ML20196J074
| ML20196J074 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/28/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20196J072 | List: |
| References | |
| NUDOCS 9907070143 | |
| Download: ML20196J074 (4) | |
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UNITED STATES j
NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D.C. 20066 0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTCR REGULATION RELATED TO AMENDMENT NO. 65 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 65 TO FACILITY OPERATING LICENSE NO. NPF-89 k
IEXAS UTILITIES ELECTRIC COMPANY j
COMANCHE PEAK STEAM ELECTRIC STATION. UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 1.0 INTRODUCT!ON By application dated May 27,1999, as supplemented by letter dated May 28,1999, Texas Utilities Electric Company (TU Electric /the licensee) requested changes to the Technical Specifications for the Comanche Peak Steam Electric Station (CPSES), Units 1 and 2. The proposed changes would revise the Technical Specifications (TSs) to add a footnote to TS 4.8.2.1e, "D.C. Sources - Operating," which would, on a one-time basis for Unit 1 Battery BT1ED2, allow the licensee to substitute a performance discharge test "in lieu of the battery service test required by Specification 4.8.2.1d, twice within a 60 month interval." The footnote further states that "[t]his one time exception expires prior to entry into MODE 4 following the next Unit 1 outage of sufficient duration to perform a service test." The amendments also add a footnote to the comparable improved TS (ITS) that were issued by the NRC staff as License Amendments 64 and 64 to the CPSES, Units 1 and 2, Facility Operating Licenses on February 26,1999, but not as yet implemented by the licensee. In this regard, ITS Surveillance Requirement (SR) 3.8.4.7 would receive the same footnote, as added to TS 4.8.2.1e, with a i
minor grammatical change.
The May 28,1999, letter provided additional information that did not change the scope of the original application and the initial proposed no significant hazards consideration determination.
2.0 BACKGROUND
During the process of conducting reviews of battery surveillance testing, the NRC staff discovered that for CPSES Unit 1 Battery BT1ED2, credit had been taken for a performance discharge test, in lieu of a service test, more frequently than permitted by TS 4.8.2.1e, which states,in part:
Once per 60 month interval this performance discharge test may be performed in lieu of the battery service test required by TS 4.8.2.1d.
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~ 4 Performance discharge testing is required by TS 4.8.2.1e once per 60 months. When the battery reaches 85 percent of the service life expected for the application or if the battery shows signs of degradation, TS 4.8.2.1f requires that the performance discharge test be performed once per 18 months.
Battery BT1ED2 reacheo 85 percent of its expected service life in April 1996 just prior to CPSES, Unit 1, Refueling Outage 5 (1RF05). During this refueling, a performance discharge -
test was performed on this battery; similarly, a performance discharge test was performed in 1998 during 1RF06. The licensee mistakenly assumed that each performance discharge test could be credited for a service test. Since TS 4.8.2.1e permits the substitution only once per 60-month interval and the two refuelings were in the same 60-month interval, this substitution was not valid.
3.0 EVALUATION The licensee has requested, on a one-time basis, the use of the performance discharge test in lieu of the service test by adding the following footnote to TS 4.8.2.1e:
On a one time basis, for battery BT1ED2, this performance discharge test may be performed in lieu of the battery service test required by Specific & tion 4.8.2.1d, twice within a 60 month interval. This one time exception expires prior to entry i
into MODE 4 following the next Unit 1 outage of sufficient duration to perform a service test.
- The performance discharge and the service tests are complementary to each other to confirm that the battery has the capacity and the capability to perform its safety functions. At CPSES, Unit 1, the load requirements of the first minute is approximately 506 amps (A) while the procedure for the service test requires the test to be carried at 550A for 1 minute. The performance 8-hour discharge rate test as recommended by the manufacturer is 243A. The performance discharge test does not envelop the service test requirements; thus, the two tests are required in the TSs.
The licensee is requesting the crediting of the performance discharge test, for a second time in the 60-month period, in lieu of the required service test.
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The staff reviewed the results of previous performance and service tests, and found the following:
(a)
The cell connection tests performed in IRF04, IRF05, and IRF06 concluded that there
. are no signs of degradation of the connections.
(b)
- The performance discharge test capacities were 97.2 percent and 95.4 percent for 1RF05 and 1RF06, respectively, showing sufficient margin to ensure that the battery has enough capacity to power the required loads.
(c)
The last service tests of the BT1ED2 battery were performed during IRF02 and IRF04.
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The measured end voltages of the battery were 115.6 and 115.3 volts, respectively, -
compared to a minimum specified 105 volts. The margin is over 10 volts. Comparing
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< l the end voltages between IRF02 and IRF04, the staff noted that the degradation is I
minimal (0.3V). The preceding results indicate that the battery would have passed the service tests if they had been performed in IRF05 or 1RF06.
Based upon the preceding evaluation, the NRC staff concludes that, on a one-time basis for battery BT1ED2, the performance discharge test may be performed in lieu of the battery service test required by Specification 4.8.2.1d, twice within a 60-month interval. 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. Accordingly, the proposed changes to TS 4.8.2.1e and ITS
'l SR 3.8.4.7 are acceptable.
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4.0 EXIGENT CIRCUMSTANCES
in the licensee's letter dated May 28,1999, the licensee explained the exigent circumstances associated with its May 27,1999, application. The licensee noted that the normal 30-day Federal Reaister notice period could not be utilized because the application results from the i
licensee's request that the NRC exercise enforcement discretion. The NRC responded to the licensee's May 26,1999, request for enforcement discretion by issuing a Notice of Enforcement Discretion (NOED) on June 2,1999. The staff finds that, by submitting the application only 1 day after it requested issuance of the NOED, the licensee used its best efforts to file a timely application. The subject NOED indicated that the NRC staff plans to complete its review of the application within 4 weeks of the date of the NOED, which is less time than permitted by the normal 30-day Federal Register notice period. Accordingly, the staff finds that the amendment involves exigent circumstances in that the Commission and the licensee must act quickly and that time does not permit publication of a notice allowing 30 days for comment.
5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
S DETERMINATION The Commission's regulations in 10 CFR 50.92(c) state that the Commission may make a final determination that a license amendment involves no significant hazards considerations if operation of the facility, in accordance with a proposed amendment, would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) result in a significant reduction in the margin of safety. As required by J
10 CFR 50.91(a), the licensee has provided its analysis of the issue of no significant hazards consideration, which is presented, as follows:
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.
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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 l
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.
Based upon the preceding considerations, the NRC staff concludes that the amendments meet the three criteria of 10 CFR 50.92. Therefore, the staff has made a final determination that the proposed amerdments do not involve a significant hazards consideration.
6.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendments. The State official had no comments.
7.0 ENVIRONMENTAL CONSIDERATION
The amendments change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (64 FR 31881 dated June 14,1999).
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
8.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (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 Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: S.Saba D. Jaffe Date: June 28, 1999
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