1CAN081302, Response to Request for Additional Information, Adoption of Technical Specification Task Force (TSTF)-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360.

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Response to Request for Additional Information, Adoption of Technical Specification Task Force (TSTF)-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360.
ML13241A417
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 08/28/2013
From: Jeremy G. Browning
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN081302, TAC MF0596
Download: ML13241A417 (33)
v • d • e


Text

s Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Vice President - Operations Arkansas Nuclear One 1CAN081302 August 28, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Request for Additional Information Adoption of Technical Specification Task Force (TSTF)-500, Revision 2 DC Electrical Rewrite - Update to TSTF-360 Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCES:

1. Entergy letter dated November 8, 2007, Pending License Amendment Requests Affected by TSTF-500 (CNRO-2007-00039) (ML073180400)
2. Entergy letter dated January 28, 2013, License Amendment Request -

Adoption of Technical Specification Task Force (TSTF)-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360 (TAC No. MF0596)

(ML13029A767)

3. NRC email dated July 15, 2013, Arkansas Nuclear One, Unit 1 -

Request for Additional Information Regarding License Amendment Request for Adoption of Technical Specifications Task Force (TSTF)

Traveler TSTF-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360 (TAC No. MF0596) (ML13197A014)

Dear Sir or Madam:

By email (Reference 3) the NRC requested additional information associated with Entergy Operations, Inc. (Entergys) request to amend the Arkansas Nuclear One, Unit 1 (ANO-1)

Technical Specifications (TS) consistent with TSTF-500, Revision 2. Entergys response is included in Attachment 1 of this letter.

Changes, as detailed in this letter, to the original Entergy request have been reviewed and Entergy has determined that the changes do not invalidate the no significant hazards consideration included in the Reference 2 letter.

1CAN081302 Page 2 of 2 In accordance with 10 CFR 50.91(b)(1), a copy of this application and the reasoned analysis about no significant hazards consideration is being provided to the designated Arkansas state official.

This letter contains no new regulatory commitments.

If you have any questions or require additional information, please contact Stephenie Pyle at 479-858-4704.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on August 28, 2013.

Sincerely, ORIGINAL SIGNED BY JEREMY G. BROWNING JGB/dbb Attachments:

1. Response to Request for Additional Information - ANO-1 Adoption of TSTF-500
2. Replacement Technical Specification and Bases Changes (mark-up)
3. Replacement Revised (clean) Technical Specification Pages cc: Mr. Steven A. Reynolds Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205

Attachment 1 to 1CAN081302 Response to Request for Additional Information ANO-1 Adoption of TSTF-500 to 1CAN081302 Page 1 of 15 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ANO-1 Adoption of TSTF-500 By email dated July 15, 2013 (Reference 2), the NRC requested additional information associated with Entergy Operations, Inc. (Entergys) request to amend the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specifications (TS) consistent with Technical Specification Task Force (TSTF) Traveler TSTF-500, Revision 2 (Reference 1). Questions provided by the NRC in the subject email are included below, followed by the respective Entergy response.

1. In Attachment 1, Section 1 of the LAR, the licensee proposed relocating the requirements of Technical Specification (TS) Table 3.8.6-1, Battery Surveillance Requirements, to the proposed TS 5.5.6, Battery Monitoring and Maintenance Program.

Confirm that the Table 3.8.6-1 Categories A, B, and C values (electrolyte level, float voltage, specific gravity) that will be relocated to TS 5.5.6, will continue to be controlled at their current levels in the TS Battery Monitoring and Maintenance Program and that actions to restore deficient values will be implemented in accordance with the licensees corrective action program.

Response

Procedure OP-1307.063, Unit 1 D06 and D07 Battery Surveillance, verifies battery electrolyte level, float voltage, and specific gravity in accordance with current ANO-1 TS Table 3.8.6-1. The TS table is repeated in the procedure as Attachment 1. This procedure, along with proposed TS 5.5.6, Battery Monitoring and Maintenance Program, is being used as the basis for developing the new battery program required by adoption of TSTF-500. In general, the procedure establishes normal operating limits that are conservative to the TS limits, such that corrective action is initiated prior to reaching a TS limit. The procedure requires Electrical and Operations supervision to be notified, condition reports be initiated (and work orders, if required), and immediately refers the user to other procedures to correct conditions adverse to quality (procedures to correct temperature, eliminate corrosion, adjust specific gravity, and equalize the battery, as necessary).

2. In Attachment 1, Section 2.1 of the LAR, the licensee proposed adopting TSTF-500 TS 3.8.5, Condition A, which applies when a required battery charger on one subsystem is inoperable and the required redundant subsystem battery and charger are operable.

Condition A is included only when the plant-specific implementation of TS 3.8.5 may require both subsystems of the direct current (DC) electrical power system to be operable. Arkansas Nuclear One, Unit 1 ANO-1 TS LCO 3.8.5 requires the DC electrical power subsystem to be operable to support the DC electrical power distribution subsystem(s) required by Limiting Condition for Operation (LCO) 3.8.10 in Modes 5 and 6.

a) Clarify whether ANO-1 TS requires one or both DC electrical power subsystem(s) to be operable in Modes 5 and 6. If TS 3.8.5 requires one DC electrical power subsystem to be operable, justify the adoption of the second part of Condition A, which states the required redundant subsystem battery and charger are operable.

to 1CAN081302 Page 2 of 15 b) The licensee proposed adopting TSTF-500 TS 3.8.5 Required Action (RA) A.1, which requires restoring the battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Explain how the licensee would ensure that the battery was returned to its fully charged state from any discharge that might have occurred due to the charger inoperability.

