Text

Submittal of License Amendment Request 02-00278 Re Revision to Technical Specifications Regarding DC Electrical Power Sources Based on TSTF-360
	ML021610477
Person / Time
Site:	Limerick
Issue date:	05/31/2002
From:	Gallagher M; Exelon Nuclear
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML021610477 (85)
	v • d • e

SExelo. n, Exelon Nuclear www exeloncorp.com Nuclear 20o Exelon Way Kennett Square, PA 19348 10CFR50.90 May 31, 2002 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

License Amendment Request 02-00278 Revision to Technical Specifications Regarding DC Electrical Power Sources Based on TSTF-360

Reference:

Technical Specifications Task Force (TSTF) Traveler-360, "DC Electrical Rewrite,"

Revision 1 Pursuant to 1 OCFR50.90, Exelon Generation Company (Exelon), LLC proposes changes to Appendix A, Technical Specifications (TS), of the Limerick Generating Station (LGS) Units 1 & 2 Facility Operating Licenses. The proposed changes would modify TS requirements for direct current (DC) sources through revision of Specifications 3.8.2.1 and 3.8.2.2, and addition of new Specification 6.8.4.h. The proposed TS requirements are consistent, except for format, with the requirements of Specifications 3.8.4, 3.8.5, 3.8.6, and 5.5.14 described in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4," Revision 2, which are based on the NRC approved industry Technical Specification Task Force (TSTF) change TSTF-360, Revision 1 (Reference above).

The proposed changes have been reviewed by the Plant Operations Review Committee and approved by the Nuclear Safety Review Board. This information is being submitted under unsworn declaration.

We are notifying the State of Pennsylvania of this application for changes to the TS and Operating Licenses by transmitting a copy of this letter and its attachments to the designated state officials.

Exelon requests approval of the proposed amendment by May 30, 2003.

Once approved, this amendment shall be implemented within 60 days of issuance.

Revision to Technical Specifications Regarding DC Electrical Power Sources Based on TSTF-360 May 31, 2002 Page 2 This proposed license amendment request is subdivided as follows.

1. Attachment 1 provides a description of the proposed changes, the evaluation of the proposed changes, and no significant hazards consideration (NSHC) determination.

2. Attachment 2 includes the markup of the current TS pages.

3. Attachment 3 provides the TS pages retyped to include the proposed changes.

4. Attachment 4 provides a summary of the licensing commitments made in this submittal.

5. Attachment 5 provides the markup of the current TS Bases pages to show the proposed changes. The TS Bases changes are provided for information only.

6. Attachment 6 provides the TS Bases pages retyped to include the proposed changes. The TS Bases changes are provided for information only.

If you have any questions or require additional information, please contact me at (610) 765-5664.

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

Respectfully, Executed on 5--33 -- .

Michael P. Gallagher Director, Licensing and Regulatory Affairs Mid-Atlantic Regional Operating Group Attachments : Evaluation of Proposed Changes : Markup of Technical Specification Pages : Typed Technical Specification Pages : List of Commitments : Markup of Technical Specification Bases Pages (for information only) : Typed Technical Specification Bases Pages (for information only) cc: H. J. Miller, Administrator, Region I, USNRC A. L. Burritt, USNRC Senior Resident Inspector, LGS C. Gratton, Senior Project Manager, USNRC R. R. Janati - Commonwealth of Pennsylvania

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES LIMERICK GENERATING STATION UNITS 1 and 2 DOCKET NOS. 50-352 50-353 LICENSE NOS. NPF-39 NPF-85 LICENSE AMENDMENT REQUEST 02-00278 "Revision to Technical Specifications Regarding DC Electrical Power Sources Based on TSTF-360"

ATTACHMENT 1 Evaluation of Proposed Changes

1.0 INTRODUCTION

In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company (Exelon), LLC, proposes changes to the Limerick Generating Station Units 1 & 2 (LGS) Technical Specifications (TS), Facility Operating License Nos. NPF-39 and NPF-85.

The proposed changes would modify the TS requirements for direct current (DC) sources through revision of Specifications 3.8.2.1, "DC Sources - Operating," and 3.8.2.2, "DC Sources - Shutdown." Additionally, a new Administrative Controls Section 6.8.4.h, "Battery Monitoring and Maintenance Program," is being proposed for the monitoring and maintenance of station batteries based on the recommendations of the Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead Acid Batteries for Stationary Applications."

The proposed changes are related to the TS Actions and Surveillance Requirements of the battery chargers, the batteries, and the DC electrical power subsystem. New, less restrictive Actions are proposed for inoperable battery charger(s) as well as for out-of limits conditions for battery cell voltage, battery float current, electrolyte level, and electrolyte temperature. The proposed changes would also include relocating the following to a licensee-controlled program (i.e., the Technical Requirements Manual (TRM) or TS Bases): (a) a number of Surveillance Requirements that require the performance of preventive maintenance, and (b) certain battery and battery cell parameter values that are periodically verified to monitor early indications of DC subsystem degradation.

The proposed TS requirements are consistent, except for format, with the requirements of Specifications 3.8.4, 3.8.5, 3.8.6, and 5.5.14 described in NUREG-1433, "Standard Technical Specifications, General Electric Plants, BWR/4," Revision 2 (Reference 1) and with the NRC approved industry Technical Specification Task Force (TSTF) change TSTF-360, Revision 1, "DC Electrical Rewrite" (Reference 2).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT This license amendment request (LAR) revises LGS TS 3.8.2.1 and 3.8.2.2, and adds new Specification 6.8.4.h to be consistent, except for format, with NUREG-1433 (Reference 1) and with the NRC approved industry Technical Specification Task Force (TSTF) traveler TSTF-360, Revision 1 (Reference 2). Since LGS is a non-Improved Standard Technical Specification plant, differences in format from NUREG-1 433 and TSTF-360 are required (e.g., NUREG-1433 Specification 3.8.6 provides a separate Specification for battery parameters -- that format is not utilized in LGS TS; rather the applicable Actions and Surveillance Requirements are incorporated in the LGS DC Source Specifications). The TS Bases for LGS TS 3.8.2.1 and 3.8.2.2 have also been revised to present content consistent with NUREG-1433 for Specifications 3.8.4, 3.8.5, and 3.8.6 as they relate to the requested changes.

Page 1 of 18

ATTACHMENT 1 Evaluation of Proposed Changes Each related change is grouped and discussed in detail. These groupings follow the general presentation found in TSTF-360, Revision 1. Section 5.0, "Technical Analysis,"

presents subsections that are numbered following the below numbered summary of changes. Additionally, revised Bases consistent with these changes are provided for information only as Attachments 5 and 6 to assist the review of the proposed changes.

(1) Provide Specific Actions and Increased Restoration Time For An Inoperable Battery Charger Specifications 3.8.2.1 and 3.8.2.2 number the existing Action as Action c., and add new Action a. to address inoperable battery charger(s). A portion of the existing 3.8.2.1 Action is editorially moved to the end of the Actions as the common default action. Specification 3.8.2.2 also renumbers the existing Action b. as Action d.

The new Actions consist of:

(i) Ensuring that a battery charging source is applied to the battery within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (Action a.1: Restore battery terminal voltage to greater than or equal to the minimum established float voltage);

(ii) Ensuring that the battery is fully recharged within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months (Action a.2: Verify battery float current is within limits); and (iii) Restoring the battery charger to operable status within 7 days (Action a.3).

(2) Relocate Preventive Maintenance Surveillance Requirements Existing Surveillance Requirements 4.8.2.1.b.2, c.1, c.2, and c.3 and the conditional performance requirements (battery discharge or overcharge) specified in 4.8.2.1 .b, are relocated from the TS to the TRM.

(3) Replace Battery Specific Gravity Monitoring With Battery Float Current Monitoring The specific gravity limits of Table 4.8.2.1-1, associated Footnotes (5) and (6), and associated portions of existing Surveillance Requirements 4.8.2.1.a.1 and 4.8.2.1.b.1 are deleted. In its place, new Surveillance Requirement 4.8.2.1.a.1 will require that Divisions 1 and 2 battery float current is < 2 amps, and Divisions 3 and 4 battery float current is < 1 amp, when battery terminal voltage is greater than or equal to the minimum established float voltage of 4.8.2.1 .a.2. Additionally, new Action b.2 for both Specifications 3.8.2.1 and 3.8.2.2 will impose the requirement to restore battery float current to within these limits within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . This will replace the existing Table 4.8.2.1-1 Footnotes (1), (2), and (3) action times as they apply to specific gravity measurements that are out of limits.

(4) Relocate Limiting Values For Battery Float Voltaqe And Battery Cell Voltage, Level, and Temperature And Revise Associated Surveillance Requirements The following are relocated from TS to the Bases or to the TRM:

(a) The specific value for battery float voltage in 4.8.2.1 .a.2 and in existing 4.8.2.1.c.4 (renumbered 4.8.2.1.d.1) and Page 2 of 18

ATTACHMENT 1 Evaluation of Proposed Changes (b) The specific value for cell electrolyte temperature in 4.8.2.1.b.3.

(c) The Table 4.8.2.1-1 Category A and B Limits for cell float voltage and all Table 4.8.2.1-1 limits for electrolyte level.

The following revisions are made:

(d) The frequency of monitoring battery cell voltage and electrolyte level (proposed 4.8.2.1.b.1 and b.2) is revised from the existing 7-days for pilot cell and 92 days for each connected cell, to 31 days for each pilot cell voltage and each connected cell level, (e) Electrolyte temperature monitoring of pilot cells (proposed 4.8.2.1.b.3) replaces monitoring of every sixth-cell, and (f) Table 4.8.2.1-1 Footnote (4) is deleted.

(5) Create New Battery Monitoring and Maintenance Program LGS TS 6.8.4.h, "Battery Monitoring and Maintenance Program," is added to require a program that provides for restoration and maintenance, based on the recommendations of IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries For Stationary Applications," of the following:

(a) Actions to restore battery cells with float voltage < 2.13 volts, and (b) Actions to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limit.

