ML17284A731

LER 98-012-00:on 980716,determined That 24-month SR 3.8.4.7 Had Not Been Fulfilled within Specified Frequency.Caused by Inadequate Work Practices.License Requested & Received Enforcement Discretion Re Battery Svc test.W/980817 Ltr

ML17284A731
Person / Time
Site:	Columbia
Issue date:	08/17/1998
From:	Bemis P, Schill F WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
G02-98-148, G2-98-148, LER-98-012, LER-98-12, NUDOCS 9808240284
Download: ML17284A731 (10)

Text

MWL ZaM&K.X J.REGULATO INFORMATION DISTRIBUTIO SYSTEM (RXDS)ACCESSION NBR:9808240284 DOC.DATE: 98/08/17 NOTARIZED:

NO FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe AUTH.NAME, AUTHOR AFFILXATION SCHILL<F.A., Washington Public Power Supply System BEMIS,P.R.

Washington Public Power Supply System RECIP.NAME

'ECIPIENT AFFILIATION DOCKET 05000397

SUBJECT:

LER 98-012-00:on 980716,determined that 24-month SR 3.8.4.7 had not been fulfilled within specified frequency.

Caused by inadequate work practices.

License requested&: received enforcement discretion re battery svc test.W/980817 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR

\ENCL g SIZE: TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.NOTES: E RECIPIENT ID CODE/NAME PD4-2 PD"INTERNAL:

ACRS AEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HOHB NRR/DRPM/PECB RES/DET/EXB EXTERNAL: L ST LOBBY WARD NOAC POORE,W.NRC PDR t,"COPIES (LTTR ENCL 1 1 1 1 1 1 1 1 1, 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME POSLUSNY,C NRR/DE/EELB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RGN4 FILE 01 LITCO BRYCE,J H NOAC QUEENERiDS NUDOCS FULL TXT COPIES LTTR ENCL 1 1 2, 2 1 1 1 1 1 1 1 1 1 1 1.1 1 1 1 1 1 1 0 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LIST>>OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROZ DESK (DCD).ON EXTENSION 415-2083 FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REOUIRED: LTTR 23 ENCL 23 WASHINGTON PUBLIC POWER SUPPLY SYSTEM I'.0.Box 96B~3000 George Washington Way~Richland, Washington 993S2-0968

~{'509)372-5000 Docket No.50-397 August 17, 1998 602-98-148 U.S.Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

Subject:

WNP-2, OPERATING, LICENSE NPF-21 LICENSEE EVENT REPORT NO, 98-012-00

Reference:

Letter GO2-98-125, JV Parrish (SS)to NRC,"Request for Enforcement Discretion for Technical Specification Surveillance Requirement 3.8.4.7," dated July 16, 1998.Transmitted herewith is Licensee Event Report No.98-012-00 for VIP-2.This report is submitted pursuant to 10 CFR 50.73 and discusses the items of reportability, corrective action taken, and action taken to preclude recurrence.

Should you have any questions or desire additional information pertaining to this report, please call me or P.J.Inserra at (509)377-4147.es ctfull P,.i'ee-Pres'rdent, Nuclear Operations

'il Drop PE23 Attachment cc: EW Merschoff-NRC MV DF Kirsch-NRC RIV, WCFO C Poslusnny, Jr.-NRC NBR PD Robinson-Winston k Strawn!9808240284 9808'LT PDR*DaCV.0S0003V7 8 PDR NRC Senior Resident Inspector-927N (2)DL Williams-BPA1399 INPO Records Center LXCENSEE EVENT REPDRT (LER)FACILITY NAME (1)Washin ton Nuclear Plant-Unit 2 TITLE (4)DOCKET NUMBER (2)50-397 PAGE (3)1OF5 I'ailure to corn 1 with re uirements of Technical S ecification Surveillance Re uirement 3.8 4.7 EVENT DATE (5)OAY MONTH LER NUMBER (6)SEQU ENRAL NUMBER REV.NUMBER REPORT DATE (7}MoNIII DAY OTHER FACILITIES INVOLVED (8}DOCKET NUMBER FACIUTY NAME 07 16 98 012 00 08 17 FACILITY NAME DOCKET NUMBER OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQVIREHEHTS OF 10 CFR 5: (Check one or more)(lli 100 20.402(b)20.405(s)(1)(I)20.405(a)(1)(ii)20.405(s)(1)(iii)20.405(a)(1)(iv)20.405(a)(1)(v)20A05(c)50.36(c)(1)50.36(c)(2)

