NLS2011087, Response to Nuclear Regulatory Commission Request for Additional Information Non-Conservative Battery Terminal Voltage and Specific Gravity in Technical Specification Surveillance Requirements
| ML11250A160 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/31/2011 |
| From: | O'Grady B Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2011087, TAC ME4974 NEDC 87-131A, Rev 10 | |
| Download: ML11250A160 (9) | |
Text
H Nebraska Public Power District Always there when you need us 50.90 NLS2011087 August 31, 2011 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Nuclear Regulatory Commission Request for Additional Information Re: Non-Conservative Battery Terminal Voltage and Specific Gravity in Technical Specification Surveillance Requirements (TAC No. ME4974)
Cooper Nuclear Station, Docket No. 50-298, DPR-46
References:
- 1. E-mail from Lynnea Wilkins, U. S. Nuclear Regulatory Commission, dated June 15, 2011, "Draft RAI Response to ME4974, Battery Terminal.
Voltages & Specific Gravities"
- 2. Letter from Brian J. O'Grady, Nebraska Public Power District, to the U.S.
Nuclear Regulatory Commission, dated October 29, 2010, "Non-Conservative Battery Terminal Voltage and Specific Gravity in Technical Specification Surveillance Requirements"
Dear Sir or Madam:
The purpose of this letter is for Nebraska Public Power District to submit a vendor engineering estimate requested by the Nuclear Regulatory Commission (NRC) (Reference 1). The requested information is in support of NRC's review of a license amendment request (LAR) for the Cooper Nuclear Station (CNS) facility operating license and technical specifications to correct non-conservative values of battery terminal voltage and specific gravity (Reference 2).
Provided as an enclosure to this letter is Appendix R excerpted from CNS Calculation NEDC 87-131 A Revision 10 (typical of calculations NEDC 87-131 B, C and D for 250 volt (v) and 125v batteries). These excerpted pages are a 1992 Memorandum with attachments from C&D Charter Power Systems to Entergy Operations, Inc. answering questions for the Waterford Unit 3 LCUN-33 type batteries, and.2009 e-mails confirming the applicability of the information to CNS LCR-25 batteries. These were used by CNS in the load and voltage studies as the engineering estimate provided by battery manufacturer C&D Charter Power System, Inc. to explain the battery de-rating of 96% to quantify the end of life performance reduction for a lead calcium type battery such as the LCR-25 D841 type used at CNS.
COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3871 / Fax: (402) 825-5211 www.nppd.com
NLS2011087 Page 2 of 2 No regulatory commitments are made in this submittal. The information submitted herein does not change the conclusions or the basis of the no significant hazards consideration evaluation provided with Reference 2.
If you have any questions concerning this matter, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on I a (date)
Sincerely, Brian J. O'Grad Vice President - Nuclear and Chief Nuclear Officer
/em Enclosure cc: Regional Administrator w/ enclosure USNRC - Region IV Cooper Project Manager w/ enclosure USNRC - NRR Project Directorate IV-l Senior Resident Inspector w/ enclosure USNRC - CNS Nebraska Health and Human Services w/ enclosure Department of Regulation and Licensure NPG Distribution w/ enclosure CNS Records w/ enclosure
NLS2011087 Enclosure Enclosure Excerpt from NEDC 87-131A, Rev 10, 250 VDC Division 1 Load and Voltage Study Appendix R, Letter from G. Walker (C&D) and Accompanying E-Mails of 2009 Confirming Continued Applicability
, -,giJ NEDC 87-131A, Rev 10 07 O ( de1', 07ý Appendix R Page 1 of 5 CHAMPU POWI SYSTUME, IftO MoDMmmm~
TO ikh.MaimI~amn m..M W Oa e IiM.,.N Inc.
FROM: Groham Wmalker SATE: 26 Aqugut 1632 SUBJEM? P.C. Ifo WPO47464 Legapen Power &LICit CO.
WMaterd 3 Nualee 12 it ama In 81afti NEPEREN9KIICE: 10 August 1992 Memo Olemalim ROWng of LOUN4S3 Celle Your quemone, as prented In t I rtfhren d memo, a r stpeaed a fulh ."Te
- UN calls being pui~mlimdby Etesg peWrAti fonhmahe eflaa eesbsdoa tempwfatum of 778F u, asm lfo gmvty of 1.21 Entg requestsoonresUon feao. for al dsllargo cuem for the folowino oondlfof:
- 2. 1419 ipqgr. 1.176qpgr.
we aloa requet kvomartlon on ay other ROBSN tsot Woud Influene the Puhh ratings other than tempermure (per 1.468) and specif gsvt mqueedW above."
CAD Response:
T varilation I bttei pesfomamn due to 41fa. n in elehlyle ~ to dependedtan two (2) condlltons Cass gravity1:mess Thetian or batetey off, ftfy *haiedl, but d* to COWr mm 1asInpsMo baUsr,ewla. A Can 2. bhftDey, or balty a.el, is mphit d"h d d6 to th Grer beIg Out of mMe or when system Woas have i*moedad Ish"*ia of tfh o .baier.
uloe there leIls e ornotest det for OwH Cum I orCmu tZeflt l`nO tableu W f peerformance reduuaion Isour bet eqlnmeeng esunmanas 4W
A NEDC 87-131A, Rev 10 Appendix R dr7*W'neaW r Page 2 of 5 PAG6 3 25 Augus iM2" John McKiman PageS Puly Chimed nad Pewfmmnb aNfnWlM 1.215 ian 100% 100%
NW NW 100 47% '7%
tarn 15% *2% 35%
1.175 82% 82% 85%
max kflennmw Ken a a is 1.215 100% 100% 100% 100%
1.205.