(6) Provide Specific Actions with Increased Restoration Time For Certain Battery And Battery Cell Parameter Out-Of-Limits Conditions New Action b. is added to Specifications 3.8.2.1 and 3.8.2.2. Action b. replaces existing Table 4.8.2.1-1 Footnotes (1), (2), and (3) (which provided Action Restoration Times for out-of-limits parameters) and presents Actions for:

(a) Cell voltages < 2.07 volts with restoration time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Action b.1);

(b) Cell electrolyte level less than minimum established design limits with restoration time of 31 days provided level is above the top of the plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and no evidence of leakage is found within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Action b.3).

The Footnote to Action b.3 assures the verification that there is no evidence of leakage is completed regardless of when electrolyte level is restored; (c) Pilot cell electrolyte temperature less than minimum established design limits with restoration time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Action b.4).

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ATTACHMENT 1 Evaluation of Proposed Changes (d) Action b.5 restricts any concurrent degradations to one DC division, and (e) Action b.6 imposes a 2-hour restoration time for any battery having both cell(s) voltage < 2.07 volts and battery float current not within limits.

Additionally, the existing Action for 3.8.2.1 (renumbered Action c.) is made more restrictive in allowing the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restoration time to be applied only when battery(ies) on one division are inoperable.

(7) Eliminate "Once per 60 Month" Restriction On Crediting Performance Discharge Test For Service Test - Restrict to "Modified" Performance Discharge Test Surveillance Requirement 4.8.2.1 .e, which currently allows a battery performance discharge test to be performed in lieu of a battery service test once per 60 months, is revised to allow unrestricted substitution; however, only a "modified" performance discharge test is allowed to satisfy this substitution.

(8) Delete Excessive Surveillance Requirement Detail of 4.8.2.1.d.2 Surveillance Requirement 4.8.2.1 .d.2 reflects a specific method of performing the battery service test that is also required by 4.8.2.1 .d.l. Therefore, 4.8.2.1 .d.2 is editorially deleted.

(9) Revise Battery Charger Service Test 8 Hour Duration To 4 Hours Surveillance Requirement 4.8.2.1 .c.4 (renumbered 4.8.2.1 .d.1), which currently requires battery charger testing for at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , is revised to require a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months duration.

(10) Revise Battery Performance Discharge Test 18-Month Frequency To 12/24 Months Surveillance Requirement 4.8.2.1 .f requires accelerated frequency for performance discharge tests or modified performance discharge tests. The current frequency of 18 months is revised to:

(i) 12 months for batteries that show signs of degradation or have reached 85%

of the expected service life with capacity < 100% of manufacturer's rating, and (ii) 24 months for batteries that have reached 85% of the expected service life with capacity > 100% of manufacturer's rating.

The definition of "degraded" within the existing SR 4.8.2.1.f is relocated to the Bases.

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ATTACHMENT 1 Evaluation of Proposed Changes 2.1 NEED FOR REVISION TO THE TS To support the request for new actions and increased completion times for an inoperable battery charger, Exelon plans to utilize a spare battery charger as a means of supplying backup DC power during periods when maintenance is being performed on the normal divisional charger or in conditions that cause the normal charger to be inoperable.

Relocation of the preventive maintenance SRs and battery cell parameter requirements to a licensee controlled program will provide for better control of these requirements; assure the battery is maintained at current levels of performance; allow flexibility to monitor and control these limits at values directly related to the battery's ability to perform its assumed function; and allow the TS to focus on parameter value degradations that approach levels that may impact battery operability.

3.0 BACKGROUND

There are four independent divisions of Class 1E DC systems for each unit; two 125/250 V systems for Divisions 1 and 2 and two 125 V systems for Divisions 3 and 4.

Each 125/250 V system is comprised of two 125 V batteries, each with its own charger.

Each 125 V system is comprised of one 125 V battery with its own charger. Each Class 1E battery bank is sized to have sufficient capacity without its charger to independently supply the large break LOOP/LOCA load profile shown in UFSAR Tables 8.3-18 through 8.3-26 and Figure 8.3-3 for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The battery is estimated to be 98% charged when stable charging current measurements are less than or equal to 2 amps for the Divisions 1 and 2 batteries, and less than or equal to 1 amp for the Divisions 3 and 4 batteries.

Each battery is sized to perform its duty cycle at the 98% charged level. When measured at float voltage, the charging current of a correctly charged battery is an accurate measure of the capability of the battery.

Each charger is supplied from separate 440 V motor control centers. Each of these motor control centers is connected to an independent Class 1 E AC bus. The battery chargers are sized using the formula (1) in IEEE 946-1992, "IEEE Recommended Practice for the Design of DC Auxiliary Power Systems for Generating Stations," Section 6.2. Each Class 1 E battery charger has sufficient capacity to supply the largest combined demand of the various steady-state loads and the charging current required to restore the battery from the design minimum charge state to the fully charged state, regardless of the plant status during the time in which these demands occur. The approximate recharge time is 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months .

During normal operation, the DC loads are powered from the battery chargers with the batteries floating on the system. In case of the loss of the supply from the charger, the DC loads are automatically supplied from the battery. Loads are diversified among different battery systems so that each system serves loads that are identical and redundant, or are different but redundant to plant safety, or are backup equipment to the AC driven equipment. Where two-channel or four-channel redundancy and separation are required, such as control power for the four diesel generators and the four Page 5 of 18

ATTACHMENT 1 Evaluation of Proposed Changes emergency switchgear assemblies, the loads are divided among the four divisions.

Power required for the larger loads, such as DC motor-driven pumps and valves, is supplied at 250 V from the two 125 V sources of each system, connected in series and distributed through 250 V DC motor control centers. Power required for most DC control functions, such as that required for the control of the 4 kV circuit breakers and control relays, is supplied at 125 V from the several 125 V sources.

4.0 REGULATORY REQUIREMENTS & GUIDANCE 4.1 LGS UFSAR 8.3.2.2.1, Compliance with General Design Criteria, Regulatory Guides, and IEEE Standards LGS UFSAR 8.3.2.2.1, Compliance with General Design Criteria, Regulatory Guides, and IEEE Standards, provides detailed discussion of LGS compliance with the applicable regulatory requirements and guidance. The proposed TS amendment:

(a) Does not alter the design or function of any DC electrical power system; (b) Does not result in any change in the qualifications of any component; and (c) Does not result in the reclassification of any component's status in the areas of shared, safety related, independent, redundant, and physically or electrically separated.

This amendment will result in changes to LGS compliance with Regulatory Guide 1.93 in that inoperable battery chargers will be justified for up to a 7-day restoration time.

Additionally, the existing LGS commitments to IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead Acid Batteries for Stationary Applications," will be revised to reflect commitment to the 1995 edition of IEEE Standard 450, with the exception of specific gravity monitoring frequency.

4.2 10 CFR 50.36(c)(2)(ii)

Portions of the proposed license amendment request result in relocating certain surveillances and surveillance acceptance criteria based on the criteria in 10 CFR 50.36(c)(2)(ii). The existing TS Table 4.8.2.1-1 Category A & B Limits reflect nominal fully charged battery parameter values. Significant margin above that required for declaration of an OPERABLE battery is provided in these values. These Category A

& B Limit values represent appropriate monitoring levels and appropriate preventive maintenance levels for long term battery quality and extended battery life. As such, they do not reflect the 10 CFR 50.36 criteria for LCOs of "the lowest functional capability or performance levels of equipment required for safe operation of the facility." It is proposed that these values, and the actions associated with restoration, be relocated to licensee controlled programs that are under the control of 10 CFR 50.59.

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ATTACHMENT 1 Evaluation of Proposed Changes

5.0 TECHNICAL ANALYSIS

5.1 Provide Specific Actions and Increased Restoration Time For An Inoperable Battery Charger Current TS Actions for an inoperable battery charger are the same as for an inoperable battery or a completely deenergized DC distribution subsystem, which require restoration of battery charger operability within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

New Actions with their associated restoration times would be added to Specification 3.8.2.1 and Specification 3.8.2.2 (Action a. in both cases) to address battery charger inoperability. Each of these Actions addresses the condition where one or both battery charger(s) for any one division becomes inoperable. For Specification 3.8.2.1, multiple divisions with inoperable battery charger(s) will result in no longer applying the existing 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months restoration time, but will require applying the "Otherwise, ... " default action.

While, the proposed Action a. for Specifications 3.8.2.1 and 3.8.2.2 provides a 7-day restoration time for inoperable battery charger(s) on one division, this time is contingent on a focused and tiered approach to assuring adequate battery capability is maintained.

The first priority is to minimize the battery discharge. Action a.1 assures the discharge is terminated by requiring 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 . There is no comparable limitation in the current LGS TS, as such, including this action provides continued safe plant operation.

The second tier action (Action a.2) requires that within 18-hours (and continuing at 12-hour intervals) the verification is made that the battery has sufficient capacity to perform its assumed duty cycle. The 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months is provided since there may involve some recharging of lost capacity that occurred during the initial 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This provides a reasonable time to fully recharge the battery. TSTF-360, Revision 1, contains a Reviewer's Note discussing the criteria for establishing a plant-specific time for this recharging allowance. (This Reviewer's Note also applies for the LGS proposed Action b.2 restoration time, which is based on NUREG-1433, Specification 3.8.6 Required Action B.2. See this submittal section 5.4.) The Reviewer's Note states:

A plant that cannot meet the 12-hour Completion Time due to an inherentbattery chargingcharacteristiccan propose an alternatetime equal to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months plus the time experienced to accomplish the exponential chargingcurrentportion of the battery charge profile following the service test.

