LR-N10-0227, Response to Request for Additional Information - License Amendment Request: One-Time On-Line Safety-Related Battery Replacement

Response to Request for Additional Information - License Amendment Request: One-Time On-Line Safety-Related Battery Replacement

ML101880040
Person / Time
Site:	Salem
Issue date:	06/25/2010
From:	Fricker C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N10-0227
Download: ML101880040 (15)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 0 PSEG NuclearLLC JUN2 a*J ' *10 CFR 50.90 LR-N 10-0227 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Salem Generating Station -Unit 2 Facility Operating License No. DPR 75 NRC Docket No. 50-311

Subject:

Response to Request for Additional Information - License Amendment Request: One-Time On-Line Safety-Related Battery Replacement

References:

(1) Letter from PSEG to NRC, " License Amendment Request: One-Time On-Line Safety-Related Battery Replacement," dated March 29, 2010 In Reference 1, PSEG Nuclear LLC (PSEG) submitted a license amendment request (S10-03) for the Salem Generating Station - Unit 2. This license amendment request proposed changes to Technical Specification (TS) Surveillance Requirements (SR) to allow a one-time replacement of the Salem Unit 2 2C 125VDC battery while at power.. Specifically, SR 4.8.2.3.2 f and g would be revised, on a one time basis, to permit battery testing in a non-shutdown condition. The proposed one-time change is necessary to support the on-line replacement of the existing 2C battery with a new battery tested in accordance with the SR 4.8.2.3.2 f and g.

The NRC provided PSEG a Request for Additional Information (RAI) on the license amendment request. The NRC RAI questions and the PSEG responses are provided in to this letter. Attachment 2 to this letter provides additional proposed changes to the Salem Unit 2 TSs. I PSEG has reviewed the information supporting a finding of no significant hazards consideration that was provided in Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. No new regulatory commitments are established by this submittal.

Should you have any questions regarding this submittal, please contact Mr. Jeff Keenan at (856) 339-5429.

95-2168 REV. 7/99

Document Control Desk 2 LR-N 1 0-0227 I declare under penalty of perjury that the foregoing is true and correct.

JUN 1 5 2010 Executed on (Date)

Sincerel F cker Site ice President - Salem Attachments (2)

CC S. Collins, Regional Administrator - NRC Region I R. Ennis, Project Manager - USNRC NRC Senior Resident Inspector - Salem P. Mulligan, Manager IV, NJBNE Commitment Coordinator - Salem PSEG Corporate Commitment Manager

LR-N10-0227 Attachment 1 REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT ONE-TIME ON-LINE BATTERY REPLACEMENT SALEM NUCLEAR GENERATING STATION, UNIT NO. 2 DOCKET NO. 50-311 By letter dated March 29, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100970064), PSEG Nuclear LLC (the licensee) submitted an amendment request for Salem Nuclear Generating Station (Salem), Unit No. 2. The proposed amendment would revise the Technical Specifications (TSs) to allow a one-time replacement of the 2C 125-volt direct current (VDC) battery while Salem Unit 2 is at power.

The Nuclear Regulatory Commission staff has reviewed the information the licensee provided that supports the proposed amendment and has made a Request For Additional Information (RAI) in order to complete its review.

Question 1 Provide the actual service life of the existing 2C battery and the qualified service life of the existing and the new replacementbatteries.

RESPONSE I The existing 2C battery was installed in October 2000. As of June 2010, the actual service life of the existing 2C battery is nine years and nine months. The qualified service life of the existing and the new replacement batteries is 20 years. The existing 2C battery will be within the manufacturers qualified service life at the time of replacement.

Question 2 Discuss, in detail, the failure mechanism of the 2C battery that caused battery degradation. Provide a detailed technical discussion that demonstratesthat the same failure mechanism does not apply to the other safety-related batteries,the temporary battery, and the new replacement battery.

RESPONSE 2 Two potential failure mechanisms have been identified, low initial capacity, and high ambient temperatures.

