L-14-271, Request for Licensing Action to Amend Technical Specification 3.8.4, DC Sources - Operating

Request for Licensing Action to Amend Technical Specification 3.8.4, DC Sources - Operating

ML14328A665
Person / Time
Site:	Perry
Issue date:	11/24/2014
From:	Harkness E FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-14-271
Download: ML14328A665 (17)

Text

• -: ,:

FENOC' Perry Nuclear Power Plant P.O. Box 97 10 Center Road Perry, Ohio 44081 RrstEnergy Nuclear Operating Company Ernest J. Harkness 440-280-5382 Vice President Fax: 440-280-8029 November 24, 2014 L-14-271 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Request for Licensing Action to Amend Technical Specification 3.8.4, "DC Sources - Operating" Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) is requesting an amendment to the Perry Nuclear Power Plant (PNPP) Technical Specification 3.8.4, "DC Sources - Operating."

An evaluation of the proposed amendment is provided as an enclosure. FENOC is requesting Nuclear Regulatory Commission (NRC) staff approval by December 7, 2015, and an implement?tion period of 60 days following issuance of the amendment.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 315-6810.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 11-'/, 2014.

Sincerely, I

.QAv19 ~l'-'!VN~

Ernest J. Harkness

Enclosure:

Evaluation of Proposed License Amendment cc: NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

EVALUATION OF PROPOSED LICENSE AMENDMENT Page 1 of 8

Subject:

Request to Amend Technical Specification 3.8.4, "DC Sources - Operating" 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 General

Description:

Class 1E, Division 1 and 2 Direct Current Systems 2.2 General

Description:

Class 1E, Division 3 Direct Current System 2.3 Surveillance Requirement (SR) 3.8.4.8 2.4 Proposed Changes to SR 3.8.4.8

3.0 TECHNICAL EVALUATION

3.1 Revised SR 3.8.4.8 Frequency Requirements 3.2 Credit for Unplanned Events 3.3 MODE or OPERABILITY Restrictions on Testing 3.4 Modified Discharge Performance Test

4.0 REGULATORY EVALUATION

4.1 Significant Hazards Consideration 4.2 Applicable Regulatory Requirements/Criteria 4.3 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

Attachments:

1. Proposed Technical Specification Changes (MARK-UP)

2. Proposed Technical Specification Changes (RETYPED)

3. Planned Technical Specification Bases Changes

Page 2 of 8 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Perry Nuclear Power Plant (PNPP)

Technical Specification (TS) 3.8.4, "DC Sources - Operating." Surveillance Requirement (SR) 3.8.4.8 for battery capacity testing would be revised to be consistent with the battery capacity testing frequencies identified in the Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications."

By revising the SR, the proposed amendment addresses an issue related to battery testing frequency. Specifically, it was determined that SR 3.8.4.8 does not align with the increased testing frequency of IEEE 450-1995 for degraded Class 1E batteries.

The proposed TS changes are marked in Attachment 1; the TS retyped pages incorporating the proposed changes are provided in Attachment 2. The planned TS Bases changes in Attachment 3 are provided for information only.

2.0 DETAILED DESCRIPTION 2.1 General

Description:

Class 1E. Division 1 and 2 Direct Current Systems The Class 1E, Division 1 and Division 2, 125-volt direct current (DC) systems are two completely independent and redundant systems. Each is capable of supplying required DC power to associated loads needed for safe shutdown. Each system includes a 1260 ampere hour battery and a 400 ampere battery charger. For Division 1, both Unit 1 and Unit 2 have identical 61-cell batteries. For Division 2, both Unit 1 and Unit 2 have identical 60-cell batteries. In addition, a 400 ampere reserve battery charger is provided for each division. The reserve battery chargers are located with the equipment associated with Unit 1, but can be connected to the appropriate division of either the Unit 1 or Unit 2, Class 1E, 125-volt DC systems by means of the maintenance tie buses. No interdivisional ties are provided between the divisions associated with Unit 1 or Unit 2. Maintenance tie buses only connect the same divisions of the two units (Unit 1, Division 1 to Unit 2, Division 1; and Unit 1, Division 2 to Unit 2, Division 2). The maintenance tie bus circuit breakers are normally open and are manually operated under administrative control.

