RBG-46171, License Amendment Request for Removal of Mode Restrictions for Surveillance Testing of the Division III Battery

License Amendment Request for Removal of Mode Restrictions for Surveillance Testing of the Division III Battery

ML033030535
Person / Time
Site:	River Bend
Issue date:	10/21/2003
From:	Hinnenkamp P Entergy Nuclear South
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-46171
Download: ML033030535 (19)

Text

Entergy Nuclear-South River Bend Station 5485 U.S. Highway 61 AM P.O. Box 220

-= - 7 ' St. Francisnvile, LA 70775 Tel 225 381 4374 Entergy Fax 225 381 4872 phinnen~entergycom Paul D. Hinnenkamp Vice Presdent. Operations River Bend Station RBG-46171 October 21, 2003 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request River Bend Station, Unit I (RBS)

Docket No. 50-458 License No. NPF-47 Removal of MODE Restrictions for Surveillance Testing of the Division IlIl Battery

Dear Sir or Madam:

Pursuant to 10CFR50.90, Entergy Operations, Inc. (Entergy) hereby requests the following amendment for River Bend Station, Unit 1 (RBS). The proposed change will remove the MODE restrictions for performance of Surveillance Requirements (SR) 3.8.4.7 and 3.8.4.8 for the Division IlIl DC electrical power subsystem. The batteries tested by these surveillances are part of the DC power source of control and motive power as required for the High Pressure Core Spray (HPCS) system logic, HPCS diesel-generator set control and protection, and all Division IlIl related controls. These surveillances verify that the battery capacity is adequate to perform their required functions. The purpose of the proposed changes is to allow performance of the surveillances during normal plant operation in conjunction with a HPCS system outage rather than only during refueling outages. This will help to reduce the complexity of work and testing activities during refueling outages.

The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards considerations. The bases for these determinations are included in the attached submittal.

The proposed change contains two new commitments as summarized in Attachment 4. Entergy has submitted a similar license amendment request for the Grand Gulf Nuclear Station which is still pending (TAC No. MB8938).

Entergy requests approval of the proposed amendment by August 15, 2004. The requested approval date and implementation period will enable RBS to optimize refueling outage planning and activities. Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review is requested.

RBG-46171 Page 2 of 2 If you have any questions or require additional information, please contact Ron Byrd at 601-368-5792.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 21, 2003.

Sincerely, Paul D. Hinnenkamp Vice President, Operations River Bend Station PDH/rwb Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

3. Changes to TS Bases pages - for information only

4. List of Regulatory Commitments cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Senior Resident Inspector P. 0. Box 1050 St. Francisville, LA 70775 U.S. Nuclear Regulatory Commission Attn: Mr. Michael K. Webb MS 0-7D1 Washington, DC 20555-0001 Mr. Prosanta Chowdhury Program Manager - Surveillance Division Louisiana Department of Environmental Quality Office of Radiological Emergency Plan and Response P. 0. Box 82215 Baton Rouge, LA 70884-2215

Attachment 1 RBG- 46171 Analysis of Proposed Technical Specification Change to RBG-461 71 Page 1 of 7

1.0 DESCRIPTION

This letter is a request to amend Operating License NPF-47 for River Bend Station, Unit 1 (RBS).

Entergy requests changes to Section 3.8.4, "DC Sources - Operating" of the Technical Specification (TS), Appendix A of the Operating License. Specifically, the proposed change will remove the MODE restrictions for performance of Surveillance Requirements (SR) 3.8.4.7 and 3.8.4.8 for the Division IlIl DC electrical power subsystem. The batteries tested by these surveillances are part of the DC power source of control and motive power as required for the High Pressure Core Spray (HPCS) system logic, HPCS diesel-generator set control and protection, and all Division IlIl related controls. These surveillances verify that the battery capacity is adequate to perform their required functions. The purpose of the proposed changes is to allow performance of the surveillances during MODE 1, 2, or 3 in conjunction with a HPCS system outage such that the testing will no longer have to be performed only during plant outages. This will help to reduce the complexity of work and testing activities during refueling outages.

The next RBS refueling outage is scheduled for the Fall of 2004. Entergy desires that this amendment be issued by August 15, 2004 to support work planning prior to the outage.

2.0 PROPOSED CHANGE

TS Limiting Condition for Operation (LCO) 3.8.4 "DC Sources - Operating" governs the DC electrical power subsystem requirements for all three divisions of Engineered Safety Feature (ESF) systems. The DC electrical power sources are required to be operable in plant MODES I (Power Operation), 2 (Startup), and 3 (Hot Shutdown). Currently certain TS 3.8.4 Surveillance Requirements (SRs) contain notes which prohibit performance during MODES 1, 2 or 3. The proposed changes will modify the notes associated with these SRs for Division Ill.

