Text

License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360
	ML17355A019
Person / Time
Site:	Perry
Issue date:	12/20/2017
From:	Hamilton D; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-17-247
	Download: ML17355A019 (93)
	v • d • e

FENOC Perry Nuclear Power Plant P.O. Box 97 10 Center Road first Elc E/ I\nrcraar @!ry Corrtpry Perry, Ohio 44081 David B. Hamilton 440-280-5382 Vice Prcsident Fax: 440-280-8029 December 20, 2017 L-17-247 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 License Amendment Request for Adoption of Technical Snecifications Task Force ffSTn Traveler TSTF-500, Revision 2. " Electrical Rewrite - Uodate to TSTF-360" ln accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, FirstEnergy Nuclear Operating Company (FENOC) is submitting a request for an amendment to the Perry Nuclear Power Plant Technical Specifications (TSs) to incorporate the NRC-approved TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360."

Enclosure A provides a description and assessment of the proposed changes including the requested confirmation of applicability and plant-specific verifications; technical analysis; regulatory analysis; environmental considerations; summary of the required Updated Safety Analysis Report (USAR) descriptions; markup pages of existing TSs and TS Bases; and the revised (clean) TS pages. Enclosure B provides several battery manufacturer letters regarding float current monitoring.

FENOC requests approval of the proposed license amendment by December 31, 2018, with the amendment being implemented within 75 days.

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

Perry Nuclear Power PIant L-17-247 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on December Zo_,2017.

Sincerely, David B. Hamilton

Enclosures:

A. Evaluation of Proposed License Amendment B. Letters from Battery Manufacturers Verifying the Acceptability of Using Float Current Monitoring CC: NRC Region lll Administrator NRC Resident lnspector NRC Prolect Manager Branch Chief, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

EVALUATION OF PROPOSED LICENSE AMENDMENT Page1of11

Subject:

License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-36o',

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1. Applicability of TSTF-500 and Model Safety Evaluation 2.2. Verifications and Required Updated Safety Analysis Report Changes 2.3. Optional Changes and Variations 3.0 REGUI-ATORY ANALYSIS 3.1. Significant Hazards Consideration 3.2. Applicable Regulatory Requirements/Criteria

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

6.0 ATTACHMENTS

Evaluation of Proposed License Amendment Page 2 of 11

1.0 DESCRIPTION

The Technical Specification (TS) requirements are revised from requirements on battery cells to requirements on the battery. This focuses the requirements on the assumed safety function of the battery. The proposed amendment would revise TS requirements related to direct current (DC) electrical systems in TS Iimiting condition for operation (LCO) 3.8.4, "DC Sources - Operating;" LCO 3.8.5, "DC Sources - Shutdown;" and LCO 3.8.6, "Battery Cell Parameters." A new "Battery Monitoring and Maintenance Program" is being proposed for Section 5.5, "Administrative Controls - Programs and Manuals."

Specifically, the proposed changes request new actions for an inoperable battery charger and alternate battery charger testing criteria for LCO 3.8.4, "DC Sources -

DC Operatiflg," and LCO 3.8.5, Sources - Shutdown." The proposed changes also include the relocation of a number of Surveillance Requirements (SRs) in TS 3.8.4 and TS 3.8,5 that perform preventive maintenance on the safety-related batteries to a licensee-controlled program. lt is proposed that LCO 3.8.6, "Battery Cel! Parameters,"

is renamed "Battery Parameters," and is modified by relocating Table 3.8.6-1, "Battery Cell Parameter Requirements," to a licensee-controlled program, and that specific actions with associated Completion Times (CTs) for out-of-limits conditions for battery cell voltage, electrolyte level, and electrolyte temperature be added to TS 3.8.6. ln addition, specific SRs are being proposed for verification of these parameters.

A new program is being proposed for Section 5.5 of the Administrative Controls for the maintenance and monitoring of station batteries. The items proposed to be relocated will be contained within this program, titled the "Battery Monitoring and Maintenance Program."

The proposed changes provide new Actions for an inoperable battery charger and alternate battery charger testing criteria. ln addition, a number of SRs are relocated to licensee contro! including the monitoring of battery cell parameter requirements and performance of battery maintenance activities.

These changes are consistent with the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360" (Reference 2). The availability of this TS improvement was announced in the Federal Regisfer on September 1 ,2011 (76 FR 54510) (Reference 1), as supplemented on November 8, 2011 (76 FR 69296).

Evaluation of Proposed License Amendment Page3of11 2.A ASSESSM.ENT 2.1 Aoolicabilitv of TSTF-500 a nd Model Safetv Evaluation FirstEnergy Nuclear Operating Company (FENOC) has reviewed the model Safety Evaluation (SE) (Reference 3) referenced in the FederalRegisfer Notice of Availability published on September 1,201 1 (76 FR 54510). The review included the NRC staffs SE, as well as the supporting information provided in TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360.' As described herein, FENOC has concluded that the technical bases for the proposed changes presented in TSTF-500, Revision 2, and the model SE prepared by the NRC staff are applicable to the Perry Nuclear Power Plant (PNPP) and support incorporation of this amendment into the PNPP TS.

The PNPP TS use different numbering than the Standard TS (STS) (NUREG-1434) on which TSTF-500, Revision 2, is based. The new "Battery Monitoring and Maintenance Program" is contained in TS 5.5.16 as opposed to TS 5.5.14. These differences are editorial and do not affect the applicability of TSTF-500, Revision 2, to the PNPP TS.

The PNPP DC system is similar to the system described in TSTF-500, with respect to its ability to meet the duty cycle assumed in the accident analyses and with its operations in the float and equalize modes. However, the PNPP 125 VDC CIass 1E electrical power system consists of a combined Unit 1 and Unit 2 system, each separated into three independent Class 1E DC electrical power subsystems per unit.

Following is a brief description of the PNPP system.

General

Description:

Class 1E. Division 1 and 2 Direct Current Svstems The CIass 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. ln 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 eitherthe Unit 1 or Unit 2, Class 1 E, 12S-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 during normal operating conditions. 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. lf 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.

Evaluation of Proposed License Amendment Page4of11 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 17 years.

General Descriotion: Class 1E. D ivis ion 3 Direct Current S vstem The Class 1 E, 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. ln 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, 12S-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. lf the DC batteries are the only applicable 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.

The PNPP TS differfrom the Standard TS (STS) (NUREG-1 434) which werethe basis for TSTF-500, Revision 2, in the following ways:

1. The PNPP Division 1,2, and 3 batteries have different required currents for determining that their respective batteries are charged. Therefore, the proposed PNPP SR 3.8.4.2 is divided into a requirement for Divisions 1 and 2 and a separate requirement for Division 3. PNPP SR 3.8.4.2 includes the following additional language to address Division 3 surveillance requirements, "and each required Division 3 battery charger supplies > 50 amps at > 125 V for E 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ." This additional surveillance action is in the current technical specifications and does not affect the applicability of the published model SE.

2. The PNPP was designed with qualified Unit 1 and Unit 2 class 1E, safety related batteries, and has the ability to tie in the Unit 2 batteries to their respective Unit 1 buses. Based on the operational flexibility of having both Unit 1 and Unit 2 batteries, required battery and/or charger testing does not require declaring a division inoperable, and does not require entry into an LCO action statement. Therefore, the standard technical specification note, which states battery load testing cannot be

Evaluation of Proposed License Amendment Page 5 of 11 completed with the plant in Modes 1 , 2, or 3, does not apply to the PNPP. Battery load testing is possible in all plant operating modes if there exists a fully qualified reserve that can support Unit 1 bus operability. Current PNPP surveillance requirements (SR) SR 3.8.4.7 does not contain the Note stating that the surveillance shall not be performed in Modes 1,2, or 3. Therefore, this specification will not be modified, other than to be re-numbered. ln addition, the Note was not incorporated into SR 3.8.6.6. This does not affect the applicability of the published model SE.

3. The PNPP was designed with qualified Unit 1 and Unit 2 class 1E, safety related batteries, and has the ability to tie in the Unit 2 batteries to their respective Unit 1 buses. Based on the operational flexibility of having both Unit 1 and Unit 2 batteries, loss of one of two batteries and/or chargers on one subsystem does not require declaring a division inoperable, and therefore TS 3.8.4, "DC Sources - Operating,"

specifically Condition A was revised to state "Required" baffery charger on one subsysfem inoperable and Condition B was revised to state "Required" batteries on one subsysfem inoperable. !n addition, TS 3.8.5, "DC Sources - Shutdown" Condition A was also revised to state the "Required" battery charger on one subsysfem inoperable. Because this change does not alter the intended application of the LCO and its related Actions, the change is considered a minor variation from TSTF-500.

4. The current PNPP SR 3.8.4.7 does not include the 60-month provision for the modified performance test, which TSTF-500 removes, consequently, this spec will not be modified, other than to be re-numbered. Othenrvise, the changes to this SR are the same as the TSTF. This does not affect the applicability of the published mode! SE.

5. The proposed PNPP Actions for LCO 3.8.5 Condition B includes an action to suspend movement of recently irradiated fuel assemblies in the "fuel handling building" as well as in "primary containment." This additional action does not affect the applicability of the published model SE.

6. PNPP has implemented the Surveillance Frequency Control Program (SFCP) per the provisions of TSTF-425, and as approved by the NRC via Amendment 171. As a result, the surveillance frequencies in this submittal are listed as "ln accordance with the Surveillance Frequency Control Program," or similar language. Therefore, the SR frequencies specified in TSTF-500, Revision 2, "DC Electrical Rewrite Update to TSTF-360" will be incorporated into the PNPP SFCP upon implementation of the proposed amendment. ln the current PNPP TS, the surveillances that verify battery terminal voltage, charger function, battery capacity, electrolyte level and temperature, specific gravity (which, per procedure, includes a measurement of float current) and cell float voltage have frequencies controlled by the SFCP. Proposed frequency changes are evaluated by NEI 04-10, "Risk Informed Method for Controt of Surveillance Frequencies," Revision 1.

Evaluation of Proposed License Amendment Page6of11

7. The proposed PNPP TS pages include pages marked as "This Page lntentionally Left Blank." The TSTF does not include these pages. The proposed pages were added to maintain the PY TS page numbering structure due to the deletion of multiple Surveillance Requirements. This does not affect the applicability of the published model SE.

2.2 Verifications and Required Updated Safetv Analysis Report Changes As described in Section 4.7.1, "Verifications," in TSTF-500, FENOC provides the fol lowi ng verifi cations.

1 . Enclosure B contains letters from the manufacturers of the batteries used at the PNPP verifying the acceptability of using float current monitoring instead of specific gravity monitoring as a reliable and accurate indication of the state-of-charge of the battery and that this will hold true over the life of the battery.

2. FENOC verifies that the equipment that will be used to monitor float current under SR 3.8.6.1 will have the necessary accuracy and capabilityto measure electrical currents ln the expected range. Additionally, FENOC verifies that the minimum required procedural time to measure battery float current will be 30 seconds or as recommended by the float current measurement instrument manufacturer. This minimum float current measurement time is required to provide a more accurate battery float current reading.

3, FENOC verifies that battery room temperature is routinely monitored such that a room temperature excursion could reasonably expect to be detected and corrected prior to the average battery electrolyte temperature dropping below the minimum electrolyte temperature.

4. The cell resistance limits in existing SR 3.8.4.5 are relocated to the "Battery Monitoring and Maintenance Program." The connection resistance limit is 50 pOhm for Divisions 1 and 2, and 100 UOhm for Division 3. The resistance limits apply to the overall connection resistance and allows for normal degradation while maintaining battery operability.

5. Monitoring of battery parameters (that is, specific gravity, electrolyte level, cell temperature, float voltage, connection resistance, and physical condition) will be relocated to the licensee-controlled program, required and described in TS Section 5.5, "Programs and Manuals," and titled the "Battery Monitoring and Maintenance Program."

6. FENOC verifies that plant procedures will require verification of the selection of the pilot cell or cells when performing SR 3.8.6.5.

Evaluation of Proposed License Amendment Page 7 of 11 As described in Attachment 1, "List of Required Updated Analysis Report (USAR)

Descriptions," FENOC will revise the USAR to include the following, as part of the adoption of TSTF-500, Revision 2:

1 . How a 15 percent design margin for the batteries corresponds to a 2 amp float current value indicating that the battery is 92 percent charged for Division 1, 96 percent charged for Division 2, and 95 percent charged for Division 3.

2. How long term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer.

3. How the batteries are sized with correction margins that include temperature and aging and how these margins are maintained.

4. The minimum established design limit for battery terminal float voltage.

5. The minimum established design limit for electrolyte Ievel.

6. The minimum established design limit for electrolyte temperature.

7. How each battery is designed with additional capacity above that required by the design duty cycles to allow for temperature variations and other factors.