The history of the 2C battery has been markedly different from the other Salem Unit 2 safety related stationary batteries. All other batteries had initial capacities of 100% or greater. The 2C battery had an initial capacity of 90%. Stationary batteries are often supplied at 90%

capacity, with capacity increasing to 100% during the first several years of service; however the manufacturer's data sheet for LCR-33'cells states that the cells are supplied with an initial capacity of 100%. The other Unit 2 safety related stationary batteries have capacities greater than 100% as of the most recent performance test (see response to question 6).

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LR-N10-0227 Attachment 1 The two cells with the lowest performance test end voltage were removed from the 2C battery and sent to the battery manufacturer for testing. The cells were given a boost charge and floated to stabilization. The cells were tested for capacity and found to be 89.7%and 90.5%. The cells were visually examined by the vendor and no signs of abnormal degradation were found. The vendor also reviewed the temperature history from the quarterly surveillance data and suggested that the elevated temperatures may have reduced the capacity of the battery due to accelerated aging.

Cell electrolyte temperatures greater than 77 degrees Fahrenheit shorten battery life. The temperatures from the battery quarterly surveillances for the 2C battery performed during summer months were generally greater than 90 degrees Fahrenheit and were recorded as high as 100 degrees Fahrenheit. The other Salem Unit 2 batteries have not experienced the elevated temperatures seen by the 2C battery.

An evaluation of the effect of battery temperature on expected battery life was performed.

The evaluation was based on IEEE 450-2002, Appendix H, using the most recent 5 years of weekly pilot cell temperature measurements. The temperature adjusted expected life of the original battery was estimated to be greater than 15 years. To provide additional conservatism, only 80% of this life (12 years) will be considered. Based on a 12 year life, the existing 2C battery has more than 2 years of remaining life.

28 cells of the battery were replaced in November 2009. The new cells increased the tested battery capacity from 85.3% to 88.2%. Installing new cells in an older battery can result in premature cell degradation of the new and/or old cells. Degradation occurs when all cells cannot be maintained within the manufacturer's allowable float voltage range. This is because the amount of float voltage developed for a given float current differs between groups of cells and changes over the life of the cells. Since all cells are connected in series, and must have the same float current, the float voltage of some cells may be very high while others may be very low. This results in excessive gassing or sulfation, and premature degradation.

The current 2C battery, with its mix of new and old cells, has all cell float voltages within the manufacturer's allowable range and is therefore not subjected to this premature cell degradation. Battery cell parameters are recorded at an increased frequency of monthly. All cell voltages and specific gravities are recorded and all are within the manufacturer's allowable range and Technical Specification requirements for battery cell parameters.

Based on this, the battery will remain operable until replacement.

Question 3. Confirm that the plant will be in a stable condition with no Required Actions in effect at the start of the battery replacement activity necessitatingplant shutdown and no risk significant,planned maintenanceor testing activities which could impactAC or DC normal or emergency electrical distribution sources.

RESPONSE 3 Prior to entering TS 3.8.2.3 ACTION (a), and when the 2C 125 VDC bus is disconnected from the battery, the plant will be maintained in a stable condition (i.e., no power changes) 2

LR-N10-0227 Attachment 1 and testing activities which could impact AC or DC normal or emergency electrical distribution will be prohibited In addition, the risk of the evolution will be managed in accordance with PSEG's procedures for on-line work management. These procedures determine the actions that need to be taken to manage the overall plant risk during the evolution.

Question 4 Provide clarificationwhether the existing 2C battery will be tested and the results recordedfor the "As Found"condition before it is replaced.

RESPONSE 4 Since the existing 2C 125 VDC Battery is known to be degraded and will be replaced there is no requirement or plan to perform any "AS FOUND" testing. Any such testing would not provide any significant operational data and would also add unnecessary time and delays to the overall replacement scheduled window. Two performance discharge tests were recently performed on the battery (October 2009 and November 2009). An additional performance discharge test would not provide information to support failure determination.

