L-2011-072, Proposed Changes to Technical Specifications Regarding D.C. Sources Surveillance Requirements License Amendment Request (LAR) No. 210

From kanterella
(Redirected from L-2011-072)
Jump to navigation Jump to search
Proposed Changes to Technical Specifications Regarding D.C. Sources Surveillance Requirements License Amendment Request (LAR) No. 210
ML110670224
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 03/03/2011
From: Kiley M
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2011-072, LAR 210
Download: ML110670224 (22)
v • d • e


Text

0 MAR 32011 L-2011-072 IFPL. 10 CFR 50.90 POWERING TODAY.

EMPOWERING TOMORROW.

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 2055-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed Change to Turkey Point Technical Specifications Regarding D.C. Sources Surveillance Requirements License Amendment Request (LAR) No. 210 Pursuant to 10 CFR 50.90, Florida Power & Light (FPL) hereby requests a License Amendment to Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4. The proposed amendment would modify Technical Specification (TS) Surveillance Requirements (SR) 4.8.2.1 pertaining to periodic verification of battery bank capacity and intercell and connection resistance. FPL requests approval of the proposed amendment prior to February 2012, with the amendment being implemented within 60 days of its receipt by FPL. There are no new commitments made in this submittal.

The Enclosure to this letter contains a description of the proposed changes and includes a no significant hazards determination and environmental considerations.

The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1), using the criteria in 10 CFR 50.92(c) and FPL has determined that the proposed changes do not involve a significant hazards consideration.

The Turkey Point Nuclear Safety Committee (PNSC) has reviewed the proposed license amendments. In accordance with 10 CFR 50.91(b)(1), a copy of this letter is being forwarded to the State Designee of Florida.

Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto, Licensing Manager, at 305-246-7327.

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

DOI an FPL Group company

Turkey Point Nuclear Plant L-2011-072 Docket Nos. 50-250 and 50-251 Page 2 of 2 License Amendment Request No. 210 Executed on March ., ,2011 Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant Enclosure cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Mr. W. A. Passetti, Florida Department of Health

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License. Amendment Request No. 210 Page 1 of 15 Turkey Point Units 3 and 4 LICENSE AMENDMENT REQUEST NO. 210 PROPOSED CHANGE TO TURKEY POINT TECHNICAL SPECIFICATIONS REGARDING D.C. SOURCES SURVEILLANCE REQUIREMENTS ENCLOSURE

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 2 of 15 TABLE OF CONTENTS LICENSE AMENDMENT REQUEST PROPOSED CHANGE TO TURKEY POINT TECHNICAL SPECIFICATIONS REGARDING D.C. SOURCES SURVEILLANCE REQUIREMENTS SECTION TITLE PAGE Cover Sheet 1 Table of Contents 2

1.0 Purpose and Scope

3 2.0 Background Information 3 3.0 Description of Proposed Changes 4 4.0 List of Commitments 12 5.0 Conclusion 12 6.0 No Significant Hazards Determination 12 7.0 Environmental Considerations 15 ATTACHMENT 1 1.0 Technical Specification Markups

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 3 of 15

1.0 Purpose and Scope

Florida Power and Light Company (FPL) proposes to revise the Turkey Point (PTN)

Units 3 and 4 licensing basis by amending Technical Specification (TS) Surveillance Requirement (SR) 4.8.2.1 to incorporate the enclosed TS revisions. The proposed TS changes would relocate the TS SR 4.8.2.1 .b.2 and c.3 to the plant battery maintenance procedures and revise the 18 and 60 month battery performance discharge test service life and capacity acceptance values of TS SR 4.8.2.1 .e and f.

2.0 Background Information The NRC 2008 CDBI audit requested documentation demonstrating that the Safety Related (SR) battery calculation of record accounts for the inter-cell resistance. The safety related battery voltage drop calculation of record (PTN-BFJE-94-002) is based on the inter-cell resistance acceptance criteria values established in plant maintenance surveillance procedures, which are lower than the < 150 micro-ohms value established in Technical Specification (TS) Surveillance Requirements (SR) 4.8.2.1. The calculation shows compliance with the design basis requirements of the safety related battery system.