8. Normal DC system operation i.e., powered from the battery chargers with the batteries floating on the system, and with a loss of normal power to the battery charger.

2.3 Optiona! Chanqes and Variations FENOC is not proposing any variations or deviations from the TS changes described in the TSTF-500, Revision 2, or the applicable parts of the NRC staffs model SE referenced in the Federal Regrsferon September 1,2011 (76 FR 54510).

3.0 REGULATORY ANALYSIS

3.1 SionificantHazardsConsideration FENOC has evaluated the proposed changes to the Technical Specifications (TS) using the criteria in Section 50.92 to Title 10 of the Code of Federal Regulations (10 CFR) and has determined that the proposed changes do not involve a significant hazards consideration.

The proposed amendment would revise TS requirements related to direct current (DC) electrical systems in TS limiting condition for operation (LCO) 3.8.4, "DC Sources -

Operatihg," LCO 3.8.5, "DC Sources - Shutdowfl," and LCO 3.8.6, "Battery Parameters."

Evaluation of Proposed License Amendment Page8of11 A new "Battery Monitoring and Maintenance Program" is being proposed for TS 5.5 "Administrative Controls - Programs and Manuals."

Basis for proposed no significant hazards consideration determination: As required by 10 CFR 50.91(a), the FENOC analysis of the issue of no significant hazards consideration is presented below:

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

Response: No.

The proposed changes restructure the Technical Specifications (TS) for the direct current (DC) electrical power system and are consistent with TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360.. The proposed changes modify TS Actions relating to battery and battery charger inoperability. The DC electrical power system, including associated battery chargers, is not an initiator of any accident sequence analyzed in the Updated Safety Analysis Report (USAR). Rather, the DC electrical power system supports equipment used to mitigate accidents. The proposed changes to restructure TS and change surveillances for batteries and chargers to incorporate the updates included in TSTF-500, Revision 2, will maintain the same level of equipment performance required for mitigating accidents assumed in the USAR. Operation in accordance with the proposed TS would ensure that the DC electrical power system is capable of performing its specified safety function as described in the USAR. Therefore, the mitigating functions supported by the DC electrical power system will continue to provide the protection assumed by the analysis. The relocation of preventive maintenance surveillances, and certain operating limits and actions, to a licensee-controlled battery monitoring and maintenance program will not challenge the ability of the DC electrical power system to perform its design function. Appropriate monitoring and maintenance that are consistent with industry standards will continue to be performed. ln addition, the DC electrical power system is within the scope of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," which will ensure the control of maintenance activities associated with the DC electrical power system.

The integrity of fission product barriers, plant configuration, and operating procedures as described in the USAR will not be affected by the proposed changes.

Therefore, the consequences of previously analyzed accidents will not increase by implementing these changes. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

Evaluation of Proposed License Amendment Page9of11

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

Response: No The proposed changes involve restructuring the TS for the DC electrical power system. The DC electrical power system, including associated battery chargers, is not an initiator to any accident sequence analyzed in the USAR. Rather, the DC electrical power system supports equipment used to mitigate accidents. The proposed changes to restructure the TS and change surveillances for batteries and chargers to incorporate the updates included in TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360," wi!! maintain the same level of equipment performance required for mitigating accidents assumed in the USAR. Administrative and mechanical controls are in place to ensure the design and operation of the DC systems continues to meet the plant design basis described in the USAR.

Therefore, operation of the facility in accordance with this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The margin of safety is established through equipment design, operating parameters, and the setpoints at which automatic actions are initiated. The equipment margins will be maintained in accordance with the plant-specific design bases as a result of the proposed changes. The proposed changes will not adversely affect operation of plant equipment. These changes will not result in a change to the setpoints at which protective actions are initiated. Sufficient DC capacity to support operation of mitigation equipment is ensured. The changes associated with the new battery maintenance and monitoring program will ensure that the station batteries are maintained in a highly reliable manner. The equipment fed by the DC electrical sources will continue to provide adequate power to safety-related loads in accordance with analysis assumptions.

TS changes made in accordance with TSTF-500, Revision 2, "DC Electrical Rewrite

- Update to TSTF-360," maintain the same level of equipment performance stated in the USAR and the current TSs. Therefore, the proposed changes do not involve a significant reduction of safety.

Based on the 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.

Evaluation of Proposed License Amendment Page 10 of 1 1 3.2 Applicable Regulatorv Requirements/Criteria FENOC has reviewed the NRC staffs model SE referenced in the Notice of Availability and concluded that the Regulatory Evaluation section is applicable to PNPP. The PNPP is committed to different Regulatory Guide (RG) 1.32 and 1.75 revisions than those referenced in the Regulatory Evaluation section in the model SE as described below.

a The model SE refers to Revision 3 of RG 1 .32, "Criteria for Power Systems for Nuclear Power Plants." However, as described in USAR Section 1.8 and TS Bases 3.8.4, PNPP is committed to RG 1.32, Revision 2 (February 1977).

I The model SE refers to Revision 3 of RG 1.75, "Criteria for Independence of Electrical Safety Systems." However, as described in USAR Section 1.8, PNPP is committed to Revision 2 of RG 1.75 (September 1978), "Physica!

Independence of Electrical Systems," with clarifications and/or exceptions.

FENOC concluded these differences do not result in any needed changes for adoption of TSTF-500, Revision 2 at the PNPP and do not affect the applicability of the NRC staff model SE.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed TS change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed TS change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(cxg). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed TS change.

5.0 REFERENCES

1 . Federal Regrsfer Notice of Availability of Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-500, Revision 2, DC Electrical Rewrite - Update to ISIF 360 (77 FR 545410, September 1 , 2011)

2. Technical Specifications Task Force Traveler TSTF-500 Revision 2 (Accession No. ML0926702421

3. Model Application and Safety Evaluation for Plant-Specific Adoption of TSTF-500, Revision 2 (Accession No. ML111751792)

Evaluation of Proposed License Amendment Page11of11 6.0 ATTACHMENTS

1. List of Required Updated Safety Analysis Report (USAR) Descriptions

2. Proposed Technical Specification Changes (Mark-Up)

3. Proposed Technical Specification Changes (Retyped)

4. Proposed Technical Specification Bases Changes (Mark-Up)

Attachment 1 Evaluation of Proposed License Amendment List of Required Updated Safety Analysis Report (USAR) Descriptions (1 Page Follows)

ATTACHMENT 1 LIST OF REQUIRED UPDATED SAFETY ANALYSIS REPORT (USAR)

DESCRIPTIONS The following table identified USAR descriptions required by FENOC as part of the adoption of TSTF-500, Revision 2.

REQUIRED USAR DESCRIPTIONS FENOC will change or DUE VE that the USAR: DATE/EVENT 1 . Describes how a 15 percent design margin for the batteries Upon corresponds to a 2 amp float current value indicating that the implementation of battery is 92 percent charged for Division 1, 96 percent the approved charged for Division 2, and 95 percent charged for Division 3. Technical Specification

2. States that the long term battery performance is supported by amendment maintaining float voltage greater than or equal to the (applies to all) minimum established design Iimits provided by the battery manufacturer, which corresponds to 2.21 V per connected cell and that there are 61 connected cells in the battery, which corresponds to 135 V at the battery terminals for Division 1, and 2.25 V per connected cell and that there are 60 connected cells in the battery, which corresponds to 135 V at the battery terminals for Divisions 2 and 3,

3. Describes how the batteries are sized with correction margins that include temperature and aging and how these margins are maintained.

4. States the minimum established design limit for battery terminal float voltage.

5. States the minimum established design limit for electrolyte level.

6. States the minimum established design limit for electrolyte temperature.

7. Describes how each battery is designed with additional capacity above that required by the design duty cycles to allow for temperature variations and other factors.

B. Describes normal DC system operation (i.e. powered from the battery chargers) with the batteries floating on the system, and a loss of normal power to the battery charger describing how the DC load is automatically powered from the station batteries.

Attachment 2 Evaluation of Proposed License Amendment Proposed Technical Specification Changes (Mark-Up)

(23 Pages Follow)

TEC H N ICAL SPECIFICATION MARK-UP DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The Division 1, Division 2, and Division 3 DC electrical power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Divisien 1 er 2 DC A.1 Restere Divisien 1 and 2 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months subsys,tem

+@ sta+u+. Restore batterv battery charger on one terminal voltage to oreater subsvstem i noperable. than or equal to the minimum established float voltage.

AND 4.2 Verifv battery float current Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

{ 2 amps.

AND A.3 Restore batterv charqer to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

B. Divisien 3 DC eleetrieel 8.1

@ +@

battery on one battery to OPERABLE subsvstem in operable status.

c.@ c.1 ffi 12 heure

@ie++

AdHg or 2 DC electrical power subsvstem inoperable for 3*eur+2 hours Divisionland2DC PERRY - UNIT 1 3.8-24 Amendment No.69 I

TECHN IGAL SPECIFICATION MARK.UP DC Sources - Operating 3.8.4 CONDITION REQUIRED ACTION COMPLETION TIME reasons other than electrical power Condition A or B. subsystems to OPERABLE status.

(continued)

PERRY - UNIT 1 3.8-25 Amendment No. 68

TEC H NICAL SPECIFICATION MARK.UP DC Sources - Operating 3.8.4 ACTI N CONDITION REQUIRED ACTION COMPLETION TIME D. Division 3 DC electrical D.1 Declare High Pressure Core lmmediatelv power subsystem Sprav Svstem lnoperable.

inoperable.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months PERRY - UNIT 1 3.8-24a Amendment No.

TEC H N ICAL SPECIFICATION MARK.UP DC Sources - Operating 3.8.4 SURVEI LLANCE REQU IREMENTS SURVEILLANCE FREQUENCY sR 3.8.4.1 Verify battery terminal voltage i# ln accordance qreater than or equal to the minimum with the established fl oat voltaqe. Surveillance Frequency Gontrol Program sR 3.8.4.2 Verifv each required Division 1 and 2 batterv ln accordance charger supplies > 400 amps at > 125 V for > I with the hours, and each required Division 3 batterv charqer Surveillance supplies > 50 amps at > 125V for > I hours. Frequency Control Program OR Verifv each batterv charqer can recharqe the batterv to the fully charqed state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplvino the Iargest combined demands of the va.fipus.gontinuous steadv state loads. after a batterv discharge to the boundino design basis event discharge state.

Verify ne visible eerresien at battery terminals and eenneeters, is

{ 5,0 E 5 ehm fer intr eell eennec+iens;

{ 5=0 E 5 ehm fer inter raek eenneetiens;

{ 5.0 E 5 ehm fer inter tier eenneetien+

5 5,0 E 5 ehm fer terminal eenneetiens;

{ 1,0 ,E 4 ehm fer inter eell eenneetiens;

{ 1,0 E 1 ehm fer inter raek eenneetienei 4 1,0 E 4 ehm fer inter tier eenneetiens; 4 1,0 E 4 ehm fer terminal eenneetiens; fer Div 3, sR 3.8.4.3 .NOTE.

The modified performance discharge test in SR 3.8.6.6 mav be performed in lieu of SR 3.8.4.3..