LGS UFSAR 8.3.2.1.1.3 presents the LGS-specific recharge time as "approximately 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months ." Given this, the appropriate LGS restoration time applicable to the new proposed Action a.2 is proposed as 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months plus 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months -- or 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

Given that the DC bus remains energized (as required by Specification 3.8.3.1 or 3.8.3.2), the battery discharge (if it was occurring) is terminated (Action a.1), and the battery is fully recharged (Action a.2), there is reasonable basis for extending the restoration time for an inoperable charger beyond the existing 8-hour limit to 7 days.

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ATTACHMENT 1 Evaluation of Proposed Changes The revised Actions are acceptable because they focus efforts on retaining battery capabilities, retaining the requirement for charger operability, and applying a reasonable restoration time for an inoperable battery charger to avoid an unnecessary plant shutdown transient.

5.2 Relocate Preventive Maintenance Surveillance Requirements The basic premise of TS Surveillances, based on 10 CFR 50.36, is that Surveillance Requirements represent the minimum acceptable requirements for operability of the required equipment. However, for existing Surveillance Requirements 4.8.2.1.b.2, c.1, c.2, and c.3 and the conditional performance requirements specified in 4.8.2.1 .b, failure to meet the requirements does not necessarily mean that the equipment is not capable of performing its safety function, and the corrective action is generally a routine or preventive maintenance type activity.

The proposed change relocates the following Surveillance Requirements: (a) 4.8.2.1.b (conditional performance requirements after a battery discharge or overcharge); (b) 4.8.2.1 .b.2 (verification of visible corrosion or battery connection resistance); (c) 4.8.2.1 .c.1 (verification of physical damage or deterioration of battery cells, cell plates, and racks), (d) 4.8.2.1 .c.2 (removal of visible corrosion, tightening terminal connections, and coating the terminals); and (e) 4.8.2.1 .c.3 (verification of battery connection resistances). These activities will be included in the TRM and controlled under the plant maintenance program, which will be based on the recommendations of IEEE Standard 450-1995 "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications." This will make all changes subject to review under 10 CFR 50.59, "Changes, tests, and experiments" to determine if the proposed changes will require prior NRC review and approval, and will require reporting of all changes to the NRC in accordance with 10 CFR 50.71 (e), "Maintenance of records, making of reports."

Based on the above, the proposed changes provide adequate assurance of system operability commensurate with the safety significance.

5.3 Replace Battery Specific Gravity Monitoring With Battery Float Current Monitoring Existing LGS Surveillance Requirements 4.8.2.1.a.1 and 4.8.2.1.b.1, in conjunction with Table 4.8.2.1-1 require monitoring of individual cell and average of connected cell specific gravity. However, the provision of Table 4.8.2.1-1, Footnote (6) allows battery charging current verified < 1 amp when on float charge to be substituted for all specific gravity measurements except the quarterly verification against Table 4.8.2.1-1 Category B Limits (as required by 4.8.2.1.b.1).

New Action b.2 for both Specifications 3.8.2.1 and 3.8.2.2 will impose the requirement to restore battery float current for the Divisions 1 and 2 battery to < 2 amps, and for Divisions 3 and 4 battery to < 1 amp, within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months . This will replace the existing Table 4.8.2.1-1 Footnotes (1), (2), and (3) action times as they apply to specific gravity measurements that are out of limits.

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ATTACHMENT 1 Evaluation of Proposed Changes Use of float current to determine the state of charge of the battery is consistent with Section 4.5 of IEEE Standard 450-1995.

The battery float current limit applicable to Divisions 1 and 2 batteries (1500 amp-hour batteries) is being relaxed to 2 amps. As supported by LGS UFSAR 8.3.2.1.1.3(2), the battery is estimated to be 98% charged when stable charging current measurements are less than or equal to 2 amps for the Divisions 1 and 2 batteries, and less than or equal to 1 amp for the Divisions 3 and 4 batteries (which are 250 amp-hour batteries). Each battery is sized to perform its duty cycle at the 98% charged level. Therefore, the appropriate battery float current limit for the LGS Divisions 1 and 2 batteries is 2 amps.

Given the existing TS allowance and UFSAR support for utilizing float current to determine the state of charge of the battery, and the IEEE Standard 450 support of this position, deleting the requirement for specific gravity measurements will not have a significant impact on safety or the ability to accurately determine the operability of the batteries.

This change is also the original focus of what was approved as TSTF-360, Revision 1.

Documents included with TSTF-360 provide further detailed generic technical support for the acceptability of this change.

5.4 Relocate Limiting Values For Battery Float Voltage And Battery Cell Voltage, Level, and Temperature And Revise Associated Surveillance Requirement The basic premise of TS Surveillances based on 10 CFR 50.36 is that Surveillance Requirements represent the minimum acceptable requirements for operability of the required equipment. However, for:

(a) the specific value for battery float voltage in 4.8.2.1 .a.2; (b) the specific value for cell electrolyte temperature; (c) all Table 4.8.2.1-1 limits for electrolyte level and Category A and B Limits for cell float voltage (including Footnote 4);

(d) the frequency of monitoring battery cell voltage and electrolyte level (proposed 4.8.2.1.b.1 and b.2); and (e) the change to pilot cell temperature monitoring from averaging every sixth cell, failure to meet the requirements do not necessarily mean that the equipment is not capable of performing its safety function, and the corrective action is generally a routine or preventive maintenance type activity.

The proposed change removes these requirements from the TS (the specific value of the minimum float voltage requirement is revised to state "greater than or equal to the minimum established float voltage"). These removed limits and actions will be included in the TRM or TS Bases or controlled under the plant maintenance program which will be based on the recommendations of IEEE Standard 450-1995 "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications." This will make all changes subject to review under 10 CFR 50.59, "Changes, tests, and experiments" to determine if the proposed changes will require prior NRC review and approval, and will require reporting of all changes to the Page 9 of 18

ATTACHMENT 1 Evaluation of Proposed Changes NRC in accordance with 10 CFR 50.71 (e), "Maintenance of records, making of reports."

Based on the above, the proposed changes provide adequate assurance of system operability commensurate with the safety significance.

5.5 Create New Battery Monitoring and Maintenance Program The existing battery cell voltage Table 4.8.2.1-1 Category A and B Limits of 2.13 volts are relocated to a new Administrative Controls Specification, 6.8.4.h, "Battery Monitoring and Maintenance Program." This Program also requires that restoration and maintenance of this limit be provided. The existing actions of Table 4.8.2.1-1, Footnotes (1) and (2), will be relocated to the implementing procedures for this Program, and supplemented with IEEE Standard 450-1995 corrective actions (refer to Section 4.4.2 c),

to address the restoration and maintenance of the battery when cells below this limit are discovered.

Furthermore, new limitations are introduced in the new Administrative Controls Specification, 6.8.4.h, "Battery Monitoring and Maintenance Program," that require provisions to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limit. Testing of these cells will be based on the informational Annex D attached to IEEE Standard 450-1995.

Together, the relocated cell voltage limit and the new programmatic requirements associated with the new Battery Monitoring and Maintenance Program will ensure that the batteries are maintained in a highly reliable condition.

5.6 Provide Specific Actions with Increased Restoration Time For Certain Battery And Battery Cell Parameter Out-Of-Limits Conditions New Action b. is added to Specifications 3.8.2.1 and 3.8.2.2. Action b. replaces existing Table 4.8.2.1-1 Footnotes (1), (2), and (3) (which provided Action for out of limits parameters) and presents Actions for:

(a) Cell voltages < 2.07 volts with restoration time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Action b.1). With any cell voltage < 2.07 volts, the battery is considered degraded. The Action is to verify: (a) the battery terminal voltage to be greater than or equal to minimum established float voltage; and (b) the battery float current is within limits. These actions assure that there is still sufficient capacity in the battery to perform its intended function. Continued operations up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is permitted to allow the restoration of the affected cell(s) voltage to greater than or equal to 2.07 volts.

(b) Cell electrolyte level less than minimum established design limits with restoration time of 31 days provided level is above the top of the plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and no evidence of leakage is found within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Action b.3). The Footnote to Action b.3 assures the verification that there is no evidence of leakage is completed regardless of when electrolyte level is restored. If the level is above the top of the battery plates, but below the minimum established design limit, the battery still has sufficient capacity. With electrolyte level below the top of the Page 10 of 18

ATTACHMENT 1 Evaluation of Proposed Changes plates, there is a potential for dryout and plate degradation. These Actions restore the level and ensure that the cause of the loss of electrolyte level is not due to a leak in the battery casing. These actions are only required if the level in the battery is found below the top of the battery plates. In addition, the Battery Monitoring and Maintenance Program described in proposed TS Section 6.8.4.h and discussed under paragraph 5.5 above, would require action, based on IEEE Standard 450 1995, to equalize and test battery cells that have been discovered with an electrolyte level below the minimum established level limit.

(c) Pilot cell electrolyte temperature less than minimum established design limits with restoration time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Action b.4). A low electrolyte temperature limits the current and power available from the battery. However, because the battery is sized with adequate margins to perform its intended functions (refer to UFSAR Section 8.3.2.1.1.2), the proposed 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months completion time is reasonable to restore the battery electrolyte temperature.

(d) Action b.5 restricts any concurrent degradations to one DC division. If two or more batteries are degraded for any parameters discussed above, there is not sufficient assurance that the DC system will be able to perform its intended function. With two batteries with an out-of-limit parameter, loss of an assumed function for systems that depend upon the batteries is possible. Thus, it is proposed that battery parameters be restored to within limits on at least one division within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

(e) Action b.6 imposes a 2-hour restoration time for any battery having both cell voltage < 2.07 volts and battery float current not within limits. Discovering one or more batteries in one division with one or more battery cell float voltages

< 2.07 volts and float current not within limits indicates that the battery capacity may not be sufficient to perform the intended functions.

(f) Electrolyte temperature compensation for cell voltage is an optional allowance not required for mild environment applications, and is therefore deleted.