Specifically, Entergy proposes to modify Note 2 for SR 3.8.4.7 and the note for SR 3.8.4.8, that currently read This Surveillance shall not be performed in MODE 1, 2, or 3. However, credit may be taken for unplanned events that satisfy this SR." The Note for each of these SRs will be revised to state This Surveillance shall not be performed in MODE 1, 2, or 3 (not applicable to Division ll). However, credit may be taken for unplanned events that satisfy this SR."

In summary, Entergy is proposing to remove the MODE restrictions for performing SR 3.8.4.7 and SR 3.8.4.8 for the Division Ill DC electrical power subsystem batteries to allow SR performance during plant operation.

Changes to the TS Bases associated with the proposed changes to SR 3.8.4.7 and SR 3.8.4.8 are provided in Attachment 3 for your information and will be implemented in accordance with the TS 5.5.11, Technical Specification Bases Control Program.

3.0 BACKGROUND

River Bend Station Technical Specification 3.8.4 "DC Sources - Operating" specifies the requirements for the Engineered Safety Feature (ESF) DC electrical power subsystems. The to RBG-46171 Page 2 of 7 DC electrical power subsystems are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence (AOO) or a postulated Design Basis Accident (DBA). The DC power system provides the AC emergency power system with control power and both motive and control power to selected safety related equipment. The 125 VDC electrical power system consists of three independent Class E DC electrical power subsystems, Divisions I, II, and lil.

Each subsystem consists of a battery, associated battery charger(s), and all the associated control equipment and interconnecting cabling. As required by 10 CFR 50, Appendix A, General Design Criteria (GDC) 17, the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure.

During normal operation, the DC loads are powered from the battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC loads are automatically powered from the ESF batteries. Each DC battery subsystem is separately housed in a ventilated room apart from its charger and distribution centers. Each subsystem is located in an area separated physically and electrically from the other subsystems to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. There is no sharing between the redundant Class E subsystems such as batteries, battery chargers, or distribution panels.

The function of the Division III 125 VDC power system is to provide a reliable, continuous, and independent 125 VDC power source of control and motive power as required for the HPCS system logic, HPCS diesel-generator set control and protection, and all Division IlIl related controls. A battery charger is provided for the battery. The Division III 125 VDC system is classified as Class E. The Division III 125 VDC system is independent of all other divisional batteries and there is no manual or automatic connection to any other battery.

The Division IlIl DC power source is required for HPCS diesel generator field flashing, control logic, and control and switching function of 4.16 kV breakers. Updated Safety Analysis Report (USAR) Table 8.3-6 lists the Division IlIl peak amperage requirements per time interval after AC power loss during accident conditions. The Division IlIl battery has adequate storage to carry the required load continuously for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The battery charger of Division IlIl DC electrical power subsystem has sufficient capacity to restore the battery bank from the design minimum charge to its fully charged state in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while supplying normal steady state loads.

The ESF divisional batteries are required by TS SR 3.8.4.7 and 3.8.4.8 to be service tested and performance discharge tested periodically. The battery service test verifies the battery's capability to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for Division ll) correspond to the design duty cycle requirements. The battery performance test is a test of constant current capacity of the battery to detect any change in the capacity. The performance discharge test is intended to determine overall battery degradation due to age and usage.

The required surveillance frequency for the battery service test is every 18 months. The frequency for the performance discharge test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life, the surveillance frequency for the performance discharge test is reduced to 18 months.

to RBG-46171 Page 3 of 7 The TS Bases currently state that "degradation" is indicated when the battery capacity drops by more than 10% of rated capacity from its average on previous performance tests or is below 90% of the manufacturer's rating. As discussed in sections 5.1 and 6.0 of this Attachment, the definition of "degradation" is being changed to be consistent with the 1995 edition of IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing and Replacement of Large Lead Storage Batteries for Generating Stations and Substations." and NUREG 1434, Standard Technical Specifications General Electric Plants, BWR/6. The revised Bases will require RBS to determine whether battery degradation has occurred by comparing performance test results with the previous performance test rather than the average of previous performance tests.

RBS will implement the Bases change in accordance with TS 5.5.11 within 60 days following issuance of this requested amendment.