However, compliance can not be demonstrated in the calculation using the maximum TS SR value of 150 micro-ohms for the battery cell interconnection resistance. This evaluation provides the basis for requesting that the requirement to verify the intercell connections resistance value be removed from TS SR 4.8.2.1. Successful results of the TS SR functional discharge and capacity testing inherently validates the acceptability of the intercell connections. The inter-cell resistance acceptance criteria values would remain controlled by the plant maintenance procedures and accounted for in the SR battery calculation of record.

During the engineering review of the safety related battery sizing calculation, it was also identified that Battery 4D03 / 4B and Battery D52 / Spare (when used in place of Battery 4B) are sized with an aging factor less than the IEEE standard 20 years (Aging Factor 125%). The basis /intent of TS SR 4.8.2.1.e and f battery service life and capacity values are based on an Aging Factor of 125% / 20 year life expectancy design. Thus, the 85% of service life value in TS SR 4.8.2.1.e and a battery discharge capacity value of at least 80% of manufacturer's rating in TS SR 4.8.2.1.f are considered non-conservative. This evaluation provides the basis for requesting that the 18 and 60 month TS SR battery performance discharge test service life and capacity acceptance values be revised to values based on the 115% aging factor /18.6 years (worst case), established in the battery calculation, for Battery 4D03 / 4B and Battery D52 / Spare (when used in place of Battery 4B). Both batteries are presently > 100% of manufacturer rating capacity which is well above the required design basis loading capacity. In addition, the Spare (D52) battery is 1 year old and 4B is only in its' 1 0 th year of operation. The other safety related batteries are sized with an Aging Factor of 125% / 20 years.

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 4 of 15 3.0 Description of Proposed Changes This evaluation provides the basis for the following proposed changes to TS SR 4.8.2.1:

" Request to relocate the cell connection resistance limits form TS SR 4.8.2.1 .b.2 and c.3 to the plant battery maintenance procedures.

" Request to revise the 18 and 60 month battery performance discharge test service life and capacity acceptance values of TS SR 4.8.2.1.e and f for Batteries 4B and D52 / Spare (when used in place of Battery 4B) to values based on the 115% aging factor / 18.6 years (worst case - D52) established in the battery calculation / design.

Proposed Technical Specification Surveillance Requirement Changes:

The applicable wording in the affected sections of TS SR 4.8.2.1 currently read:

b. At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts, by verifying that:
1) The parameters in Table 4.8-2 meet the Category B limits,
2) There is no visible corrosion of either terminals or connectors, or the connection resistance is less than 150 x10-6 ohms, and
3) The average electrolyte temperature of every sixth cell is above 60'F.
c. At least once per 18 months by verifying that:
1) The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration,
2) The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material,
3) The resistance of each cell-to-cell and termination connection is less than or equal to 150 x10-6 ohms, and
4) Each 400 amp battery charger (associated with Battery Banks 3A and 4B) will supply at least 400 amperes at > 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and each 300 amp battery charger (associated with Battery Banks 3B and 4A) will supply at least 300 amperes at > 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 5 of 15

d. At least once per 18 months, during shutdown**, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.
e. At least once per 18 months, during shutdown**, by giving performance discharge tests of battery capacity to any battery that shows signs of degradation or has reached 85% of the service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% of rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.
f. At least once per 60 months, during shutdown**, by verifying that the battery capacity is at least 80% of the manufacturer's rating when subjected to a performance discharge test. Once per 60-month interval this performance discharge test may be performed in lieu of the battery service test required by Specification 4.8.2.1 .d.

