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LAR 99-004 to Licenses NPF-87 & NPF-89 by Incorporating Attached Change Re Plant Battery Surveillance Into TS
	ML20195B641
Person / Time
Site:	Comanche Peak
Issue date:	05/27/1999
From:	Terry C, Walker R; TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20195B645	List: ML20195B641; ML20195B646;
References
	TXX-99133, NUDOCS 9906020109
	Download: ML20195B641 (7)
	v • d • e

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Log # TXX-99133 y File # 10010 916 C

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Ref. # 10CFR50.90 10CFR50.36a 1EIELECTRIC May 27,1999 1

7 C.15ess'Ihny s der weerma v

& PrhecQ,elNancl or Opicer U. S; Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEA'K STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 99-004 LICENSE REVISION TOAMENDMENT PLANT BATTERY REQUEST SURVEI (LAR)LLANCE REF: TXU Electric letter logged, TXX-99131 from C. L. Terry to the NRC dated May 26,1998 Gentlemen:

Pursuant to 10CFR50.90, TXU Electric

hereby requests an amendment to the CPSES

. Unit 1 Operating License (NPF-87) and CPSES Unit 2 Operating License (NPF-89) by

-incorporating the attached change into the CPSES Units 1 and 2 Technical Specifications. This change is only applicable to CPSES Unit 1 and is administrative for

'CPSES Unit 2.

On May 26,1999, TXU Electric submitted the referenced letter (TXX-99131) requesting

. enforcement discretion. Subsequent to the NRC staff's review of the referenced letter, Mr. Stuart Richardson, Director of Project Directorate IV, Office of NRR on May 27,1999 at 8:20 am initiated a phone call to Mr. Roger Walker of our staff and granted the requested enforcement discretion. This license amendment request (LAR) satisfies the commitment in that enforcement discretion request to submit a license amendment

- request for a one time exception to allow crediting the battery performance discharge

test in lieu of the required service test for Unit 1 battery BT1EDT2. This one time

exception expires prior to entry into MODE 4 following the next Unit 1 outage of sufficient duration to perform a service test.

This LAR is being submitted as follow-up to the request for enforcement discretion. The license amendrnent should be effective upon issuance to be implemented immediately.

1 Attachment 1 is the required affidavit. Attachment 2 provides a detailed description of

~ the proposed change, a safety analysis of the change, and TXU Electric's determination

that the proposed change does not involve a significant hazard consideration.

' Attachment 3 provides the affected Technical Specification pageS, marked-up to reflect the proposed change. _.

9906020109 990527 PDR .ADOCK 05000445 LP PDR

TXU Electric was formerly TU Electric. A license amendment request (LAR 99-003)

.was submitted per TXX-99122, dated May 14,1999, to revise the company name contained in the CPSES operating licenses.

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} (i d h _ COMANCHE PEAK SIEAM ELECTRIC STATION P.O. Box 1002 Glen Rose. Texas *16043-1002

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E TXX-99133 Page 2 of 2.-

-. In accordance with .10CFR50.91(b), TXU Electric is providing the State of Texas with a copyof this proposed amendment.

This communication contains no new commitments or revised commitments. Should you have any questions, please contact Mr. B.(Bob) S. Dacko at (254) 897-0122.

j Sincerely, Yi Q

- C. L. Terry By: M4- - ,

Ro'gert. Walker ' 7 Regulatory Affairs Manager

. BSD/bsd .

~ Attachments: 1. Affidavit

2. Description and Assessment

3. Affected Technical Specification page (marked-up of page) l l-

.c- E. W. Merschoff, Region IV

!. . J.1. Tapia, Region IV

l. Resident inspectors, CPSES D. H. Jaffe, NRR Mr. Authur C. Tate

. Bureau of Radiation Control

+

Texas Department of Public Health li 1100. West 49th Street-l : Austin, Texas 78704 ll t

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l. Attachment 1 to TXX-99133 li Page 1 of 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION in the Matter of )

! )

TXU Electric Company ) Docket Nos. 50-445

) 50-446

'(Comanche Peak Steam Electric Station, ) License Nos. NPF-87 Units 1 & 2) ) NPF-89 AFFIDAVIT Roger D. Walker being duly sworn, hereby deposes and says that he is Regulatory Affairs Manager of TXU Electric, the licensee herein; that he is duly authorized to sign and filewith the Nuclear Regulatory Commission this License Amendment Request 99-004; 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.

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/E R'o e D. Walker '

R latory Affairs Manager l STATE OF TEXAS )

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COUNTY OF Somervell )

Subscribed and sworn to before me, on this N7* day of YM 1999.

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, Notary Pdblic CAROLYN L COSENTINO 1

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l ATTACHMENT 2 to TXX-99133 DESCRIPTION AND ASSESSMENT j i

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Attachment 2 to TXX-99133 Page 1 of 3 DESCRIPTION AND ASSESSMENT

l. BACKGROUND During the procese of conducting reviews of battery surveillances, CPSES discovered that credit had been taken for the performance of a battery performance discharge test in lieu of a service test more frequently than is permitted by SR 4.8.2.1e. l Until the battery has reached 85% of its service life, a performance discharge test is only required once per 60 months (per SR 4.8.2.1e). SR 4.8.2.1e permits the substitution of this performance discharge test for the SR 4.8.2.1d required service test once per 60 month interval. Generally that means that each required performance discharge test could be substituted for a required service test. However,if the battery is considered degraded or after 85% of its service life, performance discharge tests of 3 the battery are required on an 18 month frequency per SR 4.8.2.1f. Battery BT1ED2 )

reached 85% of its service life in April 1996 just prior to 1RFOS. A performance discharge test was conducted per SR 4.8.2.1f in 1RF05. It was mistakenly assumed that each performance discharge test could be credited for a service test after 85% .

service life. Similarly, a performance discharge was substituted for a service test in l 1RFO6. Since SR 4.8.2.1e permits substitution only once per 60 months test interval, I and since 1RFO5 and 1RFO6 are in the same 60 month interval, this substitution was l not valid. The invalidity of the substitution was not recognized at the time.