Response - Part 2.a With regard to Question 2.a, LCO 3.8.10 requires necessary power sources to be operable in support of the following TS structures, systems, or components (SSCs):

LCO 3.3.9, "Source Range Neutron Flux" LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits" LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled LCO 3.4.8, "RCS Loops - MODE 5, Loops Not Filled LCO 3.4.11, "Low Temperature Overpressure Protection (LTOP) System" LCO 3.7.9, "Control Room Emergency Ventilation System (CREVS)"

LCO 3.7.10, "Control Room Emergency Air Conditioning System (CREACS)

LCO 3.9.2, "Nuclear Instrumentation," for one monitor LCO 3.9.4, "Decay Heat Removal (DHR) and Coolant Circulation -

High Water Level" LCO 3.9.5, "Decay Heat Removal (DHR) and Coolant Circulation -

Low Water Level" Both the ANO-1 and the standard (NUREG 1430) NRC-approved TS Bases associated with DC Sources - Shutdown state that the assumption of single failure or concurrent loss of offsite power is not required when the unit is shutdown. Therefore, many of the above LCOs can be met via a single DC train. In lieu of discussing each individual LCO listed above, the question permits focusing on any example that would require two independent trains of DC electrical power subsystems to be available while operating in Mode 5 or 6.

One example is LCO 3.7.9, which requires both CREVS trains to be operable during the movement of irradiated fuel assemblies. This provides radiological protection for station Operators should a fuel handling accident occur, regardless of the plant operating mode.

This restriction applies to the movement of irradiated fuel in the Spent Fuel Pool (SFP) area as well as in the reactor cavity or refueling canal. In addition, the CREVS trains are shared with ANO, Unit 2 (ANO-2). ANO-2 is normally operating in Mode 1 when ANO-1 is in a shutdown condition. Like the ANO-1 TSs, the corresponding ANO-2 CREVS LCO requires two CREVS trains to be operable in Modes 1-4 and during the movement of irradiated fuel. Because single failure criterion is required to be met when operating in Modes 1-4, the SSCs which support CREVS operability must be operable and independent. Therefore, two independent DC electrical power subsystems must be operable to meet the aforementioned CREVS LCOs in nearly all operating conditions.

The only exception would be if both units were operating in Mode 5 or 6 simultaneously and no fuel movement were in progress on either unit.

to 1CAN081302 Page 3 of 15 For those LCOs that do not require two independent DC electrical power subsystems, the second part of Condition A, which states the required redundant subsystem battery and charger are operable, will permit appropriate application of the Action. This is due to the term required. If a second, independent DC electrical power subsystem is not required to support a specific LCO, then this 2nd part of the Condition is not applicable; however, the 1st part of Condition A remains applicable and Required Action A.1 must be performed (see Section 2.3 of the original LAR).

Based on the above, conditions can and often do exist where two independent DC electrical power subsystems are required to be operable while operating in Modes 5 or 6.

The second part of Condition A may, therefore, be applicable (depending on the status and configuration of both ANO units), and will not prevent appropriate application of the Action in cases where only one DC electrical power subsystem is required to be operable in support of other TS SSCs.

Response - Part 2.b As discussed in the NRC-approved TSTF-500 TS 3.8.5 Bases, the capability of restoring the battery to the fully charged state is verified when float voltage has returned to greater than or equal to the minimum established float voltage. This would require a fully capable battery charger to be placed in service. The Action (as discussed in the Bases) is focused on ensuring a capable battery charger is, or is placed, in service.

With float current beyond limits, LCO 3.8.6 Action B requires verification of float voltage every two hours until float current is restored to 2 amps. Surveillance Requirement (SR) 3.8.6.1 establishes this float current as an operability limit, which verifies the battery is fully charged (see response to Question 4.a). The SR 3.8.6.1 Bases states that verification of float current represents the state of charge of the battery. Therefore, LCO 3.8.6 Action B should ensure the battery is returned to the fully charged state.

Notwithstanding the above, Entergy proposes to adopt TSTF-500, LCO 3.8.5, Required Action A.2, which verifies float current is returned to 2 amps within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Adoption of this action ensures the battery will be verified to be returned to a fully charged state.

As a result, revised markup TS and TS Bases pages are included in Attachment 2 of this letter, and a revised (clean) TS page is included in Attachment 3 of this letter.

3. In Attachment 1, Page 6 of the LAR, the licensee stated that the maintenance of the ANO-2 DC distribution system, given the program modifications committed to via adoption of TSTF-500, meets the intent of the Regulatory Guidance (RG) 1.129, Revision 2, Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plant.

Clarify whether the above statement refers to ANO-1 instead of ANO-2 and whether ANO-1 is committed to RG 1.129, Revision 2.

to 1CAN081302 Page 4 of 15

Response

The above statement should (and does) apply to ANO-1. As discussed in Attachment 1, Page 6, of the original LAR (Reference 1), a review of RG 1.129, Revision 2, and subsequently IEEE 450-2002, was performed. Both ANO-1 and ANO-2 meet the intent of the subject guidance. Entergy believes no specific commitment to RG 1.129, Revision 2, is required since the new battery program in proposed ANO-1 TS 5.5.6 requires conformance with the guidance:

The program shall be in accordance with IEEE Standard (Std) 450-2002, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," as endorsed by Regulatory Guide 1.129, Revision 2

4. In Attachment 1, Section 2.2 of the LAR, the licensee stated that ANO-1 will revise the ANO-1 Safety Analysis Report (SAR) to include how a 2 percent design margin for the batteries corresponds to a 2 amperes (amps) float current value indicating that the battery is 98 percent charged.

a) Provide the bases for the 2-amp float current at which ANO-1 batteries are capable of performing its design function.

b) Explain how maintaining a 2 percent design and 98 percent charge will ensure that the ANO-1 safety-related batteries are fully charged (i.e., capable of performing their design function).