After implementation of the proposed amendment, the wording in TS SR 4.8.2.1 would read as follows:

b. At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts, by verifying that:
1) The parameters in Table 4.8-2 meet the Category B limits, and
2) There is no visible corrosion of either terminals or connectors, or-the

,,nneetions r..,i ..tan.. is less than 150 x10 4 -e , and

3) The average electrolyte temperature of every sixth cell is above 60'F.
c. At least once per 18 months by verifying that:
1) The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration,
2) The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material,
3) The r-esistance of each eel! to cce11 and termnination connection is less tha or equal to 150 xlO0 eo-hs, and DELETED
3) Each 400 amp battery charger (associated with Battery Banks 3A and 4B) will supply at least 400 amperes at > 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 6 of 15

4) each 300 amp battery charger (associated with Battery Banks 3B and 4A) will supply at least 300 amperes at > 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
d. At least once per 18 months, during shutdown**, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.
e. At least once per 18 months, during shutdown**, by giving performance discharge tests of battery capacity to any battery that shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% [7% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of rated capacity from its average on previous performance tests, or is below 90% [93% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturer's rating.
f. At least once per 60 months, during shutdown**, by verifying that the battery capacity is at least 80% [87% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the manufacturer's rating when subjected to a performance discharge test. Once per 60-month interval this performance discharge test may be performed in lieu of the battery service test required by Specification 4.8.2.1 .d.

Basis for the Changes:

Design Basis Requirements System design requirements for the station DC power sources for Turkey Point Units 3 and 4 are provided in the UFSAR and Turkey Point Design Basis Document. The following are applicable excerpts:

Applicable Regulatory Commitments:

The Technical Specifications (TSs) ensure the operational capability of structures, systems and components that are required to protect the health and safety of the public.

The U.S. Nuclear Regulatory Commission's (NRC's) requirements related to the content of the TSs are contained in Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR 50.36) which requires that the TSs include items in the following specific categories: (1) Safety Limits, Limiting Safety Systems Settings, and Limiting Control Settings; (2) Limiting Condition for Operation; (3) Surveillance Requirements per 10 CR 50.36(c)(3); (4) Design Features; and (5) Administrative Controls.

This amendment is related to the third category, surveillance requirements per 10 CR 50.36(c)(3).

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 7 of 15 The following regulatory requirements and guidelines documents apply to the affected DC sources:

Turkey Point Units 3 and 4 were designed prior to the implementation of 10 CFR 50, Appendix A, General Design Criteria (GDC) for Nuclear Power Plants, and utilized the criteria of 1967 proposed GDC 39, Emergency Power for Engineered Safety Features, in the design of the site electric power systems. Subsequently, 1967 proposed GDC 39 was implemented in 1971 as GDC 17, Electric power systems, and established more specific requirements than previously identified. An evaluation of the site electrical system design was performed in 1982 and concluded (

Reference:

FPL letter L-82-509, November 16, 1982) that Turkey Point complies with the requirements of GDC 17.

Criteria: 1. 1967 Proposed GDC 39 "Alternate power systems shall be provided and designed with adequate independency, redundancy, capacity and testability to permit the functioning required of the engineered safety features. As a minimum, the onsite power system and the offsite power system shall each, independently, provide this capacity assuming a failure of a single active component in each system."

2. GDC 17, Electric Power Systems In order to satisfy the above criteria, independent alternate power systems are provided for each unit. These alternate power systems have adequate capacity to supply the power required for engineered safety features and protection systems. The following normal, standby and emergency power sources are available:
1. The source of auxiliary power during normal operation is the main generator and switchyard. The auxiliary transformer is connected to the generator isolated phase bus and the C bus transformer is connected to the switchyard. Both supply power to the 4.16 kV system.
2. Standby power during unit startup, shutdown and after unit trip is supplied from a startup transformer and a C bus transformer, which are connected to the switchyard 240 kV bus and feed the 4.16 kV system.
3. Four Emergency Diesel Generators (EDGs). supply emergency power. Each EDG is connected to a separate power train, two per unit. With any credible single failure, the EDGs are capable of assuring a safe shut down of both units with a loss of offsite power concurrent with Maximum Hypothetical Accident (MHA) conditions in one unit.
4. Emergency power for vital instrumentation and controls is supplied from four 125V DC station batteries. Each is capable of feeding its associated load for two hours without charging. A spare 125V DC Station Battery is also provided which can be

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 8 of 15 substituted for any of the four 125V DC Station Batteries to allow for maintenance or testing.

5. For each unit, a non-safety related 125V DC bus provides power to the non-safety related C-bus 4.16 kV and 480V switchgear, C-bus transformer relay panels and the turbine emergency oil pumps.