These breakers permit isolation of the battery and normal battery charger associated with either Unit 1 or Unit 2 for purposes of maintenance, testing, or equalizing the battery. If the DC batteries are the only available power source, the maintenance tie circuit breakers may be closed to allow the Unit 1 and Unit 2 batteries to be paralleled.

Battery design (loading, sizing, and capacity) used the guidance in IEEE 485-1997, "IEEE Recommended Practice for Sizing Lead-Acid Batteries for Stationary Applications." The Division 1 and 2 batteries have a manufacturer rated expected life of 20 years and are typically replaced every 16 years.

Page 3 of 8 2.2 General

Description:

Class 1E, Division 3 Direct Current System The Class 1E, Division 3, 125-volt DC system is an independent and redundant system capable of supplying required DC power to the high pressure core spray (HPCS) system logic, the Division 3 diesel generator control system, and other Division 3 DC controls.

The system includes a 250 ampere hour battery and a 50 ampere battery charger. For Division 3, both Unit 1 and Unit 2 have identical 60-cell batteries. In addition, a 50 ampere reserve battery charger is provided. The reserve battery charger is located with the equipment associated with Unit 1 but can be connected to the Unit 2, Class 1E, 125-volt DC system by means of a maintenance tie bus. No interdivisional ties are provided between the divisions associated with Unit 1 or Unit 2. The maintenance tie bus only connects Unit 1, Division 3 to Unit 2, Division 3. The maintenance tie bus circuit breaker is normally open and is manually operated under administrative control. This breaker permits isolation of the battery and normal battery charger associated with either Unit 1 or Unit 2 for purposes of maintenance, testing or equalizing the battery. If the DC batteries are the only available power source, the maintenance tie circuit breaker may be closed to allow the Unit 1 and Unit 2 batteries to be paralleled.

Battery design (loading, sizing, and capacity) used the guidance in IEEE 485-1997. The Division 3 batteries have a manufacturer rated expected life of 20 years and are typically replaced every 17 years.

2.3 Surveillance Requirement (SR) 3.8.4.8 PNPP's SR 3.8.4.8 is a constant current capacity test of the Division 1, 2 and 3 Class 1E batteries and determines overall battery degradation due to age and usage. The battery capacity tests are scheduled at five-year (60-month) intervals until the battery reaches 85 percent(%) of its service life or shows specific signs of degradation. If 85% is reached or degradation is determined, the test frequency increases to 18 months.

2.4 Proposed Changes to SR 3.8.4.8 IEEE 450-1995 specifies a testing frequency of 12 months when a battery shows degradation, or has reached 85% of the expected life with a capacity less than (<) 100% of manufacturer's rating, and a 24-month testing frequency when a battery reaches 85% of the expected life and has a capacity greater than or equal to (2::)100% of the manufacturer's rating.

The proposed amendment to PNPP's TS 3.8.4, "DC Sources - Operating," will align the frequency requirements of SR 3.8.4.8 with the frequency requirements of IEEE 450-1995, as described below.

Surveillance frequency requirements The current SR 3.8.4.8 cites an 18-month testing frequency, which is only applicable if a battery shows degradation or has reached 85% of its expected life, and does not include a 24-month testing frequency when a battery reaches 85% of the expected life and has a capacity 2::100% of the manufacturing rating. This does not align with IEEE 450-1995.

Page 4 of 8 The following criteria will replace the current "18 month" frequency requirements:

12 months when battery shows degradation, or has reached 85% of the expected life with capacity < 100% of manufacturer's rating AND 24 months when battery has reached 85% of the expected life with capacity ;:: 100%

of the manufacturer's rating These proposed frequency requirements are consistent with those recommended in IEEE 450-1995, Section 5.2, "Performance," Item c.