Response - Part 4.a IEEE 450-2002 A.2 states:

As the cells approach full charge, the battery voltage rises to approach the charger output voltage, and the charging current decreases. When the charging current has stabilized at the charging voltage for three consecutive hourly measurements, the battery is near full charge. The expected charging current range applicable to each model may be verified by test or in consultation with the manufacturer.

Entergy has verified via the battery manufacturer (C&D) that a charging current 2 amps is an indication that the battery is at least 98% charged. Therefore, the fully charged float current applicable to the battery model at ANO-1 is 2 amps or less.

Response - Part 4.b Entergy has verified via the battery manufacturer (C&D) that a charging current 2 amps is an indication that the battery is at least 98% charged. Therefore, maintaining an additional 2% design margin in the ANO-1 battery sizing calculation is needed to ensure that 100% battery capacity is available once charging current is 2 amps or less. This is equivalent to the battery being 100% charged because the sizing calculation ensures that the battery can perform its safety related function during a design bases event.

to 1CAN081302 Page 5 of 15

5. In Attachment 1, Section 2.2 of the LAR, the licensee proposed to adopt into the Battery Monitoring and Maintenance Program, the battery connection resistance limit of 50 micro ohms which ensures that the minimum DC voltage is maintained for all required loads.

a) Clarify whether 50 micro ohms is the overall connection resistance limit or the resistance limit for each inter-cell connection, each inter-rack connection, each inter-tier connection, and each terminal connection.

b) Provide a summary table that includes current baseline resistance values or the battery manufacturers recommended resistance limits for each type of battery connections.

c) Provide the basis for the proposed connection resistance value.

Response - Part 5.a The 50 µohm limit is the resistance limit for any one inter-cell connection, inter-tier (or inter-rack) connection, or terminal cable connection.

ANO-1 batteries (C&D LCR-21) have two posts per pole, identified in the battery procedure as P1 & P2 and N1 & N2. For these two-post cells, two resistance measurements are taken for each inter-cell resistance measurement, i.e. P1 to N1 and P2 to N2, in accordance with IEEE Std. 450-2002, Annex F. Although the connections are essentially in parallel, if either of these measurements exceeds the 50 micro-ohms maintenance limit, then actions are taken to correct the condition. Battery terminal cable connections and interior cable connections are treated in the same manner.

Response - Part 5.b The D06 battery (newly installed during 1R24 - spring 2013) inter-cell connection resistance readings range from 28.0 to 37.7 µohms and inter-tier / cable connection resistance readings range from 3.8 to 24.5 µohms (see below data from the May 17, 2013, test).

Note that the ANO-1 battery surveillance procedure does not distinguish between inter-tier and inter-rack connections (both are listed as inter-tier connections). Connections between cells 15-16 and cells 45-46 are inter-rack connections, but are listed as inter-tier connections from the procedure. The connection between cells 30-31 is an inter-tier connection. The connection details for inter-tier and inter-rack cables are the same (the only difference is the length of cables for each).

Cell #1 Cell #15 Cable CONNECTION Inter-Tier CONNECTION (MICRO-OHMS) (MICRO-OHMS)

Cable # G1 Lug to Plate 24.1 Plate to N1 Battery Post 7 Cable # G2 Lug to Plate 24.3 Plate to N2 Battery Post 4.6 Cable # H1 Lug to Plate 24.5 Cable # 1 Lug to Plate 11.9 Plate to P1 Battery Post 5.7 Cable # 2 Lug to Plate 12.2 Plate to P2 Battery Post 5.1 Cable # 3 Lug to Plate 13.7 to 1CAN081302 Page 6 of 15 Cell #58 Cell #16 Cable CONNECTION Inter-Tier CONNECTION (MICRO-OHMS) (MICRO-OHMS)

Plate to N1 Battery Post 8.1 Cable #1 Lug to Plate 12.9 Plate to N2 Battery Post 5.5 Cable #2 Lug to Plate 11.2 Cable # J1 Lug to Plate 10.1 Cable #3 Lug to Plate 11.3 Cable # J2 Lug to Plate 13.1 Plate to P1 Battery Post 7.7 Cable # H2 Lug to Plate 14.1 Plate to P2 Battery Post 3.8 Cell #30 (MICRO-OHMS) Inter-Tier CONNECTION CELL CONNECTION (MICRO-OHMS)

N1-P1 N2-P2 Plate to N1 Battery Post 6.7 1-2 30.1 29.8 Plate to N2 Battery Post 5.6 2-3 29.6 31.3 Cable #1 Lug to Plate 11.8 3-4 30.0 29.5 Cable #2 Lug to Plate 11.9 4-5 29.8 29.2 Cable #3 Lug to Plate 11.8 5-6 29.6 29.6 6-7 27.7 29.1 Cell #31 Inter-Tier CONNECTION 7-8 29.2 30.2 (MICRO-OHMS) 8-9 29.8 29.4 Cable # 1 Lug to Plate 12.5 9 - 10 29.5 29.1 Cable # 2 Lug to Plate 11.9 10 - 11 29.6 28.8 Cable # 3 Lug to Plate 11.6 11 - 12 29 30.7 Plate to P1 Battery Post 7 12 - 13 30.2 29.7 Plate to P2 Battery Post 7.6 13 - 14 30.2 29.3 14 - 15 31.1 29.8 Cell #45 Inter-Tier CONNECTION 16 - 17 30.9 30.3 (MICRO-OHMS) 17 - 18 30.3 31.3 Plate to N1 Battery Post 5.6 18 - 19 27.9 28.6 Plate to N2 Battery Post 10.5 19 - 20 30.1 30.4 Cable # 1 Lug to Plate 14 20 - 21 30.1 30.2 Cable # 2 Lug to Plate 11.9 21 - 22 30 31.7 Cable # 3 Lug to Plate 11.1 22 - 23 30.3 29.4 to 1CAN081302 Page 7 of 15 Inter-Tier Cell #46 (MICRO-OHMS)