UFSAR:

Section 8.1.1 states that: "Each (battery) is capable of feeding its associated load for two hours without charging. A spare 125V DC Station Battery is also provided which can be substituted for any of the four 125V DC Station Batteries to allow for maintenance or testing."

Section 8.2.2.3 of the UFSAR describes the station DC power systems. Emergency power for vital instrumentation and controls is supplied by a station DC power system that contains five safety related 125V batteries and four DC distribution panels. Two battery banks are associated with each unit, one 1800 Ampere-Hour (AH) and one 1200 AH (all ratings are for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at 77°F). Each 1800 AH battery bank has two safety related full capacity 400 Ampere solid-state battery chargers associated with it, while each 1200 AH has two safety related full capacity 300 Ampere solid-state battery chargers associated with it. The spare battery bank is normally isolated from the vital DC buses and maintained in a fully charged condition by a non-safety related battery charger, The spare 1945 AH station battery is an equivalent source for any of the four station batteries during maintenance or testing, and allows continuous operation of the units without entering into a Limiting Condition for Operation while performing these functions.

Each battery has been sized to support operation of its required loads for two hours without terminal voltage falling below its minimum required value. The capability of the safety related batteries to provide required power is demonstrated by the performance of 30 minute service and performance tests in accordance with the plant's Technical Specifications. This service testing time of 30 minutes is conservatively based on the time required to manually load a charger during a station blackout event.

Design Basis Document (DBD) 5610-003-DB-002 Vital AC/DC System Each battery shall be capable of providing power to its loads for 30 minutes during a Loss of Offsite Power event, without the battery terminal voltage falling below 105 volts for 3D03, 4D03 and 4D24, below 105.59 volts for battery 3D24, and below 108.6 volts for battery D52.

Each battery required to provide power source to the Auxiliary Feedwater System pump trains shall provide power to the Auxiliary Feedwater pump train for at least two hours

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 9 of 15 during a loss of all offsite and onsite AC power to assure operation of one Auxiliary Feedwater System pump train. This is a post-TMI commitment.

Each battery shall be sized to provide power to its loads for two hours during a design basis accident concurrent with a Loss of Offsite Power (LOOP) without terminal voltage falling below 105 volts for batteries 3D03, 4D03 and 4D24, below 105.59 volts for battery 3D24, and below 108.6 volts for battery D52.

Each battery shall be load tested in accordance with Technical Specifications 4.8.2.1.d, 4.8.2.1.e and 4.8.2.1.f to demonstrate its capability to provide power to its loads following a LOOP without the terminal voltage falling below 105 volts for batteries 3D03, 4D03 and 4D24, below 105.59 volts for battery 3D24, and below 108.6 volts for battery D52.

Request to relocate the cell connection resistance limits from TS SR 4.8.2.1.b.2 and c.3 to the plant battery maintenance procedures.

The safety related battery voltage drop calculation of record is based on the inter-cell resistance acceptance criteria values established in plant maintenance surveillance procedures, which are lower than the < 150 micro-ohm value established in Technical Specification (TS) Surveillance Requirements (SR) 4.8.2.1. The calculation shows compliance with the design basis requirements of the safety related battery system.

However, compliance can not be demonstrated using the maximum TS SR value of 150 micro-ohms for the battery cell interconnection resistance in the calculation. Note: a clean tight inter-cell connection resistance (baseline) is less than 30 micro-ohms.

The vendor (Gould-National Battery) performance data (fan curves) accounts for inter-cell connector resistance (i.e., cells are connected in series during testing) that is used in Turkey Point Units 3 and 4 battery calculation of record, PTN-BFJE-94-002. However, the vendor does not record the inter-cell connector resistance during battery testing. It can be conservatively assumed that the vendor connector resistance during testing was as least as good as the baseline value for a clean, tight connection established in Turkey Point Units 3 and 4 battery procedures 0-SME-003.03, 003.4 and 003.15. The calculation also includes the Maintenance Limit Allowable Value (MLVA) margin (5 to 7 micro-ohms) above the baseline resistance value for a proper connection, since it is not considered accounted for in the battery data performance curve. Resistances for cable transition connections are also included in the calculation. Thus, the cell connector resistances are accounted for in the battery calculation. The battery calculation demonstrates compliance with the licensing design basis requirements of the battery system.