Surveillance description The current SR 3.8.4.8 does not include a provision to prevent unnecessary cycling of plant equipment. This does not align with NUREG-1434, Revision 4, Volume 1, "Standard Technical Specifications - General Electric BWR/6 Plants."

The following note will be added before the current SR 3.8.4.8 description:

"Credit may be taken for unplanned events that satisfy this SR" This note is found in NUREG-1434, TS 3.8.6, "Battery Parameters," SR 3.8.6.6. This SR number is different from PNPP's SR 3.8.4.8. However, both SRs verify battery capacity.

This numbering difference does not affect the proposed amendment or the battery capacity testing requirements of PNPP's SR 3.8.4.8.

Other proposed changes to SR 3.8.4.8 By correspondence dated March 25, 2014 (Accession No. ML14084A165), FENOC submitted a license amendment request to adopt TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b." NRC approval of the proposed amendment would modify the SR 3.8.4.8 battery testing frequency requirement by replacing "60 months" with "In accordance with the Surveillance Frequency Control Program."

The changes proposed herein and those requested in the March 25, 2014 FENOC letter can be implemented independently (that is, the changes may be approved in any order).

3.0 TECHNICAL EVALUATION

3.1 Revised SR 3.8.4.8 Frequency Requirements The revised SR 3.8.4.8 frequency requirements, as proposed, are considered acceptable since they align with the recommendations of IEEE 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications." As cited in the Updated Safety Analysis Report (USAR),

Table 1.8-1, PNPP conforms, with certain exceptions, to Regulatory Guide 1.129, "Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plants," which endorses the IEEE standard. Per the USAR, PNPP

Page 5 of 8 specifically adopted IEEE 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications."

The revised SR 3.8.4.8 frequency requirements, as proposed, are considered acceptable since they align with the recommendations of IEEE 450-1995. These frequency requirements are also consistent with the battery capacity testing frequencies provided in NUREG-1434, Revision 4, SR 3.8.6.6.

The revised frequency requirements have no impact on the USAR Chapter 15 accident analyses. Prescribed battery capacity testing will continue to be performed in accordance with approved procedures, thus ensuring the batteries are capable of performing their design basis functions.

3.2 Credit for Unplanned Events The NUREG-1434 note associated with SR 3.8.6.6 [PNPP SR 3.8.4.8] includes the statement "credit may be taken for unplanned events that satisfy this SR." Adding this statement to PNPP's SR 3.8.4.8 permits control room staff to take credit for SR performance when an emergent or unplanned activity requires performance of an associated SR 3.8.4.8 surveillance instruction (for example, battery capacity testing following maintenance or replacement). Taking credit for SR performance would reset the next required SR performance due date for that particular battery and prevent unnecessary cycling of plant equipment.

3.3 MODE or OPERABILITY Restrictions on Testing As described above, all three divisional DC battery systems have a redundant Unit 2 battery for each Unit 1 battery. For each division, only one battery, either the Unit 1 battery or the Unit 2 battery, is required to be OPERABLE. Each division also includes a maintenance tie bus to permit maintenance, testing or equalizing of either the Unit 1 battery or Unit 2 battery in any MODE of operation. This PNPP-specific feature allows one battery in each division to be out of service for maintenance, testing or equalizing, while the remaining divisional battery satisfies OPERABILITY requirements in any applicable MODE of operation. This feature also allows the out of service battery to be restored to an OPERABLE status independent of the battery that is already OPERABLE. By design, this restoration activity can occur without an additional assessment to determine that the safety of the plant is maintained. As a result, PNPP's SR 3.8.4.8 does not currently include any MODE restrictions or require any plant safety assessments to be performed when reestablishing OPERABILITY of a battery. Therefore, the NUREG-1434 note associated with SR 3.8.6.6 [PNPP SR 3.8.4.8] invoking MODE restrictions or requiring plant safety assessments is not required.