1.135 a2% 4% mW N5%
1,1751 70% 70% 70%
In remon to mte r of Vyour qumsion, thue Sasau ooqdopq (Ohtwthan poo pt temperutre) that Ima y pedormanue, or morosasutty, mu lr tenlnSw vusage.
HIgh. nesm aoemedlm
- 1) nen, ban afey s.
Lon obi ens bhnA bery reft
- 3) Battry age an plate condiOn (Is., I=u of atve malaia due to uhed adngWf podilv plae -ri pmmlhlflron)
- 4) ImuflaisailWL m Ntglt
- mau Inmuted 0la
- 5) mliw laat ii b* level Indwloo Gtpmi t11hi udOtnVnl Imlpat pe*formance for dmu one howr end Wln I a ma a~fbovk1dm endsao. Ifyouhaveany queton lease0odonoliS ateito ad me.
Gule.m Wadil Manger, Appleoi Eqiedn CM Charter Powe yfM Ira
NEDC 87-131A, Rev 10 Appendix R Page 3 of 5 Proprietary Drawing Removed
NEDC 87-131A, Rev 10 Appendix R Page 4 of 5 Gocek, Steve W.
From: Archer, Phyllis [PArcher@cdtechno.com]
Sent: Friday, July 24, 2009 1:47 PM To: Van Winkle, Marshall B.
Cc: Gocek, Steve W.; Bysfield, G. A.; Rexroad, Raymond A.; Dickerson, Matthew J.; Carson, Larry; Williamson, Al; Floyd, Kyle D.
Subject:
Letter from Grahm Walker to John McKema of Entergy dated 25 August 1992
- Hello, This is to confirm that the values given in table for Case 1 of the subject letter can be applied to the LCR-25.
Case 1 values are for a fully charged battery or battery cell where for some unspecified reason the specific gravity is less than normal.
Note that the same caveat applies, i.e. there is little or no data so the performance reduction is based on our best engineering judgment.
Regards, Phyllis Archer Applications Engineer C&D Technologies, Inc From: Van Winkle, Marshall B. [1]
Sent: Wednesday, July 15, 2009 2:13 PM To: Archer, Phyllis Cc: Gocek, Steve W.; Bysfield, G. A.; Rexroad, Raymond A.; Dickerson, Matthew J.
Subject:
RE: Battery Specific Gravity Question We obtained a letter from Graham that describes the relationship between battery performance and specific gravity for the LCUN-33. Does this also apply to the LCR-25? See attached. Also, can I deduce that the specific gravity values in the tables are based on electrolyte level at the low level indicator? It would seem so based on bullet 5) in the letter.
Marshall Van Winkle Electrical Design Engineering Supervisor Cooper Nuclear Station 72676 648A Avenue Brownville, NE 68321 ph: (402) 825-2906 fax: (402) 825-5099 From: Archer, Phyllis [2]
Sent: Tuesday, July 14, 2009 4:32 PM To: Gocek, Steve W.
Cc: Van Winkle, Marshall B.; Carson, Larry
Subject:
RE: Battery Specific Gravity Question Hello, Specific gravity does not decrease as a function of battery age so ,Jthink, there are two main reasons why the battery would possibly be at 1.190, or 1.195 average specific gravity.
The first is that the electrolyte has been removed and replaced with water-in which case the sp. gr. should be adjusted.
The second is that the battery is either discharging or recharging. If recharging ,the gravity will lag behind the state of charge and is not indicative of battery capacity until fully mixed.
1
NEDC 87-131A, Rev 10 Appendix R 5 of 5 I am not sure what condition you are trying to address. Page
- Regards, Phyllis Archer From: Gocek, Steve W. [3]
Sent: Tuesday, July 14, 2009 4:45 PM To: Archer, Phyllis Cc: Van Winkle, Marshall B.
Subject:
Battery Specific Gravity Question Ms. Archer, I was part of the group that spoke with you earlier this afternoon on specific gravity ratings.
One possible way to evaluate the lower than nominal specific gravity question may be the following:
Is it possible to conclude?
- An electrolyte level is at or above the Min Level for the battery, with a specific gravity of 0.020 less than rated (allow by our Tech Specs). The volume of acid present in the electrolyte is greater than or equal to an electrolyte level above the top of the plates at nominal specific gravity?
- If you could conclude the above, would the battery still perform as depicted by the battery curve?
Steven W. Gocek Electrical Design Engineer Design Engineering Department 72676 648A Avenue Brownville, NE 68321 2 (402) 825-5021 A (402) 825-5099 E swqocekOnopd.com 2
4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS©4 Correspondence Number: NLS2011087 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None PROCEDURE 0.42 REVISION 27 PAGE 18 OF 25