ML20207C210

Forwards Summary of Joint Nrc/Tss Task Force Owner'S Group Meeting in Rockville,Md on 990513.List of Attendees Encl

ML20207C210
Person / Time
Issue date:	05/25/1999
From:	Beckner W NRC (Affiliation Not Assigned)
To:	Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
PROJECT-689 NUDOCS 9906020228
Download: ML20207C210 (27)

Text

'

l

. l May 25, 1999

)

Mr. James Davis Nuclear Energy Institute 1776 Eye Street, N. W. J Suite 300 )

Washington, DC 20006-2496

Dear Mr. Davis:

l Enclosed is a summary of our joint NRC/ Technical Specifications Task Force (TSTF)

Owner's Group meeting at the Nuclear Regulatory Commission in Rockville, Maryland, on May 13,1999. Should the TSTF have any comments or questions, please do not hesitate to contact me on 301-415-1161 or by e-mail at wdb@nrc. gov.

I Sincerely, Original Signed 0;<

William D. Beckner, Chief Technical Specifications Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: Those on Attendees Ust (Attachment 5)

Project No. 689

~

DISTRIBUTION:

PUBL C b DMathews SNewberry TSB Staff DOCUMENT NAME: G:\DLNATGSUM59.WPD *see previous concurrences.

OFFICE NRR/ DRIP /RTSB NRR/ NRR/ DRIP /RTSB 'NRR/ DRIP /RTSB NAME DLJohnson* SMagruder* RLDennigf WDBeckner WW DATE 05/19/99 05/21/99 05/ar/99 05/ 5 /99 OFFICIAL RECORD COPY O?.? i qcf.qj pAOhb 9906020228 990525 PDR REVCP ERGNUMRC PDR Ed.h '!.

t

$***:9 f \ -

UNITED STATES s* NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30seHOM

• +g*****

May 25, 1999 Mr. James Davis

. Nuclear Energy Institute 1776 Eye Street, N. W. -

Suite 300 Washington, DC 20006-2456

Dear Mr. Davis:

Enclosed is a summary of ourjoint NRC/ Technical Specifications Task Force (TSTF)

Owner's Group meeting at the Nuclear Regulatory Commission in Rockville, Maryland, on May 13,1999. Should the TSTF have any comments or questions, please do not hesitate to contact me on 301-415-1161 or by e-mail at wdb@nrc. gov.

Sincerely, 4/h D $&

William D. Beckner, Chief Technical Specifications Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: Those on Attendees Ust (Attachment 5)  !

. Project No. 689 l

l i

l TECHNICAL SPECIFICATIONS TASK FORCE MEETING

SUMMARY

May 13,1999 TST*-250 Disposition After discussion during the April 1999 Owners Group meeting, the TSTF was to have proposed an altamative to their proposed change, but wishes the proposed change to stand as submitted. After further discussion, the sts# agreed to hold disposition in abeyance until .

the TSTF can provide case studies to NRC showing experience of incorporation by reference.  !

The TSTF agreed to provide these case studies within three months.

NRC-Generated Travelers Staff provided a listing of NRC-generated proposed changes to the TSTF, as shown in Attachment 1.

Ice Condenserissues j Two travelers containing proposed changes are under TSTF review. These travelers address

" flow channel inspection" and " ice basket weight criteria." The TSTF estimated these travelers l will be submitted to NRC by early June 1999.

" Met vs. Performed"lasues

]

At the April 1999 Owners Group meeting, the TSTF committed to providing a White Paper and  :

training modules to the Staff. In addition, revisions to TSTF-284 and -288 were to be submitted. The White Paper was submitted to the Staff during this meeting and training modules were to be provided at a later date. The staff agreed to hold disposition of TSTF-284 in abeyance until TSTF submitted a revision incorporating TSTF-270. This revision is to be received by the NRC by earty June.

Pubhcotion of Revision 2 to the Standard Technical Specifications The TSTF submitted comments on formatting of Revision 2 to the Standard Technical Specifications via letter dated May 10,1999. These comments are under review by Tom Dunning TSB, and will be discussed during the June 16,1999 meeting. Prior to this meeting, the staff agreed to participate in a teleconference between the TSTF and NRC contacts.

The TSTF added that they wish to have incorporated with the this revision all outstanding high priority travelers.

The method for continued review of proposed changes to the ISTS was briefly touched on.

~ The TSTF proposed the numbering system for proposed changes to Rev. 2 begin with 400 to make it easier to identify these travelers as affecting Rev. 2. However, they do not wish to reconstruc'. proposed changes submitted prior to publication that were not incorporated with Rev. 2, but want to work with the staff to assure these proposed changes do not interfere with whatwas incorporated into Rev. 2.

Enclosure

p ~

. \

The TSTF suggested expanding the June 1999 meeting to two-days instead of the planned one. The staff will confirm availability on June 16 and 17.

Commitments made durina the April 1999 Owners Group Meetino A list summarizing commitments made during the April Owners Group meeting was provided with the Me2ng Summary distributed by letter dated April 27,1999. An update to those commitments appear in bold next to each commitment (see Attachment 3).

Determination of the priority of a proposed change was reintroduced for discussion. The staff l

believes that safety significant/ burden reduction changes should be assigned the highest priority. The staff will be looking at the age of outstanding proposed changes and their priority.

TSTF-287. R.2 (Control Room Habitability Envelope)

The staff indicated that there have been licensee requests to implement AOTs for control room integrity. The staff would like to see a generic TS that would address some ongoing issues .

related to surveillance testing of the boundary, as well as the requested AOTs. The TSTF will respond as to whether this is something they think they can make progress on.

