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Part 21 Rept Re Nuclear Logistics Inc 10CFR21 Notification for Gnb Industrial Battery Co Batteries.Util Will Obtain Replacement Batteries from C&D Power Sys,Inc & Alarm Features to Be Tested by End of Refuel 5
	ML20115D633
Person / Time
Site:	Waterford
Issue date:	10/15/1992
From:	Burski R; ENTERGY OPERATIONS, INC.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	REF-PT21-92 W3F192-0329, W3F192-329, NUDOCS 9210210063
	Download: ML20115D633 (7)
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M E ENTERGY ["W " """"" '"*'

R.F. Ourski

) W3F192-0329 A4.05 QA

! October 15, 1992 U.S. Nuclear Regulatory Commission l Attn: Docuraent Control Desk L Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License 40. hPF-38 Batteries 3A-S, 3B-S, and 3AB-S

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) Centlemen:

E Waterford 3 personnel have discussed with the NRC recent developments and new information regarding the Nuclaar Logistics Inc. (NLI) 10 CFR 21 notification for the Glib Industrial Battery 'n (GNB) batteries. These developments and new information had a bearing on Waterford 3 existing plans, evaluations, and commitments for the 3A-S, 3B-S, and 3AB-S batteries. We have now completed our assessment of the various technical and licensing issues, and an integrated approach has been established to address the resolution of the various issues.

The purpose of this letter is to inform the NRC about our integrated approach, see attachment, and how the approach provides for the res':lution of the various m issues for the batteries.

Please contact me or Rt,bert J Muriilo should there be any questions regarding this letter.

- Very truly yours, ,

7 l J

<ffusu'Vf'%uclear Safety

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fRFB/RJM/dc Attachment J.L. Milhoan, NRC Region IV cc:

W.R. Johnson, NRC Region IV T.O. McKernon, NRC Region IV P. Wagner, NRC Region IV D.L. Wigginton, NRC-NRR R.B. McGehee N.S. Reynolds NRC Resident Inspectors Office

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AttachmeAt._19 Letter W3F192-0322 1.0 finckaround The following background information about the buttories is summarized.

Information about the Wtterford 3 batteries was submitted to the NRC in letters W3F1-91-0387, W3F192-0015, and W3F192-0079 dated August 30, 1991, February 28, 1992, and May 29, 1992. Information about the batteries is also contained in NRC Safety Evaluation Report (SER) on Station Blackout (SBO) dated January 15, 1992 and NRC Supplemental Safety Evaluation Report (SSER) on SB0 dated June 17, 1992.

These documents established that Waterford 3 would replace du wg refuel 5 the existing batteries 3A-S, JB-S, and 3AB-S with new batteries of s similar typ and c;pacity. Waterford 3 committed to establish by the end of refuel 3 a reduced life for the new batteries 3A-S and 38-5 to satisfy a design margin of 1.10 at an electrolyte temperature of 70*F. Waterford 3 also committed to modify the de system by the end of refuel 6 to satisfy a Jesign margin of 1.10 for battery 3AB-S. Subsequent to the issuaace of the foregoing documents, Nuclear Logistics Inc. (NLI) on July 3,1992 filed with the NRC a 10CFR Part 21 notification regarding the NCX-17 battery and cells manufactured by GNB Industrial Battery Company, formerly Gould. Testing had been performed by NLI to determine a discharge rate where the cells will consistently meet the acceptance criteria of 1.75 Volts per Cell (VPC). A one minute rate of 1165 amps to 1.75 VPC was established for the NCX-17 cells as compared with the published rating of 1306 amps to 1.75 VPC. Waterford 3 personnel were informed that additional testing was planned by GNB Industrial Battery Company and NLI. The additional testing was required in order to establish the battery performance over a range of voltages and discharge rates, kis data is used for battery sizing calculations l performed in accordance with IEEE 485. . Waterford 3 personnel performed preliminary calculations for the Design Basis Event (DBE) using extrapolated data based on the single data point of 1165 amps. The prelimin.ry calculations established that the Waterford 3 bitteries 3A-S, 38-S, and 3AB-S have sufficient capacity for a DBE. Waterford 3 had intended to replace, during refuel 5, the.

existing batteries with identical batteries. However, after careful consideration of the 10CFR21 notification and other pertinent information, Waterford 3 ascertained that the long term capabilities of the new GNB batteries were indeterminate. Accordingly, an intensive and expedited effort was impicmented to thoroughly evaluate alternatives. Waterford 3 has decided to

obtain replacement batteries from C&D Power Systems, Inc. (C&D).