Question 5 The 12-month TS surveillance requirement (SR) frequency prescribedby SR 4.8.2.3.2.h is based on the uncertaintyof battery operabilitygiven a degraded condition. This basis is supported by IEEE Standard450, which is the industry consensus document for maintenance and testing of stationarylead-acid batteries. Provide a detailed technical basis for proposing to extend the 12-month test frequency prescribedby SR 4.8.2.3.2.h.

RESPONSE 5 PSEG intends to replace the existing 2C 125VDC Battery prior to the due date for SR 4.8.2.3.2.h as performance of this SR would require unit shutdown. Consequently SR 4.8.2.3.2.h will not need to be performed as discussed in Section 1.0 of LAR S10-03; by replacing the battery SR 4.8.2.3.2.h will no longer be applicable, instead the replacement (new) battery will need to be tested to SR 4.8.2.3.2 f and g. As discussed in Section 3.2 of LAR S1 0-03 PSEG chose on-line replacement versus SR testing extension as there was no precedent for testing extension.

Also as discussed in Section 1.0 of LAR S10-03, PSEG intends to complete the replacement by November 2, 2010 (within the 12 calendar month period from when the battery was last tested and determined to be degraded). However, as a contingency, the allowances of TS 4.0.2 may be utilized (allowing a 25% extension to the SR 4.8.2.3.2.h due date), which would allow completion of the replacement to be extended until February 1, 2011. Even if this contingency is used SR 4.8.2.3.2.h will not need to be performed; SR 4.8.2.3.2.h will no longer be applicable and the replacement (new) battery will need to be tested to SR 4.8.2.3.2 f and g. As discussed in the response to question 2, degradation is not an issue for extending the replacement date by 25%.

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LR-N 10-0227 Attachment 1 Question 6 Provide a summary of the results of the previous capacity tests for the safety-related batteries.

RESPONSE 6 Below is a summary of the previous capacity tests for Salem Unit 2 125VDC Safety Related Batteries:

2A125VDC Battery (Installed 11/2003)

Test Date Capacity 04/2005 100%

10/2009 100%

2B 125 VDC Battery (Installed 4/2002)

Test Date Capacity 03/2002 104%

10/2006 106%

2C 125 VDC Battery (Installed 10/2000)

Test Date Capacity 10/2000 90%

04/2005 96%

10/2009 85.3%

11/2009 88.2%

Question 7 Describe the design and capability of the temporary battery charger,including how it will be connected to a Class 1E supply. Furthermore,describe how the temporary battery chargerwill impact the emergency diesel generatorloading.

Also describe how adequate electricalseparationand isolation will be maintainedand the capabilityof the temporary battery chargerto respond to a seismic event.

RESPONSE 7 To clarify the information contained in the March 29, 2010 submittal, the temporary battery will be powered from the existing Class 1E 2C 125VDC battery charger when it is connected to the Class 1 E DC bus. Since the existing charger is used there is no additional impact to the 2C diesel loading. The additional cabling used to make the connections to the temporary battery will be installed to meet the Salem electrical separation and Appendix R separation criteria as discussed in Attachment 1 Section 4.2 of the March 29, 2010 submittal. The temporary battery and additional cabling will be seismically installed as discussed in Section 4.2 and 4.3 of the March 29, 2010 submittal.

When the temporary battery is installed in the 4160 Volt Switchgear room prior to being connected to the Class 1E DC bus, the temporary battery's charge will be maintained through the use of a temporary charger. This temporary charger will be installed in accordance with PSEG procedures for temporary equipment. The temporary charger will be disconnected from the temporary battery prior to connecting the temporary battery to the Class 1 E DC bus. The temporary battery charger will not be connected to the Class 1E Bus, 4

LR-N 10-0227 Attachment 1 therefore there are no electrical separation or seismic requirements for the temporary battery charger.

Question 8 Provide a list of loads associatedwith Circuit 36 of Panel 2CCDC.

