ML041830353
| ML041830353 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/01/2004 |
| From: | Thadani M NRC/NRR/DLPM/LPD4 |
| To: | Blevins M TXU Energy |
| Thadani M, NRR/DLPM, 415-1476 | |
| References | |
| TAC MB9532, TAC MB9533 | |
| Download: ML041830353 (28) | |
Text
July 1, 2004 Mr. M. R. Blevins Senior Vice President
& Principal Nuclear Officer TXU Energy ATTN: Regulatory Affairs P. O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES), UNITS 1 AND 2 -
ISSUANCE OF AMENDMENTS RE: DIRECT CURRENT (DC) ELECTRICAL POWER SYSTEMS (TAC NOS. MB9532 AND MB9533)
Dear Mr. Blevins:
The Commission has issued the enclosed Amendment No. 113 to Facility Operating License No. NPF-87 and Amendment No. 113 to Facility Operating License No. NPF-89 for CPSES Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 6, 2003, as supplemented by letter dated February 24, 2004.
The amendments revise the TSs for CPSES Units 1 and 2, adopting the TS Task Force (TSTF)
Standard TS Change Traveler TSTF-360, Revision 1, DC Electrical Rewrite. The proposed changes would revise TS 3.8.4, DC Sources-Operating, TS 3.8.5, DC Sources-Shutdown, TS 3.8.6, Battery Cell Parameters, and TS 5.5.19, Battery Monitoring and Maintenance Program.
The February 24, 2004, supplemental letter provided clarifying information that did not change the scope of the original Federal Register notice or the original no significant hazards consideration determination published in the Federal Register on July 8, 2003 (68 FR 40721).
A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
Mohan C. Thadani, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosures:
- 1. Amendment No. 113 to NPF-87
- 2. Amendment No. 113 to NPF-89
- 3. Safety Evaluation cc w/encls: See next page
July 1, 2004 Mr. M. R. Blevins Senior Vice President
& Principal Nuclear Officer TXU Energy ATTN: Regulatory Affairs P. O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES), UNITS 1 AND 2 -
ISSUANCE OF AMENDMENTS RE: DIRECT CURRENT (DC) ELECTRICAL POWER SYSTEMS (TAC NOS. MB9532 AND MB9533)
Dear Mr. Blevins:
The Commission has issued the enclosed Amendment No. 113 to Facility Operating License No. NPF-87 and Amendment No. 113 to Facility Operating License No. NPF-89 for CPSES Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 6, 2003, as supplemented by letter dated February 24, 2004.
The amendments revise the TSs for CPSES Units 1 and 2, adopting the TS Task Force (TSTF)
Standard TS Change Traveler TSTF-360, Revision 1, DC Electrical Rewrite. The proposed changes would revise TS 3.8.4, DC Sources-Operating, TS 3.8.5, DC Sources-Shutdown, TS 3.8.6, Battery Cell Parameters, and TS 5.5.19, Battery Monitoring and Maintenance Program.
The February 24, 2004, supplemental letter provided clarifying information that did not change the scope of the original Federal Register notice or the original no significant hazards consideration determination published in the Federal Register on July 8, 2003 (68 FR 40721).