CELL CONNECTION CONNECTION (MICRO-OHMS)

N1-P1 N2-P2 Cable # 1 Lug to Plate 15 23 - 24 28.4 29.8 Cable # 2 Lug to Plate 15 24 - 25 30.1 29.5 Cable # 3 Lug to Plate 12.6 25 - 26 29.4 28.8 Plate to P1 Battery Post 6 27 - 28 28.8 28.1 Plate to P2 Battery Post 5.8 28 - 29 29.3 28.4 29 - 30 29.1 28.8 (MICRO-OHMS)

CELL CONNECTION 31 - 32 29.6 29.6 N1-P1 N2-P2 32 - 33 30.7 29.8 46 - 47 28.9 32 33 - 34 30 29.3 47 - 48 30.9 33.4 34 - 35 28.8 29.3 48 - 49 29.1 27.7 35 - 36 29.2 29.5 49 - 50 29.5 29.4 36 - 37 29.5 30 50 - 51 29.8 28 37 - 38 28.4 29.8 51 - 52 28.1 32 38 - 39 29.7 28.3 52 - 53 29.7 29.4 39 - 40 29.6 29.2 53 - 54 29.5 30 40 - 41 30.3 30.4 54 - 55 29.8 31.1 41 - 42 29.8 30.8 55 - 56 30.5 28.3 42 - 43 29.8 28.6 56 - 57 31.4 37.7 43 - 44 29.7 29.3 57 - 58 30.7 34.2 44 - 45 30.1 31.3 The D07 battery (newly installed during 1R23 - fall 2011) inter-cell connection resistance readings range from 27.5 to 33.7 µohms and inter-tier / cable connection resistance readings range from 4.0 to 14.6 µohms (see below data from the May 22, 2013, test).

Cell #1 Cell #15 Cable CONNECTION Inter-Tier CONNECTION (MICRO-OHMS) (MICRO-OHMS)

Cable # G1 Lug to Plate 4.6 Plate to N1 Battery Post 4.2 Cable # G2 Lug to Plate 4.6 Plate to N2 Battery Post 5.5 Cable # H1 Lug to Plate 4.4 Cable # 1 Lug to Plate 13.3 Plate to P1 Battery Post 7.9 Cable # 2 Lug to Plate 12.3 Plate to P2 Battery Post 4.0 Cable # 3 Lug to Plate 13 to 1CAN081302 Page 8 of 15 Cell #58 Cell #16 Cable CONNECTION Inter-Tier CONNECTION (MICRO-OHMS) (MICRO-OHMS)

Plate to N1 Battery Post 5.0 Cable #1 Lug to Plate 13.5 Plate to N2 Battery Post 6.1 Cable #2 Lug to Plate 11.9 Cable # J1 Lug to Plate 7.2 Cable #3 Lug to Plate 11.2 Cable # J2 Lug to Plate 5.8 Plate to P1 Battery Post 7.3 Cable # H2 Lug to Plate 6.6 Plate to P2 Battery Post 11.8 Cell #30 (MICRO-OHMS) Inter-Tier CONNECTION CELL CONNECTION (MICRO-OHMS)

N1-P1 N2-P2 Plate to N1 Battery Post 4.8 1-2 30.3 31.1 Plate to N2 Battery Post 6.0 2-3 29.3 28.9 Cable #1 Lug to Plate 13.7 3-4 29.2 29.1 Cable #2 Lug to Plate 10.4 4-5 28.5 28.6 Cable #3 Lug to Plate 12.3 5-6 30.6 29.3 6-7 28.4 29.6 Cell #31 Inter-Tier CONNECTION 7-8 28.3 30.1 (MICRO-OHMS) 8-9 28.9 29.6 Cable # 1 Lug to Plate 10.2 9 - 10 28.2 28 Cable # 2 Lug to Plate 12.7 10 - 11 29.1 29.3 Cable # 3 Lug to Plate 14.6 11 - 12 28.1 30.2 Plate to P1 Battery Post 4.3 12 - 13 28.2 28.3 Plate to P2 Battery Post 9.0 13 - 14 27.5 29.3 14 - 15 28.7 33.7 Cell #45 Inter-Tier CONNECTION 16 - 17 29.1 30.2 (MICRO-OHMS) 17 - 18 29.3 29.3 Plate to N1 Battery Post 9.0 18 - 19 31 30.3 Plate to N2 Battery Post 5.0 19 - 20 28.5 29.9 Cable # 1 Lug to Plate 13.6 20 - 21 29.9 29.2 Cable # 2 Lug to Plate 12.6 21 - 22 30.2 30.5 Cable # 3 Lug to Plate 11.9 22 - 23 28.8 28.8 to 1CAN081302 Page 9 of 15 (MICRO-OHMS) Cell #46 CELL CONNECTION Inter-Tier CONNECTION N1-P1 N2-P2 (MICRO-OHMS) 23 - 24 29.1 29.5 Cable # 1 Lug to Plate 13.7 24 - 25 29.6 29.5 Cable # 2 Lug to Plate 11.2 25 - 26 28.4 29.8 Cable # 3 Lug to Plate 10.9 26 - 27 30.3 29.5 Plate to P1 Battery Post 9.0 27 - 28 30.5 29.7 Plate to P2 Battery Post 9.4 28 - 29 29.5 32.2 29 - 30 29.8 30.4 (MICRO-OHMS)