PERRY - UNIT 1 3.8-25 Amendment No. 171

TECH N ICAL SPECIFICATION MARK.UP DC Sources - Operating 3.8.4 SURVEILLANCE FREQUENCY Verifv batterv canacitv is adeouate to suoplv. and ln accordance maintain in OPERABLE status. the required with the emeroencv Ioads for the desiqn dutv cvcle when Surveillance subjected to a batterv service test. Frequency Verify battery eells; eell plates' and raeks shew ne visual indieatien ef Control Program physieal damege er a SR 3,8, L l -- . Remeve visible eerresien, and verify battery eell te with the eerresien material, Surveillanee freg+rency

{n+in+red}

SURVEITTANEE FRESUENCY SR 3.8,1,5 Verify battery eenneetien resistanee is with the

< 5,0 E 5 ehrnjer inter eell cennectisns;

{ 5,0 E 5 ehm fer inter raek eenneetiens, frcq+teney 4 5,0 E 5 ehm fer inter tier eenneetiens; @

{ 5,0 E 5 ehm fer terminal eenneetiens; fer Div 1 and Div 2

+HC

{ 1,0 E I ehm fer inter eell eenneetiene;

' { 10 E 1 ehm fer inter raek eenneetiens,

{ 1=0 E 1 ehm fer inter tier eenneetien+

4 1,0 E { ehm fer terminal eenneetiens fer Div 3, SR 3,8, 1,6 Verify eaeh required Divisien 1 and 2 battery with the Su1ryeiilne freq+teney SR 3,8, 1,8 may be perfermed in Iieu ef SR 3,8, 1.7, Verify battery eapaeity is adequate te supply' and with the PERRY - UNIT 1 3.8-25 Amendment No. 171

TEG H N IGAL SPECIFICATION MARK.UP DC Sources - Operating 3.8.4 SURVEITTANCE FREQUENCY emergeney leads fer the design duty eyele when Surveillanee frequeney SURVEITTANCE FREQUENCY Credit may be taken fer unBlanned events that ffi ln aeeerdanee Surveillanee frequeney ANE 12 menths when bettery-how has reaehed 85%

< 100% ef manufaeturer's Fating ANE ffi ga+eefhas reaehed 85% ef ut*n+apaeity

+4g%+f manufaeturer's rattflg PERRY - UNIT 1 3.8-27 Amendment No. 171 I

TECHNIGAL SPECIFICATION MARK.UP DC Sources - Operating 3.8.4 THIS PAGE INTENTIONALLY LEFT BLANK PERRY - UNIT 1 3.8-26 Amendment No. 171

TECH N ICAL SPECIFICATION MARK.UP DC Sources - Operating 3.8.4 THIS PAGE INTENTIONALLY LEFT BLANK PERRY - UNIT 1 3.8-27 Amendment No. 171 I

TEC H N ICAL SPECIFICATION PROVIDED FOR GONTEXT DC Sources - Shutdown

. NO GHANGES . 3.8.s 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 The following DC electrical power subsystems shall be OPERABLE:

a One CIass 1E DC electrical power subsystem capable of supplying one division of the Division 1 or 2 onsite Class 1E electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems - Shutdown";

b. One Class 1E battery or battery charger, other than the DC electrical power subsystem in LCO 3.8.5.a, capable of supplying the remaining Division 1 or Division 2 onsite Class 1E DC electrical power distribution subsystem when required by LCO 3.8.8; and c The Division 3 DC electrical power subsystem capable of supplying the Division 3 onsite Class 1E DG electrical power distribution subsystem, when the Division 3 onsite Class 1E DC electrical power distribution subsystem is required by LCO 3,8.8.

APPLICABILITY: MODES 4 and 5, During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building.

PERRY - UNIT 1 3.8-28 Amendment No. 102

TEG H NICAL SPEGIFICATION MARK.UP DC Sources - Shutdown 3.8.5 ACTIONS OTE LCO 3.0.3 is not applicable CONDITION REQUIRED ACTION COMPLETION TIME A. Required batterv A.1 Restore batterv terminal 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months charger on one voltage to greater than or sr.rbsytem inoperable equal to the minimum established float voltaoe.

AND AND The redundant subsyst-e_F batlgry and A.2 Verifv batterv float current Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months charqer OPERABLE. < 2 amns.

AND 4.3 Restore batterv charqer to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

(continued)

PERRY - UNIT 1 3.8-29 Amendment No.4S2

TECH N ICAL SPECIFICATION MARK.UP DC Sources - Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME EA. One or more required DC EA.1 Declare affected required lmmediately electrical power feature(s) inoperable.

subsystems i noperable.

OR 84.2.1 Suspend CORE lmmediately ALTERATIONS.

AND g*.2.2 Suspend movement of lmmediately recently irradiated fuel assemblies in the primary containment and fuel handling building.

AND E4.2.3 lnitiate action to suspend lmmediately operations with a potential for draining the reactor vessel.

AND 84.2.4 lnitiate action to restore lmmediately required DC electrical power subsystems to OPERABLE status.

PERRY - UNIT 1 3.8-29a Amendment No.

TECHN ICAL SPECIFICATION MARK.UP DC Sources - Shutdown 3.8.5 SURVEI LLANCE REQUIREMENTS SURVEILLANCE FREQUENCY sR 3.8.5.1 The following SRs are not required to be performed:

sR 3,8,,1,4; SR 3,8,4,6i SR 3,8,4,7; and SR ln accordance For DC sources required to be OPERABLE, the with applicable following SRs are applicable: SRs sR 3.8.4.1 sR 3,8, 1,4 SR 3,8, 1,7 sR 3.8.4.2 sR 3,8,,1 ,5 SR 3,8, 1,8 sR 3.8.4.3 sR 3,8, 1,6 PERRY - UNIT 1 3.8-30 Amendment No. 85

TEC HN IGAL SPECIFIGATION MARK.UP Battery GellParameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery CellParameters LCO 3.8.6 Batteryeell parameters for the Division 1, 2, and 3 electrical power subsvstems batteries shall be within Iimits.

APPLICABILITY: U/hen associated DC electrical power subsystems are required to be OPERABLE.

ACTIONS Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME A, One or twomere batteries 4.1 4-hesr! frours

+n meet Table 3,8,6-1 TahlaeQe4l^a$aaaarA r sprv v.v.v . vgfvYvr, , r

@ sR 3.8.4.1 subsvstem with one or more batterv cell float AND voltaqe < 2.07 V.

4.2 W 24+u+s2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months T^1-l^ e O A'l /+^*^^^^, l^

r qvrv vrv.v r vufvvvr J v AND l+m+t+Perform SR 3.8.61 AND A.3 Restore bettery+ell pa{Paete+s-te voltaqe > 2.07 V.

(continued)

PERRY - UNIT 1 3.8-32 Amendment No. {80

TEC H N ICAL SPECIFICATION MARK.UP Battery GellParameters 3.8.6 ACTIONS conti CONDITION REQUIRED ACTION COMPLETION TIME B.@ 8.1 rform SR Time ef Cenditien A net 3.8.4.1 ffi+

AND

---R 8,2 Restore batterv float 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months One er mere batteries currentto 5 2 amps.

- 77."F, 4

One er mere batteries in fi#i++One or two batteries on one subsvstem with float current > 2 amps.

c. ------------N NOTE Required Action C.2 shall Required Actions C.1 and C.2 are be completed if onlv applicable if electrolvte level electrolvte level was was below the top of plates.

below the top of the plates.

One or two batteries on C.1 Restore eleqtrolvte level to I hours one subsvstem with ong above top of plates.

or more cells electrolvte level less than minimum AND established design limits.

C.2 Verifv no evidence of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months leakaoe.

AND C.3 Restore electrolvte level to 31 davs qreater than or equal to PERRY - UNIT 1 3.8-33 Amendment No. 171 I

TEGHN ICAL SPECIFICATION MARK.UP Battery CellParameters 3.8.6 mlntm m established desiqn limits D. One or two batteries on D.1 Restore batterv pilot cell 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months one subsvstem with pilot temperature to greater cell electrolvte than or equal to minimum temperature Iess than established design limits.

minimum established desiqn limits.

E. One or more batteries in E.1 Restore batterv 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months redundant subsystems parameters for batteries in with batterv narameters one subsystem to within not within limits. limits.

(continued)

PERRY - UNIT 1 3.8-34 Amendment No. 171

TEC H N ICAL SPECIFICATION MARK.UP Battery CellParameters 3.8.6 ACTI N COND!TION REQUIRED ACTION COMPLETION TIME F. Required Action and F.1 Declare associated batterv lmmediatelv assqqieted Completion inoperable.

Time of Condition A, B.

C D or E not met OR One or two batteries on one subsvstem with one or more batterv cells float voltaqe < 2.OT V and float current > 2 amps.

SURVEILLANCE REQUI REMENTS SURVEILLANCE FREQUENCY sR 3.8.6.1 OTE Not reouired to be met when batterv terminal voltaqe is less than the minimum established float voltase of SR 3.8.4.1 .

Verify battery eell pararneters meet Table 3,8,6 1 In accordance erifv each batterv float current is with the

< 2 amos. Surveillance Frequency Control Program sR 3.8.6.2 Verify battery eell parameters meet Table 3.8,6 1 In accordance with the 2.O7 V. Surveillance Frequency Control Program ANEI ffi everharge

> 1,15 V (continued)

PERRY - UNIT 1 3.8-33a Amendment No. 171

TECHNICAL SPECIFICATION MARK.UP Batte ry Cell-Para meters 3.8.6 SU RVEILLANCE REQU I REMENTS continued SURVEILLANCE FREQUENCY sR 3.8.6.3 Verify ln accordance with the connected cell electrolyte level is greater than or Surveillance equal to minimum established design limits. Frequency Control Program SR 3.8.6.4 Verifu each batterv pilot cell temperature is greater In accordance than or equal to minimum established desiqn limits. with the Surveillance Frequencv Control Proqram SR 3.8.6.5 Verifv each batterv connected to cel! float voltage is ln accordance

> 2,07 V. with the Surveillance Freouencv Control Program (continued)

PERRY - UNIT 1 3.8-34 Amendment No. 171

TEC H NICAL SPECIFICATION MARK.UP Battery ellParameters 3.8.6 SURVEILLANCE REQUI REMENTS conti SURVEILI-ANCE FREQUENCY SR 3.8.6.6 Verify batterv capabilitv is 2 80% of the ln accordance manufacturer's rating when subiected to a with the performance discharqe test or a modified Surveillance performance discharqe test. Frequencv Control Program AND 12 months when battery shows degradation. or has reached 85%

of the expected life with capacitv

< 100% of the manufacturer's ratinq AND 24 months when the battery has reached 85% of the expected life with capacitv

> 100% of the manufacturer's ratino PERRY - UNIT 1 3.8-34a Amendment No. 6S

TEGH NICAL SPECIFICATION MARK.UP Battery CellParameters 3.8.6 ffi TIMITS FOR EAGH GftTEGORY B: CATEGORY C:

DESIGNATED TIMITS FOR EACH TIMITS FOR ENCH PARNMETER PttgT cEtt ffi ffi eme*+ty+e > Minimum level > Minimum level indieatien @

tevel @ minc ffi mg+k{e}

ffiarkF) gee++dtege >+.1+I-\l > 2,07 V

=++31/

Specifie ffi =

1.195 fer Div 1 and Net more than 0=020 e+a+tt#bxe @

M A,IlEr AND eells > 1=205 fer DiY 1 and n"eregffl Div 2; 1,200 fer Eiv 3 M

=

ffi W

Di+g (a) tt rs aeeeptaU (b) eerreeted fer eleetrelyte temFerature and level, tevel eerreetien is net required; (e) A battery eharging cHrrent f < 2 amBs whefl en fleet Gharge i$ acceptable fer meeting PERRY - UNIT 1 3.8-34a Amendment No. 68 I

TECH NICAL SPECIFICATION MARK.UP Battery CellParameters 3.8.6 THIS PAGE INTENTIONALLY LEFT BLANK PERRY - UNIT 1 3.8-35 Amendment No. 69 I

TEG H N ICAL SPEGIFICATION MARK.UP Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.15 Surveillance Frequencv Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a The Surveillance Frequency Control Program shall contain a Iist of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 14-1O, "Risked - Informed Method for Control of Surveillance Frequencies." Revision 1

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

5.5.16 Batterv Monitorin o and Maintenance Prooram This Program provides controls for batterv restoration and maintenance. The nrnflrem shal he in accordance with IEEE Sta n rlarrl lstrl'l 4F.nJfin) .ltrtrtr Recommended Practice for Maintenance, Testino. and Replacement of YFnted Lead-Acid Batteries for Stationarv lications," as endorsed bv Requlatorv Guide 1.129. Revision 2 (RG). with RG exceptions and prosram provisions as identified below:

a The orooram allows for the fol nq RG 1.129. Revision 2 excentions:

1. Batterv temoerature correctio mav be performed before or after conducting discharge tests.

2. RG 1 .129. Reoulatorv Position 1, Subsection 2, "References." is not applicable to this proqram.

3. ln lieu of RG 1 129. Reoulatorv Position 2. Subsection 5.2. 'lnsoections."

the following shall be used: "Where reference is made to the pilot ceil,.

oilot cell selection shall be based on the lowest voltaoe cell in the batterv."

(continued)

PERRY - UNIT 1 5.0-15d Amendment No. 171 I

TECH N ICAL SPECIFIGATION MARK.UP Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.16 Batterv Monitorinq and Maintenance Proqram (continued)

4. ln Reoulatorv Guide 1.129. Reoulatorv Position 3. Subsection 5.4.1.

"State of Charoe lndicator." the followino statements in Daraoraph (d) mav be omitted: "Ut'hen it has been recorded that the charqinq current has stabilized at the charqinq voltaqe for three consecutive hourlv measurements, the batterv is near full charqe. These measurements shall be made after the initiallv hiqh charoinq current decreases sharplv and the batterv voltage rises to approach the charger output voltaoe."