A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
Mohan C. Thadani, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosures:
- 1. Amendment No. 113 to NPF-87
- 2. Amendment No. 113 to NPF-89
- 3. Safety Evaluation cc w/encls: See next page Distribution: See attached page Accession No.:ML041830353
- no significant change from the SE input OFFICE PDIV-1/PM PDIV-1/LA IROB-BC*
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DISTRIBUTION FOR CPSES, UNITS 1 AND 2 ISSUANCE OF AMENDMENTS RE:
ADOPTION OF NRC APPROVED TSTF-360 Dated: July 1, 2004 PUBLIC PDIV-1 Reading RidsNrrDlpmLpdiv (HBerkow)
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TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NO. 1 DOCKET NO. 50-445 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 113 License No. NPF-87 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by TXU Generation Company LP dated June 6, 2003, as supplemented by letter dated February 24, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. NPF-87 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 113, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. TXU Generation Company LP shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
The license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: July 1, 2004
TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NO. 2 DOCKET NO. 50-446 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 113 License No. NPF-89 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by TXU Generation Company LP dated June 6, 2003, as supplemented by letter dated February 24, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. NPF-89 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 113, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. TXU Generation Company LP shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: July 1, 2004
ATTACHMENT TO LICENSE AMENDMENT NO. 113 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 113 TO FACILITY OPERATING LICENSE NO. NPF-89 DOCKET NOS. 50-445 AND 50-446 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert iii iii 3.8-24 3.8-24 3.8-25 3.8-25 3.8-26 3.8-26 3.8-27 3.8-27 3.8-29 3.8-29 3.8-30 3.8-30 3.8-31 3.8-31 3.8-32 3.8-32 3.8-33 3.8-33 5.0-28a
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 113 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 113 TO FACILITY OPERATING LICENSE NO. NPF-89 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446
1.0 INTRODUCTION
By letter dated June 6, 2003 (Reference 1), as supplemented by letter dated February 24, 2004 (Reference 2), the TXU Generation Company LP (the licensee) submitted a request for license amendments to the Technical Specifications (TSs) for Comanche Peak Steam Electric Station (CPSES) Units 1 and 2, adopting the TS Task Force (TSTF) Standard TS Change Traveler, TSTF-360, Revision 1 DC Electrical Rewrite (Reference 3). The proposed changes would revise TS 3.8.4, DC Sources-Operating, TS 3.8.5, DC Sources-Shutdown, TS 3.8.6, Battery Cell Parameters, and add a new TS Section 5.5.19, Battery Monitoring and Maintenance Program.
The February 24, 2004, supplemental letter provided clarifying information that did not change the scope of the original Federal Register notice or the original no significant hazards consideration determination (68 FR 40721 dated July 8, 2003).
The licensee proposed revision to TS 3.8.4, TS 3.8.5, and TS 3.8.6 that would add new Conditions and Required Actions to provide alternate charger testing criteria in the revised TS 3.8.4 and TS 3.8.5. The proposed changes would also include the relocation of some Surveillance Requirements (SRs) in TS 3.8.4 that relate to preventive maintenance on the safety-related batteries to a licensee-controlled program. The current TS Table 3.8.6-1, Battery Cell Parameters Requirements, will be relocated to a licensee-controlled program.
Specific Required Actions associated with out-of-limits conditions for battery cell float voltage, float current, electrolyte level, and electrolyte temperature will be added to TS 3.8.6.
Additionally, the new administrative TS program, "Battery Monitoring and Maintenance Program," is being proposed for the maintenance and monitoring of station batteries in TS 5.5.19. The program is 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 (Reference 4). The items proposed in IEEE Standard 450-1995 are to be relocated and its current requirements contained within this new program.
The licensee stated that the proposed changes are to support performance of periodic on-line battery charger maintenance and post-maintenance testing, thereby reducing plant refueling outage duration and improving battery charger availability during shutdown. The changes will provide operational flexibility by allowing more efficient application of plant resources to safety significant activities. The licensee further stated that the proposed changes are consistent with the changes previously approved by the Nuclear Regulatory Commission (NRC) for Clinton Power Station on February 15, 2002, and Byron Station on September 19, 2002. In those plants the proposed changes to the conditions, required actions, completion time (CT), and SRs of the battery chargers, batteries, and the DC electrical power subsystem are consistent with TSTF-360, Revision 1, as incorporated in NUREG-1431, Revision 2, Standard Technical Specifications, Westinghouse Plants (Reference 5).
2.0 REGULATORY EVALUATION
2.1 Conformance to TSTF-360, Revision 1 The changes to the standard TS (STS) in TSTF-360, Revision 1, were approved by the NRC staff for incorporation into STS on December 18, 2000, in a letter from W. D. Beckner to A. R.