CELL CONNECTION 31 - 32 29.4 30.5 N1-P1 N2-P2 32 - 33 30 29.2 46 - 47 30.9 30.1 33 - 34 29.6 31.2 47 - 48 33 32.1 34 - 35 28.9 29.7 48 - 49 30.4 30.6 35 - 36 29.8 30.5 49 - 50 31.3 30.3 36 - 37 29.8 29.8 50 - 51 30 30.1 37 - 38 29 30.3 51 - 52 31.2 30.4 38 - 39 30.1 30 52 - 53 30.7 30.1 39 - 40 30.4 30.1 53 - 54 31.4 30.5 40 - 41 29.2 29.9 54 - 55 31.4 28.9 41 - 42 30 31.1 55 - 56 32 30.7 42 - 43 32.7 29.2 56 - 57 30.4 30.4 43 - 44 31.5 29.8 57 - 58 31.1 32.4 44 - 45 31.7 30.8 Response - Part 5.c As discussed in Attachment 1, Page 7, of the original LAR (Reference 1), ANO-1 DC voltage drop calculations indicate that minimum DC voltage is maintained for all required loads assuming a resistance of 50 µohms per inter-cell connection. The current proceduralized battery maintenance limit is, therefore, 50 µohms on a per-connection basis, which significantly minimizes potential impact to overall battery performance (i.e.,

maintenance is not delayed to the point where many cells might indicate resistance values greater than that assumed in the calculations).

to 1CAN081302 Page 10 of 15

6. In Attachment 4 of the LAR, the licensee proposed an alternative criterion for new TS Surveillance Requirement (SR) 3.8.4.2 which states, Verify each battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is bracketed in TSTF-500.

Explain the basis for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Response

The D06 and D07 battery duty cycle calculation indicates that the D06 amp-hours utilized during a design basis event (emergency duty cycle) is 300.1 amp-hours. For D07, the amp-hours utilized during a design basis event is 348.5 amp-hours. Assuming 110% of the amp-hours utilized will need to be replaced to fully recharge the battery, D06 will require 330.1 amp-hours (300.1 x 1.1) and D07 will require 383.3 amp-hours (348.5 x 1.1). Using the battery charger proposed surveillance tested capacity of 300 amps (actual battery charger current limit rating is 400 amps) and a continuous DC bus load of 120 amps, 180 amps remain available to recharge the battery (300 amps -

120 amps). Using D07 as an example (worst case), approximately 2.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (383.3 amp-hours / 180 amps) are required to recharge D07 assuming the battery would accept the full 180 amps continuously during the recharge. However, because the battery chargers are constant voltage chargers rather than constant current chargers, it is recognized that the battery charging current will taper off from the initial maximum current that the charger can supply to a final value of < 2 amps. ANO does not possess battery recharge current characteristic curves, but it is considered reasonable to expect that the battery would be fully recharged in < 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to < 2 amps charging current given the above charger capacity and relatively small amount of capacity removed from the batteries (D06 and D07 batteries, C&D Technologies model LCR-21, are rated for 1442 amp-hours at the 8-hour rate to 1.81 vpc). This expectation is further supported by empirical data indicating that these batteries are typically fully recharged in under 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a battery performance discharge test that fully depletes the battery (100% depth of discharge) while the battery charger is supplying normal continuous DC bus loads of ~100 amps. In addition, NUREG/CR 7148, Confirmatory Battery Testing:

The Use of Float Current Monitoring to Determine Battery State-of-Charge, Figures 3-20 and 3-21, provide a graph of an LCR-33 battery type recharge at 180 amps, with recharge (< 2 amps) completed within ~20 hours following full 100% depth of discharge

(~2000 Amp-Hours discharged). This battery type is significantly larger (higher capacity) than the ANO-1 LCR-21 type batteries.

7. In Attachment 4 of the LAR, the licensee proposed new SR 3.8.4.3 as in TSTF-500.

SR 3.8.4.3 in TSTF-500 includes a note that states, This Surveillance shall not be performed in Mode 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Explain why this note was not adopted in ANO-1 SR 3.8.6.6.

to 1CAN081302 Page 11 of 15

Response

Entergy does not permit intentional entry into TS Conditions and Required Actions where Completion Times would be significantly challenged. In this respect, battery service or discharging testing is not performed during plant operation. Nevertheless, Entergy proposes to adopt the subject Note to provide greater consistency with TSTF-500. As a result, revised markup TS and TS Bases pages are included in Attachment 2 of this letter, and a revised (clean) TS page is included in Attachment 3 of this letter, adopting the subject note.

8. In Attachment 4 of the LAR, the licensee proposed TS 3.8.5, Condition A, RA A.1, which requires the restoration of the battery terminal voltage to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when one of the required battery charger on one subsystem is inoperable and the required redundant subsystem battery and charger are operable.

a) Explain how the licensee will ensure that the battery is returned to its fully charged state from any discharge that might have occurred due to the charger inoperability.

b) Per TSTF-500, Page 9, the new TS 3.8.5, Condition A is included only when the plant-specific implementation of TS 3.8.5 may require both trains of the DC electrical power system to be operable. Clarify whether ANO-1 TS 3.8.5 requires both DC subsystems to be operable.

c) The mark-up version of TS 3.8.5, Condition A states, the required redundant subsystem battery and charger while the clean version of TS 3.8.5, Condition A in Attachment 5 states, the redundant subsystem battery and charger. Explain this apparent discrepancy.

Response - Part 8.a Please see response to Item 2.b above.

Response - Part 8.b Please see response to Item 2.a above.