4.0 TECHNICAL ANALYSIS

The TS Bases, as currently written, state that the reason for the MODE restriction note for SRs 3.8.4.7 and 3.8.4.8 is to preclude the potential for perturbations of the electrical distribution system during plant operation. However, the noted concern is unwarranted with respect to Division Ill. By virtue of the HPCS being a stand-alone system with its dedicated DG and independent distribution system, there is minimal opportunity for the performance of these SRs to have any impact on other safety related plant equipment. The Division Ill DC system is independent of all other divisional batteries and there is no manual or automatic connection to any other battery. The Division Ill batteries are disconnected from the battery chargers during the test and have no connection with any other equipment that is required to be operable.

Therefore, performance of the required testing during plant operation would not result in a challenge to any other plant safety system.

Currently, the Division Ill HPCS DG and HPCS system are removed from service to perform scheduled maintenance while in MODE 1, 2, or 3 as allowed by the TS. The TS change is desired to allow the Division Ill battery tests to be performed in conjunction with these scheduled system outages. The change will allow the Division Ill battery service test required by SR 3.8.4.7 and the Division Ill battery performance discharge test required by SR 3.8.4.8 to be performed in MODES 1, 2, or 3 in conjunction with a HPCS system outage or for unplanned events. The TS allow up to 14 days of inoperability if the Reactor Core Isolation Cooling system is operable. This provides ample time for the performance of the battery SRs. The time needed to perform the battery testing is approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The required SRs make the Division Ill batteries unavailable for supporting the HPCS system during portions of the tests. However, as noted above, the batteries are expected to be unavailable for approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This testing period is within the period of time that the system will already be out of service for other planned maintenance. Therefore, the battery test does not increase unavailability of the supported system or represent any change in risk above the current practice of planned system maintenance outages as currently allowed by the TS.

Regarding risk management, the testing of the Division Ill batteries will be enveloped by the risk management of the system outage. Risk management of the system outage is addressed in

Attachment I to RBG-46171 Page 4 of 7 several ways. First, in addition to TS LCO limitations, the Safety Function Determination Program (SFDP) of TS 5.5.10 is required to protect against a loss of safety function. Secondly, the RBS approach to performing maintenance also uses a protected division concept. This means that without special considerations work is performed on only one division at a time.

RBS has a Configuration Risk Management Program (CRMP) in place in accordance with RBS commitments for compliance with 10 CFR 50.65, Monitoring the Effectiveness of Maintenance".

The program provides assurance that risk-significant plant equipment configurations are precluded or minimized when plant equipment is removed from service. Additionally, the HPCS system reliability and availability are monitored and evaluated in relationship to Maintenance Rule goals to ensure that total outage times do not degrade operational safety over time.

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

Entergy has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, other than the TS, and do not affect conformance with any GDC differently than described in the USAR. As required by 10 CFR 50, Appendix A, General Design Criteria (GDC) 17, the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The proposed changes do not affect the design or function of the DC system.

USAR Table 1.8-1 discusses compliance with Regulatory Guide 1.129, "Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Nuclear Power Plants,"

February, 1978 edition. This edition of the Regulatory Guide states that the battery service test should be done during refueling operations or at some other outage. This amendment will allow the battery test for the Division IlIl battery to be performed on-line.

Regulatory Guide 1.129 also endorses IEEE Standard 450-1975, IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications." The 1975 edition of the IEEE standard defined battery degradation" in relation to a change in capacity from the average of previous performance tests. However, newer editions of the standard define degradation in relation to the change in capacity from only the previous performance test. As discussed earlier, the TS Bases will be revised to define "degradation" consistent with the newer edition of the IEEE standard and NUREG 1434.

The proposed TS changes deviate from the Standard TS for BWR6s, NUREG 1434. This deviation is acceptable because the RBS Division IlIl system is designed as a stand-alone ECCS system with its dedicated DG and independent distribution system. Therefore, there is minimal opportunity for the performance of these SRs to have any impact on plant operation or on other safety related plant equipment.

to RBG-46171 Page 5 of 7 5.2 No Significant Hazards Consideration The Entergy request is to change Section 3.8.4, "DC Sources - Operating" of the Technical Specification (TS), Appendix A of the Operating License. Specifically, the proposed change will remove the MODE restrictions for performance of Surveillance Requirements (SR) 3.8.4.7 and 3.8.4.8 for the Division IlIl DC electrical power subsystem. The battery tested by these surveillances is part of the direct current (DC) power source of control and motive power as required for the High Pressure Core Spray (HPCS) system logic, HPCS diesel-generator set control and protection, and all Division IlIl related controls. These surveillances verify the battery capacity is adequate to perform the required functions. The purpose of the proposed changes is to allow performance of the surveillances during MODES 1, 2, or 3 such that the testing will no longer have to be performed only during plant outages. Entergy Operations, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The power supplied by the battery is used as a source of control and motive power for the HPCS system logic, HPCS diesel-generator set control and protection, and other Division IlIl related controls. The loads supplied by this system are loads associated with Division IlIl of the Emergency Core Cooling Systems (ECCS).