5. In f ieu of RG 1.129, Requlatorv Position 7, Subsection 7.6, "Restoration,"

the following may be used: "Followino the test. record the float voltage of each cell of the stfinq,"

b. The prosram shall include the followinq provisions:

1. Actions to restore batterv cells with float voltaoe < 2.13 V:

2. Actions to determine whether the float voltase of the remaininq batterv cells is 2 2.13 V when the float voltaqe of a battery cell has been found to be < 2.13 V:

3. Actions to equalize and test batterv cells that had been discovered with electrolvte Ievel below the too of the nlates,

4. Limits on averaqe electrolyte temperature. battery connection resistance.

and battery terminal voltaqe: and

5. A reouirement to obtain specific qravitv readinqs of all cells at each d sch a rqe test. co nsiste nt,with. mg n ufa,plu ref rqqgm me n d gti o n s.

i PERRY - UNIT 1 5.0-15e Amendment No.

Attachment 3 Evaluation of Proposed License Amendment Proposed Technical Specification Changes (Re-Typed)

[Provided for Information Only]

(17 Pages Follow)

TEGHNICAL SPECIFICATION INFORMATION ONLY DC Sources - Operating GLEAN, RETYPED PAGE 3.8_4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The Division 1, Division 2, and Division 3 DC electrical power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1,2, and 3.

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

AND 4.2 Verify battery float current Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

< 2 amps.

AND A.3 Restore battery charger to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

B. Required battery on 8.1 Restore battery to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months one subsystem OPERABLE status.

inoperable.

C. Division 1 or 2 DC c.1 Restore Division 1 and 2 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power DC electrical power subsystem inoperable for subsystems to OPERABLE reasons other than status.

Condition A or B.

(continued)

PERRY - UNIT 1 3.8-24 Amendment No.

TECH N ICAL SPECIFICATION INFORMATION ONLY DC Sources - Operating CLEAN, RETYPED PAGE 3.8.4 ACTIONS continued CONDITION REQUIRED ACTION COMPLETION TIME D. Division 3 DC electrical D.1 Declare High Pressure Core lmmediately power subsystem Spray System lnoperable.

inoperable.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months PERRY - UNIT 1 3.8-24a Amendment No.

TEC H N ICAL SPEGIFICATION INFORMATION ONLY DC Sources - Operating CLEAN, RETYPED PAGE 3.8.4 SURVEI LLANCE REQUIREMENTS SURVEILLANCE FREQUENCY sR 3.8.4.1 Verify battery terminal voltage is greater than or ln accordance equal to the minimum established float voltage. with the Surveillance Frequency Control Program sR 3.8.4.2 Verify each required Division 1 and 2 battery ln accordance charger supplies > 400 amps at > 125 V for > 8 with the hours; and each required Division 3 battery charger Surveillance supplies > 50 amps at E 125 V for > I hours. Frequency Control Program OR Verify each battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

sR 3.8.4.3 The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.

Verify battery capacity is adequate to supply, and ln accordance maintain in OPERABLE status, the required with the emergency Ioads for the design duty cycle when Surveillance subjected to a battery service test. Frequency Control Program PERRY - UNIT 1 3.8-25 Amendment No.

TECHNICAL SPECIFIGATION INFORMATION ONLY DC Sources - Operating CLEAN, RETYPED PAGE 3.8.4 THIS PAGE INTENTIONALLY LEFT BI.ANK PERRY - UNIT 1 3.8-26 Amendment No.

TEC H N ICAL SPECIFICATION INFORMATION ONLY DC Sources - Operating CLEAN, RETYPED PAGE 3.8.4 THIS PAGE INTENTIONALLY LEFT BLANK PERRY - UNIT 1 3.8-27 Amendment No.

TEGHN ICAL SPECIFICATION PROVIDED FOR CONTEXT DC Sources - Shutdown

. NO GHANGES - 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 The following DC electrical power subsystems shall be OPERABLE:

CT One Class 1E DC electrical power subsystem capable of supplying one division of the Division 1 or 2 onsite Class 1E electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems - Shutdown";

b. One Class 1E battery or battery charger, other than the DC electrical power subsystem in LCO 3.8.5.a, capable of supplying the remaining Division 1 or Division 2 onsite Class 1E DC electrical power distribution subsystem when required by LCO 3.8.8; and C. The Division 3 DC electrical power subsystem capable of supplying the Division 3 onsite Class 1E DC electrical power distribution subsystem, when the Division 3 onsite Class 1E DC electrical power distribution subsystem is required by LCO 3.8.8.

APPLICABILITY: MODES 4 and 5, During movement of recently irradiated fuel assemblies in the primary containment or fuel handling building.

PERRY - UNIT 1 3.8-28 Amendment No. 102

TECH NICAL SPECIFICATION INFORMATION ONLY DC Sources - Shutdown CLEAN, RETYPED PAGE 3.8.5 ACTIONS LCO 3.0.3 is not applicable CONDITION REQUIRED ACTION COMPLETION TIME A. Required battery A.1 Restore battery terminal 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months charger on one voltage to greater than or subsystem inoperable equal to the minimum established float voltage.

AND AND 4.2 Verify battery float current Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months The redundant < 2 amps.

subsystem battery and charger OPERABLE. AND 4.3 Restore battery charger to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

(continued)

PERRY - UNIT 1 3.8-29 Amendment No. I

TECHN ICAL SPECIFICATION INFORMATION ONLY DC Sources - Shutdown CLEAN, RETYPED PAGE 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required DC 8.1 Declare affected required lmmediately electrical power feature(s) inoperable.

subsystems inoperable.

OR 8.2.1 Suspend CORE lmmediately ALTERATIONS.

AND 8.2.2 Suspend movement of lmmediately recently irradiated fuel assemblies in the primary containment and fuel handling building.

AND 8.2.3 Initiate action to suspend lmmediately operations with a potential for draining the reactor vessel.

AND 8.2.4 lnitiate action to restore lmmediately required DC electrical power subsystems to OPERABLE status.

PERRY - UNIT 1 3.8-29a Amendment No.

TECH N ICAL SPECIFIGATION INFORMATION ONLY DC Sources - Shutdown CLEAN, RETYPED PAGE 3.8.5 SU RVEILLANCE REQU !REMENTS SURVEILLANCE FREQUENCY sR 3.8.5.1 The following SRs are not required to be performed:

SR 3.8.4.2 and SR 3.8.4.3 For DC sources required to be OPERABLE, the ln accordance following SRs are applicable: with applicable SRs sR 3.8.4.1 sR 3.8.4.2 sR 3.8.4.3 PERRY - UNIT 1 3.8-30 Amendment No. I

TEC H N IGAL SPECIFICATION INFORMATION ONLY CLEAN, RETYPED PAGE Battery Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters LGO 3.8.6 Battery parameters for the Division 1, 2, and 3 electrical power subsystems batteries shall be within Iimits.

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

ACTIONS Separate Condition entry is allowed for each battery CONDITION REQUIRED ACTION COMPLETION TIME A. One or two batteries on 4.1 Perform SR 3.8.4.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months one subsystem with one or more battery cell float AND voltage < 2.07 V.

4.2 Perform SR 3.8.6.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND 4.3 Restore affected cell 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months voltage > 2.07 V.

(continued)

PERRY - UNIT 1 3.8-32 Amendment No

TECH N IGAL SPECIFICATION INFORMATION ONLY CLEAN, RETYPED PAGE Battery Parameters 3.8.6 ACTIONS contin CONDITION REQUIRED ACTION COMPLETION TIME B. One or two batteries on 8.1 Perform SR 3.8.4.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months one subsystem with float current > 2 amps. AND 8.2 Restore battery float 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months currentto<2amps.

C. -NOTE--

Required Action C.2 shall Required Actions C.1 and C.2 are be completed if only applicable if electrolyte level electrolyte level was was below the top of plates.

below the top of the plates.

One or two batteries on c.1 Restore electrolyte level to I hours one subsystem with one above top of plates.

or more cells electrolyte Ievel less than minimum AND established design limits.

c.2 Verifo no evidence of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months leakage.

AND c.3 Restore electrolyte level to 31 days greater than or equal to minimum established design limits.

D. One or two batteries on D.1 Restore battery pilot cell 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months one subsystem with pilot temperature to greater cell electrolyte than or equal to minimum temperature less than established design limits.

minimum established design limits.

E. One or more batteries in E.1 Restore battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months redundant subsystems parameters for batteries in with battery parameters one subsystem to within not within limits. limits.

(continued)

PERRY - UNIT 1 3.8-33 Amendment No.

TEGHNICAL SPECIFICATION INFORMATION ONLY Battery Parameters GLEAN, RETYPED PAGE 3.8.6 ACTIONS contin CONDIT!ON REQUIRED ACTION COMPLETION TIME F. Required Action and F.1 Declare associated battery lmmediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met, OR One or two batteries on one subsystem with one or more battery cells float voltage < 2.OT V and float current > 2 amps.

SURVEILLANCE REQUI REMENTS SURVEILI.ANCE FREQUENCY sR 3,8.6.1 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. In accordance with the Surveillance Frequency Control Program SR 3.8.6.2 Verify each battery pilot cell voltage is > 2.07 V. In accordance with the Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.8-33a Amendment No.

TEC H NICAL SPEGIFICATION INFORMATION ONLY CLEAN, RETYPED PAGE Battery Parameters 3.8.6 SURVEI LLANCE REQUIREMENTS contin SURVEILLANCE FREQUENCY sR 3.8.6.3 Verify each battery connected cell electrolyte Ievel is ln accordance greater than or equal to minimum established design with the limits. Surueillance Frequency Control Program sR 3.8.6.4 Verify each battery pilot cell temperature is greater ln accordance than or equal to minimum established design limits. with the Surveillance Frequency Control Program sR 3.8.6.5 Verify each battery connected to cell float voltage is ln accordance

> 2.07 V. with the Surveillance Frequency Control Program (continued)

PERRY - UNIT 1 3.8-34 Amendment No

TECH N ICAL SPEGIFICATION INFORMATION ONLY CLEAN, RETYPED PAGE Battery Parameters 3.8.6 SURVEILLANCE REQU I REMENTS continued SURVEILLANCE FREQUENCY sR 3.8.6.6 Verify battery capability is > 80% of the ln accordance manufacturer's rating when subjected to a with the performance discharge test or a modified Surveillance performance d ischarge test. Frequency Control Program AND 12 months when battery shows degradation, or has reached 85%

of the expected Iife with capacity

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

> 100% of the manufacturer's rating PERRY - UNIT 1 3.8-34a Amendment No

TEG HN ICAL SPECIFICATION INFORMATION ONLY Battery Parameters CLEAN, RETYPED PAGE 3.8.6 THIS PAGE

!NTENTIONALLY LEFT BLANK PERRY - UNIT 1 3.8-35 Amendment No.

TEGHNICAL SPECIFICATION INFORMATION ONLY Programs and Manuals CLEAN, RETYPED PAGE 5.5 5.5 Programs and Manuals (continued) 5.5.15 SurveillanceFrequencvC.ontrol Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a The Surveillance Frequency Control Program shall contain a Iist of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b Changes to the Frequencies Iisted in the Surveillance Frequency Control Program shall be made in accordance with NEI 14-10, "Risked - Informed Method for Control of Surueillance Frequencies." Revision 1 C. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Gontrol Program.

5.5.16 Batterv Monitorinq and Maintenance Proqram This Program provides controls for battery restoration and maintenance. 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 (RG), with RG exceptions and program provisions as identified below:

a. The program allows for the following RG 1.129, Revision 2 exceptions:

1. Battery temperature correction may be performed before or after conducting discharge tests.

2. RG 1 .129, Regulatory Position 1 , Subsection 2, "References," is not applicable to this program.

3. !n lieu of RG 1.129, Regulatory Position 2, Subsection 5.2, "lnspections,"

the following shall be used: "lUhere reference is made to the pilot cell, pilot cell selection shall be based on the lowest voltage cell in the battery."

(continued)

PERRY _ UNIT 1 5.0-15d Amendment No.

TECH N IGAL SPECIFICATION INFORMATION ONLY Programs and Manuals GLEAN, RETYPED PAGE 5.5 5.5 Programs and Manuals (continued) 5.5.16 Battery Monitorinq and Maintenance Program (continued)

4. ln Regulatory Guide 1.129, Regulatory Position 3, Subsection 5.4.1, "State of Charge lndicator," the following statements in paragraph (d) may be omitted: "When it has been recorded that the charging current has stabilized at the charging voltage for three consecutive hourly measurements, the battery is near full charge. These measurements shall be made after the initially high charging current decreases sharply and the battery voltage rises to approach the charger output voltage."