While the new Actions proposed provide increased restoration time for various battery and battery charger degradations, the existing Action for Specification 3.8.2.1 (renumbered Action c.) is made more restrictive in allowing the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months restoration time to be applied only when battery(ies) on one division are inoperable. For Specification 3.8.2.1, multiple divisions with inoperable battery(ies) will result in no longer applying the existing 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months restoration time, but will require applying the "Otherwise, ...." default action.

Page 11 of 18

ATTACHMENT 1 Evaluation of Proposed Changes 5.7 Eliminate "Once per 60 Month" Restriction On Crediting Performance Discharge Test For Service Test - Restrict to "Modified" Performance Discharge Test Surveillance Requirement 4.8.2.1 .e, which currently allows a battery performance discharge test to be performed in lieu of a battery service test once per 60 months, is revised to allow unrestricted substitution; however, only a "modified" performance discharge test is allowed to satisfy this substitution. Since the modified performance discharge test completely encompasses the load profile of the battery service test, it adequately confirms the intent of the service test - to verify the battery capacity to supply the design basis load profile.

5.8 Delete Excessive Surveillance Requirement Detail of 4.8.2.1.d.2 Existing Surveillance Requirement 4.8.2.1.d.2 reflects a specific method of performing the battery service test that is also required by 4.8.2.1 .d.1 (which is being renumbered 4.8.2.1 .d.2). Deleting this explicit method of performing the battery service test will not impact the requirement to perform the test, which remains required by 4.8.2.1 .d.1 (renumbered 4.8.2.1.d.2). Detailing methods of performing surveillances is not required to be included in TS.

5.9 Revise Battery Charger Service Test 8 Hour Duration To 4 Hours Surveillance Requirement 4.8.2.1 .d.1 (which is being renumbered 4.8.2.1 .d.2), which currently requires battery charger testing for at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , is revised to require a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months duration. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months duration, in the current TS, is based on engineering judgment.

According to NUREG-1 433 Bases, the duration is intended to provide sufficient time for the battery charger temperature to have stabilized and have been maintained for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The battery manufacturer has confirmed that while operating at rated current, the battery charger electronic components reach temperature stability within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The proposed 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months duration provides the intended 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months operation at stable temperature.

5.10 Revise Battery Performance Discharge Test 18-Month Frequency To 12/24 Months Surveillance Requirement 4.8.2.1 .f requires accelerated frequency for performance discharge tests or modified performance discharge tests. The current frequency of 18 months is revised to:

(i) 12 months for batteries that show signs of degradation or have reached 85% of the expected service life with capacity < 100% of manufacturer's rating, and (ii) 24 months for batteries that have reached 85% of the expected service life with capacity > 100% of manufacturer's rating.

These revised frequencies are consistent with the 1995 edition of IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," Section 5.2.c.

The definition of "degraded" within the existing SR 4.8.2.1.f is relocated to the Bases.

This presentation is consistent with the format and content of NUREG-1433. No change in practice is proposed.

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ATTACHMENT 1 Evaluation of Proposed Changes 5.11 Summary All proposed items to be relocated to licensee-controlled documents (e.g., TRM or TS Bases), will have changes subject to review under 10 CFR 50.59, "Changes, tests, and experiments," to determine if the proposed changes will require prior NRC review and approval, and will require reporting of all changes to the NRC in accordance with 10 CFR 50.71 (e), "Maintenance of records, making of reports." This provides sufficient management control of the requirements to assure the batteries are maintained in a highly reliable condition.

The increased restoration times and revised criteria for monitoring the capacity of the battery and battery chargers to perform their intended function, are reasonable and consistent with approved standards, guidance and regulations.

6.0 REGULATORY ANALYSIS

LGS UFSAR 8.3.2.2.1, Compliance with General Design Criteria, Regulatory Guides, and IEEE Standards, provides detailed discussion of LGS compliance with the applicable regulatory requirements and guidance. The proposed TS amendment:

(a) Does not alter the design or function of any DC electrical power system; (b) Does not result in any change in the qualifications of any component; and (c) Does not result in the reclassification of any component's status in the areas of shared, safety related, independent, redundant, and physically or electrically separated.

This amendment will result in changes to LGS compliance with Regulatory Guide 1.93 in that inoperable battery chargers will be justified for up to a 7-day restoration time.

Additionally, the existing LGS commitments to IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead Acid Batteries for Stationary Applications," will be revised to reflect commitment to the 1995 edition of IEEE Standard 450, with the exception of specific gravity monitoring frequency. With the inclusion of Surveillance Requirement 4.8.2.1 .a.1 (which requires that each battery float current is < 2 amps for Divisions 1 and 2, and < 1 amp for Divisions 3 and 4, when battery terminal voltage is greater than or equal to the minimum established float voltage of 4.8.2.1 .a.2 every 7 days), adequate periodic verification of the charged state of the battery is provided without reliance on specific gravity measurements.

Portions of the proposed amendment request result in relocating certain surveillances and surveillance acceptance criteria based on the criteria in 10 CFR 50.36(c)(2)(ii). The existing TS Table 4.8.2.1-1 Category A & B Limits reflect nominal fully charged battery parameter values. Significant margin above that required for declaration of an OPERABLE battery is provided in these values. These Category A & B Limit values represent appropriate monitoring levels and appropriate preventive maintenance level for long term battery quality and extended battery life. As such, they do not reflect the 10 CFR 50.36 criteria for LCOs of "the lowest functional capability or performance levels of equipment required for safe operation of the facility." It is proposed that these values, Page 13 of 18

ATTACHMENT 1 Evaluation of Proposed Changes and the actions associated with restoration, be relocated to licensee controlled programs that are under the control of 10 CFR 50.59.

All proposed items to be relocated to licensee-controlled documents (e.g., TRM or TS Bases), will have changes subject to review under 10 CFR 50.59, "Changes, tests, and experiments," to determine if the proposed changes will require prior NRC review and approval, and will require reporting of all changes to the NRC in accordance with 10 CFR 50.71 (e), "Maintenance of records, making of reports." This provides sufficient management control of the requirements to assure the batteries are maintained in a highly reliable condition.

The increased restoration times and revised criteria for monitoring the capacity of the battery and battery chargers to perform their intended function, are reasonable and consistent with approved standards, guidance and regulations.

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

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION (NSHC)

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

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

The class 1 E direct current (DC) electrical power system including associated battery chargers are not initiators to any accident sequence analyzed in the Updated Final Safety Analysis Report (UFSAR). Operation in accordance with the proposed Technical Specification (TS) ensures that the DC system is capable of performing its function as described in the UFSAR, therefore the mitigative functions supported by the DC system will continue to provide the protection assumed by the analysis. The relocation of preventive maintenance surveillances, certain operating limits and actions to either the Technical Requirements Manual (TRM), TS Bases, or newly-created TS 6.8.4.h, "Battery Monitoring and Maintenance Program," will not challenge the ability of the DC system to perform its design function. Appropriate monitoring and maintenance, consistent with industry standards, will continue to be performed. In addition, the DC 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 system.

These changes do not involve any physical change to structures, systems, or components (SSCs) and do not alter the method of operation or control of SSCs. The current assumptions in the safety analysis regarding accident initiators and mitigation of accidents Page 14 of 18

ATTACHMENT 1 Evaluation of Proposed Changes are unaffected by these changes. No additional failure modes or mechanisms are being introduced and the likelihood of previously analyzed failures remains unchanged.

The integrity of fission product barriers, plant configuration, and operating procedures as described in the UFSAR will not be affected by these changes. Therefore, the consequences of previously analyzed accidents will not increase because of these changes.

Based on the above discussion, the proposed TS changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

The proposed changes do not involve a physical alteration of the plant. No new equipment is being introduced, and installed equipment is not being operated in a new or different manner. There are no setpoints, at which protective or mitigative actions are initiated, affected by this change. These changes will not alter the manner in which equipment operation is initiated, nor will the function demands on credited equipment be changed. Any alteration in procedures will continue to ensure that the plant remains within analyzed limits, and no change is being made to the procedures relied upon to respond to an off-normal event as described in the UFSAR. As such, no new failure modes are being introduced.

The changes do not alter assumptions made in the safety analysis and licensing basis.

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

7.3 The proposed amendment does not involve a significant reduction in a margin of safety.

The margin of safety is established through equipment design, operating parameters, and the setpoints at which automatic actions are initiated. The proposed changes are acceptable because the operability of the DC system is unaffected, there is no detrimental impact on any equipment design parameter, and the plant will still be required to operate within assumed conditions. Operation in accordance with the proposed TS ensures that the DC system is capable of performing its function as described in the UFSAR; therefore, the support of the DC system to the plant response to analyzed events will continue to provide the margins of safety assumed by the analysis. The relocation of preventive maintenance surveillances, certain operating limits and actions to either the TRM, TS Bases, or newly-created TS 6.8.4.h, "Battery Monitoring and Maintenance Program," will not challenge the ability of the DC system to perform its design function. Appropriate monitoring and maintenance, consistent with industry standards, will continue to be performed. In addition, the DC 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 system. This provides sufficient management control of the requirements that assure the batteries are maintained in a highly reliable condition.

Page 15 of 18

ATTACHMENT 1 Evaluation of Proposed Changes The increased restoration times and revised criteria for monitoring the capacity of the battery and battery chargers to perform their intended function, are reasonable and generally consistent with approved standards, guidance and regulations.

Based on the above discussion, the proposed TS changes do not involve a significant reduction in a margin of safety.

Conclusion Based upon the evaluation above, Exelon concludes that the proposed amendment presents no significant hazards under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

8.0 ENVIRONMENTAL CONSIDERATION

An environmental assessment is not required for the proposed changes since the proposed changes conform to the criteria for "actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). In accordance with 10 CFR 51.22(c)(9) a proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not:

(1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amount of any effluents that may be released off site, or (3) result in an increase in individual or cumulative occupational radiation exposure.