As the invalid substitution constitutes a failure to perform a SR within the surveillance frequency plus allowable extension and performance of the SR within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months was not

! achievable, enforcement discretion was requested and granted by the NRC.

II. DESCRIPTION OF TECHNICAL SPECIFICATIONS CHANGE REQUEST This LAR requests, on a one time basis, the substitution of the performance discharge test in lieu of the service test twice within the 60 month interval for battery BT1ED2.

This one time exception expires prior to entry into MODE 4 following the next Unit 1 outage of sufficient duration to perform a service test.

Ill. ANALYSIS The safety function of the batteries is to automatically pick up required DC loads in the event of loss of normal power to the battery chargers. The service test and the performance discharge test surveillances provide assurance that the batteries are capable of performing their safety function. The battery service test is a special test of battery capability to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length correspond to the design duty cycle requirements as specified in the FSAR. The battery performance discharge test is a test of battery capacity performed to an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months discharge rate as specified by the manufacturer, and is intended to determine overall battery capacity and battery degradation due to age and usage. The performance discharge test is generally considered a more severe test of battery capacity than the service test because it removes more ampere-hours. Partially because of this it is allowed to be substituted for the service test once per 60 month interval. However, the service test has higher short term ampere requirements and thus the performance discharge test does not completely envelope the service test requirements.

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? Attachment 2 to TXX-99133 Page 2 of 3 The batteries are designed with sufficient margin to ensure that they are capable of

. powering their required loads throughout the design life of the batteries. The batteries are normally replaced when the capacity of the battery based on the performance discharge test approaches 80%.' While the performance discharge test does not

specifically test at the higher ampere rating of the service test, it would be expected that if the battery were to develop problems associated with the ability to provide those higher ampere ratings, it would be more likely to occur near the end of service life of the battery (i.e.,80% capacity). The performance discharge test capacities of battery

. BT1ED2 were 97.2% and 95.4% for 1RF05 and 1RFO6 respectively. With the

.. available capacity margins indicated by these results the battery would certainly have passed a service test. In addition, during the service test the battery voltage is monitored. The margin between the recorded end of test voltage and the minimum required voltage provides an indication of the ability of the battery to sustain some degradation (e.g., normal battery aging) and still meet the service test current

- requirements. The last service test performed on BT1ED2 was during 1RFO4. For that test the battery's end of test voltage was 115.3V compared to a minimum required 105V. The end of test voltage for an earlier service test conducted during 1RFO2 was 115.6V. . The large margin (10.3V) between minimum required voltage and the end of test voltage for the service test in 1RFO4 and the small degradation in end of test voltages between.1RFO2 and 1RFO4 (0.3V) provides additional confidence that the battery would have passed service tests if they had been performed in 1RFO5 or

- 1 RFO6.

TXU Electric believes that the crediting the performance discharge test in lieu of the required service test is an acceptable alternative to requiring a Unit i shutdown to perform the missed surveillance.

Based upon the results of a Probabilistic Risk Assessment (PRA) evaluation, even using conservative assumptions with respect to the battery rellaollity, it is concluded that the change in risk can be considered to be non-risk significant. When one considers the risk related with transition and shutdown, it can be concluded that the undesirable transients (associated with transition and shutdown) pose greate_r risk than remaining at power while crediting the battery performance discharge test in lieu of the required service test.

.IV. SIGNIFICANT HAZARDS CONSIDERATIONS ANALYSIS i TXU Electric has evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10CFR50.92(c) as discussed below:

' 1.. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Crediting the battery performance discharge test in lieu of the required service test will not impact the ability of the battery to perform its safety functions. ,

Therefore, this change will not increase the probability or consequences of an !

accident previously evaluated. i o j

Attachment 2 to TXX-99133 Page 3 of 3

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

Crediting the performance discharge test in lieu of the required service test will not create a new or different kind of accident.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Crediting the performance discharge test in lieu of the required service test does not create any new failure scenarios and no margin is expected to be reduced.

As such, there is no reduction in any margin of safety.

In summary, TXU Electric has determined that crediting the performance discharge test in lieu of the required service test does not involve a significant hazard consideration and will not be of potential detriment to the public health and safety.

V. ENVIRONMENTAL EVALUATION TXU Electric has determined that the proposed amendment would change requirements with respect to the installation or use of a facility component located within the restricted area, as defined in 10CFR20, or would change an inspection or surveillance requirement. TXU Electric has evaluated the proposed changes and has determined that the changes do not involve (1) a significant hazards consideration, (2) l a significant change in the types or significant increase in the amounts of any effluent i that may be released offsite, or (3) a significant increase in individual or cumulative I

occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), an environmental assessment of the proposed change is not required.

VI. REFERENCES None l

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ML20195B641

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