RESPONSE 8 As discussed on page 7 of Attachment 1 of LAR S10-03, there is an existing condition related to Circuit 36:

"The available voltage at each panel during various periods of battery duty cycle is lower than the calculated voltage from PSEG calculation ES-4.003 due to the addition of the temporary 500 MCM cable to the temporary 2C 125VDC battery. However, this is acceptable since the length of the temporary cable will be sized to ensure that the available voltages at the DC panels are still higher than the required voltages per calculation ES-4.003 with the exception of circuit 36 of Panel 2CCDC. This is an existing condition, which was previously determined to be acceptable in the calculation as this circuit is for annunciation only and is not a safety function."

The components of Circuit 36 are acceptable except for one component, a local annunciation remote auxiliary relay, as identified in the table below. This one component is for non-safety related function; PSEG calculation ES-4.003 previously evaluated the acceptability of this condition.

PANEL 2CCDC, CIRCUIT 36 AVAILABLE COMPONENT DESCRIPTION VOLTAGE ID ACCEPTABLE?

YES /NO UV-1 Under Voltage Relay YES IND. LIGHT Indicating Light YES SV-1 418 2C Diesel Generator 23B Starting Air Receiver YES Booster Rack Solenoid Valve (SV-1 418)

SV-889 Air Receiver Solenoid Valve (Full Cycle) YES SV-891 Air Receiver Solenoid Valve (3 seconds cycle) YES SRB Auxiliary Start Relay YES SV-592 Inlet Valves for Jacket & Lube Oil Coolers YES IND. LIGHT Diesel Jacket & Lube Oil Coolers Supply Valve YES Indicating Light SRX Auxiliary Start Stop Relay YES SRAX Auxiliary Start Stop Relay YES DRBX Auxiliary Man Loading Drop Relay YES SPRX Auxiliary Diesel Ready to Load Relay YES OCRX1 Auxiliary Diesel Fail to Start relay YES DUTRX Auxiliary Diesel Unit Trip Relay YES LOX Auxiliary Lockout Relay YES 70X1X Auxiliary Diesel Trouble Acknowledge Relays YES TAX Auxiliary Diesel Trouble Acknowledge Relays YES 5

LR-N 10-0227 Attachment 1 PANEL 2CCDC, CIRCUIT 36 AVAILABLE COMPONENT VOLTAGE ID ACCEPTABLE?

YES / NO DTA Auxiliary Diesel Trouble Acknowledge Relays YES 23FOS-1 Fuel Oil Day Tank Regular Pump Start YES 23FOS-2 Fuel Oil Day Tank Backup Pump Start YES 23FOS-3 Fuel Oil Day Tank Regular Pump Stop YES 23FOS-4 Fuel Oil Day Tank Level Trouble & Over Flow YES Trip Pump Stop IND. LIGHT RP5 (W) - White Indicating Light YES SDR Shutdown Relay YES PSi 2C Diesel Generator 24VDC Power Supply For YES 1STG Speed Switch PS2 2C Diesel, Generator 24VDC Power Supply For YES 2STG Speed Switch PS3 2C Diesel Generator 24VDC Power Supply for YES Interposing Relays Off 1STG Speed Switch DTR Diesel Trouble Local Alarm Reset YES LWHR Water Heater Temperature Low YES HWHR Water Heater Temperature High YES JWTR Jacket Water Temperature High Alarm YES JWTHA Jacket Water Temperature High Alarm YES Auxiliary JWTHR Jacket Water Temperature Shutdown YES CWHR Cooling Water Temperature High YES CWLR Cooling Water Temperature Low YES LOHR Oil Heater Temperature Alarm Low YES HOHR Oil Heater Temperature Alarm High YES LOTR High Lube Oil Temperature Alarm YES LOTHR High Lube Oil Temperature Shutdown YES LOTHA High Lube Oil Temperature Shutdown Auxiliary YES CKPR High Crankcase Pressure YES OPRA Low Oil Pressure Alarm YES OPRL Low Oil Pressure Shutdown YES OPRB Low Oil Pressure Shutdown YES SALIR Start System Low Air Alarm System 1 YES SALIT Start System Low Air Alarm System 1 YES SAL2R Start System Low Air Alarm System 2 YES SAL2T Start System Low Air Alarm System 2 YES LSPR Secondary Potential Loss Alarm YES OSA Overspeed Alarm Auxiliary YES OSR Overspeed Alarm YES OCR OverCrank Relay YES PLA Pre-lube 'Failure Timer Auxiliary YES PLT Pre-lube Failure Timer YES NPSR Negative Phase Sequence Alarm YES 6

LR-N 10-0227 Attachment 1 PANEL 2CCDC, CIRCUIT 36 AVAILABLE COMPONENT DESCRIPTION VOLTAGE ID ACCEPTABLE?