Batterv Technical Specifications (TSTF-198 throuah -203) l Discussion involved TSTF response to NRC comments on a draft revision submittal. The staff felt there was not adequate justification for some of the proposed changes and also found the l draft revision to be inconsistent with what was agreed upon. The staff provided a preliminary reaction to the TSTF's proposal (see Attachment 4).

DC Sources - Shutdown (TSTF-204)

. The staff stated that Comanche Peak, during the conversion review, was found to be an acceptable approach. Basically, the discussion focused on how the Standard assumes a two-train bearing basis, but most, if not all, plants have a one-train basis. To improve the value of the Standard, it was decided to add a Reviewers Note to include both one- and two-train plants and appropriate altomative standard specs.

Next Joint NRC/TSTF Owners Group Meetina j

. 1 The NRC and TSTF will meet in June primarily to discuss publication of Revision 2 of NUREGs-1430 through -1434. A meeting notice will be distributed shortly.  ;

i l

1

s ..

Attachment 1 The TSTF has received 8 TSBs from the NRC. Their status is below.

TSB-2, Rev. O, Correct symbol in Table 3.3.1-1 (High) Harbuck This change is included in TSTF-310.

TSB 3, Rev. O, Correct SR Reference in 3.1.3, Required Actions A and C (Low) Dunning This change was processed as editorial change NRC EDIT-019.

TSB-7, Rev. O, Modify SR 3.2.1.1 to reference the COLR (Medium) Schulten The TSTF is considering this change. It would appear to apply in many locations arid may be mere work than the benefits warrant. TSTF and NRC to discuss.

l TSB-11, Rev. O, Update STS to Reflect 10 CFR 20 and 10 CFR 50.36a Changes Tjader '

Withdrawn 12/97 under the condition that TSTF would combine it with TSTF-086, -121, & -167 and submit as new traveler TSB-12, Rev. O, Revise DHR/SDC/RHR Condition Wording (Medium) Luehman l This issue is corrected in TSTF-263. 1 l

TSB-15, Rev. O, Allow 7 day Completion Time for a turbine-driven AFW pump l inoperable in MODE 3 (Medium) Giardina TSTF agrees with concept, but believe it needs a better presentation. A revition has been drafted and will be provided to the NRC shortly.

TSB 16, Rev. O, Revise NUREG-1431 LTOP requirements (Mediurr$ Weston Change is being reviewed by the WOG. Existing presentation is not j consistent with ISTS Writer's Guide. WOG to prepare a revision. l TSB 17, Rev. O, Change to Pressurizer level and LCO 3.4.9 and SG water levelto cover SG tubes Weston The TSTF is evaluating this change.

TSB 18, Rev. O, Removal of the word " irradiated" from LCO 3.9.4, Shutdown Cooling Weston The TSTF is evaluating this change.

Please note that the TSTF has not received:

TSB 1 (CSS 1) to CSS 17/97 l TSB-4 (CSS 1) to CSS 12/96 TSB 5 (CSS 1) to CSS 14/96 TSB-6 (CSS 1) to MWW 7/97 TSB-8 (CSS 1) to WDB for disp. 9/97 TSB-9 (TRT) retumed to TRT 9/97 TSB 10 (TRT) to FMR for disp.6/97 TSB 13 (RJG) to FMR for disp. 6/97 TSB 14 ;O31) to CSS 11/97

,+c-4*", .,a.no., ,n, ==e- -w-y.w.,,,,~uew . - + . .e.' -m -

" Met" versus " Performed" Ilp Reference to Surveillances)

The Surveillance Requirements' impact on complying with an I.CO have associated with them two distinct attributes. First, the Surveillance must beperformed. Second, the Surveillance must be met. The result of 7. performance can either be sadsfactory or unsatisfactory; that is it can meet the acceptance citeria or it can fall to meet the acceptance cdteda. Addidonally, '

acceptance criteda can be knwn to be met or not met even without a specific Surveillance performance.

These attributes are integral to, and spedically addressed in ITS SR 3.0.1 and SR 3.0.3.

Furthermore, these concepts /attdbutes have always been a part of the STS " motherhood" Specificadons 4.0.1 and 4.0.3. {The iTS SR 3.0.1 and 3.0.3 are presented as Attachments l with emphasis added to highlight these attributes.}

The phrase " performance of a Survel//ance" refers only to doing the activity required by the Surveillance to obtain specific knowledge which can then be evaluated against the stated acceptance cdteda (note: no mendon of passing or failing the criteria). The phrase " meet a Survei//ance" refers only to the knowledge that the stated acceptance cdteda of the Surveillance (note: no mendon of Frequency or performance) is sadsfied, i.e., the pump will  ;

pump the required flow at the required head. "Perfonnance" is done periodically. Meedng" the surveillance requirements is a condnuous acdvity, that can be evaluated based on either.  !

operadonal observadon, or surveillance performance.

Ideally, the use of " met" and " performed" in SR Notes would not be necessary: Notes above the Surveillance would be modifying the acceptance criteda (i.e., the " met" issue) and Notes above the Frequency would be modifying when the surveillance is to be conducted (i.e., the

" performed" issue). However, the Frequency column proved too narrow to accommodate the Note details in many cases. Once it was decided to allow these Frequency modification Notes in the SR column, guidance had to be created to distinguish between the two possible Note functions.

The reported confusion in property interpreting these Notes usually involves the " perform"  :

Notes, and usually results from inferdng that the " perform" Notes are establishing a prerequisite for conducting the test, as opposed to the actual intent of stadng when the Surveillance would become "past due" (or when the Frequency is applicable). When the Frequency states "31 days," it is understood that the requirement is not ' wait 31 days before allowed to perform,' but the requirement is that the next performance must be completed before the next 31 days is past. Similady, a Frequency Note stadng Only required to be performed in MODE 1" is not a prerequisite requiring MODE 1 to conduct the test, but it is 4 an allowance to consider the window for performance as not expired undl reaching MODE 1.

