. The Division I 125V batteries (ENB-BAT 01 A) are used to provide emergency backup de power to the Division I safety.
related equipment in order to mitigate the effects of an accident and to provide for the safe shutdown of the plant. ENB-BAT 01 A is a 2100 Amp-Hour, 60 cell l
battery bank manufactured by GNB.
During normal operation, the 125V de loads are fed from the battery chargers, with the batteries floating on the de system. Upon loss of ac power to the battery chargers, the entire de load is supported from the batteries until ac power is l
restored to the battery chargers from either offsite power or the standby diese!
generators. The batteries are designed and sized to carry this load for four hours.
Suppe ting Analysis:
l Although the Performance Discharge Test was not performed as required for the increased frequency testing, the battery service test was performed during RF-6.
His test was performed in accordance with Tech. Spec. SR 3.8.4.7 which states, I
" Verify battery capacity is adequate to supply, and maintain in OPERABLE status, i
the required emergency loads for the design duty cycle when subjected to a battery service test." The load profile service test demonstrated the ability of the battery to perform its specified safety function. Additionally, based on the terminal voltage, substantial excess battery capacity remamed following the profile load service test.
The surveillance " Notes" from the Technical Requirements Manual (TRM) states, "This SR may be accomplished by verification that the battery capacity is adequate to supply a dummy load of the following profile in accordance with IEEE 450 l
while maintaining the battery terminal voltage > 105 volts.
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JUL-88-1996 13:55 GEMRAL ITt#GER P.06 l
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DistcAl i
2 671 amperes for the first 60 seconds 2 270 amperes for the next 9 minutes 2 336 amperes for the next 60 seconds 2 270 amperes for the next 228 minutes i
2 451 amperes for the next 60 seconds" The Bases for Tech. Spec. 3.8.4.7 states, "A battery service test is a special test of -
the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate 'and test length l
correspond to the design duty cycle requirements ofreference 4."
t Reference 4 for the Bases of Tech. Spec. 3.8.4.7 is IEEE Standard 450,1987.
L For conservatism and to offse' any potential measurement error, the survedlance l
l test was set up and performed with the fouowing values.
I-2 678 amperes for the first 60 seconds 2 273 amperes for the next 9 minutes 2 340 amperes for the next 60 seconds 2 273 amperes for the next 228 minutes 2 456 amperes for the next 60 seconds l
l l
The actual design load profile for this battery, shown in calculation E-143, Rev 7E is as follows.
l 586 amperes for the first 60 seconds 245 amperes for the next 9 minutes 274 amperes for the next 60 seconds 245 amperes forthe next 228 minutes 443 amperes for the next 60 seconds The battery overall voltage at the end of the Battery Service Test was 113.5 volts.
This is 8.5 volts higher than minimum voltage requirement given by the TRM and required by the battery sizing calculation. While this does not measure the actual battery capacity that a Performance Discharge Test would have, it does give a reasonable assurance that the battery has adequate margin to carry its required safety related loads.
The calculated load profile is conservative byjust over 14%. The station blackout (SBO) and LOCA load pro 61es given in calculation E-143 have temperature correction factors (11%) aging factors (25%), and a design margin (5%) included.
e Additional margin is added due to rounding up to a whole number of plates per cell. The temperature correction factor is included to insure that a low battery
JUL-11-89% 13:55 GENERAL MANAGER P.07 temperature will not degrade the battery's capability to supply its required loads and the aging factor is included to insure the battery can perform its function all the way down to 80% ofits capacity. As the temperature and agmg factors are required to meet the battery's commitments, they can not be considered additional margin. However, the upsinng to the nearest whole number of positive plates and the 5% design margin do add additional conservatism to the calculation.
The total load profile ofENB-BAT 01 A given in the TRM is 110% of the designed LOCA load profile as shown in calculation E-143.
BLOCK DURATION DESIGN AMPS DESIGNENERGY TRM AMPS TRM ENERGY I
I min.
5s6
$86 amp-min 671 671 amp-min 2
9 min.
245 2205 a. sp min 270 2430 amp-min 3
1 min.
275 275 r.mp-min 336 336 amp-min 4
228 min.
M 55%0 amp-min 270 61560 amp-min 4
5 1 min.