The battery testing period is within the period of time that the system will already be out of service for other planned maintenance. The battery test does not increase unavailability of the supported system or represent any change in risk above the current practice of planned system maintenance outages as currently allowed by the TS. Any risk associated with the testing of the Division IlIl batteries will be enveloped by the risk management of the system outage.

The out of service condition is controlled and evaluated for safety implications in accordance with 10 CFR 50.65. The HPCS system reliability and availability are monitored and evaluated in relationship to Maintenance Rule goals to ensure that total outage times do not degrade operational safety over time.

Therefore, the proposed change will have no effect on the probability or consequences of any previously evaluated accident.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

This request involves the testing of the HPCS battery on-line while the system is already out of service. The testing will not add additional out of service time. Testing during this period has no influence on, nor does it contribute in any way to, the possibility of a new or different kind of accident or malfunction from those previously analyzed. The method of to RBG-46171 Page 6 of 7 performing the test is not changed. No new accident modes are created by testing during the period when the system is already unavailable. Because the system is already out of service, no safety-related equipment or safety functions are altered as a result of this change.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The battery testing will be performed when the HPCS system is already out of service for maintenance. The out of service condition is controlled and evaluated for safety implications in accordance with 10 CFR 50.65. The batteries are not expected to be unavailable for more than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This testing period is within the period of time that the system will already be out of service for other planned maintenance. Therefore, the battery test does not increase unavailability of the supported system or represent any change in risk above the current practice of planned system maintenance outages as currently allowed by the TS. Timing of this test has no effect on any fission product barrier.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed amendment(s) present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of 'no significant hazards consideration" is justified.

5.3 Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 PRECEDENCE Entergy has submitted a similar license amendment request for the Grand Gulf Nuclear Station (GGNS) which is still pending (Reference 7.1). During NRC staff review of this amendment, Entergy and members of your staff held a call concerning the TS Bases definition of "degradation" for SR 3.8.4.8. The current TS Bases defines "degradation" as when battery capacity drops by more than 10% of rated capacity from the average of previous tests or is below 90% of the manufacturer's rating. After some discussion, Entergy agreed to revise the TS

Attachment I to RBG-46171 Page 7 of 7 Bases for SR 3.8.4.8 and supplemented the GGNS request with a letter dated August 7, 2003 (Reference 7.2).

Entergy is committing in this letter to make the same Bases change under the provisions of TS 5.5.11, "Technical Specifications (TS) Bases Control Program."

7.0 REFERENCES

7.1 Letter GNRO-2003/00033 from J. C. Roberts of Entergy to USNRC, "License Amendment Request, Removal of MODE Restrictions for Surveillance Testing of the Division 3 Battery," dated May 12, 2003, ADAMS Accession No. ML031420552.

7.2 Letter GNRO-2003/00044 from J. C. Roberts of Entergy to USNRC, Supplement to License Amendment Request, Removal of MODE Restrictions for Surveillance Testing of the Division 3 Battery (TAC No. MB8938)," dated August 7, 2003, ADAMS Accession No. ML032310412.

Attachment 2 RBG-461 71 Proposed Technical Specification Changes (mark-up)

RBG-461 71 Page 1 of X DC Sources -Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.6 Verify each battery charger supplies 2 300 amps for 18 months chargers 1A and 1B and 2 50 amps for charger 1C at a 130.2 V for > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

SR 3.8.4.7 -NOTES-

1. SR 3.8.4.8 may be performed in lieu of SR 3.8.4.7 once per 60 months.

2. This Surveillance shall not be performed in MODE 1, 2, or 3XHowever, credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and 18 months maintain In OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.

(continued)

RIVER BEND) 3.8-26 Amendment No. 81 RBG-46171 Page 2 of X DC Sources-Operating 3.8A SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.8 NOTE T This Surveillance shall not be performed in MODE 1, 2, or 3' However, credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is k 80% of the manufacturers 60 months rating when subjected to a performance discharge test.

-NOTE---

Only applicable when battery shows degradation or has reached 85% of expected life.

18 months RIVER BEND 3. -27 Amendment No. 81

Attachment 3 RBG-46171 Changes to Technical Specification Bases Pages For Information Only RBG-46171 Page 1 of 3 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.. (continued)

REQUIREMENTS the fully charged state, irrespective of the status of the unit during these demand occurrences. The minimum required amperes and duration ensure that these requirements can be satisfied. Momentary transients that are not attributable to charger performance do not invalidate this test.