X 5o.73(s)(2)OI 50.73(a)(2)(ii)50.73(s)(2)(iii) 50.73(a)(2)(iv) 50.73(s)(2)(v) 50.73(s)(2)(vii) 50.73(a)(2)(viii)(A)50.73(s)(2)(viii)(B) 50.73(s)(2)(x) 73.71(b)73.71(c)OTHER NAME I'.A.Schill, Licensing Engineer LICENSEE CONTACT FOR TiiIS LER (12)TELEPHONE NUMBER (inciude Area Code)~(509)377-2269 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)CAUSE svsTEM COMPONENT MAMJFACTVIIER REPORTABLE TO NPRDS CAUSE svsTDII COMPONENT MANUFACTURER REPORTABLE TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14)YES X f os corn loted EXPECTED SUBiVJSSIONDAT NO EXPECTED MONTH 10 DAY YEAR 30 98 ABSTRACT: On July 15, 1998 at 1600 with the plant operating at 100%power, it was determined that the 24 month Surveillance Requirement (SR)3.8.4.7 had not been fulfilled within the specified Prequency of SR 3.0.2 for the division 2, 125 VDC battery E-Bl-2[EJJ.The Supply System declared SR 3.8.4.7 not met and then used the provision of SR 3.0.3 to delay declaring Technical Specification (TS)Limiting Condition for Operation{LCO)3.8.4 not met while enforcement discretion was pursued.The Supply System requested and received enforcement discretion for completion of the battery service test of SR 3.8.4.7 for the division 2, 125 VDC battery E-B1-2.SR 3.8.4.7 was not met because surveillance procedure ESP-B12-I'101 was not revised to incorporate the"modified" discharge profile described in TS Bases 3.8.4.8 when surveillance procedure changes were made to implement the Improved Technical Specifications.

Note 1 of SR 3.8.4.7 permits the use of a"modified" performance discharge test to be performed in lieu of the battery service test once every 60 months.The battery discharge profile in the 60 month performance discharge surveillance procedure ESP-B12-17101 was not modified to envelope the discharge profile of the'service test and therefore was not sufficient to meet the verbatim requirements of SR 3.8.4.7 when it was used for that purpose on April 30, 1997.This procedure deficiency was discovered as a result of questions raised by the NRC during an engineering inspection at VPF-2.A subsequent evaluation revealed that this event had no impact on the battery's capability to perform its intended safety function.

fACILITY NAME (I)Washington Nuclear Plant-Unit 2 LICENSEE EVENT REPORT (LER)TEXT CONTINUATION DOCKET NUMBER (2).YEAR 50-397 LER NUMBER (6)SEQUENTIAL N(MBER 012 REvzsros NPiQER PAGE (3)2 QF TEXT (If more space is required, use additional copies of NRC Form 366A)(17)Event Descri tion On Iuly 15, 1998 with the plant operating at 100%power, it was determined that the requirements of the 24 month Surveillance Requirement (SR)3.8.4.7 had not been fulfilled within the Frequency plus the allowed extension time specified in the Technical Specifications (TS)for the division 2, 125 VDC battery E-Bl-2 tEJJ.The Supply System declared SR 3.8.4.7 not met, then used the provision of SR 3.0.3 to delay taking compensatory measures required by TS Limiting Condition for Operation (LCO)3.8.4, while enforcement discretion was pursued.The Supply System requested and received enforcement discretion fiom the Staff for completion of the battery service test of SR 3.8.4.7 for the division 2, 125 VDC battery E-B1-2.SR 3.8.4.7 was not fully met because the battery discharge profile in the 60 month performance discharge surveillance procedure ESP-B12-F101 was not suficient to meet the requirements specified in the TS Bases for SR 3.8.4.8.Note 1 of SR 3.8.4.7 permits the use of a"modified" performance discharge test to be performed in lieu of the battery service test once every 60 months.This was a change&om previous TS (SR 4.8.2.1.e) which allowed the unmodified performance test to be performed in lieu of the battery service test once every 60 months.Surveillance procedure ESP-B12-F101 was not rewritten to incorporate the"modified" discharge profile prior to its use on April 30, 1997 to meet SR 3.8.4.7 in accordance with the note.The fact that the verbatim requirements of SR 3.8.4.7 had not been met was determined as a result of questions raised by an NRC inspector who was conducting an engineering inspection at the time.The inspector's questions resulted in the discovery of the inadequate battery surveillance procedure.

