ML20202F748
| ML20202F748 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/03/1986 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20202F753 | List: |
| References | |
| NUDOCS 8607150226 | |
| Download: ML20202F748 (4) | |
Text
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Nebraska Public Power District
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July 3,1986 l
Office of Nuclear Reactor Regulation BWR' Project Directorate No. 2 Division of BWR Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Daniel R. Muller
Reference:
- 1) Letter from L. G. KuncI to D. B. Vassalo, dated April 26, 1985, " Proposed Change No.19 to Technical Specifications for Cooper Nuclear Station; 125/250 VDC Station Batteries"
Attachment:
- 1) Revised Pages to Proposed Change No.19 and Attachment I to Technical Specifications
Dear Mr. Muller:
Subject:
Revision to Proposed Change No.19 to Technical Specifications, Cooper Nuclear Station; 125/250 VDC Station Batteries; NRC Docket No. 50-298, DPR-46 In accordance with the applicable provisions specified in 10CFR50, Nebraska Public Power District submitted a request for revision to Cooper Nuclear Station (CNS) Technical Specifications in Reference 1 for review and approval.
Subsequently, during conversations with the Staff, the necessity for revisions to Proposed Change No.19 was demonstrated.
The subject revisions are submitted herewith in addition to a revision to the evaluation of the (revised) proposed change with respect to the requirements of 10CFR50.92 in Attachment 1.
s This change incorporates all amendments to the CNS Facility Operating License through Amendment 100 issued May 20, 1986.
Should you have any questions or require additional information, please contact me.
Sincerely, tK h. Pilant Technical Staff Manager Nuclear Power Group JMP/Irb:lk cc:
H. R. Borchert Department of IIealth State of Nebraska 8607150226 860703 N
PDR ADOCK 05000298 l{g P
Attachmsnt 1 Revised Technical Specifications for 125/250 Volt D-C Station Batteries Revised Pages:
194 195 196 197 198 199 200 NRC inspection (84-26) was focused on the 125/250 volt D-C station batteries and resulted in the identification of Severity Level III violations and a subsequent civil penalty.
The NRC observed that the District had apparently failed to demonstrate the operability of the station batteries.
A thorough study of this issue was conducted by the District in order to correct any departure from NRC requirements.
The study included a review of pertinent NRC-endorsed and generated documents including, but not limited to, IEEE Standard 450-1980; IEEE Standard 308-1978; Regulatory Guides 1.129, 1.118, and 1.32; GE Standard Technical Specifications for BWR/4 (NUREG-0123); and the Standard Review Plan (NUREG-0800); as well as applicabic sections of the CNS Technical Specifications, USAR, Engineering Procedures, and the battery manufacturer's recommendations.
Nebraska Public Power District requests a revision to the Technical Specifications which will incorporate changes to the station battery surveillance requirements and bases in order to: ~1) improve the demonstration of the unit battery system operability, 2) incorporate appropriate guidance from the various aforementioned NRC endorsed industry standards, regulatory guides, etc., and battery manufacturer's recommendations.
In order to clarify the difference between existing and proposed Technical i
Specifications, a point-by-point explanation follows:
1.
The absolute value for the total battery terminal voltage on float charge
(>125 volts for the 125-volt batteries, >250 volts for the 250-volt batteries) was specified for the weekly surveillance addressing the measurement and recording of total battery voltage.
2.
Measurement and logging of electrolyte level for each pilot cell and a specified acceptable level range was added to the weekly surveillance items.
3.
Temperature and electrolyte level correction were added to the pilot cell voltage and specific gravity measurement surveillances, as well as the requirement that these parameters meet the specific numeric values noted.
4.
The measurement tolerance of 0.1 volt was deleted since it was deemed to be more appropriately addressed in the revised CNS surveillance procedure.
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A tolerance band of 15'F was specified for the acceptable temperature differential between a representative sample of battery cells.
6.
A performance discharge test to verify the station battery capacity to be at least 85 percent of the manufacturer's rating will be performed once per operating cycle.
J Each of the above changes were introduced to improve the overall demonstration of battery operability and provide for improved assurance of verification that the CNS station batteries fully satisfy their design function, utilizing the aforementioned documents as guidance.
It is the District's position that these changes will improve plant safety, hence there is no loss of safety function or any reduction in the degree of protection provided public health l
and safety.
Evaluation of this Revision with Respect to 10CFR50.92 A.
The enclosed Technical Specification change is judged to involve no significant hazards based upon the following:
1.
Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously evaluated.
Evaluation:
The proposed change will result in improved surveillance requirements and related surveillance procedures.
No changes to existing equipment are being introduced and no changes are being
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made to surveillances or procedures which will affect the probability or consequences of an accident previously evaluated.
I 2.
Does the proposed license amendment create the possibility for a new or different kind of accident from any accident previously evaluated?
Evaluation:
4 The proposed changes does not introduce any new mode of operation, l
and the possibility of an accident of a different type than analyzed in the FSAR would not result from the change.
3.
Does the proposed amendment involve a significant reduction in a i
margin of safety?
Evaluation:
i The proposed change does not change existing facility equipment.
The proposed change will, however, change existing surveillances and procedures, making them more stringent than previously required.
The additional surveillance requirements use NRC-endorsed or
~
generated standards as acceptance criteria and are being introduced to increase demonstrated operability of the station batteries.
This will not involve a significant reduction in the margin of safety.
I
B.
Additional basis for proposed no significant hazards consideration determination:
The Commission has provided guidance concerning the application of the standards for making a no significant hazards consideration determination by providing certain examples (48FR14870). The examples include "(11) A change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications:
for example, a more stringent surveillance requirement."
It is the District's belief I
that the proposed change is encompassed by the above example.
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