The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these 18 month Intervals.

In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

SR 3.8.4.7 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length correspond to the design duty cycle requirements as specified in Reference 4.

The Surveillance Frequency of 18 months is consistent with the recommendations of Regulatory Guide 1.32 (Ref. 9) and Regulatory Guide 1.129 (Ref. 10), which state that the battery service test should be performed during refueling operations or at some other outage, with intervals between tests not to exceed 18 months.

This SR is modified by two Notes. Note I allows the once per 60 months AdzA e A'ibo-

\'

m performance of SR 3.8A.8 in lieu of SR 3.8.4.7. This substitution is acceptable because the battery performance test (SR 3.8.4.8) represents 1-fest By be amore severe test of battery capacity than the battery service test oer Po u beSR (ed3.8.4.7). Because both the battery service test and the battery 2, O3 performance test involve battery capacity determination, complete battery replacement invalidates the previous performance of these surveillance I7 col Rc4 on( requirements. In addition to requiring the re-performance of both of these jy4?9p~ , Ssurveillance tests prior to declaring the battery OPERABLE, complete battery replacement also resets the 60 month time period used for

.Sptic{Co 4r& es. substitution of the service test by the performance test. For this reason, substitution is acceptable for performance testing conducted within the first two years of service of a new battery as required by Reference 8.

The reason for Note 2 is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution sstem, and challenge safety systems redit may beten o unpanned events that satisfy the- uiV mfnce. Examples of unplanned events may include:

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and (continued)

RIVER BEND B 3.8-56 Revision No. 103 RBG46171 Page 2 of 3 DC Sources - Operating B3.8.4 BASES SURVEILLANCE SR 3.8.4.7 (continued)

REQUIREMENTS

2) Post corrective maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

SR 3.8.4.8 A battery performance test is atest of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change Inthe capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 8)and IEEE-485 (Ref. 11). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturers rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there isample capacity to meet the load requirements.

The Surveillance Frequency for this test is normally 60 months. If the battery shows degradation, or Ifthe battery has reached 85% of its expected life the Surveillance Frequency is reduced to 18 months.

AselO~p, Degradation is indicated, according to IEEE450 (Ref. 8). when the

battery capacity drops by more than 10% of rated capacity its yem VAe rating. heserevioustes,,'or when t Is 2 10% below the manufacturers on rating. Th Fqqfnes ni are based on the recommendations in IEEE-450 (Ref. 8).

This SR is modified by a Note. The reason for the Note Isthat performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the electrical distribution system, and challenge safety systems. Credit may be taken for unplanned events that satisfy the Surveillance. Examples of unplanned events may include:

(continued)

K ,sw(" 1o

• Z/ AJ 0i4 44"Co,,,Ce RIVER END B 3.8-67 Revision No. 4-6 RBG-46171 Page 3 of 3 DC Sources - Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.8 (continued)

REQUIREMENTS

1) Unexpected operational events which cause the equipment to perform the function specified by this Surveillance, for which adequate documentation of the required performance is available; and

2) Post corrective maintenance testing that requires performance of this Surveillance in order to restore the component to OPERABLE, provided the maintenance was required, or performed in conjunction with maintenance required to maintain OPERABILITY or reliability.

REFERENCES 1. 10 CFR 50, AppendixA, GDC 17.

2. Regulatory Guide 1.6, March 10, 1971.

3. IEEE Standard 308, 1978.

4. USAR, Section 8.3.2.

5. USAR, Chapter 6.

6. USAR, Chapter 15.

7. Regulatory Guide 1.93, December 1974.

8. IEEE Standard 450, WtI

9. Regulatory Guide 1.32, February 1977.

10. Regulatory Guide 1.129, December 1974.

11. IEEE Standard 485.

RIVER BEND B 3.8-58 Revision No. 4-6

Attachment 4 RBG-461 71 List of Regulatory Commitments RBG46171 Page I of I List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

RBS will implement the Bases change in X Within 60 accordance with TS 5.5.11 within 60 days following days of issuance of this requested amendment. The revised amendment Bases will require RBS to determine whether battery issuance degradation has occurred by comparing test results with the previous performance test rather than the average of previous performance tests.

The Division IlIl battery service test required by SR X Within 60 3.8.4.7 and the Division IlIl battery performance days of discharge test required by SR 3.8.4.8 may be amendment performed in MODES 1,2, or 3 in conjunction with a issuance HPCS system outage or for unplanned events.