Turkey Point Units 3 and 4 battery maintenance procedures 0-SME-003.03 (Battery Quarterly Maintenance), 003.4 (Battery Refueling Interval Maintenance) and 003.15 (Battery Monthly Maintenance), ensure that all battery terminations are clean, properly torqued and meet the MLVA limit allowable value for resistance. The TS SR battery

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 10 of 15 discharge and capacity testing demonstrates that the battery is capable of meeting the Turkey Point Units 3 and 4 licensing design basis requirements. Therefore, satisfactory results of the TS SR battery discharge and capacity testing inherently validates the acceptability of the intercell connections. Thus, relocating the cell connection resistance limits from TS SR 4.8.2.1 to the plant battery maintenance procedures does not diminish the ability of the TS surveillance to ensure that the battery is capable of meeting the Turkey Point Units 3 and 4 licensing design basis requirements.

Review of the latest (Rev. 3, 3/31/04) NUREG 1431 Standard Technical Specification for Westinghouse plants shows that the requirement to verify the resistance of each battery cell-to-cell and termination connection has been removed. The licensees are required to have a maintenance program to monitor battery parameters based on recommendations of IEEE Standard 450-1995. Turkey Point Units 3 and 4 request to relocate the battery cell connection resistance limits from TS SR 4.8.2.1 to the plant battery maintenance procedures is consistent with this approach.

Based on the above evaluation, the proposed change to TS SR 4.8.2.1 .b.2 and c.3 to relocate the cell connection resistance limits to the plant battery maintenance procedures does not reduce the capability of the surveillance from detecting a battery condition that is not in compliance with its' licensing design basis requirements.

Request to revise the 18 and 60 month battery performance discharge test service life and capacity acceptance values for TS SR 4.8.2.1.e and f for Batteries 4B and D52 Spare (when used in place of Battery 4B) consistent with the battery design basis calculation.

The safety related battery sizing calculation (PTN-BFJE-94-002) identifies that Battery 4B / 4D03 and Battery D52 / Spare (when used in place of Battery 4B) are sized to an aging factor of 115% / 18.6 years (worst case - spare) instead of the IEEE Standard 485-1997 of 20 years (Aging Factor 125%). The other safety related batteries are sized to meet IEEE standard 20 years (Aging Factor 125%). The TS SR 4.8.2.1.e and f battery service life and capacity values are based on a 125% aging factor / 20 year life expectancy design in accordance with the IEEE Standard. Thus, the 85% of service life value in TS SR 4.8.2.1.e and a battery discharge capacity value of at least 80% of manufacturer's rating in TS SR 4.8.2.1 .f are considered non-conservative for Batteries 4B and D52 / Spare (when used in place of Battery 4B). This evaluation provides the basis for requesting that the 18 and 60 month battery TS SR performance discharge test service life and capacity acceptance values be revised to reflect an Aging Factor of 115% / 18.6 year life for Battery 4B / 4D03 and Battery D52 / Spare as established in the battery calculation. The TS SR values for the other safety related batteries will remain unchanged.

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 11 of 15 IEEE 485-1997 recommends the use of an aging factor of 1.25 (125%) when initially sizing a battery. The aging factor of 125% ensures that at least 80% of battery nameplate capacity will be available at the end of its' expected battery life and this will be sufficient to serve 100% of the design load. The aging factor essentially oversizes the required number of positive plates per battery cell in a battery bank to ensure that the duty cycle load profile of the battery is met throughout the expected 20 year life of the battery. The vendor's typical expected battery life curve indicates a 100% battery capacity over the initial 14 years. The capacity then decreases to 80% at the end of the expected 20-year life at which point the battery bank is recommended for replacement per IEEE 450-1995.

An aging factor of 1.15 (115%) essentially reduces the battery service life to 18.6 years during which time the battery would have sufficient capacity to provide 100% of the power requirements for the design load.