Pietrangelo. The TSTF-360 provides guidance to rewrite current TS requirements for Class 1E DC power supply systems as referenced in the STS, Revision 1, NUREG-1430 (Babcock &
Wilcox), NUREG-1431 (Westinghouse), NUREG-1432 (Combustion Engineering),
NUREG-1433 (General Electric-BWR/4), and NUREG-1434 (General Electric-BWR/6). The acceptability of a licensee-proposed rewrite of its DC Electrical Systems TS requirements is based on the NRC staff review and evaluation of the licensees justifications for each of the proposed changes. Justifications are also evaluated for revising, relocating, and removing current plant-specific requirements in order to convert the current TS into revised TS Limiting Conditions for Operations (LCOs) 3.8.4, 3.8.5, 3.8.6, and 5.5.19 as outlined in the TSTF-360.
In adopting the NRC staff approved TSTF-360, Revision 1, the licensees are expected to address the consistencies of the revisions with TSTF-360 in the following areas during conversion of plant TSs to the ITS format of the above cited NUREGs:
a.
Relocation of preventive maintenance SRs to licensee-controlled programs; b.
Specification of alternate testing criteria for battery charger testing; c.
Replacement of battery specific gravity monitoring with float current monitoring; d.
Relocation of maintenance surveillance for cell voltage and electrolyte level based on the industry recommendations in IEEE Standard 450-1995 to a licensee-control program and creation of a new section in Chapter 5 of the TS program (this new section in Chapter 5 program will be a TS-controlled activity with its detailed requirements relocated to plant procedures);
e.
Addition of specific Actions and increased CTs for out-of-limits conditions for battery cell voltage, electrolyte level, and electrolyte temperature; f.
Elimination of the once per 60 month restriction on replacing the battery service test with the battery modified performance discharge test; and g.
Provision of enhanced TS Bases for each of the newly proposed TS 3.8.4, 3.8.5, 3.8.6, and 5.5.19.
The NRC staff has reviewed the licensees justifications for adopting the various elements of TSTF-360 consistent with the revised Bases in TSTF-360. The revised Bases were reviewed and accepted by the NRC staff during the review of the TSTF-360, Revision 0, and TSTF-360, Revision 1, as submitted by Nuclear Energy Institute (NEI) on behalf of the industry on February 4 and November 6, 2000.
2.2 50.36(c)(2)(ii) of Title 10 of the Code of Federal Regulations (10 CFR) Requirements The Commissions regulatory requirements related to the content of the TSs are set forth in 10 CFR 50.36. That regulation requires the TSs to include items in the following categories:
(1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) SRs; (4) design features; and (5) administrative controls. However, the regulation does not specify the specific requirements to be included in a plants TSs.
Under 10 CFR 50.36(c)(2)(ii), an LCO must be included in the TSs for any item meeting one or more of the following four criteria:
1.
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; 2.
A process variable, design feature or operating restriction that is an initial condition of a design-basis accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; 3.
A structure, system or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; and 4.
A structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
Accordingly, the existing TS requirements that fall within or satisfy any of the criteria in 10 CFR 50.36 must be retained in the TSs, while those TS requirements that do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents.
3.0 TECHNICAL EVALUATION
At CPSES, the 125 VDC electrical power system consists of two independent and redundant safety related Class 1 E DC electrical power subsystems (Train A and Train B). Each subsystem consists of two 125 VDC batteries, the associated battery chargers for each battery, and all the associated control equipment and interconnecting cabling.
There are two 100 percent capacity battery chargers per battery. One charger for each battery is required for operation and the other is kept as a spare. If the spare battery charger is substituted, then the requirements of independence and redundancy between subsystems are maintained.
During normal operation, the 125 VDC load is powered from the battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC load is automatically powered from the station batteries. The Train A and Train B DC electrical power subsystems provide the control power for its associated Class 1 E AC power loads fed from 6.9 kilovolts (kV) switchgear and 480 Volts (V) load centers. The DC electrical power subsystems also provide DC electrical power to the inverters, which in turn power the AC vital buses.
The 125 VDC batteries of each subsystem (train) are separately housed in a ventilated room apart from its charger and distribution centers. Each subsystem is located in an area separated physically and electrically from the other subsystem to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. There is no sharing between redundant Class 1E subsystems, such as batteries, battery chargers, or distribution panels.
Each battery has adequate capacity to meet the duty cycle(s) as discussed in the CPSES Final Safety Analysis Report (FSAR), Chapter 8. The battery is designed with additional capacity above that required by the design duty cycle to allow for temperature variations and other factors.