Immediate Corrective Action The Supply System reviewed historical test data for the battery to determine if justification existed for continued reliance on the battery to perform its required safety function.Once this justification was established and the manufacturer's concurrence obtained, enforcement discretion was pursued.AAer enforcement discretion was granted, the Supply System submitted an exigent Technical Specification amendment request to allow the (unmodified) performance discharge.

test specified in SR 3.8.4.8 to be performed in lieu of the battery service test for the division 2, 125 VDC battery E-B 1-2.It was requested this amendment remain in effect until entry into Operational Mode 4 (cold shutdown)for the R-14 maintenance and refueling outage or an outage of suf6cient duration to perform the service test and subsequent battery recovery.Additionally, a review of other surveillance procedures used to meet the conditions of station battery SRs was conducted.

Tliis review determined that the same situation existed for the division 1 and 3 125 VDC batteries and the division 1 250 VDC battery.However, the Frequency requirements of SR 3.0.2 have not been exceeded for performance of the service tests (SR 3.8.4.7)for these batteries.

FACILITY NAME (II LICENSEE EVENT REPORT (LER)TEXT CONTINUATION DOCKET NUMBER (2)LER NUMBER (6)SEQUENTIAL NUMBER REVISION NUMBER PAGE (3)Washington Nuclear Plant-Unit 2 TEXT (If more space is required, use additional copies of NRC Form 366A)(17)50-397 98 012 3 OF Further Evaluation The battery service test required by the 24 month SR 3.8.4.7 is a special test of the battery's as found capability to satisfy the design requirements (battery duty cycle)of the DC Electrical power system tEJj.The test discharge rate and test length correspond to the design duty cycle requirements specified in the WNP-2 CESAR (Section 8.3.2).The 60 month SR 3.8.4.8 is satisfied by performance of a battery performance discharge test or a modified battery performance discharge test.A battery performance discharge test is an as found test of the constant current, capacity of the battery intended to determine overall battery degradation due to age and usage.In this test, the battery is subjected to a constant discharge rate.A modified battery performance discharge test is a combination of the two aforementioned tests and is considered a more severe test of battery capacity.It employs two discharge rates, a short duration discharge rate consistent with the largest current load of the duty cycle, followed by the discharge rate used in the battery performance discharge test.The test is intended to confirm the battery's ability to meet the critical period of the load duty cycle and determine its percentage of rated capacity.The discharge rate of the modified performance test envelopes the duty cycle of the service test described above.Technical Specification SR 3.8.4.7 (Note 1)allows the modified performance discharge test of SR3.8.4.8 to be performed in lieu of the 24 month battery service test once every 60 months in order to fulfill the requirements of SR 3.8.4.7 and SR 3.8.4.8 with the performance of one test in order to avoid excessive battery depletion.

The provision of tliis note was not fully implemented the last time the surveillance was performed for the Division 2 125 VDC battery (April 1997)in that the test that was performed was the performance discharge test and not the modified performance discharge test.Prior to the implementation of Improved Technical Specifications (ITS), the Technical Specifications allowed the performance test (vice the modified performance test)to satisfy the service test surveillance requirements once every 60 months.