Exelon has reviewed the proposed license amendment and concludes that it meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with issuance of the proposed license change. The basis for this determination is as follows:

1. The proposed license amendment does not involve significant hazards as described previously in the no significant hazards consideration evaluation.

2. As discussed in the no significant hazards consideration evaluation, the proposed change does not introduce any new equipment, nor does it require any existing equipment or systems to perform a different type of function than they are presently designed to perform during normal operation. Exelon has concluded that there will not be a significant increase in the types or amounts of effluents that may be released offsite and this change does not involve irreversible environmental consequences beyond those already associated with normal operation.

3. The proposed amendment involves a revision to the TS requirements that in some instances involve changes to procedural methods of verifying operability of the DC system; however, these revised methods will not affect worker radiation exposure.

Thus, the proposed amendment does not increase individual or cumulative occupational radiation exposure.

Page 16 of 18

ATTACHMENT 1 Evaluation of Proposed Changes 9.0 PRECEDENT In a letter dated February 15, 2002, the U.S. Nuclear Regulatory Commission issued Amendment No. 142 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit 1. The amendment was in response to the application from AmerGen Energy Company, LLC, dated August 21, 2001 (Reference 5), as supplemented January 11, 2002 (Reference 6). The amendment revised the actions taken for an inoperable battery charger, revised the battery charger testing criteria, and relocated certain safety related battery surveillance requirements from the Technical Specifications to a licensee controlled program that were based on TSTF-360, Revision 1.

In the AmerGen request and subsequently issued amendment, Clinton Power Station adopted a new Administrative Controls Program, "Battery Monitoring and Maintenance Program" (as required in adopting TSTF-360, Revision 1). However, the Clinton Program requirements included a minor difference from TSTF-360, Revision 1, that was not adopted in this Exelon request for amendment to LGS TS.

The proposed LGS TS 6.8.4.h, while imposing requirements for provisions based on IEEE Standard 450, does not include an issue date for that Standard. (Note that TSTF-360 had an inconsistency in presenting the new Program - in one instance the date was included; in another it was not. The Historical Q&A provided with TSTF-360 indicates that the Industry proposal was to not include the date.) The committed to issue of IEEE Standard 450 is explicitly delineated in the LGS TS Bases (provided for reference in Attachments 5 and 6) as well as the LGS UFSAR. As such, all changes to specific issue dates of this Standard will be subject to review under 10 CFR 50.59, "Changes, tests, and experiments," to determine if the proposed changes will require prior NRC review and approval, and will require reporting of all changes to the NRC in accordance with 10 CFR 50.71 (e), "Maintenance of records, making of reports."

Exelon has provided an amendment request that it believes to be more consistent with the NRC approved TSTF-360, Revision 1. The difference between the approved amendment for Clinton Power Station and this request is justified above.

10.0 REFERENCES

1. NUREG-1 433, "Standard Technical Specifications, General Electric Plants, BWR/4,"

Revision 2, dated June 2001.

2. Industry/Technical Specifications Task Force Standard Technical Specification Change Traveler-360, "DC Electrical Rewrite," Revision 1.

3. Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead Acid Batteries for Stationary Applications."

Page 17 of 18

ATTACHMENT 1 Evaluation of Proposed Changes

4. U.S. Nuclear Regulatory Commission issued Amendment No. 142 to Facility Operating License No. NPF-62 for the Clinton Power Station, Unit 1, letter dated February 15, 2002.

5. AmerGen Energy Company, LLC to U. S. NRC, Request For License Amendment, dated August 21, 2001.

6. AmerGen Energy Company, LLC to U. S. NRC, Revised Technical Specification Pages for the License Amendment Request Associated With DC Electrical Power, dated January 11, 2002.

Page 18 of 18

ATTACHMENT 2 MARKUP OF TECHNICAL SPECIFICATIONS PAGES LIMERICK GENERATING STATION UNITS 1 and 2 DOCKET NOS. 50-352 50-353 LICENSE NOS. NPF-39 NPF-85 LICENSE AMENDMENT REQUEST 02-00278 "Revision to Technical Specifications Regarding DC Electrical Power Sources Based on TSTF-360" REVISED TS PAGES UNIT 1 UNIT 2 3/4 8-10 3/4 8-10 3/48-11 3/48-11 3/4 8-12 3/4 8-12 3/4 8-13 3/4 8-13 3/4 8-14 3/4 8-14 6-14c 6-14c

INSERT ACTIONS-1 (for 3.8.2.1)

a. With one or two battery chargers on one division inoperable:

1. Restore battery terminal voltage 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 ,

2. Verify associated Division 1 or 2 float current < 2 amps, or Division 3 or 4 float current < 1 amp within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, and

3. Restore battery charger(s) to OPERABLE status within 7 days.

b. With one or more batteries inoperable due to:

1. One or two batteries on one division with one or more battery cells float voltage < 2.07 volts, perform 4.8.2.1.a.1 and 4.8.2.1.a.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore affected cell(s) voltage > 2.07 volts within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. Division 1 or 2 with float current > 2 amps, or with Division 3 or 4 with float current > 1 amp, perform 4.8.2.1.a.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore battery float current to within limits within 18 hours.

3. One or two batteries on one division with one or more cells electrolyte level less than minimum established design limits, if electrolyte level was below the top of the plates restore electrolyte level to above top of plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and verify no evidence of leakage(*) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In all cases, restore electrolyte level to greater than or equal to minimum established design limits within 31 days.

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

5. Batteries in more than one division affected, restore battery parameters for all batteries in all but one division to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

6. (i) Any battery having both (Action b.l) one or more battery cells float voltage < 2.07 volts and (Action b.2) float current not within limits, and/or (ii) Any battery not meeting any Action b.1 through b.5, Restore the battery parameters to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

(*) Contrary to the provisions of Specification 3.0.2, if electrolyte level was below the top of the plates, the verification that there is no evidence of leakage is required to be completed regardless of when electrolyte level is restored.

INSERT ACTIONS-2 (for 3.8.2.2)

a. With one or two required battery chargers on one required division inoperable:

1. Restore battery terminal voltage 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 ,

2. Verify associated Division 1 or 2 float current < 2 amps, or Division 3 or 4 float current < 1 amp within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, and

3. Restore battery charger(s) to OPERABLE status within 7 days.

b. With one or more required batteries inoperable due to:

1. One or two batteries on one division with one or more battery cells float voltage < 2.07 volts, perform 4.8.2.1.a.1 and 4.8.2.1.a.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore affected cell(s) voltage > 2.07 volts within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. Division 1 or 2 with float current > 2 amps, or with Division 3 or 4 with float current > 1 amp, perform 4.8.2.1.a.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore battery float current to within limits within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

3. One or two batteries on one division with one or more cells electrolyte level less than minimum established design limits, if electrolyte level was below the top of the plates restore electrolyte level to above top of plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and verify no evidence of leakage(*) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In all cases, restore electrolyte level to greater than or equal to minimum established design limits within 31 days.

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

5. Batteries in more than one division affected, restore battery parameters for all batteries in one division to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

6. (i) Any battery having both (Action b.l) one or more battery cells float voltage < 2.07 volts and (Action b.2) float current not within limits, and/or (ii) Any battery not meeting any Action b.l through b.5, Restore the battery parameters to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. 1. With the requirements of Action a. and/or Action b. not met, or

(*) Contrary to the provisions of Specification 3.0.2, if electrolyte level was below the top of the plates, the verification that there is no evidence of leakage is required to be completed regardless of when electrolyte level is restored.

SURVEILLANCE INSERTS INSERT SR-I Each Division 1 and 2 battery float current is < 2 amps, and Division 3 and 4 battery float current is < 1 amp when battery terminal voltage is greater than or equal to the minimum established float voltage of 4.8.2.1.a.2, INSERT SR-2

1. Each battery pilot cell voltage is > 2.07 volts,

2. Each battery connected cell electrolyte level is greater than or equal to minimum established design limits, and INSERT SR-3

c. At least once per 92 days by verifying that each battery connected cell voltage is > 2.07 volts.

INSERT SR-4

f. Performance discharge tests or modified performance discharge tests of battery capacity shall be given as follows:

1. At least once per 12 months when:

(a) The battery shows degradation or (b) The battery has reached 85% of expected life with battery capacity < 100% of manufacturer's rating, and

2. At least once per 24 months when the battery has reached 85% of expected life with battery capacity > 100% of manufacturer's rating.

PROGRAM INSERT INSERT PROGRAM

h. Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance, based on the recommendations of IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries For Stationary Applications," of the following:

a. Actions to restore battery cells with float voltage

< 2.13 volts, and

b. Actions to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limit.

ELECTRICAL POWER SYSTEMS 3/4.8.2 D.C. SOURCES D.C. SOURCES - OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 As a minimum, the following D.C. electrical power sources shall be OPERABLE:

a. Division 1, Consisting of:

1. 125-Volt Battery 1A1 (1AIDlOl).

2. 125-Volt Battery 1A2 (1A2D101).

3. 125-Volt Battery Charger 1BCA1 (1A1D103).

4. 125-Volt Battery Charger 1BCA2 (1A2D103).

b. Division 2, Consisting of:

1. 125-Volt Battery 1BI (1BID101).

2. 125-Volt Battery 1B2 (1B2D101).

3. 125-Volt Battery Charger 1BCB1 (1B1D103).

4. 125-Volt Battery Charger 1BCB2 (1B2D103).

c. Division 3, Consisting of:

1. 125-Volt Battery 1C (1CD101).

2. 125-Volt Battery Charger IBCC (1CD103).

d Division 4, Consisting of:

-CTIc*J 1. 125-Volt Battery 1D (1DD101).

2. 125-Volt Battery Charger 1BCD (1DD103).

\ APPLICABILITY: OPERATIONl,- DITIONS 1.2, and 3.