5. ln lieu of RG 1.129, Regulatory Position 7, Subsection 7.6, "Restoration,"

the following may be used: "Following the test, record the float voltage of each cell of the string."

b. The program shall include the following provisions:

1. Actions to restore battery cells with float voltage < 2.13 V;

2. Actions to determine whether the float voltage of the remaining battery cells is > 2.13 V when the float voltage of a battery cell has been found to be < 2.13 V'

3. Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates;

4. Limits on average electrolyte temperature, battery connection resistance, and battery terminal voltage; and

5. A requirement to obtain specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations.

PERRY - UNIT 1 5.0-15e Amendment No

Attachment 4 Evaluation of Proposed License Amendment Proposed Technical Specification Bases Changes (Mark-Up)

For lnformation Only (31 Pages Follow)

TS BASES PROVIDED FOR CONTEXT DC Sources - Operating

. NO GHANGES . B 3.8.4 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.4 DC Sources - Operating BASES BACKGROUND The station DC electrical power system provides the AC emergency power system with control power. lt also provides both motive and control power to selected safety related equipment. As required by 10 CFR 50, AppendixA, GDC 17 (Ref. 1), the DC electrical powersystem is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The DC electrical power system also conforms to the requirements of Regulatory Guide 1.6 (Ref. 2) and IEEE-308 (Ref. 3).

The 125 VDC electrical power system consists of three independent Class 1E DC electrical power subsystems, Divisions 1, 2 and 3. Each subsystem consists of a battery, a battery charger, a reserve battery charger, and all the associated control equipment and interconnecting cabling. ln additions, the ability exists to tie in the Unit 2 batteries in each division to their respective Unit 1 buses.

During normal operation, the DC loads ae powered from the battery chargers with the batteries floating on the system. ln case of loss of normal power to the battery charger, the DC Ioads are automatically powered from the Engineered Safety Feature (ESF) batteries.

Each of the Division 1 and 2 electrical power subsystems provides the control power for its associated Class 1E AC power load group, 4.16 kV switchgear, and 480 V Ioad centers. The Division 3 DC electrical power subsystem provides DC motive and control power as required for the High Pressure Core Spray (HPCS) System diesel generator (DG) set control and protection.

The DC power distribution system is described in more detail in Bases for LCO 3.8.7, "Distribution Systems - Operating," and LCO 3.8.8, "Distribution Systems - Shutdown."

(continued)

PERRY - UNIT 1 B 3.8-51 Revision No. 1

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 BASES BACKGROUND Eaeh Divisien 1 2' and 3 battery has adequate sterage eapaeity te eaffy (continued) the reguired lead' eentinueusly fer at least 2 heurs as diseussed in USAR; The Divieien 3 battery has adequats sterage te earry the reguired lead Each DC subsystem is located in an area separated physically and electrically from the other subsystems to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem.

There is no sharing between redundant Class 1E subsystems such as batteries, battery chargers, or distribution panels.

Each batterv has adequate storage capacity to meet the dutv cycles discussed in the USAR,Section I (Ref. 4), The battery is designed with additional canacitv above that required bv the desiqn dutv cvcle to allow for temperature variations and other factors.

The batteries for a DC electrical power subsystem are sized to produce required capacity at 80% of nameplate rating. The minimum voltage design limit is 1,875 V per cell for Division 1, 1.863 V per cell for Division 2 and 1.905 V per cell for Division 3 batteries (Ref. 4).

The batterv cells are flooded lead acid construction with a nominal specific qravitv of 1.215. This specific gravitv corresponds to an open nirnr rit hatteru vnltann nf annrnv matelv 120 V for a 58 cell hattcru /i .e cell voltage of 2.065 volts per cell Vpc). The open circuit voltaqe is the voltage maintained when there is no charginq or discharqing. Once fullv charqed with its open circuit-vgltqgF Vpc. the b?ttery.Self Will further charging per

=.2,0.F5 maintain its capacity for 30 days without manufacturer's instructions, Optimal Iong term performance however, is obtained bv maintaininq a float voltage 2.20 to 2.25 Vpc. This provides adeouate over-potential. which limits the formation of Iead sulfate and self-discharoe. The nominal float voltaqe of 2.22 Vnc corresnonds to a total float voltaqe output of 128.8 V for a 58 cell battery as discussed in the USAR,Section I (Ref. 4).

Each battery charger of Division 1 and 2 DC electrical power subsystems batterv charger has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger has sufficient excess capacity to restore the battery bank from the design minimum charge to its fully charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while supplying normal steady state loads (Ref. a).

The battery charger of Division 3 DC electrical power subsystem batterv charger has sufficient excess capacity to restore the battery bank from the design minimum charge to its fully charged state in I hours while supplying normal steady state Ioads (Ref. a).

PERRY - UNIT 1 B 3.8-52 Revision No. I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 (continued)

PERRY - UNIT 1 B 3.8-54 Revision No. I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 BASES BACKGROUND The batterv charqer is normallv in float-charoe mode. Float-charoe is (continued) the condition in which the charqer is -suppl,vino the connected loads and the batterv cells are receivinq adequate current to ontimallv c-harge the battery. This assures he intqrnAl losses of a batterv are overcome and the batterv is maintained in a fullv charoed state.

When desired. the cha can be olaced in the eoualize mode- The equalize mode is at a higher voltaqe than the float mqde and charqinq current is corresH'qndinqlv hiqher. The batterv charger is operated in the equalize mode after a batterv d roe or for routine maintenance Following a batterv discharge, the battqry recharge characteristic accepts current at the current limit of the rv charoer (if the discharoe was siqnificant, e.9.. following a battery servicgleq!),Until the batterv terminal voltaoe aoproaches the charqer setooint. Charoino current then reduces exoonentiallv durino the re 2 nder of the recha ro e cvcle. Lead-calcium batteries heve recharge efficiencies of oreater than 95%. so once at least 105% of the ampere-hours discharqed have been returned.,thq battery capacity would b-e-restoled.to the same condition as itwas prior to the discharoe. This can be monitored bv direct observation of the exponentially decaving charqing current or bv evalualing the amn-hours discharged from the battery and amp-hours returned to the battery.

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the USAR, Chapter 6 (Ref. 5) and Chapter 15 (Ref. 6),

ANALYSES assume that ESF systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining DC sources OPERABLE during accident conditions in the event of:

a An assumed Ioss of all offsite AC power or of all onsite AC power; and

b. A worst case single failure.

The DC sources satisfy Criterion 3 of the NRC Final Policy Statement on Technical Specification lmprovements (58 FR 39132).

(continued)

PERRY. UNIT 1 B 3.8-53 Revision No. 7 I

TS BASES PROVIDED FOR CONTEXT DC Sources - Operating

. NO CHANGES . B 3.8.4 BASES LCO The DC electrical power subsystems, each subsystem consisting of either the Unit 1 or2 battery, eitherthe normal or reserve battery charger, and the corresponding control equipment and interconnecting cabling supplying power to the associated bus within the divisions, are required to be OPERABLE to ensure the availability of the required power to shut down the reactor and maintain it in a safe condition after an anticipated operation occurrence (AOO) or a postulated DBA. Loss of any DC electrical power subsystem does not prevent the minimum safety function from being performed (Ref. 4).

Division 1 consists of:

1. 125 volt battery 1R42-S002 or 2R42-S002.

2. 125 volt full capacity charger 1R42-S006 or 0R42-S007 Division 2 consists of:

1 . 125 volt battery 1R42-S003 or 2R42-S003.

2. 125 volt full capacity charger 1R42-S008 or 0R42-S009 Division 3 consists of:

1. 125 volt battery 1E22-S005 or 2E22-S005.

2. 125 volt full capacity charger 1E22-S006 or 0R42-S01 1.

APPLICABILITY The DC electrical power sources are required to be OPERABLE in MODES 1 , 2, and 3 to ensure safe unit operation and to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limlts are not exceeded as a result of AOOs or abnormal transients; and

b. Adequate core cooling is provided, and containment integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 4 and 5 are addressed in the Bases for LCO 3.8.5, "DC Sources - Shutdown."

(continued)

PERRY - UNIT 1 B 3.8-53a Revision No. 7 I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DG Sources - Operating B 3.8.4 BASES ACTIONS A.1, A.2. and A.3 during nermal eBeratien, lt is; thereferei imperative that the eperater's is lf nna nf tha rarrr rirall l.\irriairrn 4 nr 1 I'\I^ alar.*rir.*rl nr.rrrrar 6r r]rorre.*arv.ro io i

i eepaeity te suBBe* a sae

.pewer subsystm iE ffiConditionArepreSentSonesubsVStemwithrequired battery charger inoperable (e.9., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fullv charqed state and restoring a fullv 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time provides for returninq the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltase to qreater than or equal to the minimum established float voltaqe. Restoring the batterv terminal voltaqe to qreater than or equal to the minimum established float voltaqe provides good assurance that.

within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . the batterv will be restored to its fu llv charqed condition (Required Action A.2) from any discharge that might have occurred due to the charser inoperability A discharged battery having terminal voltage of at Ieast the minimum established float voltage indicates that the batterv is on the exponential charqinq current portion (the second part) of its recharqe cvcle. The time to return a batterv to its fullv charqed state under this condition is si mplv a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fullv recharging the battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , avoiding a premature shutdown with its own attendant risk PERRY - UNIT 1 B 3.8-54 Revision No. 4

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 lf established terminal float voltaqe cannot be restored to oreater than or equal to the minimum eslehliFhed float voltaoe within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the charqer is not operatino in the current-limiting mode. a faultv charger is indicated. A faultv charqer that is incapable of maintaininq established batterv terminal float voltaqe does not provide assurance that it can revert to and operate properlv ln the current limit mode that is necessary durinq the recoverv period followinq a batterv discharqe event that the DC system is designed for.

lf the charoer is operatino in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that is an indication that the batterv is partiallv discharqed and its capacitv marqins will be reduced. The time to return the batterv to its fullv charqed condition in this case is a function of the batterv charger capacitv. the amount of Ioads on the associated DC svstem, the amount of the previous discharge, and the recharge characteristics of the batterv. The charqe time can be extensive. and there is not adequate assurance that it can be recharged within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action A.2).

ACTIONS A.1, A.2. and A.3 (continued)

Reouired Action A.2 requires that the battery float current be verified as less than or equal to 2 amps. This indicates that, if the batterv had been discharqed as a result of the inoperable batterv charger. it is now fullv capable of supplvinq the maximum expected Ioad requirement. The 2 amp value is based on returning the battery to 95% charqe and assumes a 5o/o desiqn marqin for the batterv. lf at the expiration of the initial 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period the battery float current is not Iess than or equal to 2 amps this indicates there mav be additiona! batterv problems and the batterv must be declared inoperable.

Required Action A.3 Iimits the restoration time for the inoperable batterv charqer to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This action is applicable if an alternate means of restorinq batterv terminal voltaqe to qreater than or equal to the minimum established float voltaqe has been used (e.q.. balance of plant non-CIass 1E batterv charqer). The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time reflects a reasonable time to effect restoration of the qualified batterv charqer to OPERABLE status.

8.1 Condition B represents one subsvstem with required batterv inoperable Wth required battery inoperable, the DC bus is being supplied by the OPERABI.._E" batterv chqr$qr(.s). Any event that resglls" in aloss of tlle AC bus supportinq the batterv charqer(s) will also result in Ioss of DC to that subsystem. Recovery of the AC bus, especially if it is due to a loss of offsite power. will be hampered bv the fact that manv of PERRY - UNIT 1 B 3.8-55 Revision No. 4 I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 the components necessarv for the recoverv (e.9.. diesel oenerator control and field flash. AC load shed and diesel qenerator output circuit breakers, etc.) likelv rely upon the batteries. In addition. the energization transients of anv DC loads that are bevond the capabilitv of the batterv charqers and normally require the assistance of the batteries will not be able to be brouqht online. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Iimit allows sufficient time to effect restoration of an inoperable batterv qiven that the maioritv of the conditions that lead to batterv inoperability (e.9.. loss of batterv charger. batterv cell voltage less than2IZ V, qtc,) are identified in Specifications 3.8.4, 3.8.5, and 3.8.6 toqether with additional specific completion times.Wth the Divisien 3 EC eleetrieal pewer subsystem ineperable; the HPCS System may be i

(continued)

PERRY - UNIT 1 B 3,8-56 Revision No. 4 I

TS BASES MARK.UP - PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 BASES ACTIONS C.1 and C.2 (continued)

Condition C represents one subsvstpm wit[ a loss of abilitv to cgmpl-etely respond to an event, and a potential loss of ability to remain energized durins normal operation. It is, therefore, imperative that the operator's attention focus on stabilizinq the unit. minimizing the potential for complete loss of DC power to the affected subsystem" The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is consistent with the allowed time for an inoperable DC distribution subsvstem.

lf one of the reouired Division 1 or Division 2 DC electrical power subsvstems is inooerable for reasons other than Condition A or B (e.o..

inoperable batterv charger and associated inoperable batterv). the remaining DC electrical power subsystems have the capacitv to sunport a safe shutdown and to mitigate an accident condition. $inge,.q s,ubsequ,qnt worst case single failure could, however. result in the Ioss of the minimum necessarv DC electrica! subsvstems, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Requlatorv Guide 1 .93 and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsvstem is not restored to OPERABLE status, to prepare to effect an orderlv and safe unit shutdown.ffi whieh the tGO dees net apply, Te aehieve this status, the plant must be with the time required in Regulatery Guide 1,83 (Ref, 7"),

D.1 Wth the Division 3 DC eleetrcal power subsystem inoperable, the HPCS Svstem mav be incapable of peforminq its intended function and must be immediatelv declared inoperable. This declaration also requires entrv into applicable Conditions and Required Actions of LCO 3.5.1. "ECCS -

Operatinq."