FACILITY NAME Il)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION DOCKET NUMBER I2)LER NUMBER I6)SEQUENTIAL NUMBER RSVZS ION NtlHBER PAGE I3)Washington Nuclear Plant-Unit 2 TEXT (If more space is required, use additional copies of NRC Form 366A)(17)Root Cause 50-397 012 4 QF The apparent root cause for the noncompliance is that the work practices used to convert these specific battery procedures were inadequate to ensure that the modified performance test discharge profile was incorporated.

The preparation, review, and approval activities of assigned individuals were not carried out in a manner that ensured all changes were incorporated.

This was because the individuals involved did not perform a critical review of all required changes regardless of their characterization in the ITS change documents.

The Discussion of Changes manual presented an ambiguous description of the changes required for the modified performance test and classified it as a less restrictive change.However, the TS Bases has always been very clear in its description of the modified performance test.In the course of the root cause analysis for this event, a generic review of all other battery SR procedures was conducted.

The changes to this section of TS were numerous and complicated.

Interviews with individuals involved in the ITS change process were conducted to determine the potential for other procedure conversions to have similar work practice deficiencies.

Other procedural areas reviewed appear to have been changed with a higher level of attention to detail.The review determined that there were other instances of less restrictive changes which were inadequately incorporated, however none'of these instances resulted in a noncompliance to TS.These procedure revision work practices resulted in the failure to fully reflect the changes enacted through the implementation of Improved Technical Specifications QTS).The formal root cause analysis for this event requires additional time to complete.The results of this root cause analysis will be contained in revision 01 to this LER which will be submitted by October 30, 1998.Further Corrective Action Battery surveillance procedures are being revised to correct inadequacies discovered as a result of the generic review conducted during the root cause analysis.The performance discharge test will be changed to prohibit their use for meeting the requirements of SR 3.8.4.7 until they are revised to incorporate the modified performance discharge test.To ensure other ITS reviewers maintained adequate attention to detail, a self assessment of selected portions of the TS surveillance procedures will be conducted to determine if all details of the changes were addressed.

At the time of this report WNP-2 is in Mode 4 and presently in an operational condition which supports performance of the battery service test req'uired by SR 3.8.4.7.The battery service test has been performed on the division 2 and 3 125 VDC and the division 1 250 VDC battery with satisfactory results.The remaining division 1 125 VDC battery will be tested prior to startup.

E'AGILITY NAME (l)LICENSEE EVENT REPORT (LER)TEXT CONTINUATION DOCKET NUMBER (2)LER NUMBER (6)SEQUENTIAL NUMBER RBVISZON NUHBBR PAGE (3)5 QF Washington Nuclear Plant-Unit 2 TEXT (If moro space is required, use additional copies of NRC Form 366A)(17)50-397 98 012 0 Assessment of Safet Conse uences The service test requires a discharge rate of 400 amps for the first six seconds then drops to less than 250 amps for a duration of two hours.The performance test requires a constant discharge of 350 amps for two hours.Therefore, a di6erence of 50 amps for the first six seconds is not enveloped by the performance test.The service test requirement of 400 amps is less than half of the manufacturer's one-minute discharge rating of the battery (922 amps).The performance test completed in April of 1997 demonstrated a'battery capacity of 104.7%which is above the battery replacement criteria of 80%capacity.Additionally, the battery has been installed for less than five years and test data indicate an expected improving trend in battery capacity.Based on the substantial battery capacity demonstrated by the performance test and the short duration peak load required by the service test (400 amps)as compared to the one-minute rating of the battery (922 amps), the battery is fully capable of meeting the requirements of the modified performance test and the service te'st.Regularly performed surveillance activities of intercell connector resistance measurement, specific gravity, visual condition and battery terminal voltage indicate continued acceptable battery performance.

The battery manufacturer has stated in writing that the difFerence between the performance discharge test and the modified performance discharge test is not significant relative to the battery capacity and its short duration discharge rate.Based on tliis justification, historical test data, and results of the service test performed on August 11, 1998 it is the Supply System's position that even though SR 3.8.4.7 was not met, battery E-B1-2 has always been able to reliably perform its designed safety function..-

Therefore, there were no safety consequences resulting fiom this event.Similar Events There have been no recent similar events.