ACT ION:-o C% reo~t--1y eýecI -c4lw o0i 3 Av'Il I W ith any r66Q*;x=; of the above required D.C. electrical power sources inoperable restore the inoperable division battery to OPERABLE status J~~~~~ IUL HOTDW ihn R the hoursJ/ within the next 12 hourRFOaInJd least HOT24 SHUTDWN in atfollowing U V hours, &Ae 4.8.2.1 Each of the above required division batteries and chargers shall be

-iL~ onrLRMDLc demnIIIUI

a. At least once per 7 days by verifying that:

1. T-he parameters in Table 4.8.2.1 1 mct the C;tegory A, imiz\

and

2. Total battery terminal voltage for each 125-volt -littery is greater than or equal to 13 ol1 on 4oat ar

+iýivvminI ma~m es~btit Jfoo+volkc~

LIMERICK - UNIT 1 3/4 8-10

ELECTRICAL POWER SYSTEMS S[URVEILLANCE

v.-- REQUIREMENTS (Continued)

Ai VY ba sat to n c ery t i l e tIbatte~ t ep ete-b . n a l *aa svvoage r rmi t-ya n qe w

b i owin 105 7 d ay jaIts aov e 1 5 0 v bo f ot e r/ ar~rb at t te y sdPi c/ a rg e l l t s by v e r i f y i ovprr cha; rge ng t hat :

. ~ (or0the h~

e i pa no s-a -pZ*-*

vi/tible cbl P0*rosion 4 *-

e es;c o4Ta 1 -1 wwa S2t *erming4s ron re .stanceo ayf /either

. a t@, *9,yB..or ..c/nnectoy 4 ,;5 s]

1/

0th s iems i~ less t

.] O .x '0 - o0 'a~n_ _L

, an d/

4 &

3. The electrolyte temperature of each is

1. At least ce o per 18 onths the (ells, cell/plates and battery r ks show n visual in ication of physical d mage or abnor I deterio tion, 2/. At leas once per 8 months t e cell to- ell and termin connecti ns are cle n, tight, ree of corro on and co ed with a icorrosio material,

3. At 1 ast once p r 18 month the resis ance of ea h cell to- ell and te minal conn ction is 1 ss than or equal to 15 x 1 i0 ohm excluding able inter ell connec ions, and 7 6 t eat 2 oe p r RA Ate battery chargers will K y supply the currents listed below at for at leastr hou Charje

"-'ur rs. C a

¢ea Charcgr vot+ck es e

io +

m eres m

! r nim um C

-S bt'sh) 1BCA1 300 1BCA2 300 1BCB1 300 1BCB2 300 1BCC 75 1BCD 75 d-. At least once per 24 months by verifying that )

(017 The battery capacity is adequate to supply and maintain in OPERABLE status the required emergency loads for the design duty cycle when subjected to a battery service test, ay ~dAum 2.

equ e A r b eler d a~iy saq to .eraequir et ematervi c y V aes l

whe/vsubjected/to a bat /eryvservice t/est. I U t e si n cy LIMERICK - UNIT 1 3/4 8-11 Amendment No. ;4, 92 Corrected by letter dated June 19, 1995

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQIEET (Continued)

e. At least once per 60 months by verifying that the battery capacity is at least 80% of the manufacturers rating when subjected to a performance discharge test. At e pe performance discharge test maY be performed in lieu of the batter service test (Specification 4.8.2.1. Ti o '

f. At -ast once r 18 moPths pe tormanc discha ge test of b tery ca acit shal be giv to an battery that s ows si s of gradat* n o0 r s ched % of t servi e life pected for th appli ation.

/egr ation is indi ated w en the b tery c pacity drops ore th 10% o/

rat d capa ity fro its a erage on revio perfo mance ests, r is bA 90 of th manufa turer' rating.

LIMERICK - UNIT I 3/4 8-12 Amendment No. ;-4, 92 Corrected by letter dated June 19, 1995

TABLE 4.8.2.1 BATTERY S HRVIP\FT ANCF RFni]TIREMENTS

/

CATEGORY A"'/ CATEGORY B'Zi Parameter Limits for each Limits for each Al0owable(3 )

designated pilot connected cell lue for each cell /connected cell Electrolyte >Minimum leve >Minimum level Above top of Level indication m rk, indication mark, plates, and _ 'A" ab ve and < '4"above and not maximum 1 el maximum level overflowing indicati mark indication mar Floa Voltage > 2.13/volts > 2.13 volt ) > 2.07 volts ecific(6

/ /Gr avity > . 195")

AND 11190 Žt 1.170 AND

/ Avrage of all Averag of all nnected cells conne eed cells 1.2200 11. 90(6)

(")For any C tegory A parameter(s) outsi e the limit(s) shown, the attery may be onsidered OPERABLE provide that within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months all he Category B measu ements are taken and found o be within their allowab e values, and prov ded all Category A and B p ameter(s) are restored to within limits wi in the next 6 days.

2 Frany s Category B parameter( ) outside the limit(s) sh n, the battery may be considered OPERABLE rovided that the Categor B parameters are within their allowable va ues and provided the Cate ory B parameter(s) are restored to within limi within 7 days.

`3)Any Category B paramet not within its allowabl value indicates an inoperable battery.

() May be corrected f average electrolyte tem rature.

( 5)Corrected for el ctrolyte temperature of 7 F.

(6)Or battery ch ging current is less tha 1 amperes when on float charge.

LIMERICK - UNIT 1 3/4 8- 13 Amendment No. 123

ELECTRICAL POWER SYSTEMS D.C. SOURCES - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.2 As a minimum, two of the following four divisions of the D.C.

electrical power sources system shall be OPERABLE with:

a. Division 1, Consisting of:

1. 125-Volt Battery 1A1 (IAIDIOI).

2. 125-Volt Battery 1A2 (IA2DIO1).

3. 125-Volt Battery Charger 1BCA1 (1AID103).

4. 125-Volt Battery Charger 1BCA2 (1A2D103).

b. Division 2, Consisting of:

1. 125-Volt Battery 1B1 (1BID101).

2. 125-Volt Battery 1B2 (1B2D1O1).

3. 125-Volt Battery Charger 1BCB1 (1BID103).

4. 125-Volt Battery Charger 1BCB2 (1B2D103).

c. Division 3, Consisting of:

1. 125-Volt Battery IC (1CD101).

2. 125-Volt Battery Charger 1BCC (1CD103).

d. Division 4, Consisting of:

1.

2. 125-Volt Battery 125-Volt 1D (1DD101).

Battery Charger 1BCD (1DD103).

APPLICABILITY: OPERATIONAL COND TIONS_4. 5, and ACTION: 4 W r Cons~ D-Oker -+-tavl 4c~-i& a, apidI-ý b

,T--m<.*With less than two dvsi ons of the above reauired D.C. electrical power sources OPERABLE, issen--d CORE ALTERATIONS, handT-ng-of Si-rraditEd fuel--in the secondary containment and operations with a potential for draining the reactor vessel.

The provisions of Specification 3.0.3 are not-applicable.

SURVEILLANCE REQUIREMENTS 4.8.2.2 At least the above required battery and charger shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.1.

When handling irradiated fuel in the secondary containment.

LIMERICK - UNIT 1 3/4 8-14

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

g. Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163 "Performance-Based Containment Leakage Test program," dated September 1995.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 44.0 psig.

The maximum allowable primary containment leakage rate, La, at Pa, shall be 0.5% of primary containment air weight per day.

Leakage rate acceptance criteria are:

a. Primary Containment leakage rate acceptance criterion is less than or equal to 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are less than or equal to 0.60 La for the Type B and Type C tests and less than or equal to 0.75 La for Type A tests;

b. Air lock testing acceptance criteria are:

1) Overall airlock leakage rate is less than or equal to 0.05 La when tested at greater than or equal to Pa.

2) Seal leakage rate is less than or equal to 5 scf per hour when the gap between the door seals is pressurized to 10 psig.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

The provisions of Specification 4.0.3 are applicable to the tests described in the Primary Containment Leakage Rate Testing Program.

IMSGT R7 Pft 4 LIMERICK - UNIT I 6-14c Amendment No. 118

ELECTRICAL POWER SYSTEMS 3/4.8.2 D.C. SOURCES D.C. SOURCES - OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 As a minimum, the following D.C. electrical power sources shall be OPERABLE:

a. Division 1, Consisting of:

1. 125-Volt Battery 2A1 (2A1D1O1).

2. 125-Volt Battery 2A2 (2A2D101).

3. 125-Volt Battery Charger 2BCA1 (2A1D103).

4. 125-Volt Battery Charger 2BCA2 (2A2D103).

b. Division 2, Consisting of:

1. 125-Volt Battery 2B1 (2B1D1O1).

2. 125-Volt Battery 2B2 (2B2D101).

3. 125-Volt Battery Charger 2BCB1 (2B1D103).

4. 125-Volt Battery Charger 2BCB2 (2B2D103).

c. Division 3, Consisting of:

1. 125-Volt Battery 2C (2CD101).

2. 125-Volt Battery Charger 2BCC (2CD103).

d. Division 4, Consisting of:

ti4-I2..T 1. 125-Volt Battery 2D (2DD101).

^T.. .. ., 2. 125-Volt Battery Charger 2BCD (2DD103).

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ATION: bOA115inasn -~ Vo .

( With any 1a9rofteaoerqieD..eetiapwr sources inoperable,'restore the inoperable division battery to OPERABLE status

,----y--w1TTtFn0hoursote in at least HUI SHUIUUN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD L12 HUI1 WN withiN the following 244 hnours. /__/ __* __.