Review of the current surveillance test results show that both batteries Spare (D52) and 4B (4D03) are > 100% of rating. Battery D52 / Spare is in its first year and Battery 4B is in its 10th year, well within the 18 years of the expected designed service life.

The proposed change to TS SR 4.8.2.1.e, changes the service life value for incre'ased monitoring from 85% / 17 years (20 years x 0.85 = 17 years) to 75% / 15 years for Battery 4B / 4D03 and Battery D52 / Spare (when used in place of Battery 4B). The intent of this surveillance requirement and selected value is to ensure that the battery is tested when it is in the period where its capacity is expected or known to start decreasing due to age and prior to reaching the 100% of the required design basis loading capacity.

The proposed change maintains the present testing of at least three years prior to the battery's designed established end of service life (i.e., design basis load requirements). As such, Batteries 4B and D52 (Spare) would be tested 3.6 years prior to their designed end of service life of 18.6 years consistent with the intent of the existing TS SR. The degradation indication values would also be changed to maintain the TS SR intent of increase monitoring when the battery begins to show decreasing capacity. The battery capacity criteria for when it drops more than 10% of rated capacity from its average on previous performance tests will change to 7% and the below 90% of the manufacturer's rating will change to 93%. The TS SR values for the other safety related batteries (i.e.,

3A / 3D03, 3B / 3D24 and 4A / 4D24) will remain unchanged.

The proposed change to TS SR 4.8.2.1 .f changes the battery capacity requirement from at least 80% to 87% of manufacturer's rating for Battery 4B / 4D03 and Battery D52 / Spare (when used in place of Battery 4B). This retains the intent of the present TS SR to ensure that during the latter years of the expected battery life, there will be sufficient capacity to serve 100% of the design load. The TS SR values for the other safety related batteries (i.e., 3A / 3D03, 3B / 3D24 and 4A / 4D24) will remain unchanged.

Based on the above evaluation, the proposed changes to TS SR 4.8.2.1.e and f reflect the intent of the TS SR to ensure that sufficient battery capacity to serve 100% of the design basis load is available throughout the expected life of the battery, thus meeting all licensing requirements identified in the UFSAR and DBD.

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 12 of 15 Plant Procedures 0-SME-003.15 and 0-SME-003.4 are being revised to identify the more limiting criteria to ensure that any degrading battery capacity is identified well before Batteries 4B and D52 / Spare (when used in place of Battery 4B) reach their limiting design basis loading capacity.

4.0 LIST OF COMMITMENTS NONE

5.0 CONCLUSION

Based on the above, the ability of the TS surveillance to ensure that the batteries have the capacity to perform their specified safety functions with regard to accident mitigation and meeting their licensing design basis requirements is not reduced / diminished.

6.0 NO SIGNIFICANT HAZARDS DETERMINATION Per 10 CFR 50.92, No Significant Hazard is involved if operation of the facility in accordance with the proposed amendment would not:

(a) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (b) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (c) Involve a significant reduction in a margin of safety The proposed changes are to the Technical Specification (TS) Surveillance Requirement (SR) 4.8.2.1 associated with the 125-volt battery banks and are summarized as follows:

Request to relocate the battery cell connection resistance limits from TS SR 4.8.2.1.b.2 and c.3 to the plant battery maintenance procedures. The maintenance allowable values in plant procedures for battery termination resistance are lower /

more restrictive. TS SR battery discharge and capacity testing inherently validates the acceptability of the inter-cell connections. Thus, the ability of the TS surveillance to ensure that the batteries have the capacity to perform their specified safety functions with regard to accident mitigation or meeting their licensing design basis requirements is not reduced / diminished.

" Request to revise the 18 and 60 month battery performance discharge test service life and capacity acceptance values for TS SR 4.8.2.1.e and f to values based on the battery calculation / battery design for Batteries 4B and D52 / Spare (when used in place of Battery 4B). The proposed changes provide more restrictive battery capacity and service life surveillance requirements and ensure that the batteries can perform their specified safety functions with regard to accident mitigation and meeting their licensing design basis requirements.