E.1 and E.2 If the DC electrical subsvstem cannot be restored to OPERABLT status within the associated Completion Time, the unit must be brouqht to a MODE in which the LCO does not applv. To achieve this status, the plant must be brouqht to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within S6 hourq l-he allowed Compfetion Times are reasonable, based on operating experience. to reach the required plant conditions from full PERRY - UNIT 1 B 3.8-56 Revision No. {t I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 power conditions in an orderlv manner and without challenqinq plant svstems. The Completion Time to brinq the unit to MODE 4 is consistent with the time required in Requlatorv Guide 1,93 (Ref. il.

(continued)

BASES SURVEILLANCE sR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge helps to ensure the effectiveness of the batterv charoe,rs, which Fupport @

andthe ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal Iosses of a battery Fr+a+tery eelFand maintain the battery @in a fully charged state, while supplving the continuous steady state loads of the associated DC subsvstem. On float charge. battery cells will receive adequate current to optinallv chqfoe.tlte- !?ttery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltaqe established by the battery manufacturer 2.20 Vpc times the number of connected cells. This voltaqe maintains the batterv plates in a condition that supports maintaininq the qrid Iife. initial++el+ags ien+The Surveillance Frequency is controlled under the Surveillance Frequency Control Program, sR 3,8. l#

Visual inspeetien te deteet eerreeien ef the battery eenneetiens; er measurement ef th Be*ermanee, The Surveillanee Frequeney is eentrelled under the Surveillanee PERRY - UNIT 1 B 3.8-57 Revision No. *1 I

TS BASES MARK-UP . PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 EAffi SURVEITTANCE SR 3.8.1.3 REQUIREMENTS (eentinued) Visual insBeetien ef the battery eells' eell plates and battery raoks previAes an inai eeulC+e$entially degrade battery perfermanee, The presenee ef Bhysieal damage er deterieratien dees net neeessarily repreeent a failure ef this SR, previded an-evaluatien determines that the physieal damage er

'l-ha Q,.nralllanaa Eraa, rA6At, la aan*rallarl .,nr{ar lha Qr,*r^ill^^^^

r trv vgr rvrrtqltvv a tYYYvrrvJr rg vvrrtrvrrvu urrvvr Lf rv vsr rvrrrsrrvv SR 3,8, 1,1 and SR 3.8,'1,5 Visual inspeetien and resistanee measurements ef inter eelli- inter raek; damage er abnermal deterieratien that eeuld indieate degraded battery ien fsr eenesien is ne[ intgnded te-require remeval ef and inspeetien under The remeval ef visible eerresien is a preventative maintenanee ffi, The is TJ-^ C..nr^illan^a E.a^.iAAAt, la aan*rallar{ .,nr{ar lha C,,*r^ill^^^^

a I av vua Yvatlgl tvv I I vYvvt lvJr tv vvr rfa vrlvv u, rgvr rr rv vua ! vrllsr rvu sR 3.8.4.26 This SR verifies hg design capacity of the battery chargers. 1qs'f-4F. According to Regulatory Guide 1.32 (Ref. 9), the battery charger supply is reeqired 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 batterv charqer be capable of supplvinq 400 amps for Division 1 and 2 and 50 amps for Divisio,n 3 at the minimum established float voltaoe for PERRY - UNIT 1 B 3.8-58 Revision No. {4

TS BASES MARK.UP. PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 I hours. The amnere requirements are based on the output ratinq of the chargers. The voltage requirements are based on the charqer voltage Ievel after a response to a loss of AC power. The time period is sufficient for the charqer temperature to have stabilized and to have been maintained for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

The other option reou ires that each batterv charoer be caoable of recharging the batterv after a service test coincident with supplving-Jhe larqest coincident demands of the various continuous steadv state loads (irresoective of the status of the plant durinq which these demands occur). This level of loading mav not normallv be available following the batterv service test and will need to be supplemented with additional loads. The duration for this test may be lonqer than the-charoFr sizins criteria since the battery recharqe is affected bv float voltaoe.

temperature. and the exponential decay in charging current. The bajtFfy is recharqed when the measured charqing current is < 2 amps.

(contin ued BASES SURVEILLANCE sR 3.8.4.2 (continued)

REQUIREMENTS The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

sR 3.8.4.37 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length correspond to the design duty cycle requirements as specified in Reference 4.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR modified by a Note. The Note allows the periodic performance of a modified nerformance discharoe test in lieu of a service test. S+3?8r4+

i

SR 3,8,'1,7, PERRY - UNIT 1 B 3.8-59 Revision No. {4 I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 EAffi RESUIREMENTS

- (eentinued) A battery perfermanee test is a test ef eenstant eurrent eapaeity ef a in The aeeeptanee eriteria fer this Suryeillanee is eensistent with IEEE 450 (Ref, 8) and IEEE l85 (Ref, 11). These referenees reeemmend that the ie+is inereasi The-Surveillanee Frequeney fer this test is-nermally perfermed in Surveillanee Frequeney is redueed te 12 menths, Hewever' if the battery Surveillanee Frequeney is enly redueed te 2{ menths fer batteries that ie+is i

ie+*e Berfermanee teet er wn (Ref, 8), This SR i+medified by aNete, Credit may be taken fer unplanned events that satisfy this SR, This nete is previded te Brevent 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=33.

5. USAR, Chapter 6.

6. USAR, Chapter 15.

7. Regulatory Guide 1.93, December 1974.

(continued)

PERRY - UNIT 1 B 3.8-60 Revision No. 11 I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Operating B 3.8.4 BASES REFERENCES (continued) gS. Regulatory Guide 1.32, February1977.

94O.Regulatory Guide 1.129, December 1974.

11, IEEE Standard '185, PERRY - UNIT 1 B 3.8-61 Revision No. *1

TS BASES MARK-UP - PROVIDED FOR INFORMATION ONLY DC Sources - Shutdown B 3.8.5 BASES APPLICABILITY c. Required features necessary to mitigate the effects of events that can (continued) lead to core damage during shutdown are available; and

d. lnstrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, and 3 are covered in LCO 3.8.4.

ACTIONS The ACTIONS are modified by a Note indicating that LCO 3.0.3 does not apply. lf moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of recently irradiated fuel assemblies is not sufficient reason to require reactor shutdown.

4.1,-A.2. and A.3 Condition A represents one subsvstem with the required batterv charser inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS nrovide a tiered resoonse that focuses on returni nq the batterv to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time neriod. Required Action A.1 requires that the battery terminal voltage be restored to greater than or al to the minimum established float e within 2 h orovides for returni no the ino oera ble charqer to OPERABLE status or providing an alternate means of restoring battery terminal voltage to reater than or ual to the minimum established float volta Restori the battery terminal voltage to greater than or equal to the minimum established float voltaoe nrovides oood assurance that, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the battery will be restored to its fully charsed condition (Required Action A.2) from anv discharge that miqh.t have occuU'ed due to the charoer inooerability.

A discharoed batterv h nq terminal voltaqe of at Ieast the minimum established float voltaoe indicates that the batterv is on the exponential charqinq current portion (the second part) of its recharqe cvcle" (continued)

PERRY - UNIT 1 B 3.8-62 Revision No. 4

TS BASES MARK-UP - PROVIDED FOR INFORMATION ONLY DC Sources - Shutdown B 3.8.5 BASES ACTIONS A.1. A.2. and A.3 (continued)

The time to return a battery to its fullv charsed state under this condition is simplv a function of the amount of the nrevious discharqe and the recharge characteristic of the batterv. Thus there is qood assurance of fullv rechargins the batterv within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , avoiding a premature shutdown with its own attendant risk.

lf established batterv terminal float voltaoe cannot be restored to qreater than or equal to the minimum establlshed float voltase within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the charger is not operating in the current-limitinq modes, a faulty charger is i,ndicated. A fa!.lltv charqer that is incanable of maintaining established battery terminal float voltaoe does not provide assurance that it can revert to and onerate orooerlv in the limit mode that is necessarv durinq the recoverv period followinq a batterv discharoe event that the PC svstem is desiqned for.

lf the charoer is ooerati in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that is an indication that the batterv is partiallv discharqed and its capacitv marqins will be reduced. The time to return the batterv to its fullv charged condition in this case is a function of the batterv charser capacitv. the amount of loads on the associated DC svstem. the amount of the previous discharqe, and the recharoe characteristic of the batterv. The charqe time can be extensive, and there is not adequate assurance that it can be recharqed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Actio.n A.21.

Reouired Action A.2 reo uires that the batterv float current be verified as less than or equal to 2 amps. This indicates that, if the batterv had been discharqed as the result of the inoperable batterv charger, it has nQw been fullv recharoed. lf at the expiration of the initial 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period the batterv float current is not less than or equal to 2 amps this indicates there may be additional batterv problems and the batterv must be declared inoperable.

Reouired Action A.3 limits the restoration time for the inooerable batterv charger to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This action is applicable if an alternate means of restqring.hattery. "telminal vollaqe to qreater than or equal to the minimum established float voltage has been used (e.9.. balance of plant non-Class 1E battery charqer). The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time reflects a reasonable time to effect restoration of the qualified batterv charoer to OPERABLE status.

tt rnere than ene D PERRY - UNIT 1 B 3.8-62a Revision No. 4 I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Shutdown B 3.8.5 is primary eentainment and fuel handling building; and eperatiens with a Suspensien ef these aetivities shall net preelude eempletien ef further required te immediately initiate aetien te restere the required DC ie+e ffi The Cempletien Time ef immediately is eensistent with the required times fer aetiens requiring BremBt attentien, The resteratien ef the required DG in erder te minimize (continued)

PERRY - UNIT 1 B 3.8-63a Revision No. 4 I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY DC Sources - Shutdown B 3.8.5 BASES APPLICABILITY 8.1 , 8.2 .1, 8.2.2, 8.2.3. and 8.2.4 lf more than one DC distribution subsvstem is required accordinq to LCO 3.8.8. the DC subsvstems remaininq OPERABLE with one or more DC power sources inoperable mav be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, recentlv irradiated fuel movement. and operations with a potential for draining the reactor vessel.

Bv allowrnq the option to declare required features inoperable with associated DC power source(s) inoperable, appropriate restrictions are implemented in accordance with the affected svstem LCOs' ACTIONS. ln manv instanpe_s thiq ,qp-[ion rEav. involve undesired administrative efforts.

Therefore. the allowance for sufficientlv conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of recently irradiated fuel assemblies, and any activities that could result in inadvertent draining of the reactor vessel).

Susoension of these act ities shall not nreehrde co m n etio n of actions to estpFligh e.safe..qgnservative conditiorl,.T_h-p$e a.ctions minimize the probability of the occurrence of postulated events. It is further required to immediatelv initiate action to restore the required DC electrical power subsvstems and to continue this action until restoration is accomplished in order to provide the necessarv DC electrical power to the plant safetv systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsvstems should be completed as quickly as possible in order to minimize the time durino which the plant safety systems mav be without sufficient power SURVEILLANCE sR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requires performance of all Surveillances required by SR 3.8.4.1 through SR 3.8.4.E8. Therefore, see the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or othenruise rendered inoperable during the performance of SRs. lt is the intent that these SRs must still be capable of being met, but actual performance is not required REFERENCES 1. USAR, Chapter 6.

PERRY - UNIT 1 B 3.8-63 Revision No. 4

TS BASES MARK-UP . PROVIDED FOR INFORMATION ONLY DC Sources - Shutdown B 3.8.5

2. USAR, Chapter 15.

PERRY - UNIT 1 B 3.8-64 Revision No. 4

TS BASES MARK.UP . PROVIDED FOR INFORMATION OI,ILY Batteryell Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Batteryel{ Parameters BASES BACKGROUND This LCO delineates the limits on batterv float current as well as electrolyte temperature, level, ang!-float voltage, @r the DC power source batteries. A discussion of these batteries and their OPERABILITY requirements is provided in the Bases for LCO 3.8.4, 'DC Sources - Operating," and LCO 3.8.5, "DC Sources - Shutdown." ln addition to the limitations of this Specification. th.e, batterv monitorino and maintenance proqram also implements a program specified in Specification 5.5.16 for monitorins various battery parameters.