443 443 amp-min 451 451 amp-min TOTAL 59369 amp-min 65448 amp-min 6544R / 59369 = 1.1024 Additionally for conservatism, the values in the 18 month service discharge test, STP-305-1606 were set approximately 1% higher than the above table.
SBO loading bounds all other loading scenarios including LOCA as the SBO reauires a mimmum of 12,72 positive plates per battery cell and the LOCA only requires 12.68 positive plates per cell. However, there is not much difference.
With the 10% conservatism in the TRM, the 14% conservatism in the calculation and the 1% conservatism in the test setup, we actually test the battery with the service test to 125% ofit's expected load.
During the life of a typical battery, capacity increases during the first few years and then slowly decreases for most of the battery's remaining life. Toward the end of life, the capacity starts to drop off at an increasing rate. This drop becomes very steep when the battery's capacity has reached approximately 80%. (Note, however, that the battery capacity in 1994 was 97.4% ofrated battery capacity.)
This is the reason for sizing the batteries to carry the loads at 80% of capacity and for the required 80% capacity in the Tech. Specs.
1 These safety related batteries are presently qualified for 15 years of service life.
However, they were designed by the manufacturer to have a 20 year life expectancy as shown by the battery vendor's (GNB) cut sheet Section 2-20. They
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.. _.JUL-aa-1996 83:58 GEERfL MftFGER p,g3 l
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l temperature will not degrade the b?ttery's capability to supply its required loads and the aging factor is included to insure the battery can perform its function all
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the way down to 80% ofits capacity. As the temperature and aging factors are requiica to meet the battery's commitments, they can not be considered additional margin. However, the upsizing to the nearest whole number ofpositive plates and the 5% design margin do add additional conservatism to the calculation.
l l
The total load profile of ENB-B AT01 A given in the TRM is 110% of the designed LOCA load profile as shown in calculation E-143.
BLOCK DURATION DESIGN AMPS DESIGNENERGY TRM AMPS IBMENERGY 1
1 min.
586 586 amp-min 671 671 amp-min j
2 9 min.
245 2205 amp-min 27o 2430 amp-min 3
1 min.
275 275 amp-min 336 336 amp-min 4
228 min.
245 55860 amp-min 270 61560 amp-min 5
1 min.
443 443 amp-min 451 451 amp-min TOTAL 59369 amp-min 65448 amp-min j
l 65448 / $9369 = 1.1024 Additionally for conservatism, the values in the 18 month service discharge test, STP-305-1606 were set approximately 1% higher than the above table.
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t SBO loading bounds all other loading scenarios including LOCA as the SBO i
requires a minimum of 12.72 positive plates per battery cell and the LOCA only requires 12.68 positive plates per cell. However, there is not much difference.
With the 10% conservatism in the TRM, the 14% conservatism in the calculation and the 1% conservatism in the test setup, we actually test the battery with the service test to 125% ofit's expected load.
Dudng the life of a typical battery, capacity increases dudng the first few years and then slowly decreases for most of the battery's remaining life. Toward the end of life, the capacity starts to drop off at an increasing rate. This drop becomes very steep when the battery's capacity has reached approximately 80%. (Note, however, that the battery capacity in 1994 was 97.4% of rated battery capacity.)
This is the reason for sizing the batteries to cany the loads at 80% of capacity and for the required 80% capacity in the Tech. Specs.
i I
i These safety related batteries are presently qualified for 15 years of service life, i
However, they were designed by the manufacturer to have a 20 year life expectancy as shown by the battery vendor's (GNB) cut sheet Section 2-20. They enm n.,
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JUL-SS-1996.83:56 GEtERAL F1ANAGER P.08 l
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t were placed in servicein December of 1982 and as such are 13 and 1/2 years old.
j This means that the batteries are at 90% of their 15 year qualified life but are only l
67.5% into the expected life of 20 years. Therefore, there is no reason to believe that tiac batteries are approaching the end of their life when significant capacity loss might be suspected.
I A review of the data from the previous three (1986,1992,1996) Battery Service Tests shows that the battery has performed in the same manner with similar voltage drops seen over the tests (see graph). This also indicates that the battery
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has not degraded Based on the fact that the Battery Service Test performed during RF6 proved the l
battery had ampic capacity to satisfy' its design basis requirements, the previous l
Perfonnance Discharge Tests demonstrated a capacity of 97.4% of rated capacity, and the battery is well within the manufacturer's expected design life, we have reasonable assurance that the battery is currently capable ofproviding its safety related function and will continue to do so for the foreseeable future.