2.0 Technical and Licensino issues The various technical and licensing issues and the planned resolutions for the batteries are the following:

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i 2.1 HLi10CfR21 l The applicable events are a Design Basis Event (DBE) and Station Glackout (580). ;

1he design basis for Waterford 3 is an event concurrent with a lost-of-offsite power and a single failure wnich is assumed to be a loss of one diesel or one DC !

bus. The Waterfo s S 34 3 and 3B-S batteries are required for about 17 seconds for the DBE to provide power for essential equipment and to provide field flashing for the available diesel until at least one of the two 100% battery chargers is sequenced onto the available diesel. The 3AB-S battery is assumed to be connected to the failed diesel, and therefore the conservative assumption is made that the 3AB-S battery is required to supply loads on the AB bus for 31 minutes until op9rator action can be taken to connect the AB bus to the operable redundant bus. For station blackout, the batteries are required for four hours for a four hour coping plant.

The NCX-17 battery manufactured by GHB Industrial Battery Company was formerly designated NCX-1200 by Gould. Waterford 3 has two NCX-1200 and one NCX-2100 batteries supplied by Gould. While the NCX-17 battery and the NCX 1200 batteries are similar, the batteries have been manufactured under different company names, !

and the batteries may have minor dissimilarities, for example, degree of lead impurity. The 10CFR21 initial notification app'.ies strictly to the NCX-17 battery. The fact that the NCX-17 battery failed to meet the one minute published rating provided an indicator that the data which Waterford 3 useo to determine the capacity of batteries 3A-S, 3B-S, and 3AB-S may be in question.

preliminary calculations for operability were performed using data extrapolated from the single data point of 1165 amps. The preliminary calculations established that the Waterford 3 batteries 3A-S, 3B-S, and 3AB-S have sufficiera, capacity for the DBE.

The 3AB-S battery is required for 31 minutes for the DBE, and batteries 3A-S, 3B-S, and 3AB-S are required for four hours for an SB0. Thus, additional data for discharge ratings for times in excess of one minute was requested from NLI.

Also, additional end VPC values were requested from NLI in order to establish the '

battery perro mance curve. Waterford 3 requested the foregoing data from NLI shortly after the issuance of the 10 CFR 21 notification to the NRC on July 8, 1992. Waterford 3 planned to finalize the preliminary calculations once the foregoing data was made available by NLI. Waterford 3 on August 31, 1992 received from NLI a letter conveying that no other rates were effected. The preliminary calculations were finalized by September 15, 1992.

The derating of the Gould batteries was also considered for impact on the GB0 calculations of record. Waterford 3 requested from NL1 additional data points in order to evaluate the battery performance over a four hour period. NLI.

initially indicated that the Coup de fouet effect was noticeable up to the 30 minute rating of the battery and e.vpected to change the pt;blished data for this duration. However on August 31, 1992, NLI issued letter NCR-02-30 confirming that only the 1 minute rating was affected and other rates were empirically verified to be accurate. The battery loads for SB0 and DBE are similar for the first minute. The SB0 calculations of record were not impacted beyond this mir.ut e . Accordingly, the SB0 calculations of record were net revised as NLI maintains that the battery curves have not changed and the Coup de Fouet effect affected only it.e first minute rating of the Gould batteries.

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4 2.? IkalE9me'it of Batteries 3A-5. 3D-S. and 3AB-S Batteries 3A-S, 38-S, and 3AB-S will be replaced by the end of Refuel 5 with new buturies from C&D. The three new batteries will be C&D Type LCUK 33 with 16 positive pit.tes. The ratings of the battery will be one minute rate of 2080 amps, 30 minute rate of 1472 amps, and eight hour capacity of 2320 amp-hours, all l to a final terminal voltage of 1.75 volts per cell at 77'T and specific gravity of 1.215 1 0.005 when fully charged. l The batteries and appurtenances are Class IE. The qualified life is 20 years.

Qualification testing has bec.1 performed in accordance with IEEE-323-1974. The batteries have been seismically qualified in accordance with IEEE 344-1975.

Each assembled battery has been subjected to a two hour rate battery capacity acceptance test at the factory in accordance with IEEE 450-1987. Each assembled battery is being subjected to a battery service test. The battery service test I will demonstrate the batteries meet the DBE. l One handred and twenty three (123) cells originally intended for TVA and stored at the Browns ferry Nuclear plant were shipped to Waterford 3. These cells underwent receipt inspection in accordance with the Entergy receipt inspection procedure. cells have been shipped to Waterford 3 directly from The remaining C&D. sixty three A certificate (63)liance has been obtained from C&D for of comp all cells establishing that the cells have been provided in accordance with the Entergy procurement specification.