YES / NO FGR Field Ground Alarm YES OVR Over Voltage Alarm YES SR Start Relay YES SRA Start Relay Auxiliary YES OPRX Auxiliary Low Oil Pressure Relay Engine Firing YES OCRX Auxiliary OverCrank Alarm YES IND. LIGHT Crankcase High Pressure Indicating Light YES TALR Start System Low Turbo Boost Air Alarm YES System 1 &2 TALT Start System Low Turbo Boost Air Alarm YES System 1 &2 UV-4 125 VDC Controls Voltage Failure YES LIGHT 125 VDC Controls Voltage Failure Indicating YES Light ANNUNCIATOR Local Annunciator Remote Auxiliary Relay NO PNL PWR JWPR1 Jacket Water Pressure YES JWPR2 Jacket Water Pressure YES RDT Engine Run Solenoid Time Delay Relay YES ERS Engine Run Solenoid - Energize to Shutdown YES OCT1 OverCrank Timer Start System 1 YES CR1 Crank Control Relay 1 YES OPT1 Oil Pressure Timer Start System 1 YES OCT2 OverCrank Timer Start System 2 YES CR2 Crank Control Relay 2 YES OPT2 Oil Pressure Timer Start System 2 YES IND. LIGHTS DG Supervisory. (W) - White Indicating Light YES IND. LIGHT Indicating Light YES SV-1 417 2C Diesel Generator 23A Starting Air Receiver YES Booster Rack Solenoid Valve (SV-1417)

SV-890 Air Receiver Solenoid Valve (Full Cycle) YES SV-892 Air Receiver Solenoid Valve (3 seconds cycle) YES TVT Turbo Air Boost Timer YES TVR Turbo Air Valve Control Relay YES SV-887 Turbo Air Boost Solenoid Valve System 1 YES SV-888 Turbo Air Boost Solenoid Valve System 2 YES HCR Heater Cutoff Relay YES FST Field Shutdown Timer YES SPR Speed Relay YES K4C Field Control & Flashing Contactors YES K1C Field Control & Flashing Contactors YES ND. LIGHT Field Flash Supervisory Light YES (FFSL) 7

LR-N 10-0227 Attachment 1 PANEL 2CCDC, CIRCUIT 36 AVAILABLE COMPONENT VOLTAGE ID ACCEPTABLE?

YES/NO RMAR Exciter Regulator Relay YES DRA Drop Relay YES DR Drop Relay YES DRB Drop Relay YES BCT Breaker Closing Timer YES IND. LIGHT Indicating Light YES IND. LIGHT Indicating Light YES KWR Kilowatt Timer YES SPV Field Flash Supervisory Light YES Question 9 Describe how the temporary and the new replacementbattery will be preoperationaltested in the as-installedconfigurationconsistent with IEEE 308 and Regulatory Guide 1.32.

RESPONSE 9 As discussed in Section 4.8 of LAR S1 0-03, Steps A, B, C, D, and E, the following testing will be performed on the temporary and new replacement; this testing is consistent with the guidance of RG 1.32 (IEEE 308), which references RG 1.29 (IEEE 450) for testing requirements:

Prior to installation, the definable performance characteristics of the batteries will be tested as a unit. The batteries will be temporarily interconnected with the same hardware and cable that will be used in their installed configuration. Each battery will have an acceptance test performed in accordance with IEEE 450 by plant procedure SC.MD-FT.125-0003. The acceptance test will be a performance test at the manufacturer's two hour rate. Each battery will be re-charged and remain on float charge until ready for installation.