PSA informadon; Based on the engineering assessment discussed above the batteries are operable.
I The TS LCO currentlyin effect reflects the failure to properly increase a surveillance test frequency. The engineering assessment concluded that the batteries will be capable of meeting their intended safety function. Because the batteries remain operable, there has been no increase of CDF or increase in risk.
4.
7he basisfor the licenste's conclusion that the noncompliance w M %= of potential detriment to thepublic health andsafety and that neither as unreviewed safety question nor a sigmfcast hazard consideration is involved A "significant hazards consideration" is not involved if operation of the facility with the noncompliance does not (1) involve a significant increase in the probability or consequences of any accident previously evaluated, (2) create the possibility of a new or different kind of accident from previously evaluated, or (3) involve a significant reduction in a margin of safety. This request is evaluated against each of these criteria as follows:
Criterion 1:
Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.
l The standt; batteries are backup to the direct current power sources (charger) designed to power essential safety systems in the event of a loss of offsite and onsite AC ower. Theloss of the Division I batteryis not an accident initiatorin P
any accident previously evaluated. Therefore, the Enforcement Discretion for the i
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JUL-81-19% 83:56 GENERAL f1NGER P.09 1
Division I battery does not involve any increase to the probabahty of any accident previously evaluated.
Isased on the engineering assessment discussed above the batteries remam operable. An engineenng assessment concluded that the batteries will be capable of meetmg their intended safety fbnetion. Becauw the batteries remain operable, there has been no reduction core damage fregr.ency or increase in risk.
It is thus concluded that there is no increase in the probability or consequences of an accident under the Enforcement Discretion action.
Criterion 2:
Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated.
The Enforcement Discretion does not alter the design, configuration, or method of operation of the plant. Therefore, this change does not create the possibility of a new or different kind of accident from any previously evaluated.
l Criterion 3:
Does Not Involve a Significant Reduction in the Margin of Safety.
l The acceptance criteria for SR 3.8.4.8 is based on IEEE-450 which establishes the mimmum capacity of the battery of 80%. The last performance dicharge test demonstrated a capacity of about 97%. This is greater than the required capacity and, as such the delay in increasing the test freguncy has not impacted any margin of safety.
5.
1he basisfor the licensee's conclusion that the noncompliance will not inw>lve adverse consequences to the environment.
No release of effluents occurred or are expected as a result of the missed i
surveillance. In conclusion, there is no increase in the types or quantity of effluent that may be released offsite and no increase in individual or cumulative
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occupational radiation exposures.
l 6.
Anyproposed compensatory measure (s).
Possible compensatory measures have been reviewed and the following compensatory measures are proposed:
A bdefing of all Licensed Operations shift personnel and appropriate Maintenance and System Engineering personnel will be conducted to inform i
them of this condition. The engineering evaluation and the compensatory actions to be taken until such time as the performance discharge test can be performed will be included as a part of that discussion. The guidance on an SBO event will also be re'mforced.
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JUL-81-8996 83:57 GEtERAL MAtOGER P.10 The frequency of the equalize charges on the Division 1 and 2 station service batteries will be increased in addition to the above, the following regularly scheduled inspections and Surveillances provide assurance of the Operability of the batteries for the remainder of this cycle and/or until such time as the performance discharge test can be performed: Shiftly Operator rounds per OSP-0028 perform General Visual Inspection and battery voltage verification at input to ENB-INV01 A. STP 305-1100 Weekly Surveillance per SR 3.8.4.1,3.8.6.1, checks the following:
l Battery float vohage e
Pilot cell voltage o
Pilot cell electrolyte temp.
o Pilot cell electrolyte level J
Pilot cell specific gravity e
STP 305-1300 Quarterly Surveillance per SR 3.8.4.2, 3.8.6.2, 3.8.6.3 checks the following:
Battery float voltage e
Each cell voltage e
Each celltemperature e
Each cell electrolytelevel
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Each cell specific gravity e
Connector micro-ohm readings if signs of corrosion 7.
7hejustifcationfor the duration of the noncompliance.
The request for an additiond 7 days is to allow sufficient time to have a TS amendment prepared, submitted and approved by the NRC.