(As such, the performance in this example would occur pdor to entering MODE 1.)

Given this overview, if any change to modify the format or use/applicadon rules for the ITS is proposed it would appear to be to simply change the wording "...to be performed..." to explicidy state the histodcal implicadon of"...to have been performed to sadsfy the ' required Frequency'..."

BWR 1 3/15/97

The following is excerpted from the ITS Writer's Guide (NUMARC 9343, February 1993).

It expands some of this discussion, focusing on the applicadon to SR 3.0.4 and related excepdons.

Situations where a Surveillance could be required (i.e., its Frequency could expire), but it is not possible or not desired to be performed until sometime after the associated LCO is within the Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the Surveillance Requirement (i.e., the Surveillance and/or the Frequency) shall be stated such that it is only " required" when it can be and should be performed.

With a Surveillance Requirement satisfied, SR 3.0.4 imposes no restriction.

Taking explicit exception to the requirements of SR 3.0.4 is not an appropriate mechanism for addressing these conflicts.

To specify the precise requirements for performance of Surveillances, such that exceptions to SR 3.0.4 would not be necessary, the Frequency may be specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated as not required (to be met or performed) until a particular event, condition, or time has been reached. ~ When a Surveillance is noted as "only required" or "not required" it mus.t be accompanied by either "to be met" or "to be performed." Refer to Section 1.4. Frequency, for examples.

The use of " met" or " performed" in these instances convey specific meanings. A Surveillance is " met" only when the acceptance criteria are satisfied. Acceptance criteria known to be failed even without a

. Surveillance specifically being " performed," constitutes a Surveillance not

" met." " Performance" refers only to the requirement to specifically determine the ability to meet the acceptance criteria.

The following Examples further oudine these concepts. Note that the Examples within

" Frequency," Secdon 1.4, are also consistent with these discussions as well as the following Examples.

4 BWR 2 3/15/97

+. .

8 EXAMPi E "Not Reindred To Be Performed" When a Surveillance is "not required to be performed," no excepdon to " meet /ng" the acceptance criteria are made. If the Surveillance is known to be falling the acceptance cdteda, the SR is sdll not met and therefore, the LCO is not met. Only the requirement to ,

perform a test (assuming it was due to be performed) is taken excepdon to. This type of i excepdon is used when the performance of the Surveillance procedure would be inappropriate considering the plant condidons, or would not allow sufficient operadonal flexibility to accomplish the test.

Example...

SURVEILLANCE FREQUENCY SR 3 . 5 . 3. x - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - -

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after exceeding 920 psig. .,

Verify turbine driven pump flow rate >600 9pm 92 days when supplied with steam at >920 psig.

(Note: a similar example is found in example 1.4-3 in Section 1.4, Frequency). In this example, if the unit had been shutdown when the 92 day Frequency (+ 25%) expired,'a requirement to perform it prior to entering a MODE of Applicability would not be possible.

Therefore, performance is~ excepted undi appropriate conditions can be established and established for sufficient duradon. However, if the pump was known to be incapable of producing 600 gpm at 920 psig steam supply pressure (e.g., the acceptance criteria known to be failed), the Surveillance Requirement would still be considered not met.

BWR 3 3/15/97

'~~

... . l i

EXAMPLEt "Not Reindred To Be Met

• When a Surveillance is "not required to be mer," any knowledge that the acceptance cdteda

, are failed is of no matter - the acceptance'cdteria does not have to be met in this instance.

This type of excepdon is used when plant condidons are beyond the inidal condidons for which the Surveillance's acceptance cdteria was generated, and therefore, the specific knowledge related to the Surveillance is not direcdy applicable to evaluadon against the acceptance cdteria for this condition.

Example...

SURVEILLANCE FREQUENCY SR 3.4.x.x ---------------------NOTE-----------------------

Only required to be met when recirculation pump is in operation. l Verify [ loop parameters) are within limits. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Note: a similar example is found in example 1.4-3 in Secdon 1.4, Frequency). In this example, the loop parameter limits reflect characteristics of the pump and integrity of the loop components. The Surveillance specified to evaluate the pump and loon, was developed assuming the pump was in service. With the pump not in operadon, a paieneter may be outside of a specific limit and not necessarliy reflect unacceptable pump or loop charactedstics. ,

Note: In this instance it would appear that performance may sdll be required,

- however, if knowledge were gained by performance it could be ignored in this condition - therefore, "not requ/ red to be met" can be considered to contain an implicit excepdon to performance also.

BWR 4 3/15/97

~'.* ATTACHMENT (Extracted ITS Secdons)

SR 3.0.1 SRs shall be met during the MODES or other specified conditions in f the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Survel11ance, whether such failure is experienced during the performance of the Surveillance or betweel {

performances of the Surveillance, shall be failure to meet the LCO.

Failure to perform a Surveillance within the specified Frequency Shall be failure to meet the LCO, except as provided in SR 3.0.3.

l Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.3 l

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare ~

l the LC0 not met may be delayed, from the time of discovery, up to 24 I hours or'up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance. ,

If the Surveillance is not performed within the delay period, the LCO must imediately be declared not met, and the applicable Conditions l must be entered. The Completion Times of the Required Actions begin imediately upon expiration of the delay period.

l When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must imediately be declared not -

met, and the applicable Conditions must be entered. The Completion Times of the Required Actions begin imediately upon failure to meet the Surveillance.

l l

BWR 5 3/15/97

, , I Attachment 3 UPDATE OF COMMITMENTS MADE DURING THE 4/22/99 JOINT NRC/TSTF OWNER'S GROUP MEETING:

By 4/26/99 TSTF will submit a revision to TSTF-258 Revision 4 was received by the staff on 4/28/99.