The batterv cells are of flooded lead acid construction with a nominal specific gravitv of 1.215. This specific gravitv corresponds Io an,open circuit battery voltage of approximatelv 125 V for 58 cell batterv (i.e., cell voltaqe of 2.083 volts per cell (Vpc)). The ooen circLti-t_voltaqe is the voltaoe maintained when there is no charging or discharging. Once fullv charsed with its open circuit voltaqe E 2.083 Vpc, the batterv cell will maintain its capacitv for 30 davs without further charqinq per manufacturer's instructions. Optimal lonq term performance however, is obtained bv maintaininq a float voltaqe 2.20 to 2.25 Vpc. This provides adequate over-potential which limits the formation of lead sulfate and self-discharqe. The nominal float voltaoe of 2.25 Vpc corresponds to a total float voltage output of 135 V for a 60 cell battery as discussed in the USAR, Section 8 (Ref. 2).

APPLICABLE The initial conditions of Design Basis Accident (DBA) and transient SAFETY analyses in the USAR, Chapter 6 (Ref. 34) and Chapter 15 (Ref. !3),

ANALYSES assume that Engineered Safety Feature systems are OPERABLE. The DC electrical power subsystems provide normal and emergency DC electrical power for the diesel generators, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining at least one-Civi.sit+

subsvstem of DC sources OPERABLE during accident conditions, in the event of:

a. An assumed loss of all offsite AC power or all onsite AC power; and

b. A worst case single failure.

Since battery-eell parameters support the operation of the DC power sources, they satisfy Criterion 3 of the NRC Final Policy Statement on Technical Specification lmprovements (58 FR 39132).

(continued)

PERRY - UNIT 1 B 3.8-64 Revision No. 7

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY Batteryelt Parameters B 3.8.6 BASES LCO Battery+ell parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. Battery parameter Elastrolyts limits are conseruatively established, allowing continued DC electrical system function even with limits not met. Additional preventative maintenance, testinq. and monitorino performed in accordance with the "Batterv Monitorino and Maintenance Proqram" is conducted as specified in Specification 5.5.16.

(continued)

PERRY - UNIT 1 B 3.8-64a Revision No. 7 I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY Batteryelt Parameters B 3.8.6 BASES (continued)

APPLICABILITY The battery+ell parameters are required solely for the support of the associated DC electrical power subsystem. Therefore, battery parameter limits are eleetrelyt+is only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and LCO 3,8.5, ACTIONS A.1 , A.2. and A.

e ies-are geq+*ired+e+iens-liml*a /i a f^a*aaar., A lirmi*a nal ma* l-alaana, trl limi*a na* ma* Ar.

eapaeity te perferm the intended funetien, Therefere; the affeeted battery i

+ er C limits net met perie+

The pilet- eell eleetrelyte level and fleat veltage are required te be verified te meet Gategery C limits within t heur (Required Aetien 4,1). This eheek reasenable ameunt ef time te Berferm the required verifieatien, Verifieatien that the Categery C limits are met (Rquired Aetien 4.2) prevides assur parameters te tne C eem plete the-initjal verifi eatien beeause speeifie g ravity measurements

+m+is until the parameters are restered te Gategery A and B limits, This Centinued eperatien is enly permitted fer 31 days befere battery eell farameters must eapai PERRY - UNIT 1 B 3.8-65 Revision No.

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY Batteryell Parameters B 3.8.6 fer eperatien prier te deelaring the DC batteries ineperabl+With one or more cells in one or more batteries in one subsvsteryt < ?.QZ V, the batterv cell is deqraded. \Mthin 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months verification of the reouired batterv charoer OPERABILITY is made. bv monitoring the battery terminal voltage (SR 3.8.4.1) and of the overall batterv state of charqe bv monitoring the batterv float charoe current (SR 3.8.6.1).- This assures that there is still sufficient battery capacitv to perform the intended function. Therefore, the affected batterv is not required to be considered inoperable solely as a result of one or more cells in on or more batteries < 2.07 V. and continued. oqgr3tign i-sjermitted for a Iimited period up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Since the Reouired Acti onlv specifv "perform." a failure of SR 3.8.4.1 or SR 3.8.6.1 acceptance criter:ia does not result in this Required Action not met. However, if one of the SRs is failed the appropriate Condition(s).

depending on the causq of,.!he failures. is entered. lf SR 3.8.6.1 is failed then there is not assurance that there is still sufficient batterv capacitv to perform the intended function and the battery must be declared inoperable im med iatelv.

8.1 and 8"2 One or more batteriqs in one subsvstem with float > 2 amps indicates that a partial discharge of the batterv capacitv has occurred. This mav be due to a tqmH.orHrv.losp .of a batterv charger or possibly due to one or more batterv cells in a Iow voltaoe co reflectino some Ioss of caoacitv.

Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months verification of the ired batterv charqer OPERABILITY is made bv monitorinq the batterv terminal voltaqe. lf the terminal voltaqe is found to be less than the minimum established float voltaqe there are two possibilities, the battery qhproer is inoperable or is operating in the current limit mode. Condition A addresses charqer inoperabilitv. !f the charqer is operatinq in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that is an indication that the, ba-tterv has been substantially discharged qnd Iikelv cannot oerform its reouired desion functions. The time to return the battery to its fullv charqed condition in this cFs,F is a function of the batterv charger capacitv. the amount of loads on the associated DC svstem. the amount of the previous discharge. and the,recharqe characteristic of the batterv. The charoe time can be nsive. and there is not adequate assurance that it can be recharqed withln'12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action B"2).

The battery must therefore be declared inoperable.

(continued)

BASES ACTIONS 8.1 and 8.2 (continued) lf the float voltaoe is fou nd to be satisfactorv but there are one or more batterv cells with float vo Itao e less than 2.O7 V. the associated "OR" statement in Condition F is aool and the batterv must be declared inooerable immediatelv. lf float vo e is satisfactorv and there are no cells less than 2.07 V there is oood assurance th?! within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the PERRY - UNIT 1 B 3.8-66 Revision No.

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY Batteryell Parameters B 3.8.6 batterv will be restored to its fully charged condition (Required Action 8.2) from anv discharoe that mioht have occurred due to a temoorarv Ioss of the batterv charqer.

A discharoed batterv float voltaoe (the charoer setnoint) across its terminals indicates that the battery is on the exponential charqinq current portion (the second part) of its recharge cvcle. The time to return a batterv to its fullv charged state under this condition is simplv a function of the amount of thq previous discharqe and the recharqe characteristic of the battery. Thus there is qood assurance of fully recharoinq the battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . avoidino a premat re shutdown with its own attendant risk.

If the condition is due to one or more cells in a low voltaoe condition but still qreater than 2.07 V and float voltaqe is found to-.be satisfactory. this is not indication qf a substantiallv discharqed batterv and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is a reasonable time prior to declaring the batterv inoperahlg.

Since Reouired Action B. 1 onlv soecifies "Derform." a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met.

However. if SR 3.8.4.1 is failed. the aoorooriate Condition(s). deoendino on the cause of the failure. is entered, eenneeted eell, suffieient eaFaeity te supply the maximurn expeeteC lead eempleting the Required Aetiens ef Genditien A within the required eells falling belew 73'F; alse are eause fer immediately deelaring the C.1 , C.2, and C.3 Wth one or more batteries in one subsvstem with one or more cells electrolvte Ievel above the top of the plates. but below the minimum established desion Iimits. the still retains sufficient caoacitv to perform the intended function. Therefore. the affected batterv is not required to be considered iloperable solelv as a result of electrolyte level not met. Within 31 davs the mini um established desion limits for electrolvte level must be rqestablished.

(continued)

PERRY _ UNIT 1 B 3.8-67 Revision No.

TS BASES MARK.UP - PROVIDED FOR INFORMATION ONLY Batteryell Parameters B 3.8.6 BASES ACT!ONS C.1. C.2" and C.3 (continued)

With electrolyte level below the top of the plates there is a potential for drvout and plate deqradation, Required Actions C.1 and C.2 address this potential (as well as provisions in Specification 5.5.16, Battery Monitorinq and Maintenance Proqram). Thev are modified by a Note that indicates thev are onlv applicable if electrolvte Ievel is below the top of the nlates.

Within I hours level is required to be restored to above the top of the plates. The Required Action C.2 requirement to verifu that there is no leakaqe bv visual inspection and the Specification 5.5.16.b item to initiate action to equalize and test in accordance with manufacturer's recommendation. They are performed followinq the restoration of the electrolyte level to above the top of the plates. Based on the results of the manufacturer's recommended testing the batteries mav halre tp, be declared inoperable and the affected cells replaced.

D.1 With one or more batteries in one subsvstem with pilot cell temperature less than the minimum established design limits, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to restore the temperature tq,-WitUO_Jimits. A low elqqtrolvte tgr,nperature limits the current and power available. Since the batterv is sized with marqin, while battery capacitv is desraded, sufficient capacitv exists to pedorm the intended function and the affected battery is not reouired to be considered inoperable solelv as a result of the pilot cell temnerature not met.

E.1 With one or more batteries in redundant subsvstems with batterv parameters not within limits there is not sufficient assurance that batterv capacitv has not been affected to the deqree that the batteries can still perform their reouired function. qiven that redundant batteries are involved. With redundant batteries involved this potential could result in a total loss of function on multiple systems that rely upon the batteries. The lonqer Completion Times specified for batterv parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one subsvstem within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

(continued)

PERRY - UNIT 1 B 3.8-67 Revision No.

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY Batteryell Parameters B 3.8.6 BASES (continued)

\ffhen anv batterv Dara is outside the allowances of the Reouired Actions for Condition A, B, C, D, or E, sufficient capacitv to supplv the maximum expected load reouirement is not assured and the nnrreqnnndinn hattcnr mrrsf hc denlared nnnerahlc Additional lv discoverinq one or more batteries in one subsvstem with one or more batterv cells fl,oat voltage less than 2.07 V and float current greater than 2 amps indicates that the batterv capacitv mav not be sufficient to pedorm the intended functions. The batterv must therefore be declared inoperable immediatelv.

SURVEILLANCE sR 3.8.6.1 REQUIREMENTS Verifying battery float current while on float charge is used to determine the _$tate of chHHF, pf the batterv. Float charqe is the condition in which the charqer is supplvinq the continuou$ charge required to overcome the internal losses of a battery and maintain the batterv in a charged state" The equipment used to monitor float current must have the necessary accuracy and capabilitv to measure electrical currents in the expgcted ranoe. The float current requirements are based on the float current indicative of a charoed batterv. The Surveillance Frequencv is controlled Under the Surveillance Frequencv Control Program.

This SR is modified bv a Note that states the float current requirement is not required to be met when batterv terminal voltage is less than the minimum established float voltaqe of SR 3.8.4.1. \Mren this float voltage is not maintained the Required Actions of LCO 3.8.4 ACTION A are beinq taken, which provide the necessary and appropriate verifications of the battpry, cpndition,, Furthermore. the float current limit of ? amps is established based on the nominal float voltage value an4 is not directlv applicable when this voltaqe is not maintained.The SR yerifies t whieh reeemmends regular battery inspeetiens ineluding eleetrelyte level; P+eg+a+

SR 3.8.6.2 and 3.8.6.5 Optimal long term batterv performance is obtained bv maintaining a float voltaqe sreater than or equal to the minimum established desiqn !imits provided bv the batterv manufacturer. which corresponds to 135 V at the batterv terminals, or 2.25 Vpc for a 60 cell battery and 2.21 Vpc for a 61 cell batterv. This provides adequate over-potential. which limits the formation of lead sulfate and self discharge. which could eventually render the battery inoperable. Float voltages in this ranqe or less, but qreater than 2.07 Vpc, are addressed in Specification 5.5.16. SRs 3.8.6.2 PERRY - UNIT 1 B 3.8-68 Revision No.14

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY Batteryell Parameters B 3.8.6 and 3-.8-$.5 req_uile verification that the cell float voltaoes are equal to or qreater than the short term absolute minimum voltage of 2.OT V. The Surveillance Frequencv is controlled under the Surveillance Frequency Control Program.

under the Surveillanee Frequeney Centrel Pregram, In additien; within 72

+e#eet Categery B limits, Thie insBeetien is alse eensistent with IEEE 450 (Ref, 3), whieh reeemmends speeial inspeetiens fellewing a severe evereharge, te ensure that ne signifieant degradatien ef the battry eeeurs (continued)

PERRY - UNIT 1 B 3.8-69 Revision No.{-l I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY Batteryell Parameters B 3.8.6 BASES SURVEILI.ANCE sR 3.8.6.3 REQUIREMENTS (continued) The limit specified for electrolvte level ensures that the plates suffer no phvsical damaqe and maintains adequate electron transfer capabilitv.