After installation, with the battery in its installed configuration, the following pre-operational tests will be performed:

o The battery connection resistance (cell connections, inter-rack connections and connection of the 125 VDC bus to the battery) will be tested in accordance with IEEE 450 by plant procedure SC.MD-ST.125-0005.

o The battery cell parameters (intra-cell voltage, electrolyte specific gravity, electrolyte level, and electrolyte temperature) and overall battery voltage on float charge will be tested in accordance with IEEE 450 by plant procedure SC.MD-ST.125-0003.

The proposed testing is consistent with the testing described in the Duane Arnold Amendment 247 (ADAMS ML022280041) precedent cited in LAR S1 0-03 8

LR-N10-0227 Attachment 1 Question 10. Limiting condition for operation (LCO) 3.8.2.3 requires that the 2C battery be operable in modes 1 through 4. The proposed amendment would credit operabilityof a temporary battery during on-line replacementof the existing 2C battery.

a. Describe how the temporary DC system (i.e., the temporary battery, associatedcomponents, connections, ratings,etc.) is identical to the permanent DC system configuration.

b. Propose additionalchanges to the TSs to make it clear that the LCO requirementsare being satisfied by the temporary battery during the 2C battery replacementactivities (e.g., footnote to the LCO).

RESPONSE 10 (a) Sections 4.1 through 4.8 of Attachment 1 to the March 29, 2010 submittal describes in detail how the temporary battery is equivalent to the existing 2C battery. As discussed in sections 4.1, 4.3 and 4.8, the battery capacity, minimum and maximum voltage, short circuit current, seismic installation, and testing are identical to the 2C battery specifications and requirements. As discussed in sections 4.2, 4.4, 4.5, 4.6, and 4.7, the following differences were identified and determined to be acceptable to consider the temporary battery as a technical specification equivalent battery for the existing 2C battery:

• Section 4.2 Connections: An additional length of cable will used to connect the temporary battery to the existing leads for the 2C battery. This cable will be seismically mounted and meet the Salem electrical separation requirements and Appendix R separation requirements. The cable length will be sized to ensure acceptable voltage drops to the DC loads.

" Section 4.4 Ventilation: The temporary battery/rack is being seismically mounted to the floor of the 4160 Volt Switchgear Room outside of the existing 2C Battery Room (see Figure 1 of Attachment 1 to the March 29, 2010 submittal). An evaluation of the hydrogen buildup in the 4160 Volt Switchgear Room was performed to determine if the existing ventilation system would maintain hydrogen concentrations below 2%. This evaluation determined that the hydrogen concentration would be well below 2% with the ventilation system operating in the once-through mode (outside air brought into the area and exhausted to the outside). In the event the ventilation system is operated in the recirculation mode, hydrogen concentration would continue to increase. Regardless of ventilation system mode of operation, periodic monitoring of the hydrogen concentration will be performed with appropriate contingency actions. Contingency actions will be established to block open doors and/or use additional ventilation if hydrogen concentration reaches 1%.

" Section 4.5 Missile Hazard: The existing 2C battery is located in its own room inside of the 4160 Volt Switchgear Room. The temporary battery will be located outside the 2C battery room inside the 4160 Volt Switchgear Room. An assessment of internally and externally generated missiles determined that there were no credible missiles that can damage or impair the temporary battery in the proposed location.

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LR-N 10-0227 Attachment 1 Section S 4.6 Fire Protection: Unlike the existing 2C 125VDC battery, it is not possible to place the temporary battery in a separate enclosed room that does not contain, other plant equipment. The temporary battery will be located inside the 64 ft elevation 4160 Volt Switchgear room just outside the existing 2C battery room. The 2C battery room is inside the 4160 Volt Switchgear Room. The 4160 Volt switchgear room is separated from other areas of the plant by 3-hour fire walls and with fire doors that are rated at 1-1/2 hours. The 4160V Switchgear Room has a double interlocked pre-action sprinkler system which provides full area coverage. The suppression system is actuated when a signal is received from an ionization (smoke) detector AND a thermal detector along with fused sprinkler heads. The suppression system will remain in service while the temporary battery is connected to the 2C 125VDC bus. In the event of an inadvertent actuation of the sprinkler system over the temporary battery, the temporary battery will be declared inoperable, and LCO 3.8.2.3 ACTION (a) would be applicable. The light standards located above the temporary 2C 125VDC battery will be removed to eliminate an ignition source. The installation of the temporary battery bank and temporary charger creates a slight increase in the combustible loading in the room but remains below 1-1/2 hours. The location of the temporary battery does not alter the safe shutdown analysis or operator response due to a fire in the 4160 Volt Switchgear Room. Periodic monitoring of the hydrogen concentration will be performed with appropriate contingency actions. Contingency actions will be established to block open doors and/or use additional ventilation if hydrogen concentration reaches 1%.