TSTF will submit a revision to TSTF-266 TSTF will submit by 6/8/99.

TSTF will submit a revision to TSTF-273 TSTF will submit t>y 6/8/99.

TSTF will submit a revision to TSTF-284 TSTF will submit by 6/8/99.

TSTF will submit a revision to TSTF-288 Revision 1 was received by the staff on 4/28/99.

By 4/30/99 TSTF will submit revised travelers relating to Ice Condenser issues TSTF will submit two '

travelers by 6/8/99. I NRC will submit remaining TSB-generated proposed changes Letters have been composed and are making the signature rounds; should be dispatched by 5/17/99.

i TSTF will submit TSTF-051, Revision 1 Revision 1 was received by the staff on 4/28/99.

NRC (TRT) will make a recommendation on TSTF-107, Revision 3 A Modify disposition was  :

made by NRC 5I11/99.

NRC (MM will make a recommendation on TSTF-113, R.4 Recommendation was made to reject based on SRXB's comments. Proposed changes are related to a TSB-generated proposed change, which is to be submitted to TSTF shortly.

TSTF (TWeber) will respond to NRC's (MWW) comments (environmental vs. outside atmosphere) on TSTF-197, Revision 1 Response received by NRC 4/30; comments provided to technical branch.

TSTF (DBuschbaum) will provide additional information to NRC (EST) on TSTF-315 Additional information from TSTF is still forthcoming as of the 5/13/99 meeting.

NRC (DLJ) will submit letter to NEl regarding change in disposition to TSTF-021, Revision 1 Letter was dated 4/29/99.

TSTF (DBuschbaum) will submit revision to TSTF-309 Revision 1 received 4/28/99.

TSTF will provide comments on the March 4,1999 letter to Jim Davis from NRC regarding STS Rev. 2 formatting changes Comments received via letter dated 5/10/99.

. TSTF will submit White Paper and training modules regarding " Met vs. Performed" issues White Paper submitted 5/13/99; training modules forthcoming.

By 5/13/99 TSTF will submit a revision to TSTF-198 TSTF submitted a draft revision, for which NRC responded with further comments. The TSTF are to address these comments and submit 1 L a revision.

l TSTF will submit a revision to TSTF-199 TSTF submitted a draft revision, for which NRC responded with further comments. The TSTF are to address these comments and submit a revision. l l TSTF will submit a revision to TSTF-200 TSTF submitted a draft revision, for which NRC l responded with further comments. The TSTF are to address these comments and submit )

! a revision. l l  !

TSTF will submit a revision to TSTF-201 TSTF submitted a draft revision, for which NRC responded with further comments. The TSTF are to address these comments and submit a revision.

! TSTF will submit a revision to TSTF-202 TSTF submitted a draft revision, for which NRC responded with further comments. The TSTF are to address these comments and submit a revision.

l TSTF will submit a revision to TSTF-203 TSTF submitted a draft revision, for which NRC responded with further comments. The TSTF are to address these comments and submit l a revision.

1 NRC (CSS 1) will provide a status on TSTF-212 Proposed changes forwarded to ElCB l 5/12/99.

NRC (CSS 1) will provide a status on TSTF-215 The staff has further questions and will contact the respective OG Chairman within one week.

NRC (CSS 1) will provide a status on TSTF-218 Proposed changes forwarded to SRXB 5/12/99.

TSTF (NCarkson) will respond to NRC's Modify disposition to TSTF-262 TSTF response will be provided to the staff by 5/28/99.

TSTF (NCarkson) will respond to NRC's Modify disposition to TSTF-263 TSTF response will be provided to the staff by 5/28/99.

1 l.

TSTF (NCarkson) will respond to NRC's Modify disposition to TSTF-265 TSTF response will be provided to the staff by 5/28/99.

NRC (CSS 1) will provide a status on TSTF-264 SRXB to make a recommendation by 8/30/99.

TSTF will submit a revision to TSTF-283 TSTF to submit ~ revision by 6/8/99.

TSTF will provide a status on TSTF-286 Still under TSTF review; feedback by 6/8/99.

TSTF will submit a revision to TSTF-290 Still under TSTF review; feedback by 6/8/99.

NRC (CSS 1) will provide a status on TSTF-291 The staff has further questions and will  !

contact the respective OG Chairman within one week. I NRC (CSS 1) will provide a status on TSTF-292 Recommendation to reject made 5/12/99.

NRC (CSS 1) will provide a status on TSTF-293 Recommendation to approve made 5/12/99.

NRC (CSS 1) will provide a status on TSTF-295 Forwarded to ElCB 5/12/99.

NRC (CSS 1) will provide a status on TSTF-306 Recommendation to modify made 5/12/99. ]

NRC (CSS 1) will provide a status on TSTF-324 June 16.1999 Next Joint NRC/TSTF Owner's Group meeting TSTF proposed a two-day meeting; NRC will i confirm.

By 7/30/99 NRC (BTjader) will contact TSTF to discuss final review methods of STS Rev. 2 Other Commitments Made TSTF-016, Rev.1: Bryan Ford, TSTF will contact Ed Tomlinson, NRC Contact is forthcoming.

TSTF-036, Rev. 3: Bryan Ford, TSTF, will contact Ed Tomlinson, NRC Contact is forthcoming.