The minimum design electrolvte level is the minimum level indication mark on the batterv cell iar. The Surveillance Frequencv is controlled under the Surveillance Frequencv Control Proqram. This Surveillanee verifies that the average temperature ef reBresentative eells is E 72"F is Fregueney is eentrelled under ff.re.Suryeillanee Frequeney Centrel tewer than nermal temperatures aet te inhibit er reduee battery eapaeity, This SR ensures that the eBerating temBeratures remain within an sR 3.8.6.4 This Surveillance verifies that the pilot cell temperature is qreater than or equal to the minimum established desiqn Iimit (i.e.,40'F). Pilot cell electrolvte temperature is maintained above this temperature to assure the battery can provided the required current and voltaqe to meet the desion requirements. Temperatures lower than assumed in batterv sizinq calculations act to inhibit or reduce battery capacitv. The Surveillance Ffqgu.ency, is controlled under the Surveillance Frequenclr Control Program.

sR 3.8.6.6 A batterv performance discharqe test is a test of constant current canacitv of a battery, normallv done in the as found condition, after havinq been in service, to detect any change in the capacity determined bv the acceptance test. The test is intended to determine overall batterv deqradation due to aoe and usaqe.

Either the battery performance discharqe test or the modified performance discharqe test is acceptable for satisfvinq SR 3.8.6.6:

however, onlv the modified performance discharqe test mav be used to satisfu the battery service test requirements of SR 3.8.4.3.

A modified discharse test is a test of the batery capacitv and its abilitv to provide a high rate. short duration load (usuallv the highest rate of the dutv cvcle). This will often confirm the battery's abilitv to meet the critical period of the load dutv cvcle, in addition to determininq its percentase of rated capacity. Initial conditions for the modified performance discharqe test should be identical to those specified for a service test.

PERRY - UNIT 1 B 3.8-69 Revision No.ll I

TS BASES MARK.UP . PROVIDED FOR INFORIiilATIOH ONLY Batteryell Parameters B 3.8.6 It mev consist of iust rates'for ln sta n CC the on emi r rte rete for the batterv or the laroest current Ioad the dutv cvcle. followed bv the test rate emploved for the oerformance test. both of which envelooe the dutv clrcle of the service test. Since the ampere-ho rs removed bv a one ln r rfo r{icn h arflE ranraeanfc. a rrenr ernall nnrfinn nf fha haflanr ca nanitrr the test rate can be changed to that for the performance test without comnromisino the results of oedormance d ischaroe test.

(continued)

PERRY. UNIT 1 B 3.8-70 Revision No.At I

TS BASES MARK.UP - PROVIDED FOR INFORMATION ONLY Batteryel{ Parameters B 3.8.6 BASES SURVEILLANCE SR 3.8.6.6 (continued)

REQUIREMENTS (continued) The battery terminal voltase for the modified performance discharqe test must remain above the minimum batterv terminal voltage specified in the batterv service test for the duration of time equal to that of the service test.

The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 1) and IEEE-485 (Ref. 5). These references recommend that the batterv be renlaced if its capacitv is below 80% of the manufacturer's ratino. A capacitv of B0% shows that the batterv rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Eurthernro,fe, the batterv is sized to meet the assumed duty cvcle Ioads when the batterv desion capacitv reaches this 80% Iimit. The Surveillance Frequencv is controlled under the Surveillance Frequencv Control Program.

lf the batterv shows deqradation, or if the batterv has reached 85% of its expected life and capacitv is < 100% of the manufacturer's rating. the Surveillance Frequencv is reduced to 12 months. However. if the batterv shows no deoradation but has reached 85o/o of its expected life, the Surveillance Frequencv is onlv reduced to 24 months for batteries that retain capacitv 2 100% of the manufacturer's ratino. Degradation is indicated, accordinq to IEEE-450 (Ref. 1), when the battery capacity drops bv more than 10% relative to its capacitv on the previous performance test or when it is 10% below the manufacturer's ratinq. All these Frequencies are consistent with the recommendations in IEEE-450 (Ref. 1).

PERRY - UNIT 1 B 3.8-70 Revision No.

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY Batteryell Parameters B 3.8.6 Table 3,8,6 1 This table delineates the limits en eleetrelyte level; fleaf veltage; and Categery A defines the nermal parameter limit fer eaeh designated pilet Tha t^.:*Er{Arv A !irni*c- onani{iarl fnr alan*rnlrr*a larral .=ra haaar.l nn in IEEE 450 (Ref, 3); with the extra 1/1 ineh allewanee abeve the maxirnum eharge effeets, ln additien te this allewanee; feetnete (a) te Table 3,8,6 1 dsring equalizing eharge; previded it is net everflewing= These limits eenditiens, IEEE I50 (Ref, 3) reeemmends that eleetrelyte level readings least 72 heurs, The Categery A limit speeified fer fleat veltage is > 2,13 V Ber cell, This value is based en the reeemmendatien ef IEEE 150 (Rf, 3); whieh states that prelenged eperatien ef eelle berew 2,13 V ean reduee the life The Categery A limit speeified fer speeifie gravity fer eaeh pilet eell is

> 1,200 fer Biyisiens 1 end 2 and > 1,195 fer Divisien 3 (0,015 belsw the e

eharaeteristie ef a eharged eell with adequate eapaeity, Aeeerding te The speeifie gravity readings are eerreeted fer aetual eleetrelyte temperature and level, Fer eeeh 3'F (1,67C) abeve 77"F (25"C), 1 peint 77oF, The speeifie gravity ef the eleetrelyte in a eell inereases with a less ef water due te eleetrelysis er evaperatien, tevel eerreetien will be in Categery B defines the nermal parameter limits fer eaeh eenneeted eell.

The term "eenneeted eell" exeludes any battery eell that may beiumpered uL The Gategery B limits speeified fer eleetrelyte level and-fleat veltage are the same as these speeified fer Categery A and been diseussed abeve, The Categery B Iimit speeified fer sBeeifie gravity fer eaeh eenneeted eell i

PERRY - UNIT 1 B 3.8-70 Revision No.

I

TS BASES MARK.UP . PROVIDED FOR INFORMATION ONLY Batteryel{ Parameters B 3.8.6 fer Divisien 3 (0,010 belew the manufaeturer's fully eharged, neminal These values are based en manufaeturer's reeemmendatiens, The altheugh redueed' Brevide assuranee that suffieient eaBaeity exists te The Categery C limit speeified fer eleetrelyte level (abeve the tep ef the ptates and net evem damage and rnaintain adequate eleetren transfer eapability, The that a eell veltage ef 2,07 V er belew;-under fleat eenditiene end net preblems and may require eell replaeement, The.Categery Climit ef average sBeeifie g+avity.(8,:1.,195-fer Divisien 1 reeemmendatiens (0,020 belew the rnanufaeturer's reeemmended fully eharged; neminal'speeifie gravity), ln aCditien te tha[,limit; .it is reguired The feetnetes te Table 3,8,6 1 that apply te sFeeifie gravity are applieable Feetnete (b) in Table 3,8,6 1 requires the abeve-mentiened eerretien fer isn is net required when battery eharging Gurrent is a 2 emps en fleet charge, This eurrent prevides' in general' an indieatien ef everall baBeeause ef grevity te stebili-e (4 te Table 3,8.6-1 allews the fleat eharge eurrent te be used as an Wthin 7 days eaeh eenneeted eell's speeifie gravity rnust be measured ta PERRY - UNIT 1 B 3.8-71 Revision No. 4

TS BASES MARK.UP - PROVIDED FOR INFORMATION ONLY Batteryell Parameters B 3.8.6 EAH REFERENCES 1. IEEE _ 450.

2. USAR, Chapter I 3+ USAR, Chapter 6.

!2. USAR, Chapter 15.

5. IEEE Standard 485, 1983.

PERRY - UNIT 1 B 3.8-72 Revision No, 4 I

Enclosure B L-17-247 Letters from Battery Manufacturers VeriflTing the Acceptability of Using Float Current Monitoring (2 Pages Follow)

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Power Solutions 1400 Union Meeting Road Blue Bell, PA L9422 Phonei (215) 775-1314 Fax: (215) 6L9-7887 Sent via Email to: ipettv@firstenerqvcorp.com October 6,2017 Mr. Justin Petty First Energy Corp.

Subject Perry Nuclear Plant - Using FIoat Current for State of Charge

Dear Justin:

ln regards to the C&D battery model KCR in safety related (Class 1-E) applications at Perry, it is acceptable to use float current monitoring instead of specific gravity monitoring as a reliable and accurate indication of the state of charge of the battery.

This relationship remains valid for the Iife of these batteries.

For technical basis, please reference IEEE 450-2010, Annex A.2, which indicates in part:

4.2 Stabllized charglng current used to determlne a fully charged condltlon The paftcrn of charging curcnl dclivcrcd by a conventional voltage,regutetcd clrargcr after a dischargc is lb rffi acqnrtc metM for dacrnining tlle surc of clnrge. As the oells ryproach full durgc, ttrc baltcry voltage riscs to ryroach the chargcr orqu voltage, and the charging ctrrnl furcascs. Whcn the charging qmtrf has subilizcd ot tlrc charging voltage for throe consecutive bouty mruromcnts, tlrc baucry is ncar futl cbuge. Thc cxpccted charging cunent rmgc applicable to cach modcl mry be vcrified by tcst or in oonsultation with the manufacturcr.

I hope that this information meets your needs. If you require any additional information, please contact me.

Regards, 4,n t,@

Larry A. Carson Sr. Product Manager - Utility & Nuclear C&D Technologies, lnc.

EnerSys P.O. Box 14145 Reading, PA 1961 2-4145 800-538-3627 x 1680 Fax 610-208-1971 Email : ian.reber@enersvs.com Povver/Fctll SoLrtiorr s'

wffiil,enersvs.com Jan G. Reber Director of RP Assembly Engineering Technology & Engineeing 10t20t17 Justin Petty Plant Engineering Perry Nuclear Power Station Mail Stop PYA-250 10 Center Rd Perry, OH 44081 Re: Use of Stabilized Float Current for SOC determination for EnerSys GN Batteries

Dear Mr. Petty,

EnerSys confirms that a stabilized float current is a necessary condition to determine that a baftery is approaching a full state of charge. This value, however, is a variable of battery size and float voltage. lt is also dependant on temperature and to a lesser degree on battery age and manufacturing process variation. Due to the asymptotic nature of the charge current to state of charge relationship, EnerSys states that there exists a float cunent value that can be selected for each battery type that, given no other extraneous conditions, can be used to justiff that the monitored battery has achieved more than a particular state of charge assuming all other monitored individual attributes of the system are within the guidelines of IEEE 450.

It would be ideal to develop this value for each individual battery specifically to account for individualvariations in battery and system circumstiances. However, if we assume operating parameters of a nominal string average cell voltage and an average 72-80"F battery temperature, a reasonable estimate of the capacity returned to the battery can be made based on a particular float current by battery type and float voltage. This value is referenced to the full charge capacity that the battery is capable of at the time the measurement is taken.

With the above stipulations as prerequisites, it can be reasonably assumed that when the float current is less than or equal to a2 amp threshold the 60 cell and 61 cell 2GN-15 station batteries located at Perry NPS will have achieved a nominal returned capacity. The capacity values for the two string counts at a stabilized nominal 135 Volt are as listed below. These values are expected to be valid for the service life of the bafteries. Note: this evaluation requires that a positive float current is verified, i.e. that the battery has not experienced an open, resulting in zero or virtually zero float current.

2 GN-15 string count floating at 135 VPC Percentage of Available Capacity Returned (Measured Float Current is < or = 2 amps) 60 cell (2.25VPC) 96 61 cell (2.21VPC) 92 These values have been determined from review of internal recharge curves and Tafel plots from various GN tests, scaled to size. The estimations are, in EnerSys opinion, conservative.

lf you have any questions regarding this letter, please contact me.

ftaL Sincerely, Jan G. Reber Cc: File 352, G. Brendahl, S. Vechy, B. Ross

v t e Letter Sequence Request
EPID:L-2017-LLA-0438, TSTF-360 (Withdrawn, Closed)
Initiation Request Acceptance Administration Questions Answers Results Withdrawal Other: ML18135A427
MONTHYEAR2018-01-24 [Table View]

L-17-247, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360

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Enclosures:

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1.0 DESCRIPTION

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

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3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

Dear Justin:

Dear Mr. Petty,

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L-17-247, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360

Text

SUBJECT:

Enclosures:

Subject:

1.0 DESCRIPTION

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

1.0 DESCRIPTION

Description:

3.0 REGULATORY ANALYSIS

4.0 ENVIRONMENTAL CONSIDERATION

5.0 REFERENCES

Dear Justin:

Dear Mr. Petty,

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