Response - Part 8.c The markup version of TS 3.8.5 is correct (see discussion in Section 2.3 of the original LAR). A revised clean TS page is included in Attachment 2 of this letter, which adds the word required to the subject Condition.

to 1CAN081302 Page 12 of 15

9. In Attachment 4 of the LAR, the licensee proposed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time (CT) for TS 3.8.6, Condition B, Required Action (RA) B.2. This 12-hour CT is bracketed in TSTF-500.

Explain how the 12-hour CT is applicable to ANO-1.

Response

The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. Total normal steady state loads on D-06 and D-07 battery chargers average less than 120 amps based on monthly System Engineering walk down data. Each battery charger connected to D-06 and D-07 is rated for 400 Amps. Conservatively assuming the charger output is only 300 amps maximum based on proposed battery charger testing:

300 A available - 120 A steady state load = 180 A excess capacity for battery charging.

Assuming the battery charger is offline for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (the time allowed by TSTF-500 to place a charger on the battery) and assuming normal steady state DC system loads remain on battery during this time would equate to a 2 hr x 120 A (or 240 A-hr) loss.

Assuming 110% of 240 A-hr (or 264 A-hr) would be required to restore the battery to a fully recharged state and given the 180 A excess battery charger capacity above, the battery can be restored to fully recharged within 264 A-hr / 180 A = 1.5 hrs.

However, because the battery chargers are constant voltage chargers rather than constant current chargers, it is recognized that the battery charging current will taper off from the initial maximum current that the charger can supply to a final value of < 2 amps.

ANO does not possess battery recharge current characteristic curves, but it is considered reasonable to expect that the battery would be fully recharged in < 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to < 2 amps charging current given the above charger capacity and relatively small amount of capacity removed from the batteries. See response to Question 6 for further discussion.

10. In Attachment 4 of the LAR, the licensee proposed adding new Condition D to TS 3.8.6 which would apply to a battery found with a pilot cell electrolyte temperature less than the minimum established design limit. The RA associated with new Condition D would require the licensee to restore the pilot cell electrolyte temperature to greater than or equal to minimum established design limits within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

a) Discuss how the battery room temperature is periodically monitored at ANO-1 and provide the minimum frequency at which the temperature of the battery room is monitored.

b) Explain how the licensee would restore battery room temperature if it was outside the temperature limits.

c) Provide the method of selection of pilot cells at ANO-1.

to 1CAN081302 Page 13 of 15 Response - Part 10.a Thermometers, controlled in accordance with the ANO Maintenance & Test Equipment program, are installed in each vital battery room. Operations logs require verification of room temperature once per 12-hour shift.

Response - Part 10.b The battery rooms are cooled via respective room exhaust fans that draw cool air into the room from the surrounding vital electrical area. If the areas just outside the battery rooms reach 95 °F, a Control Room alarm will annunciate and an emergency switchgear room chiller subsystem will automatically start. Annunciator Corrective Action (ACA) procedure (OP-1203.012N) contains appropriate response measures to ensure room cooling is effective. The associated procedure begins with a caution statement, reminding Operators that dropping temperatures can be adverse to continued battery operability:

TS 3.8.6 Condition B requires battery electrolyte temperature > 60 °F.

This is also repeated in the normal operator procedure (OP-1104.027). Note that a 71 °F caution or administrative limit is included in both procedures. The procedures also require verification that the emergency cooling subsystem stops when temperature lowers to 90 °F. In addition, OP-1104.027 requires monitoring battery room temperatures at least once every three hours when an emergency room cooling subsystem is operating, to ensure room temperatures remain within acceptable limits.

Should normal and/or emergency room cooling subsystems malfunction resulting in temperature rise, doors can be opened to permit natural convection cooling.

Lowering room temperatures may also be offset by opening doors to surrounding areas if those areas, at the time of the condition, are warmer than that of the battery rooms. The battery room exhaust fans may also be secured, along with surrounding area cooling subsystems as necessary. Plant heating water would also be verified to be operating properly with respect to area supply fans that incorporate both cooling and heating coils.

Response - Part 10.c In accordance with the battery monitoring and maintenance program, which is proposed for inclusion in new ANO-1 TS 5.5.6 in accordance with TSTF-500, the cell having the lowest voltage will be selected as the pilot cell. Pilot cell selection will be verified using quarterly data obtained from required surveillance testing.

to 1CAN081302 Page 14 of 15

11. In Attachment 4 of the LAR, the licensee proposed a battery cell float voltage limit of greater than or equal to 2.07 V which is reflected in TS 3.8.6 RA A.3, SR 3.8.6.2, and SR 3.8.6.5. This 2.07-V is bracketed in TSTF-500.

a) Explain how this cell float voltage limit is applicable to ANO-1.

b) Current TS Table 3.8.6-1, Battery Cell Surveillance Requirements, Category C float voltage allowable limits for each connected cell is > 2.07 V. Explain the change from

> 2.07 V to 2.07 V.

Response - Part 11.a The ANO-1 battery cells (C&D Model LCR-21) are of the vented lead-acid type with a nominal electrolyte specific gravity of 1.215. Open circuit voltage of the lead-acid battery cell is related to the specific gravity by a constant as shown in the following equation (reference EPRI TR-100248 Rev. 2):

Open Circuit Voltage = Specific Gravity + 0.845 Therefore, for the ANO-1 battery cells, the nominal cell open circuit voltage is 1.215 +

0.845 = 2.06 volts DC. A cell voltage of less than or equal to cell open circuit voltage indicates the cell is no longer being floated at a voltage sufficient to prevent discharge.

Response - Part 11.b The actual open circuit cell voltage provided by the battery manufacturer is 2.063 V; therefore, the change from > 2.07 V to 2.07 V as the allowable limit is acceptable.