' TSTF-058: Nanette Gilles, NRC will make recommendation after NRC intemal me.etings take place Disposition to Modify was made 5/6/99.

4 en@ '-W= - OO 'R 4 4 2P -F' e, W e w$M,hh # g ,,y.. y, p e

• b488834+

4 TSTF-059: Nanette Gilles, NRC will make recommendation after NRC intomal meetings take place Disposition to Modify was made 5/6/99.

TSTF 204: Disposition changed from Reject to Modify; Ed Tomlinson and Electrical and instrumentation Controls Branch, NRC, to work with TSTF to resolve Discussed during I 6/13/99 meeting; TSTF will provide revision.

TSTF-285: Disposition changed from Reject to Modify; TSTF to provide addition, as agreed Revision 1 was received, reviewed, and approvad on 5/6/99.

TSTF 322: Bryan Ford, TSTF, will review NRC's disposition (Modify) NRC disposition letter is forthcoming.

NRC to rank NRC-generated proposed changes by High, Medium and Low, and provide to TSTF NRC provided ranking during 5/13/99 meeting (see Attachment 1).

l l

l

I Preliminary Reaction to Draft Submittal of Proposed Revision to the Battery Tech Specs (TSTF-198 through -203)

1. In LCO 3.8.4, proposed Condition A, the phrasing "one or more" does not appear to be acceptable.

2. The staff questions the use of 2.07 Volts per cell as a limit in several places in the proposed TS. Per IEEE-450, a cell with a float voltage of 2.07 volts is defective and ,

should be replaced. Some other value should be considered for OPERABill1Y determinations.

3. Proposed SR 3.8.6.4 does not state the limits for pilot cell temperature.

4. The Bases for SR 3.8.4.1 need to be revised to clearly state that failure of this SR results in an inoperable battery charger, not an inoperable battery.

5. The staff does not understand insert SR 3.8.4.3. The TSTF should explain tls icert or revise it to be more clear. Also, a Justification should be provided.

6. Insert 3.8.6 LCO Bases raises a question regarding the adequacy of float current as a means of determining the state of charge of a battery. According to this insert, a float current of less than 2 amps following a battery recharge at the float voltage level may indicate the battery is fully charged prior to actual completion of the recharge. If true, this means that float current is not an acceptable means of establishing that a battery is recharged. This question needs to be addressed in detail. '

e e

.p e *Meyer- t% **

my +=== e e= ;* y ,4 ,

737F- 148 yhni -2,o3 s hisE 3 \

Q ydY.4, f b EL b 1- Added a new action when one or more [requiredJ battery chargers inoperable. Required action: Verify associated battery terminal voltage is ;t [# of connected cells X 2.07 VJ with Comt.1 ran Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND Restore

[ required) Dattery charger (s) to OPERABLE status with completion time of 7 days. -

(p3.8-25)

DISAGREEMENT Disagree that action will assure no loss of safety function. Assurance that battery remains fully charged is not provided by measuring battery terminal voltage with a spare charger connected.

With the deletion of item 2, the completion time for an inoperable battery due to loss of a battery charger was changed from 2 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. With this deletion, the agreement for item.1 changes to disagreement 2 When one or more batteries with overall battery terminal voltage less than [# connected cells X [2.07] volts), a required action has been added to declare associated battery inoperable immediately. -p3.8-32 AGREEMENT Proposed change deleted. See item 1.

3 Changed completion time when one DC electrical power subsystem inoperable.

Completion time changed from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. - p3.8 25 j DISAGREEMENT I

This change has been deleted from their proposal.

4 Changed the location at which battery charger output is monitored. Monitoring was changed from battery terminal to charger output terminal. - p3.8-25 DISAGREE. MENT They continue to include the proposed change - IEEE 4501995 recommends battery float voltage be monitored at the battery tenninals. The staff continues to disagree 5 The frequency for monitoring battery charger output was changed. The Frequency was changed from 7 days to 31 days. - p3.8-25 DISAGREEMENT This change has been deleted from their proposal. -

6 92 day surveillance removed to verify no visible corrosion at battery terminals and connectors. - p3.8-26 AGREEMENT

2 IEEE 450-1995 recommends corrosion be checked at least once per month. The staff feels that the corrosion check is a maintenance item and that a commitment to perform the check should be included in the SAR by commitment to meet the recommendations of 450-1995. I 7 12 month surveillance removed to verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration. - p3.8-26 AGREEMENT IEEE 450-1995 recommends condition of cells, plates, and racks be checked at least once per year. The staff feels that the this chock is a maintenance item and that a commitment to I perform the check should be included in the SAR by commitment to meet the recommendations i of 450-1995.

8 12 months surveillance deleted to remove visible terminal corrosion and to verify battery cell to cell and terminal connections are [ clean and tight, and are) coated with anti-corrosion material. -- p3.8-26 AGREEMENT The staff feels that the this check is a maintenance item and that a commitment to perform the check should be included in the SAR by commitment to meet the recommendations of 450-1995. '

9 12 months surveillance deleted to verify battery connection resistance' - p3.8-26 AGREEMENT IEEE 4501995 recommends cell to cell and terminal connection detail resistance be checked at least once per year. The staff feels that the this check is a maintenance item and that a commitment to perform the check should be included in the SAR by commitment to meet the recommendations of 4501995.

10 Added an optional surveillance for verifying capability of battery charger. Option ,

surveillance: On a frequency of 18 months Verify each battery charger can rechaige the battery within [24) hours while supplying the expected normal operating loads, after a battery discharge greater than or equivalent to the battery service test and while on

" equalize"- p3.8-27  ;

DISAGREEMENT Recharge of the battery after a service test may not adequately test the full output capability of the charger.

