ML20127B413
| ML20127B413 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/03/1985 |
| From: | Morgan R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| RNPD-85-636, NUDOCS 8506210461 | |
| Download: ML20127B413 (3) | |
Text
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CP&L Carejga Poh & Light Company n
ROBINSON NUCLEAR PROJECT DEPARTMENT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 APR 3 1986 Robinson File No:
13510E Serial:
RNPD/85-636 Dr. J. Nelson Grace, Regional Administrator United States Nuclear Regulatory Commission Region II 101 Marietta Street, N. W., Suite 3100 Atlanta, Georgia 30323 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50r261 LICENSE NO. DPR-23 REGION II INSPECTION REPORT 85r08
Dear Dr. Grace:
Carolina Power and Light Company (C'&L) has received and reviewed the subject report and provides the following response.
Severity Level IV Violation R11-85-08-01-SL4 Technical Specification 6.5.1.1.1.c and 10 CFR 50 Appendix B, Criterion V collectively require that written procedures shall be established, implemented, and maintained for surveillance and test activities of safetyrrelated equipment. These procedures shall include appropriate quantitative acceptance criteria for determining that the activities specified by these proceduaes are accomplished satisfactorily.
Contrary to the above, presently established Licensee procedures and available vendor technical manuals do not provide quantitative acceptance criteria which specify an acceptable normal operating temperature range that shall be maintained to assure operability of the safety-related station batteries.
Maintenance Surveillance Test Procedure MST-902, titled " Battery Test-Daily,"
Revision 2, established to maintain the operability of the station batteries as required by Technical Specification Sections 4.6.3.1 and 4.6.3.3, did not specify a normal operating temperature range that shall be maintained such that required load capacity is assured. On January 22, 1985, it was observed 0
0 that the "A" battery temperature was 55 F, and the "B" battery was 48 F.
These temperatures are below the vendor recommended range of 60 to 90 F.
(The optimum temperature range is stated to be between 75 and 77 F.)
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B506210461 850403 PDR ADOCK 05000261 3
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. Letter to Dr. J. Nelson Grace S: rial:
RNPD/85-636 7
Page 2
Response
1.
Admission or Denial of the Alleged Violation CP&L denies the alleged violation.
2.
Reason for Denial CP&L contends that not including a normal operating temperature range quantitative acceptance criteria in Maintenance Surveillance Test, MST-902, is not in violation of Technical Specification (TS) 4.6.3.1, 4.6.3 3, and 6.5.1.1.1.c, nor 10CFR50, Appendix B, Criterion V.
TS 6.5.1.1.1.c requires that written procedures be established, implemented, and maintained covering surveillance activities.
In accordance with TS 6.5.1.1.1.c, MST-902 was implemented to satisfy the surveillance requirements of TS 4.6.3.1 and TS 4.6.3.3 TS 4.6.3 1 requires that the voltage and temperature of a pilot cell in each battery be measured and recorded daily 5 days per week. These parameters are measured and recorded by MST-902 5 days per week.
TS 4.6.3.3 requires that the data recorded be compared with the previous data to detect signs of abuse or deterioration. This ccmparison is also accomplished by MST-902.
10CFR50 Appendix B, Criterion V states that procedures shall contain appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. MST-902 contains quantitative limits for pilot cell voltage and corrected specific gravity as well as qualitative acceptance criteria to identify signs of deterioration. These acceptance criteria are appropriate for determining satisfactory compliance with the intent of Technical Specification 4.6 as specified in its Basis. This Basis states, " station batteries will deteriorate with time, but precipitous failure is extremely unlikely. The surveillance specified is that which has been demonstrated over the years to provide an indication of a cell becoming unservicable long before it fails." The Basis explains the intent of the individual surveillance items as being an indicator of long term battery degradation. To better meet the intent of TS 4.6.3.1 and 4.6.3 3, MST-902 also requires the measuring, recording, and comparison of several additional parameters not specifically required by Technical Specifications. These additional parameters are electrolyte level, specific gravity, and the specific gravity corrected for level and temperature variations. The corrected specific gravity provides a more reliable indicator of battery performance.
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" Letter to Dr. J. N. Grace Serial: RNPD/85-636 Page 3 All of the data recorded in MST-902 receives two management reviews following its completion.
Both the I&C Foreman and the Maintenance Supervisor closely review the recorded parameters to identify when corrective action is necessary. The additional recorded parameters provide a broader perspective on battery deterioration to management during their review of the completed surveillance procedure.
Carolina Power and Light Company believes that the acceptance criteria contained in MST-902 are appropriate to meet the requirements of both the Technical Specifications anc 10CFR50 Appendix B, Criterion V, and CP&L respectfully requests that this violation be withdrawn.
3 MST-902, Improvements Made Inviewofthelevelofconcernregardingbatterytemperaturesthatmag reduce battery performance, an additional administrative control of 50 F minimum temperature was added to MST-902 effective February 4, 1985.
This value provides a margin above the minimum temperature of approximately 43 F stated by the manufacturer.
A review of a sample of past battery surveillances performed during winter months has revealed no battery temperatures below 50 F prior to the unusually cold weather of January, 1985. Therefore, no battery problems due to low temperature are anticipated.
If you have any questions concerning this response, please contact Mr. David C. Stadler at (803) 383-4524 Extension 363 Very truly yours, Y*
R. E. Morgan General Manager H. B. Robinson S. E. Plant CLW:tk/C-495 cc:
Document Control Desk H. E. P. Krug
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