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 13 of 15 Evaluation of the proposed changes in accordance with the 10 CFR 50.92 criteria is provided below:

(a) Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed changes are to the surveillance requirements only. The ability of the TS surveillance to ensure that the batteries have the capacity to perform their specified safety functions with regard to accident mitigation or meeting their licensing design basis requirements is not reduced / diminished.

There are no design changes associated with this TS amendment. The DC power system /

batteries will remain designed with adequate independency, redundancy, capacity and testability to permit the functioning required of the engineered safety features. The batteries will each continue to independently provide this capacity assuming a failure of a single active component.

The proposed changes will not affect accident initiators or precursors, not adversely alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated. The proposed changes will not alter or prevent the ability of structures, systems and components from performing their intended functions to mitigate the consequences on an initiating event.

The proposed changes do not physically alter safety related systems nor affect the way in which safety related systems perform their function.

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

(b) Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed changes are to the surveillance requirements only. The ability of the TS surveillance to ensure that the batteries have the capacity to perform their specified safety functions with regard to accident mitigation or meeting their licensing design basis requirements is not reduced / diminished.

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 14 of 15 There are no proposed design changes nor are there any changes in the method by which any safety related plant structure, system, or component (SSC) performs its specified safety function. The proposed changes will not affect the normal method of plant operation or change any operating parameters. Equipment performance necessary to fulfill safety analysis missions will be unaffected. The proposed change will not alter any assumptions required to meet the safety analysis acceptance criteria.

No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of this amendment. There will be no adverse effect or challenges imposed on any safety related system as a result of this amendment.

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

(c) Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed changes do not reduce the ability of the TS surveillance requirements to ensure that the station batteries have adequate capacity to perform their engineered safety features functions with regard to accident mitigation and meeting their licensing design basis requirements. The battery inter-cell connection resistance acceptance criteria, which are more restrictive values, will be appropriately controlled in the maintenance procedures and the connections quality inherently validated by the TS SR battery performance testing.

The new values for the battery capacity and service life surveillance requirements are more appropriate acceptance criteria for verifying battery performance.

The proposed changes do not physically alter safety related systems. There will be no effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on the overpower limit, departure from nucleate boiling (DNBR) limits, loss of cooling accident peak cladding temperature (LOCA PCT), or any other margin of safety. The applicable radiological dose consequence acceptance criteria will continue to be met. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Conclusion:

Based on the above evaluation, it is concluded that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request No. 210 Page 15 of 15

7.0 ENVIRONMENTAL CONSIDERATION

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

Turkey Point Units 3 and 4 L-2011-072 Docket Nos. 50-250 and 50-251 Attachment 1 License Amendment Request No. 210 Turkey Point Units 3 and 4 LICENSE AMENDMENT REQUEST NO. 210 PROPOSED CHANGES TO TURKEY POINT TECHNICAL SPECIFICATIONS REGARDING D.C. SOURCES SURVEILLANCE REQUIREMENTS ATTACHMENT 1 TECHNICAL SPECIFACTIONS MARKUPS This coversheet plus 4 pages

Markup of Proposed Changes The attached markup reflects the currently issued revision of the Technical Specifications listed below. Pending Technical Specifications or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed markup.

The following Technical Specifications are included in the attached markup:

Technical Specifications Title Page(s)

Index, Section 4.8.2 Surveillance Requirements xi Specification 3 / 4.8.2 Electrical Power Systems 3 / 4.8-14,15

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 AC SOURCES O p e ra tin g ................................................................................................... 3/4 8-1 TABLE 4.8-1 ............................................. NO T US E D ............................................... 3/4 8-10 S h u td o w n ................................................................................................... 3/48-11 3/4.8.2 DC SOURCES O p e ra tin g ................................................................................................... 3/4 8-13 TABLE 4.8-2 BATTERY SURVEILLANCE REQUIREMENTS ............................................. 3/4 8-16 S h u td o w n ................................................................................................... 3/4 8-17 3/4.8.3 ONSITE POWER DISTRIBUTION O p e ra tin g ................................................................................................... 3/4 8-18 TABLE 3.8-1 APPLICABLE TO UNIT 3 BASED ON UNIT 4 LOAD CENTERS AND MOTOR CONTROL CENTERS INOPERABLE ALLOWABLE O UTA G E T IM E S ............................................................................................ 3/4 8-21 TABLE 3.8-2 APPLICABLE TO UNIT 4 BASED ON UNIT 3 LOAD CENTERS AND MOTOR CONTROL CENTERS INOPERABLE ALLOWABLE O UTA G E T IM E S ............................................................................................ 3/4 8-22 S h u td ow n ................................................................................................... 3/4 8-23 TURKEY POINT.- UNITS 3 & 4 xi AMENDMENT NOS. 2-3 AND 4-97