11 7 day Surveillance deleted to verify electrolyte level of designated pilot cell is > Minimum level indication mark, and s 1/4 inch above maximum level indication ma.rk - p3.8-32 AGREEMENT n

F

. s l

3 l

l 7 day surveillance was replace by a 31 day surveillance (SR 3.8.6.1) which follows the

) recommended frequency of 450-1995.

12 When electrolyte level of designated pilot cellis outside required limits, the required action has been deleted to (a) verify within one hour that electrolyte level of pi'ot cell is above top of plates and not overflowing, (b) verify within one hour that each battery cell voltage is greater than 2.07 volts, (c) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and once per 7 days thereafter) that the electrolyte level of all cells is above top of plates and not overflowing, (d) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that specific gravity of all cells is not more than 0.200 below

. average connected cells and average of all connected cells is greater or equal to

[1.195], and (e) Restore battery cell parameters to required limits within 31 days -OR-Declare associated battery inoperable. ~ p3.8 31 1

) AGREEMENT i

l SAR commitment to 4501995 13 92 day surveillance deleted to verify electrolyte level for each cell is > Minimum level indication mark, and s 1/4 inch above maximum level indication mark -- p3.8-33 l l

AGREEMENT I l 31 day surveillance added which is consistent with recommendation of 450-1995 I

14 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after battery discharge of less than [110] volts surveillance deleted to i verify electrolyte level for each cell is > Minimum level indication mark, and s 1/4 inch l l

above maximum level indication mark, cell voltage above [2.13] volts, and cell specific 1 l gravity above [1.195]. -- p3.8-33 DISAGREEMENT l 450-1995 requires a special inspection if the battery has experienced an abnormal condition (such as a severe discharge or overcharge) to ensure that the battery has not been damaged.

l 15 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after battery overcharge of greater than [150] volts surveillance deleted I

to verify electrolyte level for each cell is > Minimum level indication mark, and s 1/4 inch above maximum level indication mark, cell voltage above [2.13] volts, and cell specific gravity above [1.195]. -- p3.8-33 DISAGREEMENT 4501995 requires a special inspection if the battery has experienced an abnormal ocndition '

(such as a severe discharge or overcharge) to ensure that the battery has not been damaged.

16 When electrolyte level of any cellis outside required limits, the required action has been deleted to (a) verify within one hour that electrolyte level of pilot cell is above top of plates and not overflowing, (b) verify within one hour that each battery cell voltage is greater than 2.07 volts, (c) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and once per 7 days thereafter) that

4 the electrolyte level of all cells is above top of plates and not overflowing, (d) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that specific gravity of all cells is not more than 0.200 below average connected cells and average of all connected cells is graater or equal to [1.195], and (e)

Restore battery cell parameters to required limits with'.n 31 days -OR- Declare associated battery inoperable. - p3.8 31 AGREEMENT SAR commitment to 450-1995.

17 31 day surveillance added to verify each cell's electrolyte level is above the top of the plates. -- SR3.8.6.1 AGREEMENT Recommended by IEEE 450-1995. 450 recommends all cells -TS basis indicates 450 only recommends pilot cells 18 When electrolyte level of one or more cells is found below the top of plates, a required action has been added to restore the level above the top of the plates within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

- OR- Declare associated battery inoperable. - p3.8-31 DISAGREEMENT This change has been modified as follows: When electrolyte level of one or more cells is found below the top of plates, a required action has been added to verify each connected cells electrolyte level is equal to or greater than 90% plate coverage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and verify overall battery terminal voltage is equal to or greater than [# connected cells X [2.07] volts) within two hours, and to restore the level above the top of the plates within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> -- OR-- Declare associated battery inoperable. - p3.8-31 DISAGREEMENT 19 7 day surveillance deleted to verify pilot cell voltage is greater then or equal to [2.13]

volts. - p3.8-32 AGREEMENT Surveillance added which is consistent with 4501995 recommendations see item 21.

20 When pilot cell voltage is below 2.13 volts, the required action has been deleted to (a) verify within one hour that electrolyte level of pilot cell is above top of plates and not .

overflowing, (b) verify within one hour that each battery cell voltage is greater than 2.07 volts, (c) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and once per 7 days thereafter) that the electrolyte level of all cells is above top of plates and not overflowing, (d) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that specific gravity of all cells is not more than 0.200 below average connected cells and

.. . ~ . - , , - . . ,- .. __

s ,

• i l

average of all connected cells is greater or equal to [1.195], and (e) Restore battery cell parameters to required limits within 31 days -OR- Declare associated battery inoperable. - p3.8 DISAGREEMENT .

IEEE 450-1995 indicates cell voltage is not, by itself, an indication of the state of charge of the battery. Prolonged operation of cells below 2.13 V can reduce the life expectancy of cells.

21 31 day surveillance added to verify pilot cell voltage is greater then or equal to [2.07]

volts. - SR3.8.6.2 I

AGREEMENT Recommended by 450-1995. .

22 When pilot cell voltage is found below [2.07] volts, a required action has been added to l restore voltage above [2.07] volts within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> -- OR- Declare associated battery l Inoperable. - p3.8-31 -

1 DISAGREEMENT lEEE 450-1995 notes that a cell voltage of 2.07 or below under float conditions and not caused by elevated temperature of the cell indicates intemal cell problems and may require cell replacement.

23 92 day surveillance deleted to verify cell voltage is greater then or equal to [2.13] volts. - .

- p3.8-33 AGREEMENT-lEEE 450-1995 recommends voltage of each cell be monitored at least once per quarter which was included under item 27.