The 3A-S and 38-S battery cells will be placed in new C&D power System two-tier battery racks, model RD-15L2-18Ep3. The 3AB-S battery cells will be placed in the existing Waterford 2 battery racks. ,

The circuit breakers for the 3A-5 and 3D S de system will be replaced. The new batteries have a higher available fault current. The existing breakers are rated at 10 kilo-amps, and those breakers in service will be replaced with breakers rated at greater than 20 kilo-amps.

2.3 [qualizina Voltagg

'The 3AB-S battery will have 62 cells to provide a better voltage profile during loss of AC power. The 62 cells affect the equalizing voltage requirements. The float voltage will remain below the maximum allowable of 137.5V. The C&D l recommended equalizing voltage range is 2.33 to' 2.38 volts per cell. The l equalizing voltage range corresponds te a minimum voltage of 139.8V for the 3A-S and 3R-S batteries and 144.5V for the 3AB-S battery. These voltage levels are above the maximum allowable system W.Lage of 137.5V, and therefore, Waterford 3 will equalize the individual cells that show weakness. Should there be a need

, to equalize individual cells, then the non-lE individual cell charging unit will

! be seismically restrained, and the unit will have adequate electrical isolation

! capabilities to ensure it does not degrade the IE batteries during a postulated I

event.

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2.4. Battery Charoers The chargins requirements and capabilities of the chargers were reviewed.

Batteries 3A-S and 38-S each have two 150 amp chargers. The chargers satisfy the sizing requirement of section 5.3.4 of IEEE 308-1971 and regulatory guide 1.32, 1972. The chargers supply steady state loads during normal operation and post accident conditions. One charger can recharge the existing 3A-S or 3D-S 1200 AH battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The two chargers f9r the 3A-S or 3B-S DC system operating in the normal and load sharing mode can recharge the existing 3A-S or 3P.-S battery in less than five hours. One charger will take approximately 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months , and two chargers in parallel will ake less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months to recharge the replacement 3A-S or 30-S 2320 AH battery.

The replacement battery is essentially equivalent in size to the existing battery, and the recharge time is not significan#1y impacted. The existing 200 amp battery charger will take less that, 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months , and two parallel normally operating chargers will take approximately seven hours 40 recharge the fully '

discharged 3AB-S battery.

The recharge time is a function of the tolerable downtime of the battery and the preferred slow trickle charge time which are competing objectives. High discharge currents can lead- to excessive heat-up of the batteries, and a slow charging may take unnecessarily long to equalize the batteries. The discharging ,

load which is applied to the 3A-S or 3B-S batterics for 17 seconds during a DBE concurrent with a loss of offsite power will drain the batteries less than 0.5%

of their capacity.

A total discharge of the batteries will occur during the perforreance test. This test will be carefully planned and executed during plant outages to mintuize the '

shutdown risks associated with the unavailability of any of the DC equipment.

2.5 offected Commitments ,

The affected commitments and the impact or resolution is the following:

All620_ ud A20015 These commitments resulted from the Electrical _ Distribution System Functional Inspection (EDSFI). The commitments apply to the Elrar SUPS 3A-S and 38-5 and SCI SUPS 3MA, 3MB, 3MC, and 3MD and require considera 'on for lowering the trip setpoint-to a value below 105V DC and verification of the ability of the SUPS to provide regulated output current at the lower input voltage of 101 V DC. The new 3A-S and 3B-S battery systems will h ve a significantly increased battery capacity. The increased capacity will ensure that the terminal voltage at the SUPS is maintained at or above 105V during all postulated events. There is no longer a aecessity to consider operation of the SUPS at voltages below the design value of 105V. Waterford 3 will test by the- end of refuel 5 the shutdown ,

features of SUPS 3A-S and 3B-S at_105V. Waterford 3 will test, by the end.of 4

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Refuel 5, the alarm features of SUPS 3MA, 3MB, 3MC, and 3HD. The commitments for lowering of the setpoint no longer apply, and they will be closed.

A17962. A17992. and A20046 These commitments require replacement of batteries 3A-5, 3B-S, and 3AB-S; establishment of a reduced life for batteries 3A-S and 30-3; development of approach for ascertaining early rep 1xement; revision of calculations of record to reflect a design mergin of 1.10 for batteries 3A-S and 3B-S and the available design margin for battery 3AB-S; and modification of 3AB-S system by refue' 6 te satisfy a design margin of 1.10. The commitments, regarding the establishment of a reduced life and the development of an approach for ascertaining early repiscement are no longer applicable, and they will be closed. New commitments will be established to reflect the replacement of the existing batteries with the new C&D batteries with the 3A-S and 38-S C&D batteries having a design margin of 1.10 and an aging factor of 1.25. The 3AB-S de system will be modificd by the end of refuel 6 to satisfy a design margin of 1.10.