""SURVEILLANCE REOUIREMENTS 4.8.2.1 Each of the above required division batteries and chargers shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying that: eE .S'

1. 4hA Table 4R.8.2.1 Lmeet t paramctcrs in Catogor- A and

2. Total battery terminal voltage for each 125-volt battery is greater than or equal to vo on oa arg 4-`&

fi~A r, n%

e lj'.ý\eckf ctýoVo výq c-LIMERICK - UNIT 2 3/4 8-1i0

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

b. At least once per days and vthin 7 days ter a battery isc arge lwith/Da~tieryi*er nal vo tge/below 105 vol 's or battery Y#ercharge wiLh)

Sbattey termina voltage abofie 150 volts/b eiyn ht Tho araetcc i Tablo1.82.1 1 mooet the Categeiry B limfits, here is no visifle corrosion either termin Is or connecT rs or Ve connecti n resistance if these items ii less than 1O x 106 nh , .a ndia;

3. The

electrolyte temperature of each ell is , .

battery r cks show no v sual indication f physical /

damagei abnormal detrsioration, //

At le e t once per l1'months the cell -o-cell and term nal connectio s are clean, tig F, free of cor osion an d c oated with a t ic orr osi onmat e al ,

3. least once p 18 months the r sistance of e ch cell o-cell and te inal connection s less than o equal t 150 x 10.6 t leat once por 21, months-/he battery chargers will supply the currents listed below at 4-ts for at least hours: 4*W_ v fi A S6biVW, Charger re r

2BCA1 300 2BCA2 300 2BCB1 300 2BCB2 300 2BCC 75 2BCD 75 d.

d. At least once per 24 months by verifying that~t:N The battery capacity is adequate to supply and maintain in OPERABLE status the required emergency loads for the design duty cycle when subjected to a battery service test, or 2The ba ery capacit is adequate t supply a dumm load

[equiv ent to the equired emerg cy loads for t e design cycl whe subjected tV a battery serl'ice test. 2 -.

2 LIMERICK - UNIT 2 3/4 8-11 Amendment No. -4, 56 Corrected by letter dated June 19, 1995

FIECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

OrfibctiJýtA Te nrwaw1C.,Q . *5~ar est

e. At least once per 60 months by verifying that the battery capacity is at least 80% of the manufacturers rating when subjected to a performance discharge test. -At thiz onc per month intrv.'l, 4O performance discharge test may be performed in lieu of the battery service test (Specification 4.8.2.1.d W e4

f. At lea once per 18 onths perfor ance dihar tests of battery capacity shallI e given to y battery th shows signs fr degradation/r has reac ed 85% f the servic life expecte for the app ation. De aion is in cated when t e battery ca city drops m9ore than 10% of rated capa ty f om its avera on previou performance sts, or is beow 90% of/e ey V anufacturer' rating.

-7 LIMERICK - UNIT 2 3/4 8-12 Amendment No. 34, 56 Corrected by letter dated June 19, 1995

STABLE 4.8j.2.1 "

/ BATTERY SURVEILLANCREQUIREMENTS SCATEGORY A... z CATEGORY B( 2 Parameter / Limits for each / Limits for each /A wao e'3*

/" designated pilot/ connected cell

lu e for each

/cell i c, onected cell Electrolyte" >Minimum leve/ >Minimum level / Above top of Level /*indicated mTk, indication mark,/ plates,

//and._ : V a ove and _<ý V* abov~e and not

/"maximum, #vel maximum level overflowing

/indicat 'ormark in 'dicationm ak7 FloF Voltage _> 2. /volts -> 2.13 vol t/4) > 2.07 volts/

pecific ai ty 5 G 195(6) _ 1.170(6) 1 A/N AND verage of all Averag of all connected cells conne ed cells

> 1.200 _>1 90(6)

(')For any tegory A parameter(s)noutsi the limit(s)shown, the ba ery may be considered OPERABLE provide that within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months all the Category B meas ements are taken and found be within their allowable lues, and provided a Cat gory A and B parameter(s) ar restored to within limits thin the next 6 days (2 *)F any Category B parameter(s outside the limit(s) shown the battery may be considered OPERABLE ovided that the Category B arameters are within their allowable val es and provided the Categor B parameter(s) are r tored to "within limits within 7 d s.

(3)Any Category B paramet not within its allowable lue indicates an inoperable battery.

4

( )May be corrected f average electrolyte temp ature.

(')Corrected for e ectrolyte temperature of 7 F.

(')Or battery c, rging current is less tha 1 amperes when on floa charge.

LIMERICK - UNIT 2 3/4 8- 13 Amendment No. 88

ELECTRICAL POWER SYSTEMS D.C. SOURCES - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.2 As a minimum, two of the following four divisions of the D.C.

electrical power sources system shall be OPERABLE with:

a. Division 1, Consisting of:

1. 125-Volt Battery 2A1 (2A1D1O1).

2. 125-Volt Battery 2A2 (2A2D101).

3. 125-Volt Battery Charger 2BCA1 (2AID103).

4. 125-Volt Battery Charger 2BCA2 (2A2D103).

b. Division 2, Consisting of:

1. 125-Volt Battery 2B1 (2B1D1O1).

2. 125-Volt Battery 2B2 (2B2D101).

3. 125-Volt Battery Charger 2BCB1 (2BID103).

4. 125-Volt Battery Charger 2BCB2 (2B2D103).

c. Division 3, Consisting of:

1. 125-Volt Battery 2C (2CD1O1).

2. 125-Volt Battery Charger 2BCC (2CD103).

d. Division 4, Consisting of:

1. 125-Volt Battery 2D (2DD101).

2. 125-Volt Battery Charger 2BCD (2DD103).

APPLICABILITY: OPERATIONAL CONDITIONS 4, 5, and *.

ACTION: Ifreasongkr~ fL -Ap IAcAion-5 aL. a a )

i4 ZAith less than two divisions of the above required D.C. electrical power sources OPERAB , 1uspe-nd7OR-E ALTE-RATI-N-S-ha7Il`Mng 7f

,- -iFraT*tated fuel in the secondary containment and operations with a potential for draining the reactor vessel.

r The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.8.2.2 At least the above required batteries and chargers shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.1.

When handling irradiated fuel in the secondary containment.

LIMERICK - UNIT 2 3/4 8-14

ADMINISTRATIVE CONTROL S PROCEDURES AND PROGRAMS (Continued)

g. Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163 "Performance Based Containment Leakage Test program," dated September 1995.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 44.0 psig.

The maximum allowable primary containment leakage rate, La, at Pa, shall be 0.5% of primary containment air weight per day.

Leakage rate acceptance criteria are:

a. Primary Containment leakage rate acceptance criterion is less than or equal to 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are less than or equal to 0.60 L, for the Type B and Type C tests and less than or equal to 0.75 L, for Type A tests;

b. Air lock testing acceptance criteria are:

1) Overall airlock leakage rate is less than or equal to 0.05 La when tested at greater than or equal to Pa

2) Seal leakage rate is less than or equal to 5 scf per hour when the gap between the door seals is pressurized to 10 psig.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

The provisions of Specification 4.0.3 are applicable to the tests described in the Primary Containment Leakage Rate Testing Program.

k!

LIMERICK - UNIT 2 6-14c Amendment No. 81

ATTACHMENT 3 TYPED TECHNICAL SPECIFICATION PAGES LIMERICK GENERATING STATION UNITS 1 and 2 DOCKET NOS. 50-352 50-353 LICENSE NOS. NPF-39 NPF-85 LICENSE AMENDMENT REQUEST 02-00278 "Revision to Technical Specifications Regarding DC Electrical Power Sources Based on TSTF-360" REVISED TS PAGES UNIT 1 UNIT 2 3/4 8-10 3/4 8-10 3/4 8-1Oa 3/4 8-10a 3/4 8-1 1 3/4 8-11 3/4 8-12 3/4 8-12 3/4 8-13 3/4 8-13 3/4 8-14 3/4 8-14 3/4 8-14a 3/4 8-14a 6-14c 6-14c

ELECTRICAL POWER SYSTEMS 3/4.8.2 D.C. SOURCES D.C. SOURCES -OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 As a minimum, the following D.C. electrical power sources shall be OPERABLE:

a. Division 1, Consisting of:

1. 125-Volt Battery IAI (1Al101i).

2. 125-Volt Battery IA2 (IA2D101).

3. 125-Volt Battery Charger IBCA1 (1A1D103).

4. 125-Volt Battery Charger 1BCA2 (1A2D103).

b. Division 2, Consisting of:

1. 125-Volt Battery 1B1 (IBID101).

2. 125-Volt Battery 1B2 (1B2D101).

3. 125-Volt Battery Charger 1BCB1 (1BID103).

4. 125-Volt Battery Charger 1BCB2 (1B2D103).

c. Division 3, Consisting of:

1. 125-Volt Battery IC (ICDI01).

2. 125-Volt Battery Charger IBCC (1CD103).

d. Division 4, Consisting of:

1. 125-Volt Battery 1D (1DD101).

2. 125-Volt Battery Charger 1BCD (1DD103).

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a. With one or two battery chargers on one division inoperable:

1. Restore battery terminal voltage 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 ,

2. Verify associated Division 1 or 2 float current < 2 amps, or Division 3 or 4 float current < ] amp within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, and

3. Restore battery charger(s)-to OPERABLE status within 7 days.

b. With one or more batteries inoperable due to:

1. One or two batteries on one division with one or more battery cells float voltage < 2.07 volts, perform 4.8.2.1.a.1 and 4.8.2.1.a.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore affected cell(s) voltage

> 2.07 volts within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. Division I or 2 with float current > 2 amps, or with Division 3 or 4 with float current > 1 amp, perform 4.8.2.1.a. 2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore battery float current to within limits within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

LIMERICK - UNIT 1 3/4 8-10

ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION ACTION: (Continued)

3. One or two batteries on one division with one or more cells electrolyte level less than minimum established design limits, if electrolyte level was below the top of the plates restore electrolyte level to above top of plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and verify no evidence of leakage(*) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In all cases, restore electrolyte level to greater than or equal to minimum established design limits within 31 days.