24 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after battery discharge of less than [110] volts surveillance deleted to verify electrolyte level for each cell is > Minimum level indication mark, and s 1/4 inch above maximum level indication mark, cell voltage above [2.13] volts, and cell specific gravity above [1.195]. -- p3.8-33 DISAGREEMENT

. 4501995 requires a special inspection if the battery has experienced an abnormal condition (such as a severe discharge or overcharge) to ensure that the battery has not been damaged.

25 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after battery overcharge of greater than [150] volts surveillance deleted to verify electrolyte level for each cell is > Minimum level indication mark, and s 1/4 inch above maximum level indication mark, cell voltage above [2.13] volts, and cell specific gravity above [1.195]. - p3.8-33 s new . - m -e..---- .ap m% m . . .m p g g.- =*e**** , , _

n ,- ,

C 6

~

6

~

DISAGREEMENT 4501995 requires a special inspection if the battery has experienced an abnormal condition (such as a severe discharge or overcharge) to ensure that the battery has not been damaged.

26 When cell voltage of one or more cells is below 2.13 volts, the required action has been deleted to (a) verify within one hour that electrolyte level of pilot cell is above top of plates and not overflowing, (b) verify within one hour that each battery cell voltage is greater than 2.07 volts, (c) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and once per 7 days thereafter) that the electrolyte level of all cells is above top of plates and not overflowing, (d) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that specific gravity of all cells is not more than 0.200 below average

. connected cells and average of all connected cells is greater or equal to [1.195], and (e)

Restore battery cell parameters to required limits within 31 days -OR- Declare associated battery inoperable. - p3.8-31 .

DISAGREEMENT

IEEE 450-1995 indicates cell voltage is not, by itself, an indication of the state of charge of the battery. Prolonged operation of cells below 2.13 V can reduce the life expectancy of cells.

27 92 day surveillance added to verify ceil voltage is greater then or equal to [2.07] volts. -

p3.8-33 AGREEMENT The quarterly inspection of voltage of each connected cell is also consistent with IEEE 450-1995 -

28 When voltage of one or more cells is found below [2.07] volts, a required action has been added to restore voltage above [2.07] volts within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - OR-- Declare associated battery inoperable. - p3.8-31 DISAGREEMENT This proposed change was modified as follows: When voltage of one or more cells is found below [2.07] volts, a required action has been added (1) to verify each connected cells electrolyte level is equal to or greater than 90% plate coverage, (2) to verify overall battery terminal voltage is equal to or greater than [# connected cells X [2.07] volts], and (3) to restore voltage above [2.07] volts within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - OR-- Declare associated battery inoperable. --

p3.8 31 DISAGREEMENT lEEE 450-1995 notes that a cell voltage of 2.07 or below under float conditions and not caused by elevated temperature of the cell indicates intamal cell problems and may require cell replacement.

i .

1

~

7 29 7 day surveillance deleted to verify pilot cell specific gravity is greater then or equal to

[1.200]. ~ p3.8-32 DISAGREEMENT IEEE 450-1995 recommends pilot cell specific gravity be checked at least once per month.

30 When pilot cell specific gravity is.below [1.200) volts, the required action has been deleted to (a) verify within. one hour that electrolyte level of pilot cell is above top of plates and not overflowing, (b) verify within one hour that each battery cell voltage is greater than 2.07 volts, (c) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and once per 7 days thereafter) that the electrolyte level of all cells is above top of plates and not overflowing, (d) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that specific gr&vity of all cells is not more than 0.200 below average connected cells and average of all connected cells is greater or equal to [1.195], and (e)

Restore battery cell parameters to required limits within 31 days -OR- Declare associated battery inoperable. - p3.8-31 DISAGREEMENT 450-1995 requires increased surveillance and correction by equalize charge or analysis.

31 92 day surveillance deleted to verify each cell's specific gravity is greater then or equal to [1.195]. -- p3.8-33 DISAGREEMENT .

IEEE 450-1995 recommends 10% of the battery cells be checked for specific gravity at least once per quarter. 450 indicates specific gravity is utilized to assure the state of charge of the battery cells.

32 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after battery discharge of less than [110) volts surveillance deleted to verify electrolyte level for each cell is > Minimum level indication mark, and s 1/4 inch above maximum level Indication mark, cell voltage above [2.13] volts, and cell specific gravity above [1.195]. -- p3.8-33 DlSAGREEMENT 450-1995 requires a specialinspection if the battery has experienced an abnormal condition (such as a severe discharge or overcharge) to ensure that the battery has not been damaged.

33 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after battery overcharge of greater than [150] volts surveillance deleted to verify electrolyte level for each cell is > Minimum level indication mark, and s 1/4 inch above maximum level indication mark, cell voltage above [2.13] volts, and cell specific gravity above [1.195]. ~ p3.8-33 ,

^

DISAGREEMENT 450-1995 requires a specialinspection if the battery has experienced an abnormal condition

l 4

~

8 (such as a severe discharge or overcharge) to ensure that the battery has not been damaged.

34 When cell specific gravity of one or more cells is below [1.195], the required action has been deleted to (a) verify within one hour that electrolyte level of pilot cell is above top of plates and not overflowing, (b) verify within one hour that each battery cell voltage is greater than 2.07 volts, (c) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and once per 7 days thereafter) tnat the electrolyte level of all cells is above top of plates and not overflowing, (d) verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that specific gravity of all cells is not more than 0.200 below average connected cells and average of all connected cells is greater or equal to [1.195], and (e)

Restore battery cell parameters to required limits within 31 days -OR- Dec'.<a associated battery inoperable. - p3.8-31 AGREEMENT The staff believes that specific gravity measurements 35 31 day' surveillance added to verify battery float current is below [2] amps. - SR3.8.6.3 AGREEMENT Recommended by 450-1995.

