ML20246F697
| ML20246F697 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/24/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1695, TAC-73611, NUDOCS 8908310109 | |
| Download: ML20246F697 (2) | |
Text
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c.ye TOLEDO ~
%s EDISON:
A Centerer Energy Company Docket Number 50-346 DONAM) C. SHELTON ~
vce %.,oent-mueer License' Number NPF-3
~ Serial Number 1695-l
.,'1989
-August.24-A l United States Nuclear' Regulatory Commission Document Control Desk Washington,.D..C.
20555
Subject:
' Technical: Specification Battery Surveillance Requirements (TAC Number 73611)'
Gentlemen:
The Nuclear Regulatory Commission (NRC) letter dated March 12, 1988 (Log Number 2232), issued. Amendment Number 100 to Facility Operating License Number NPF-3 for the Davis-Besse Nuclear Power Station, Unit Number 1.
Amendment Number 100 revised Appendix A, Technical Specification Section 3/4.8.2.3, D.C.
Distribution - Operating, to be consistent with the model technical specifications for station batteries provided by the NRC in a letter to Toledo Edison dated July 16,.1981 (Log Number 756).
Prior to' issuance of Amendment Number 100, Toledo Edison identified a potential problem ~related to the interpretation of Surveillance Requirement 4.8.2.3.2 to the NRC staff during a telephone call on February 25, 1988.
Specifically, Surveillance Requirements 4.8.2.3.2.a.1 and 4.8.2.3.2.a.2 require verification of pilot cell parameters and battery terminal voltage while on float charge, at least once per seven days.
This surveillance requirement could be misinterpreted to preclude verification of these battery and pilot cell parameters while the battery is undergoing an equalizing charge.. Equalizing charges can take as long as 148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br />.
With this interpretation, a battery may unnecessarily be considered inoperable if Surveillance Requirements 4.8.2.3.2.a.1.and 4.8.2.3.2.a.2 vere due and could e
not be satisfied because the battery was on equalizing charge.
L
- e 7 g ad During the February 25, 1988, telephone call and subsequently in the'NRC g
. letter dated March 12, 1988 (Log Number 2232) issuing Amendment Number 100,
. go o
.the NRC staff acknowledged that such an interpretation vould.be incorrect and 3
that equalizing charges had not been considered in the model technical l.
l$2k specifications. The staff stated that the parameters are intended to provide
]
j68 guidance as to the condition of the batteries. The inability to observe a Jg<
~true float voltage during an equalizing charge does not result in a violation ou of the Surveillance Requirement nor does it result in an inoperable battery, oa-0-Q
' (D a. n,,..
88 m
THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 L- _ _ - - -
t iDocket Nunbar'50-346
.,, s Licensa Number NPF-3' S2 rial Number 1695' Page 2
~
In the February 25, 1988 telephone call and as acknowledged in the NRC March 12, 1988 letter Toledo Edison had indicated its intention to submit an amendment request to clarify the surveillance' requirements, even though they j
conform with NRC model technical specifications. Toledo Edison has
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reevaluated the need to revise the Surveillance Requirements in. view of the above' clarification. Toledo Edison-understands that it.is preferable to perform Surveillance Requirements 4.8.2.3.2.a.1 and.4.8.2.3.2.a.2 with the
-battery on float charge. Equalizing charges, which generally take less than 148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br /> to complete, are performed only about once per year, consistent with vendor. recommendations, industry standards and in response to surveillance
' test results.
Since Technical Specification 4.0.2 allows. extension of surveillance intervals by 25%, it will rarely be necessary to complete'the seven day interval Surveillance Requirements while the battery is on equalizing charge.
On those rare occasions, the above clarification provides the necessary flexibility.
Clarification of the Surveillance Requirements does not warrant the expenditure of the NRC and Toledo Edison resources which would be required to-process such a relatively low priority license amendment. Accordingly, Toledo Edison no; longer plans to submit an amendment request to clarify Surveillance Requirements'4.8.2.3.2.a.1 and 4.8.2.3.2.a.2.
- Toledo Edison plans to incorporate the above clarification into the weekly battery surveillance test procedure. The procedure vill indicate that the I.
tests should normally be accomplished with the battery on float charge, but if the surveillance test is due, it may be performed while the battery is on.
equalizing charge.
.If you have any questions concerning this matter, please contact Mr. R. V. Schrauder, Nuclear Licensing Manager, at (419) 249-2366.
Very truly yours, f
l
~
PVS/dlm L
cc:
P. M. Byron, DB-1 NRC Senior Resident Inspector l
A. B. Davis, Regional Administrator, NRC Region III T. V.'Vambach, DB-1 NRC Senior Project Manager
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