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

5. Batteries in more than one division affected, restore battery parameters for all batteries in all but one division to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

6. (i) Any battery having both (Action b.1) one or more battery cells float voltage < 2.07 volts and (Action b.2) float current not within limits, and/or (ii) Any battery not meeting any Action b.1 through b.5, Restore the battery parameters to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. With any battery(ies) on one division of the above required D.C. electrical power sources inoperable for reasons other than Action b., restore the inoperable division battery to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Otherwise, be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

(*) Contrary to the provisions of Specification 3.0.2, if electrolyte level was below the top of the plates, the verification that there is no evidence of leakage is required to be completed regardless of when electrolyte level is restored.

LIMERICK - UNIT I 3/4 8-10a

FIFETRTC.Al POWER SYSTEMS SIURVEILLAN E REQtIREMENTLS 4.8.2.1 Each of the above required division batteries and chargers shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying that:

1. Each Division 1 and 2 battery float current is < 2 amps, and Division 3 and 4 battery float current is < 1 amp when battery terminal voltage is greater than or equal to the minimum established float voltage of 4.8.2.1.a.2, and

2. Total battery terminal voltage for each 125-volt battery is greater than or equal to the minimum established float voltage.

b. At least once per 31 days by verifying that:

1. Each battery pilot cell voltage is > 2.07 volts,

2. Each battery connected cell electrolyte level is greater than or equal to minimum established design limits, and

3. The electrolyte temperature of each pilot cell is greater than or equal to minimum established design limits.

c. At least once per 92 days by verifying that each battery connected cel I voltage is > 2.07 volts.

d. At least once per 24 months by verifying that:

1. The battery chargers will supply the currents listed below at greater than or equal to the minimum established float voltage for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Charger Current (Amperes)

IBCA1 300 1BCA2 300 1BCB1 300 1BCB2 300 1BCC 75 1BCD 75

2. The battery capacity is adequate to supply and maintain in OPERABLE status the required emergency loads for the design duty cycle when subjected to a battery service test.

LIMERICK - UNIT 1 3/4 8-11 Amendment No. ;4-,49, Corrected by letter dated June 19, 1995

ELECTRICAL POWER SYSTEMS (IR\VFTI I ANfFF RFOLITRFMENTS

I* * * * ...... * . ................

(Continued)

e. At least once per 60 months by verifying that the battery capacity is at least 80% of the manufacturer's rating when subjected to a performance discharge test or modified performance discharge test. The modified discharge test may be performed in lieu of the battery service test (Specification 4.8.2.1.d.2).

f. Performance discharge tests or modified performance discharge tests of battery capacity shall be given as follows:

1. At least once per 12 months when:

(a) The battery shows degradation or (b) The battery has reached 85% of expected life with battery capacity < 100% of manufacturer's rating, and

2. At least once per 24 months when battery has reached 85% of expected life with battery capacity > 100% of manufacturer's rating.

LIMERICK - UNIT 1 3/4 8-12 Amendment No. 74, 92-,

Corrected by letter dated June 19, 1995

TABLE 4.8.2.1-1 (DELETED) I THE INFORMATION ON THIS PAGE HAS BEEN DELETED LIMERICK - UNIT I 3/4 8-13 Amendment No. 4-2-3,

ELECTRICAL POWER SYSTEMS n r SO[J1RCF.S - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.8.2.2 As a minimum, two of the following four divisions of the D.C.

electrical power sources system shall be OPERABLE with:

a. Division 1, Consisting of:

1. 125-Volt Battery 1A1 (1AIDI01).

2. 125-Volt Battery 1A2 (1A2D101).

3. 125-Volt Battery Charger 1BCA1 (1AID103).

4. 125-Volt Battery Charger 1BCA2 (1A2D103).

b. Division 2, Consisting of:

1. 125-Volt Battery IB1 (1BIDI01).

2. 125-Volt Battery 1B2 (1B2DI01).

3. 125-Volt Battery Charger 1BCB1 (1BID103).

4. 125-Volt Battery Charger IBCB2 (1B2D013).

c. Division 3, Consisting of:

1. 125-Volt Battery 1C (1CDI01).

2. 125-Volt Battery Charger 1BCC (1CD103).

d. Division 4, Consisting of:

1. 125-Volt Battery ID (1DD101),

2. 125-Volt Battery Charger 1BCD (1DD013).

APPLICABILITY: OPERATIONAL CONDITIONS 4, 5, and

ACTION:

a. With one or two required battery chargers on one required division inoperable:

1. Restore battery terminal voltage 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 ,

2. Verify associated Division I or 2 float current < 2 amps, or Division 3 or 4 float current 0.005 hours 2.97619e-5 weeks 6.849e-6 months and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, and

3. Restore battery charger(s) to OPERABLE status within 7 days.

b. With one or more required batteries inoperable due to:

1. One or two batteries on one division with one or more battery cells float voltage < 2.07 volts, perform 4.8.2.1.a.1 and 4.8.2.1.a.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore affected cell(s) voltage > 2.07 volts within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

When handling irradiated fuel in the secondary containment.

LIMERICK - UNIT 1 3/4 8- 14

ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

2. Division I or 2 with float current > 2 amps, or with Division 3 or 4 with float current > 1 amp, perform 4.8.2.1.a.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore battery float current to within limits within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

3. One or two batteries on one division with one or more cells electrolyte level less than minimum established design limits, if electrolyte level was below the top of the plates restore electrolyte level to above top of plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and verify no evidence of leakage(*) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . In all cases, restore electrolyte level to greater than or equal to minimum established design limits within 31 days.

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

5. Batteries in more than one division affected, restore battery parameters for all batteries in one division to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

6. (i) Any battery having both (Action b.1) one or more battery cells float voltage < 2.07 volts and (Action b.2) float current not within limits, and/or (ii) Any battery not meeting any Action b.1 through b.5, Restore the battery parameters to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. 1. With the requirements of Action a. and/or Action b. not met, or

2. With less than two divisions of the above required D.C. electrical power sources OPERABLE for reasons other than Actions a. and/or b.,

Suspend CORE ALTERATIONS, handling of irradiated fuel in the secondary containment and operations with a potential for draining the reactor vessel.

d. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REOUIREMENTS 4.8.2.2 At least the above required battery and charger shall be demonstrated OPERABLE per Surveillance Requirement 4.8.2.1.

(*) Contrary to the provisions of Specification 3.0.2, if electrolyte level was below the top of the plates, the verification that there is no evidence of leakage is required to be completed regardless of when electrolyte level is restored.

LIMERICK - UNIT 1 3/4 8-14a

ADMINISTRATIVE CONTROLS PROCEDURES AND PROGRAMS (Continued)

g. Primary Containment Leakage Rate Testing Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163 "Performance-Based Containment Leakage Test program," dated September 1995.

The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 44.0 psig.

The maximum allowable primary containment leakage rate, L., at Pa, shall be 0.5% of primary containment air weight per day.

Leakage rate acceptance criteria are:

a. Primary Containment leakage rate acceptance criterion is less than or equal to 1.0 L,. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are less than or equal to 0.60 L, for the Type B and Type C tests and less than or equal to 0.75 L,, for Type A tests;

b. Air lock testing acceptance criteria are:

1) Overall airlock leakage rate is less than or equal to 0.05 L, when tested at greater than or equal to P,.

2) Seal leakage rate is less than or equal to 5 scf per hour when the gap between the door seals is pressurized to 10 psig.

The provisions of Specification 4.0.2 do not apply to the test frequencies specified in the Primary Containment Leakage Rate Testing Program.

The provisions of Specification 4.0.3 are applicable to the tests described in the Primary Containment Leakage Rate Testing Program.

h. Battery Monitoring and Maintenance Prooram This Program provides for restoration and maintenance, based on the recommendations of IEEE Standard 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries For Stationary Applications," of the following:

a. Actions to restore battery cells with float voltage < 2.1.3 volts, and

b. Actions to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limit.

LIMERICK - UNIT 1 6-14c Amendment No. 4!--8,

ELECTRICAL POWER SYSTEMS 3/4.8.2 D.C. SOURCES D.C. SOURCES -OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 As a minimum, the following D.C. electrical power sources shall be OPERABLE:

a. Division 1, Consisting of:

1. 125-Volt Battery 2AI (2A1D1O1).

2. 125-Volt Battery 2A2 (2A2D101).

3. 125-Volt Battery Charger 2BCAI (2AID103).

4. 125-Volt Battery Charger 2BCA2 (2A2D103).

b. Division 2, Consisting of:

1. 125-Volt Battery 2B1 (2B1D101).

2. 125-Volt Battery 2B2 (2B2D101).

3. 125-Volt Battery Charger 2BCB1 (2B1D103).

4. 125-Volt Battery Charger 2BCB2 (2B2D103).

c. Division 3, Consisting of:

1. 125-Volt Battery 2C (2CD101).

2. 125-Volt Battery Charger 2BCC (2CD103).

d. Division 4, Consisting of:

1. 125-Volt Battery 2D (2DD101).

2. 125-Volt Battery Charger 2BCD (2DD103).

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, and 3.

ACTION:

a. With one or two battery chargers on one division inoperable:

1. Restore battery terminal voltage to greater than or equal to the minimum established float voltane within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

2. Verify associated Division 1 or 2 float current < 2 amps, or Division 3 or 4 float current < 1 amp within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter, and

3. Restore battery charger(s) to OPERABLE status within 7 days.

b. With one or more batteries inoperable due to:

1. One or two batteries on one division with one or more battery cells float voltage < 2.07 volts, perform 4.8.2.1.a.1 and 4.8.2.1.a.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore affected cell(s) voltage

> 2.07 volts within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. Division I or 2 with float current > 2 amps, or with Division 3 or 4 with float current > 1 amp, perform 4.8.2.1.a.2 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for affected battery(s) and restore battery float current to within limits within 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months .

LIMERICK - UNIT 2 3/4 8-10