A17960. A17961. and A20049 These commitments resulted from the EDSF1 and require the FSAR to be changed to document the battery DBE and SB0 load profiles for batteries 3A-S, 3B-S, and 3AB-S. These commitments still apply, however, the information cannot be processed for incorporation in the FSAR until the batteries hava been installed, tested, and the design change documentation is closed. Therefore, these commitments will be changed to reflect a schedule for the information bJing incorporated not in the 1992 FSAR update but ir. the next scheduled FSAR update.

2.6 Technical Specification Surveillance Reauirements 4.8.2.1.e. and f Technical Specification section 4.8.2.1, paragraphs e and f, discusses the performance test requirements t'or batteries approaching E0% capacity or

. indicating sudden degradatio1. This section is based on the premise that battery performance is predictable up to 80% capacity. Typically, batteries show a ;

tendency to have sharper degradation below 80% capacity or towards the end of useful life. Hence, the intent of this section is to ensure that the available b3ttery capacity between successive tests is adecuate for coping with the design basis event. The replacement 3AB-S battery w< 11 be at 100%. However, the replacement battery is not sized to m6et design requirements up to 80% capacity.

The replacement 3AB-S battery has to have approximately 91% capacity to satisfy SB0 and DBE requirements. This battery has had a two hour battery acceptance test to ensure 100% capacity is available. After installation, a service test will be performed to DBE requirements. This new battery is expected to reniain at (or above) 100% for greater than 10 years. The higher capacity requirements are necessary for 1 fuel cycle only. During Refuel 6, the 3AB-S DC system will be modified to ensure that the design margin requirements are-eatisfied.- The intent of technical specification section 4.8.2.1 is satisfied through cycle 6.

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9 2.7 SER and SSER on Station Blackout Waterford 3 has reviewed the SER and the SSER as well as the Waterford 3 SB0 documentation on SBO, and we believe the evaluations and conclusions in the SER and SSER are still applicable and valid. Waterford 3 will replace by the end of refuel 5 the 3A-S, 38-S, and 3AB-S batteries with new C&D batteries.

Calculations will be finalized by the end of Refuel 5 verifying the new 3A-S,3B-S, and 3AB-S batteries have sufficient capacity for a DBE and SB0. The calculations of record, by the end of Refuel 5, will be based on a design margin of 1.10 and an aging factor of 1.25 for batteries 3A-S and 38-S. The calculation of record, by the end of Refuel 5. for battery 3AB-S will be based on a combined design margin and aging factor of 1.05 or greater. The de system for battery 3AB-S will be modified by the end of refuel 6 to satisfy a design margin of 1.10, and the aging factor will be established once the final modification is determined. Load shedding of the batteries will be impicmented as documented in Waterford 3 letter W3F192-0079 and NRC SSER. The calculations of record will be based on an electrolyte temperature of 70'f. The modification to the 3AB-S de system will be complet?d by the end of refuel 6 which is within the two year time period of 10CfR50.63 commencing with the date of the SSER. Accordingly, the provisicns in the SER and SSER are mot, and thus the SER and SSER are considered still applicable and valid.

3.0 (snglgsha Recent developments and new information had a bearing on Waterford 3 existing p1tas, evaluations, and commitments for the batteries. The various technical and licensing issues were identified, and an integrated approach was established to address the resolution of the various issues. The resciutions are in accordance with the provisions contained in the SER and SSER for station blackout, and thus the SER and SSER are considered still applicable and valid.

We believe this resolution of the battery issues represents an enhanced approach for the operation of Waterford 3. The 3A-S and 3B-S batteries have about twice the capacity of the existing batteries. The 3A-S and 38-S batteries, by the end of Refuel 5, will have a design margin of 1.10 and an aging factor of 1.25. The 3AB-S battery, by the end of Refuel 5, will have a combined design margin and aging factor of 1.05 or greater. The 3AB-S battery, by the end of Refuel 6,'will havc a design margin of 1.10. Although the NLI 10CFR21 notification and other pertinent information adversely impacted Waterford 3 existing evaluations and plans for the batteries, an integrated epproach was established which has minimal impact on the pinnt configuration, which preserves cxisting regulatory evaluations, and which will enhance the operation of Waterferd 3.

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ML20115D633

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