3.4 Modified Performance Discharge Test Currently, PNPP does not perform nor does it intend to include a modified performance discharge test as part of its battery testing scheme. As such, the provision for "a modified performance discharge test" is not included in SR 3.8.4.8

Page 6 of 8

4.0 REGULATORY EVALUATION

4.1 Significant Hazards Consideration The proposed amendment to Perry Nuclear Power Plant (PNPP) Technical Specification 3.8.4, "DC Sources - Operating," would revise Surveillance Requirement 3.8.4.8 to be consistent with the battery capacity testing frequency criteria identified in the Institute of Electrical and Electronics Engineers (IEEE) 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," performance test 5.2.c.

The proposed amendment does not involve a design modification or physical change to the plant, and does not change methods of plant operation or maintenance of equipment important to safety.

FirstEnergy Nuclear Operating Company (FENOC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No The proposed amendment does not change the design function of the Class 1E divisional battery systems and does not change the way the plant is maintained or operated when performing battery surveillance testing. The proposed amendment does not affect any accident mitigating feature or increase the likelihood of malfunction for plant structures, systems and components.

The proposed amendment does not affect the operability requirements of the Class 1E divisional battery systems. Verification of operating the plant within prescribed limits will continue to be performed, as currently required. Compliance with and continued verification of the prescribed limits support the capability of the Class 1E divisional battery systems to perform their required design functions during all plant operating, accident, and station blackout conditions, consistent with the plant safety analyses.

The proposed amendment will not change any of the analyses associated with the PNPP Updated Safety Analysis Report Chapter 15 accidents because plant operation, plant structures, systems, components, accident initiators, and accident mitigation functions remain unchanged.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page 7 of 8

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

Response: No The proposed amendment does not change the design function of the Class 1E divisional battery systems, and does not change the way the plant is operated or maintained. The proposed amendment does not create a credible failure mechanism, malfunction or accident initiator not already considered in the design and licensing basis.

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

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

Response: No.

Safety margins are applied to design and licensing basis functions and to the controlling values of parameters to account for various uncertainties and to avoid exceeding regulatory or licensing limits. The proposed amendment does not involve a physical change to the plant, does not change methods of plant operation within prescribed limits, or affect design and licensing basis functions or controlling values of parameters for plant systems, structures, and components.

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

Based on the responses to the three questions above, FENOC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.2 Applicable Regulatory Requirements/Criteria The following requirements are applicable to the proposed amendment:

General Design Criterion (GDC) 17, "Electric power systems," of Appendix A, "General Design Criteria for Nuclear Power Plants," Title 10 of the Code of Federal Regulations (10 CFR) Part 50 requires, in part, that nuclear power plants have onsite and offsite electric power systems to permit the functioning of structures, systems, and components that are important to safety. The onsite system is required to have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure. The offsite power system is required to be supplied by two physically independent circuits that are designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. In addition, this criterion requires provisions to minimize the probability of losing electric power from the remaining electric power supplies as a result of loss of power from the unit, the offsite transmission network, or onsite power supplies.

Page 8 of 8 GDC 18, "Inspection and testing of electric power systems," requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.

10 CFR 50.36, "Technical specifications" requires, in part, that a licensee's technical specifications include surveillance requirements relating to test to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

FENOC has determined that the proposed amendment maintains conformance with the regulatory requirements described in the above cited documents.

4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

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

Attachment 1 Proposed Technical Specification Changes (MARK-UP)

(1 Page Follows)

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~()"TE: ---------------------

Credit may be taken for unplanned DC Sources-Operating events that satisfy this SR. 3.8.4 SURV£1 LLANCE -REQUIREMENTS-con t1 nue9 SU VOLLANCE FREQUENCY SR 3.8.4.8 Verify battery capacity is ~ 80% of the 60 months manufacturer's rating when subjected to a performance discharge test.