The licensee stated that batteries for Train A and Train B DC electrical power subsystems are sized to produce required capacity at 80 percent of nameplate rating, corresponding to warranted capacity at end of life and the 100 percent design demand. The minimum design voltage limit is 105 V. The battery cells consist of flooded lead acid construction with a nominal specific gravity of 1.215. This specific gravity corresponds to an open circuit battery voltage of approximately 2.065 volts per cell (VPC). The open circuit voltage is the voltage maintained when there is no charging or discharging. Once fully charged with cell float voltage > 2.07 VPC, the battery cell will maintain its capacity for 30 days without further charging according to the manufacturers instructions. The battery float charge voltage limit is established as 2.13 VPC, which corresponds to a total minimum float voltage output of 128 V for a 60 cell battery.
However, the optimal long term performance is obtained by maintaining a float voltage of 2.20 to 2.25 VPC. This provides adequate over-potential, which limits the formation of lead sulfate and self discharge. The nominal float voltage of 2.20 VPC corresponds to a total float voltage output of 132 V for a 60 cell battery as discussed in the CPSES FSAR, Chapter 8. Furthermore, each Train A and Train B DC electrical power subsystem battery charger has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger also has sufficient excess capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying normal steady state loads as described in the CPSES FSAR, Chapter 8.
The battery charger is normally in the float-charge mode. Float-charge is the condition in which the charger supplies the connected loads and the battery cells receive adequate current to optimally charge the battery. This assures that the internal losses of a battery are overcome to maintain the battery in a fully charged state. When desired, the charger can be placed in the equalize mode. The equalize mode is at a higher voltage than the float mode and the charging current is correspondingly higher. The battery charger is operated in the equalize mode after a battery discharge or for routine maintenance.
Following a battery discharge, the battery recharge characteristic accepts current at the current limit of the battery charger (if the discharge was significant, e.g., following a battery service test) until the battery terminal voltage approaches the charger voltage setpoint. Charging current then reduces exponentially during the remainder of the recharge cycle. Lead calcium batteries have recharge efficiencies of greater than 95 percent, so once at least 105 percent of the ampere (amp)-hours discharged have been returned, the battery capacity would be restored to the same condition as it was prior to the discharge. This can be monitored by direct observation of the exponentially decaying charging current or by evaluating the amp-hours discharged from the battery and the amp-hours returned to the battery.
3.1 Evaluation of Proposed TS Changes In its letter dated June 6, 2003, as supplemented by letter dated February 24, 2004, the licensee proposed a license amendment to the TSs for CPSES, using TSTF-360, Revision 1.
The proposed changes would revise TS 3.8.4, TS 3.8.5, TS 3.8.6, and TS 5.5.19. In particular, the licensee stated that the proposed changes will:
(1)
Provide new Conditions and Required Actions specific to the battery chargers and batteries in each DC electrical power subsystem.
(2)
Relocate preventive maintenance type Surveillance Requirements to licensee-controlled programs.
(3)
Add alternate criteria for battery charger testing.
(4)
Replace battery specific gravity monitoring with float current monitoring.
(5)
Relocate the following to a licensee controlled program based on IEEE Standard 450-1995, and/or to the TS Bases including:
(a)
Category A and B limits for battery cell float voltage and electrolyte level, along with the associated compensatory actions; (b)
Category C specific value limit for electrolyte level; (c)
The specific value limit for electrolyte temperature; and (d)
Specific value for the minimum battery charging float voltage, and (e)
New TS Administrative Control Program [5.5.19] to reference actions for cell voltage and electrolyte level.
(6)
Add specific Required Actions and increased Completion Times for out-of-limits conditions for battery cell float voltage, float current, electrolyte level, and electrolyte temperature and the associated SRs.
(7)
Provide enhanced Bases for the proposed changes.
(8)
Eliminate the once per 60 month restriction on replacing the battery service test with the battery modified performance test.
Additional administrative, renumbering, and editorial type changes are also associated with the above list of proposed changes and include:
(9)
Move SR 3.8.4.8 to TS Section 3.8.6 on battery operability.
(10)
Delete the reference to Cell from Section Headings of LCO 3.8.6.