8.
A statement that the request has been approved by thefacility organization that normally reviews safety issues (Plant Onsite Review Committee, or its equivalent).
A meeting of the RBS Facility Review Committee was held on July 11,1996 which has approved the request for enforcement discretion.
9.
The request must specifcally address how one ofthe N ED criteriafor appropriateplant conditions specifed in Section B is satisped.
Enforcement discretion is being requested to prevent a plant shutdown which, discounting enforcement discretion, will be required beginning July 11,1996.
Considering the current condition of the Division I station service batteries as discussed in the above sections, and the period of time requested for discretion, l
this extension does not constitute a significant reduction in the overall protection i
JUL-11-1996 13:57 GEtERAL MAteGER P.11 cf the public health and safety. Approval ofthis request will prevent a plant shutdown and the associated transients as discussed in NOED criteria B.1.
if afollow-up bcense amen 6nent is required the NOED request must include u.
marked-up TSpages showirg the proposed TS changes.
As noted above this request is submitted to provide time for submittal and development of a amendment request to extend the requirement to perfonn the next full capacity test on Division I battery to no later than Refueling Outage 7.
An expected mark-up of the TS pages is included in attachment.
11.
A statement thatprior adoption ofapprowdline-item improwments to the TS or the ITS would not haw obviated the needfor the NOED request.
The current technical specifications at RBS are based on NUREG-1434, this conversion was implemented in October 1995.
I2.
Any other information the NRC stafdeems necessary before making a decision to exercise enforcement discretion.
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JUL-81-19% 83:58 GENERAL F1ANAGER P.12 4
l Attachment ?
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NOTE-------------------
This surveillance shall not be performed in MODE 1, 2, or 3.
However, credit may be l
taken for unplanned events that satisfy this SR.
Verify battery capacity is 2 80% of the 60 months manufacturer's rating when subjected to a perforraance discharge test.
6ED l
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NOTE------
1.
Only j
applicable when Division II or III battery i
shows degradation or has reached 85%
of expected
- life, t
2.
Division I j
battery will be l
l tested on this t
I frequency beginning no later than RF-7.
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1 FROM:KONICA FAX TO:
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- ggg, MEMO Pa0e t of 1 Data:
July 11,1996 Memo No.: NU.M96 AS$6 To:
Tom Carpenter FAX 504 3813680 From:
Aron Selken
Subject:
ONS battery capacity The attached curve which provides the general relationship between ca service was supplied by GNB engineering. It is noted that the rate of capac constant. His curve is typical for commetcial batteries which are deUve However, the constant rate of capacity decrease is applicable.
The following data was supplied by River Bend Station for the A battery:
-1989 performance test: 113 %
-19M performance test: 97 %
-Design margin on the load profile is approximately 10%.
l Based on this data, the following conclusion can be drawn:
.ier on.cussions with GNB engineering, the rate of decrease in capacity a of the batteryis constant. The 14% decrease in capacity seen between 1989 and 1994 can be expected between 1994 and 1999. This would result in ap j
a capacity of 84%.
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-With a design margin of 10% and an aging margin of 25%, the batteries win m l
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t the load pmfile when they are at 77% capacity. He capoeted capacity of 84%
1999 provides margin from the load pro 5)e requirement of 77% of capacit Please contact me if you have any additional questions.
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i l ATTENCEES AT PHONE CONFERENCE CALL OF JULY'11. Jyis l CONSIDERATION OF ENFORCEMENT DISCRETION i NatiE AFFILIATION W. Beckner NRC/NRR/PDIV-1 J. Donohew NRC/NRR/PDIV-1 D. Thatcher NRC/NRR/EELB S. Saba NRC/NRR/EELB A. Bryant NRC/NRR/EELB J. Dyer NRC/RGIV P. Harrell NRC/RGIV l T. Gwynn NRC/RGIV l G. Werner NRC/RGIV W. Smith NRC River Bend Resident Inspector W. Kropp NRC/ED0 T. Leonard E01/ River bend ) R. King, et. al. E01/ River Bend where: EDO - Executive Director for Operations E01 - Entergy Operations, Inc. NRC - Nuclear Regulatory Comission l NRR - Office of Nuclear Reactor Regulation RGIV - Region IV l I l l l ..}}