NOTE Qppl ic:able when battery

~

degra-datian f?r has Feaehed ~

of exj'eeted

~

12 months when battery shows degradation, or has reached 85% of the expected life with capacity < 100%

of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity

~ 100% of manufacturer's rating PERRY - UNIT 1 3.8'-27 Amendment No.

Attachment 2 Proposed Technical Specification Changes (RETYPED)

(1 Page Follows)

DC Sources-Operating IRETYPED- FOR INFORMATION ONLY I . 3.8.4 SURVEILLANCE REQUIREMENTS (conhnued)

SURVEILLANCE FREQUENCY SR 3.8.4.8 -------------------NOTE-----------------

Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is ~ 80% of the 60 months manufacturer*s*rating when subjected to a performance discharge test. AND 12 months when battery shows degradation. or has reached 85%

of the expected 1ife with capacity < 100%

of manufacturer's rating AND 24 months when battery has reached 85% of the life with capacity ::?: 100%

of manufacturer's rating PERRY - UN IT 1 3.8-27 Amendment No.

Attachment 3 Planned Technical Specification Bases Changes (PROVIDED FOR INFORMATION ONLY)

(3 Pages Follow)

PROVIDED FOR INFORMATION ONLY DC Sources - Operating (Planned BASES changes are indicated)

B 3.8.4 BASES SURVEILLANCE SR 3.B.4.8 REQUIREMENTS (continued) A battery performance test is a test of constant current capacity of a battery, normally done in the as found condition. 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.

The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 8) and IEEE-485 (Ref. 11). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80% shows that the battery rate of deterioration is i ncrea s i ng . even if there i s amp l ..,..llW!Wi.,..llW..~ililliM...,.,....,._.....,.

load requirements. INSERT 'A' (see next page)

The Surveil e Freguency for this test is normally 60 months.

• degradatiaR, or if the battery has reaehed 85% of its expeeted Hfe. Degradati an h i ridi eated. accoreli 119 to IEEE*450 ER~f. 8). w"1eA the battery eapaeity Elre19s tflOre tfiar;

. 10% of Fated eapaeity frem it~ 19rev*iet13 15ef'formaflce test. of' i:s belew 90% of the maflttfaeturer's ratirig. fftese Frequenfie5 are ba5ed on the reeemmendatiofls ifl IEEE 459 fRef. 8~. The 60 meflth test is taken directly from the IEEE reealftffiel"ldeel s1:1r*veillance inte1 V1al. The 18 meMt~ iflter*val lias been the e~f)re*o'eel irite1 val sinee iliitia1 lieeRsi 1'1§ dl9el meets t1'1e i fiteflt of the IEEE to 15erform the test et a redtieed test iAterval when battery de~radatiM or bettay aging reaches the predetermined 1 imit~ di3eussed abo~e.

REFERENCES 1. 10 CFR 50. Appendix A, GDC 17.

2. Regulatory Guide 1.6, March 10. 1971.

3. IEEE Standard 308, 1978.

4. USAR. Section 8.3.2.

5. USAR. Chapter 6.

6. USAR, Chapter 15.

7. Regulatory Guide 1.93. December 1974.

8. IEEE Standard 450. 1995.

(continued)

PERRY - UNIT 1 B3.8-58 Revision No. 4

INSERT 'A' If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is< 100% of the manufacturer's 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 manufacturer's rating. 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. All these Frequencies are consistent with the recommendations in IEEE-450 (Ref. 8).

This SR is modified by a Note. Credit may be taken for unplanned events that satisfy this SR. This note is provided to prevent unnecessary cycling of plant equipment.

PROVIDED FOR INFORMATION ONLY pc Sources -Operating (This page provided for context)

B 3.8.4 BASES

. REFERENCES 9. Regulatory G4ide 1.32. February, 1~77.

• rc::onnnued)

10. Regulatory Gµide 1.129. Decemt:i~r ,1~74.

11. IEEE Standard 485.

PERRY - UNIT 1 Revision No. 1