The NRC staff reviewed and evaluated each of the proposed changes to the CPSES TSs as follows:
Proposed Change (1):
Changes to TS 3.8.4:
Add two new Conditions (A and B) to current TS 3.8.4 with its associated Required Actions and CTs:
Condition A: One or two required battery chargers on one train inoperable.
Required Actions:
A.1 Restore affected battery(ies) terminal voltage to greater than or equal to the minimum established float voltage, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
A.2 Verify affected battery(ies) float current greater than or equal to 2 amps, once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
A.3 Restore required battery charger(s) to OPERABLE status, within 7 days.
Condition B:
One or two batteries on one train inoperable.
Required Actions:
B.1 Restore affected battery(ies) to OPERABLE status, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Additionally, the current existing Conditions A and B are renumbered to become conditions C and D to reflect the addition of the proposed new conditions.
Change to current SR 3.8.4.1 The licensee proposed to revise existing SR 3.8.4.1 to state Verify battery terminal voltage is greater than or equal to the minimum established float voltage, with the specific limiting value for float voltage relocated to the TS Bases.
Evaluation of Proposed Change (1): The NRC staff reviewed existing TS 3.8.4 Condition A that applies to One DC electrical power subsystem inoperable, and finds that Required Actions in response to DC electrical power subsystem inoperability are the same regardless of whether the DC subsystem is inoperable as a result of a battery charger, a battery, or the entire subsystem without DC power. To allow for a range of possible degradations to the DC subsystem, the proposed change revises the existing TS 3.8.4 format to add two new Conditions; Condition A that is specific to one or two required battery chargers on one train inoperable, and Condition B that is specific to one or two batteries on one train inoperable.
The proposed wording of new TS 3.8.4 Condition A, "One or two required battery chargers on one train inoperable," incorporates the bracketed plant specific wording recommended in TSTF-360, Revision 1, and adds the term required to reflect the current CPSES plant specific design and licensing basis. The phrase one or two required is used to describe the possible combinations of inoperable required battery chargers in one DC subsystem (train) that in either case would result in the same DC subsystem inoperable.
The proposed new Condition A is equivalent to the existing TS 3.8.4 DC electrical power subsystem Condition A requirements for inoperable battery chargers in the same train, wherein one of the two fully qualified battery chargers associated with each battery is required operable and in service for each of the two batteries that together comprise one train of DC electrical power.
The existing TS 3.8.4 Condition A 2-hour CT limits the restoration time for an inoperable DC electrical power subsystem is based on Regulatory Guide 1.93, Availability of Electric Power Sources. Consequently, the current CT limits restoration time for an inoperable battery charger to the same time as for an inoperable battery or for a de-energized DC electrical power distribution subsystem. The primary role of the battery charger is in support of maintaining the operability of its associated battery. This is accomplished by the charger being of sufficient size to carry the normal steady state DC loads, with sufficient additional capacity to provide some minimal over-potential to the associated battery. Also, a secondary safety significant function can be attributed to carrying the post-accident DC load after restoration of alternate current (AC) power (typically 10-13 seconds, the time required for the Emergency Diesel Generator to tie on to its emergency bus). In analyzed post-accident scenarios, there are no safety related criteria for recharging a fully discharged battery in any specific time period.
The proposed new TS 3.8.4 Condition A adds new Required Actions and CTs that would allow a reasonable time of 7 days to restore the inoperable required battery charger or chargers in one DC electrical power subsystem to operable status, while: a) focusing efforts on retaining battery capabilities; b) continuing to require full charger operability that is based on the margin afforded in the design capacity of the battery charger and consistent with the current basis for charger operability; and c) complying with the 2-hour restoration time for a de-energized DC electrical distribution subsystem, as provided in TS 3.8.9. This time is contingent on a focused and tiered approach to assure that adequate battery capability is maintained.