36 When float current is greater than [2] amps, a required action has been added to restore float current to below [2] amps within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - OR-- Declare associated battery inoperable. - p3.8-31 DlSAGREEMENT This proposed change has been further modified as follows: When float current is greater than

[2] amps, a gequired action has been added (1) to verify each connected cells electrolyte level is equal to or greater than 90% plate coverage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, (2) to verify overall battery terminal voltage is equal to or greater than [# connected cells X [2.07] volts) within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and (3) to restore float current to below [2] amps within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - OR- Declare associated battery inoperable. - p3.8-31_

DISAGREEMENT No test or analysis available to demonstrate the continued capability / capacity of the battery to

' perform its required function when not fully charged when float current is between 2 and 10 amps and cell temperature are within limits. .

-37 When float current is greater than [10] amps, a required action has been added to Declare associated battery inoperable. - p8.3 32 AGREEMENT Agreement is based on the 10 amps being changed to 2 amps 1

S

. l

. I

o a --

9 38 92 day surveillance deleted to verify average electrolyte temperature of representative cells is greater or equal to [60)F - p3.8 33 DISAGREEMENT - -

4501995 recommends temperature of electrolyte of 10% of battery cells once per 92 days -

- 39 31 day surveillance added to verify pilot cell temperature is greater or equal to [60]F. -

SR3.8.6.4 :

AGREEMENT This proposed change was modified as follows: 31 day surveillance added to verify pilot cell temperature is within limits. -- SR3.8.6.4 AGREEMENT Consistent with 450-1995 - a limit (60F] needs to be specified.

4 i

l

f g ATTENDEES LIST NRC/TSTF OWNER'S GROUP MEETING MAY 13,1999 NAME ORGANIZATION ADDRESS PHONE # E-MAIL ID H:rry Pontious BWROG/ Coned LaSalle County Station 815-357-6761 herold.d.conti x2231 ous@uem.co m

Bryan Ford Entergy/BWROG P.O. Box 756 601-368-5792 hforo@entera Port Gibson, MS 39150 v.com D:nald Hoffman EXCEL /TSTF 11921 Rockville Pike 301-984-4400 donaldh@exc l Suite 100 elsves.com Rockville, MD 20852 l

D. Buschbaum TSTF/WOG TU Electric 254-897-5851 dbuschb1@tu P. O. Box 1002 electric.com l Glen Rose, TX 76043 Noel Clarkson Duke Energy Oconee Nuclear Site 864-875-3077 ntclarks@duk (BWOG TSTF) P.O. Box 1439 e-enerav.com Seneca, SC 29679 Vince Gilbert NEl Suite 400 202-739 8138 iva@nei. ora 17761 Street, NW Washington, DC 20006-3708 ,

Tcm Weber CEOG-APS Palo Verde Nuclear 602-393 5764 tweber01@ao Mail Station 7636 sc.com 5801 South Wintersburg Road Tonapah, AZ 85354-7529 Dan Williamson TSTF/ EXCEL 271 Glenlyon Dr. 904-272 5300 dwden! San Orange Pk, FL 32073 com Bob Tjador NRC/TSB NRC 301-415 1187 trt@nrc.aov Larry Kopp NRC/SRXB NRC 301-415-2879 lik@nrc.oov Angela Chu NRC/TSB NRC 301-415-2937 atc@nrc.aov Bob Dennig NRC/TSB NRC 301-415-1156 rid @nre.oov D. Johnson NRC/TSB NRC 301-415-3060 dii@nrc.aov Nanette Gilles NRC/TSB NRC 301-415-1180 nva@nre.oov Temmy Le NRC/TSB NRC 301-415 1458 nbl@nrc.aov Jim Lazevnick NRC/EElB NRC 301-415 2782 iil@nrc.oov Page 1 of 1

e .

1 i

l ATTENDEES LIST NRC/TSTF OWNER'S GROUF . 4CTING MAY 13,1999 NAME ORGANIZATION ADDRESS PHONE # E-Mall ID  ;

John Knox NRC/EElB NRC 301-415 2763 ilk @nre.oov Ed Tomlinson NRC/TSB NRC 301-415 3137 ebt@nre.aov I l

S.Saba NRC/EElB NRC 301-415-2781 sns1@nrc. gov Robert Giardina NRC/TSB NRC 301-415-3152 ria1@nrc.aov Steve LeVie NRC/SPSB NRC 301-415-10i31 sfl@nrc.aov Mark Reinhart NRC/SPSB NRC 301-415 1185 fmr@nrc.aov Harold Walker NRC/SPLB NRC 301-415-2821 hxw@nrc.aov J hn Sagata NRC/SPLB NRC 301-415-1858 los1@nrc.aov DOCUMENT NAME: G:\RTSBVOHNSON\ ATTEND 59.WPD l

l l

l l

l l

Page 2 of 2 l

I 1 l

)

NEl Project No. 689 cc: Mr. Ralph E. Beedle, Senior Vice President and Chief Nuclear Officer Nuclear Generation Nuclear Energy institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Ms. Lynnette Hendricks, Director Plant Support Nuclear Energy Institute Suite 400 17761 Street, NW Washington, DC 20006-3708 Mr. James W. Davis, Director l Operations l' Nuclear Energy institute Suite 400 17761 Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 l

j l

e e

9 e

m.

• m ,,%..ew-+--*wo.**

• iy4Wa***%mre,-.==am.+,.ea-sm===amm..~ - + e= w