12. In Attachment 4 of the LAR, the licensee proposed relocating SR 3.8.4.3 to SR 3.8.6.6 as in TSTF-500. SR 3.8.6.6 in TSTF-500 includes a note that states, This Surveillance shall not be performed in Mode 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Explain why this note was not adopted in ANO-1 SR 3.8.6.6.

Response

Entergy does not permit intentional entry into TS Conditions and Required Actions where Completion Times would be significantly challenged. In this respect, battery service or discharging testing is not performed during plant operation. Nevertheless, Entergy proposes to adopt the subject Note to provide greater consistency with TSTF-500. As a result, revised markup TS and TS Bases pages are included in Attachment 2 of this letter, and a revised (clean) TS page is included in Attachment 3 of this letter, adopting the subject note.

to 1CAN081302 Page 15 of 15 Summary During resolution of the above RAI, Entergy noted that an AND statement between Required Action B.1 and B.2 in LCO 3.8.6 was not underlined in the revised (clean) TS page. This has been corrected and a new revised (clean) TS page is included in Attachment 3 of this letter.

Based on changes proposed above, Entergy requests the corresponding TS and TS Bases markup pages, and the corresponding TS revised (clean) pages contained in the original ANO-1 LAR (Reference 1) be replaced with those included in Attachments 2 and 3 of this letter.

5.0 REFERENCE

1. Entergy letter dated January 28, 2013, License Amendment Request - Adoption of Technical Specification Task Force (TSTF)-500, Revision 2, DC Electrical Rewrite -

Update to TSTF-360 (TAC No. MF0596) (ML13029A767)

2. NRC email dated July 15, 2013, Arkansas Nuclear One, Unit 1 - Request for Additional Information Regarding License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, DC Electrical Rewrite -

Update to TSTF-360 (TAC No. MF0596) (ML13197A014)

Attachment 2 to 1CAN081302 Replacement Technical Specification and Bases Changes (mark-up)

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.32 ---------------------------------NOTE------------------------------ 18 months This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test or a modified performance discharge test.

SR 3.8.4.3 Verify battery capacity is 80% of the manufacturer's 60 months rating when subjected to a performance discharge test or a modified performance discharge test. AND 12 months when battery shows degradation, or has reached 85% of the expected life with capacity

< 100% of manufacturers rating AND 24 months when battery has reached 85% of the expected life with capacity 100% of manufacturers rating ANO-1 3.8.4-2 Amendment No. 215,

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS

NOTE----------------------------------------------------------

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Required battery charger A.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on one subsystem voltage to greater than or inoperable. equal to the minimum established float voltage.

AND AND The required redundant subsystem battery and A.2 Verify battery float current Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> charger are OPERABLE. 2 amps.

BA. One or more required DC BA.1.1 Suspend CORE Immediately electrical power ALTERATIONS.

subsystems inoperable for reasons other than AND Condition A.

BA.1.2 Suspend movement of Immediately OR irradiated fuel assemblies.

Required Action and AND associated Completion Time of Condition A not BA.1.3 Suspend operations Immediately met. involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND ANO-1 3.8.5-1 Amendment No. 215,218,

DC Sources - Shutdown 3.8.5 CONDITION REQUIRED ACTION COMPLETION TIME BA.1.4 Initiate action to restore Immediately required DC electrical power subsystems to OPERABLE status.

AND ANO-1 3.8.5-1 Amendment No. 215,218,

Battery Cell Parameters 3.8.6 SURVEILLANCE FREQUENCY SR 3.8.6.3 Verify each battery connected cell electrolyte level is 3192 days greater than or equal to minimum established design parameters meet Table 3.8.6-1 Category B limits. AND Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a battery discharge < 110 V AND Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a battery overcharge

> 145 V SR 3.8.6.4 Verify each battery pilot cellaverage electrolyte 3192 days temperature is greater than or equal to minimum established design limitsof representative cells is 60F.

SR 3.8.6.5 Verify each battery connected cell float voltage is 92 days 2.07 V.

SR 3.8.6.6 ---------------------------------NOTE------------------------------ 60 months This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken AND for unplanned events that satisfy this SR.

12 months when battery shows Verify battery capacity is 80% of the manufacturer's degradation, or has rating when subjected to a performance discharge reached 85% of test or a modified performance discharge test. the expected life with capacity < 100% of manufacturers rating AND 24 months when battery has reached 85% of the expected life with capacity 100% of manufacturers rating ANO-1 3.8.6-4 Amendment No. 215,

DC Sources - Operating B 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.2 This SR verifies the design capacity of the chargers. According to Regulatory Guide (RG) 1.32 (Ref. 9), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to 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.

This SR provides two options. One option requires that each battery charger be capable of supplying 300 amps at the minimum established float voltage for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period is sufficient for the charger temperature to have stabilized and to have been maintained 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 other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur).

This level of loading may not normally be available following the battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is 2 amps.

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 3.8.4.32 A battery service test is a special test of the battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length should correspond to the design duty cycle requirements.

The Surveillance Frequency of 18 months is consistent with considerations that the recommendations ofbattery service test should be performed during refueling outages, or at some other outage RG 1.32 (Ref. 9) and RG 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 a Note. The reason for the Note is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. Credit may be taken for unplanned events that satisfy this SR.

A modified performance discharge test may be performed in lieu of a service test. The modified performance discharge test (Ref. 8) is a simulated duty cycle consisting of just two rates; the ANO-1 B 3.8.4-5 Amendment No. 215 Rev.