• Section 4.7 Operator Response: The use of the temporary battery will have no adverse impact on operating the plant during normal or emergency operations.

Response time for implementation of any abnormal operating procedures or emergency operating procedures will not be impacted by the location of the temporary battery. Due to the temporary battery being located outside the 2C 125V room administrative controls will be established to monitor the 4160 Volt Switchgear area for hydrogen concentration to ensure the concentration remains less than.2%. Contingency actions will be established to block open doors and/or use additional ventilation if hydrogen concentration reaches 1%.

As discussed in response to Question 7, the temporary battery will be connected to the 2C 125VDC existing Class 1 E charger when the temporary battery is connected the 2C 125VDC Class 1 E bus.

(b) A footnote/* will be added to LCO 3.8.2.3 for TRAIN 2C as follows:

TRAIN 2C consisting of 125-volt D.C. bus No. 2C, 125-volt D.C. battery No. 2C*

and battery charger 2C1.

• During the one-time on-line replacement of station battery 2C, this LCO can be satisfied by a temporarybattery as described in PSEG LAR submittal dated March 29, 2010.

The TS markup is provided in Attachment 2 of this submittal.

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LR-N10-0227 Attachment 2 TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES Facility Operating License DPR-75 Technical Specification Page I

1 3.8.2.3 3/4 8-10

ELECTRICAL POWER SYSTEMS 125-VOLT D.C. DISTRIBUTION - OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.3 The following D.C. bus trains shall be OPERABLE and energized:

TRAIN 2A consisting of 125-volt D.C. bus No. 2A, 125-volt D.C. battery No. 2A and battery charger 2A1.

TRAIN 2B consisting of 125-volt D.C. bus No. 2B, 125-volt D.C. battery No. 2B and battery charger 2B1.

TRAIN 2C consisting of 125-volt D.C. bus No. 2 volt D.C. battery No. 2 nd battery charger 2C1.

APPLICABILITY: MODES 1, 2, 3 and 4.-

ACTION:

a. With one 125-volt D.C. bus inoperable or not energized, restore the inoperable bus to OPERABLE and energized status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-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 />.

b. With one 125-volt D.C. battery charger inoperable, restore the inoperable charger to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or connect the backup charger for no more than 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-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 />.

c. With one or more 125-volt D.C. batteries with one or more battery cell parameters not within the Category A or B limits of Table 4.8.2.3-1:

1. Verify within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, that the electrolyte level and float voltage for the pilot cell meets Table 4.8.2.3-1 Category C limits, and

2. Verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that the battery cell parameters of all connected cells meet Table 4.8.2.3-1 Category C limits, and

3. Restore battery cell parameters to Category A and B limits of Table 4.8.2.3-1 within 31 days, and

4. If any of the above listed requirements cannot be met, comply with the requirements of action f.

d. With one or more 125-volt D.C. batteries with one or more battery cell parameters not within Table 4.8.2.3-1 Category C values, comply with the requirements of action f.

e. With average electrolyte temperature of representative cells less than 65 0 F, comply with the requirements of action f.

f. Restore the battery to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 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 />.

osatisfied by one-time on-line replacement of staton batter L nO can a temporarybattery as described in PSEG LAR submittal dated March 29, SALEM - UNIT 2 3/4 8-10 Amendment No. 1!58