D.C. SOURCES LIMITING CONDITION FOR OPERATION ACTION: (Continued)

b. With one of the required battery banks inoperable, or with none of the full-capacity chargers associated with a battery bank OPERABLE, restore all battery banks to OPERABLE status and at least one charger associated with each battery bank to OPERABLE status within two hours* or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This ACTION applies to both units simultaneously.

SURVEILLANCE REQUIREMENTS (Continued) 4.8.2.1 Each 125-volt battery bank and its associated full capacity charger(s) shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying that:
1) The parameters in Table 4.8-2 meet the Category A limits, and
2) The total battery terminal voltage is greater than or equal to 129 volts on float charge and the battery charger(s) output voltage is _Ž 129 volts, and
3) If two battery chargers are connected to the battery bank, verify each battery charger is supplying a minimum of 10 amperes, or demonstrate that the battery charger supplying less than 10 amperes will accept and supply the D.C. bus load independent of its associated battery charger.
b. At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 105 volts (108.6 volts for spare battery D-52), or battery overcharge with battery terminal voltage above 143 volts, by verifying that:
1) The parameters in Table 4.8-2 meet the Category B limits,
2) There is no visible corrosion at either terminals or connectors, O the oennetin resistance is less than 150 x 10- ohm, and
3) The average electrolyte temperature of every sixth cell is above 60 0 F.
c. At least once per 18 months by verifying that:
1) The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration,
2) The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material,
3) The rercstance of each cel! to cel! and terminal connection is less than er equal to 15 x1-eh6hm, and DELETED
  • Can be extended to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the opposite unit is in MODE 5 or 6 and each of the remaining required battery chargers is capable of being powered from its associated diesel generator(s).

TURKEY POINT - UNITS 3 & 4 3/4 8-14 AMENDMENT NOS. 447 AND 442

D.C. SOURCES SURVEILLANCE REQUIREMENTS (Continued')

4}3) Each 400 amp battery charger (associated with Battery Banks 3A and 4B) will supply at least 400 amperes at _>129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and each 300 amp battery charger (associated with Battery Banks 3B and 4A) will supply at least 300 amperes at > 129 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

d. At least once per 18 months, during shutdown**, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.
e. At least once per 18 months, during shutdown**, by giving performance discharge tests of battery capacity to any battery that shows signs of degradation or has reached 85% [75% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of the service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% [7% for Batteries 4B and D52 (Spare) when used in place of Battery 4B] of rated capacity from its average on previous performance tests, or is below 90% [93% for Batteries 4B and D52 (Spare) when used in place of Battery 4B]of the manufacturer's rating.
f. At least once per 60 months, during shutdown**, by verifying that the battery capacity is at least 80% [87% for Batteries 4B and D52 (Spare) when used in place of Battery 4B]of the manufacturer's rating when subjected to a performance discharge test. Once per 60-month interval this performance discharge test may be performed in lieu of the battery service test required by Specification 4.8.2.1.d.
    • Except that the spare battery bank D-52, and any other battery out of service when spare battery bank D-52 is in service may be tested with simulated loads during operation.

TURKEY POINT - UNITS 3 & 4 3/4 8-15 AMENDMENT NOS. 1-3 AND 4-33

Retrieved from "https://kanterella.com/w/index.php?title=L-2011-072,_Proposed_Changes_to_Technical_Specifications_Regarding_D.C._Sources_Surveillance_Requirements_License_Amendment_Request_(LAR)_No._210&oldid=2120719"