DC Sources - Operating B 3.8.4 one minute rate published for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test, both of which envelope the duty cycle of the service test. Since the ampere-hours removed by a rated one-minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.3 (continued)

A modified performance discharge test is a test of the battery capacity, as found, and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test and the test discharge rate must envelope the duty cycle of the service test if the modified performance discharge test is performed in lieu of a service test.

SR 3.8.4.3 A battery performance discharge test is a test of constant current capacity of a battery after having been in service, to detect any change in the capacity determined by the acceptance test.

The test is intended to determine overall battery degradation due to age and usage (Ref. 8).

A battery modified performance discharge test is described in the Bases for SR 3.8.4.2. Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.4.3; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.3 while satisfying the requirements of SR 3.8.4.2 at the same time.

The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 8), which recommends that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

The Surveillance Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturers rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity 100% of the manufacturers ratings. Degradation is indicated, according to IEEE-450 (Ref. 8), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is > 10% below the manufacturer's rating. These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 8).

REFERENCES ANO-1 B 3.8.4-6 Amendment No. 215 Rev.

DC Sources - Operating B 3.8.4

1. SAR, Section 1.4, GDC 17.
2. Regulatory Guide 1.6, Independence Between Redundant Standby (Onsite)

Power Sources and Between Their Distribution Systems, March, 1971.

3. IEEE-308-1971, Criteria for Class 1E Power Systems for Nuclear Power Generating Stations.
4. SAR, Chapter 8.
5. IEEE-485-1993, June 1983.
6. SAR, Chapter 14.
7. 10 CFR 50.36.
8. IEEE-450-1995, Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications.
9. Regulatory Guide 1.32, Criteria for Power Systems for Nuclear Power Plants, March 2004.
10. Regulatory Guide 1.129, Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plants, February 2007.

ANO-1 B 3.8.4-7 Amendment No. 215 Rev.

DC Sources - Shutdown B 3.8.5 ACTIONS (continued)

A.1 and A.2 Condition A represents one subsystem with the required battery charger inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTION provides a response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This time provides for returning the inoperable charger to OPERABLE status or aligning a fully qualified swing charger to the associated DC subsystem. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides confidence that, within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the battery will be restored to its fully charged condition from any discharge that might have occurred due to the charger inoperability.

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and the charger is not operating in the current-limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as less than or equal to 2 amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it has now been fully recharged. If at the expiration of the initial 12-hour period the battery float current is not less than or equal to 2 amps, this indicates there may be additional battery problems and the battery must be declared inoperable.

BA.1.1, BA.1.2, BA.1.3, BA.1.4, and BA.1.5 With the required DC electrical subsystem inoperable (e.g., inoperable battery, no OPERABLE battery charger, or both) there may be insufficient capability to mitigate the consequences of a fuel handling accident. Therefore, conservative actions must be taken (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies in both the reactor building and the fuel handling area, and operations involving positive reactivity additions that could result in loss ANO-1 B 3.8.5-3 Amendment No. 215 Rev.

Battery Cell Parameters B 3.8.6 This SR is modified by a Note. The reason for the Note is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. Credit may be taken for unplanned events that satisfy this SR.

REFERENCES

1. SAR, Chapters 8 and 14.
2. 10 CFR 50.36.
3. IEEE-450-1995, "Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications."

ANO-1 B 3.8.6-10 Amendment No. 215 Rev.

Attachment 3 to 1CAN081302 Replacement Revised (clean) Technical Specification Pages

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.3 ---------------------------------NOTE------------------------------ 18 months This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test or a modified performance discharge test.

ANO-1 3.8.4-2 Amendment No. 215,

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS

NOTE----------------------------------------------------------

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Required battery charger A.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on one subsystem voltage to greater than or inoperable. equal to the minimum established float voltage.

AND AND The required redundant subsystem battery and A.2 Verify battery float current charger are OPERABLE. 2 amps.

B. One or more required DC B.1.1 Suspend CORE Immediately electrical power ALTERATIONS.

subsystems inoperable for reasons other than AND Condition A.

B.1.2 Suspend movement of Immediately OR irradiated fuel assemblies.

Required Action and AND associated Completion Time of Condition A not B.1.3 Suspend operations Immediately met. involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND ANO-1 3.8.5-1 Amendment No. 215,218,

Battery Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters LCO 3.8.6 Battery parameters for the Train A and Train B electrical power subsystem batteries shall be within limits.

APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE.

ACTIONS

NOTE-----------------------------------------------------

Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME A. One battery with one or A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> more battery cells float voltage < 2.07 V. AND A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND A.3 Restore affected cell voltage 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 2.07 V.

B. One battery with float B.1 Perform SR 3.8.4.1 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> current > 2 amps.

AND B.2 Restore battery float current 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 2 amps.

ANO-1 3.8.6-1 Amendment No. 215,

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 ---------------------------------NOTE------------------------------

Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.

Verify each battery float current is 2 amps. 7 days SR 3.8.6.2 Verify each battery pilot cell float voltage is 2.07 V. 31 days SR 3.8.6.3 Verify each battery connected cell electrolyte level is 31 days greater than or equal to minimum established design limits.

SR 3.8.6.4 Verify each battery pilot cell temperature is greater 31 days than or equal to minimum established design limits.

SR 3.8.6.5 Verify each battery connected cell float voltage is 92 days 2.07 V.

SR 3.8.6.6 ---------------------------------NOTE------------------------------ 60 months This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken AND for unplanned events that satisfy this SR.

12 months when battery shows Verify battery capacity is 80% of the manufacturer's degradation, or has rating when subjected to a performance discharge reached 85% of test or a modified performance discharge test. the expected life with capacity < 100% of manufacturers rating AND 24 months when battery has reached 85% of the expected life with capacity 100% of manufacturers rating ANO-1 3.8.6-3 Amendment No. 215,

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