The NRC staff finds the proposed restoration time acceptable based on the review of the following licensee justification. In the event of an inoperable battery charger, the first priority for the operator is to minimize the associated battery discharge. The proposed TS 3.8.4 Required Action A.1 ensures that the associated battery discharge is terminated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by requiring that battery terminal voltage be restored to a value greater than or equal to the battery minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This assumes that the batteries are still capable of performing their required function. During this 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> period, if the affected train batteries were not capable of performing their required function, the other train is available to perform the required function. The allowed time is adequate for restoring the inoperable battery charger or for providing an alternate means of restoring battery terminal voltage to a value greater than or equal to the minimum established float voltage. The focus of the proposed allowance is that the battery capacity be preserved and assured, while the means of accomplishing this is left to plant capabilities.
The licensee stated that in most cases, as a first tier, a spare battery charger would be employed within the initial 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in other cases other means, including using a degraded normally in service battery charger, to provide means to float and preserve the battery capacity.
Presuming that the associated battery discharge, if it had been occurring, is terminated and that the associated DC bus remains energized, as required by separate LCO 3.8.9, there is reasonable basis for extending the allowed restoration time for a required inoperable battery charger beyond the 2-hour limit of the first tier Required Action A.1 to the proposed 7 days.
In the second tier, TS 3.8.4 Required Action A.2 proposes that within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that it be established that the associated battery has sufficient capacity to perform its assumed duty cycle as measured by float current less than or equal to 2 amps. This allows time for some recharging of lost capacity that may have occurred during the initial 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion of its recharge cycle. The time to return a battery to its fully charged state under this condition is a function of the amount of the previous discharge and the recharge characteristic of the battery. In this condition, there is good assurance of fully recharging the battery within the proposed 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The licensee stated that the affected battery float current would continue to be verified less than or equal to 2 amps every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> until the required inoperable battery charger is restored to operable status.
In the third tier, TS 3.8.4 Required Action A.3 would provide 7 days for the required battery chargers in one DC electrical power subsystem be restored to operable status. Given the choice between a required plant shutdown in this condition, as per current requirements, versus an allowance for a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> determination period, at the end of which it is reasonable to conclude that the associated battery can be shown to have its assumed capacity, followed by a 7-day restoration period, and thus the proposed change is an acceptable relaxation to the existing specification.
In its supplement letter dated February 24, 2004, the licensee further stated that If both Battery Chargers for either Battery in the same DC electrical power subsystem become inoperable, then the new LCO Condition A for DC Sources - Operating would be entered and the associated Required Actions would be taken within the specified Completion Times... These would allow reestablishing and maintaining the affected battery terminal voltage and float current requirements by the use of temporary battery chargers, including partially degraded normal battery charger(s), until a fully OPERABLE battery charger is restored and returned to service. The remaining changes to LCO 3.8.4 are editorial in nature to provide clarification through renumbering and the NRC staff concludes that the editorial changes are acceptable.
As discussed above, the proposed new Actions will focus efforts on retaining battery capabilities, retaining the requirement for charger operability, and applying a reasonable restoration time for an inoperable battery charger; while avoiding an unnecessary plant shutdown transient. Therefore, the NRC staff finds that the proposed change is reasonable, it meets 10 CFR 50.36 requirements, it is consistent with the intent of NUREG-1431, Revision 2, and is acceptable.
The NRC staff reviewed the proposed changes and finds the revised SR 3.8.4.1 provides for the verification of battery terminal voltage while the system is on float charge, and this SR helps to ensure the effectiveness of the chargers. The licensee stated that voltage requirements are consistent with the minimum float voltage established by the battery manufacturer, and the 7-day frequency is consistent with manufacturer recommendations and IEEE Standard 450-1995. Therefore, the NRC staff finds that the proposed change to SR 3.8.4.1 meets 10 CFR 50.36 requirements, is consistent with the intent of with NUREG-1431, Revision 2, and is acceptable.
Proposed Change (2): The licensee proposed the following:
Relocation of current SRs 3.8.4.2, 3.8.4.3, 3.8.4.4, and 3.8.4.5 to a licensee-controlled program.
Renumber current SR 3.8.4.7 to become SR 3.8.4.3 and renumber references to SR 3.8.4.8 and SR 3.8.4.7 in the SR Note to read SR 3.8.6.6 and SR 3.8.4.3, respectively.
Renumber SR 3.8.4.6 as 3.8.4.2.
Move current SR 3.8.4.8 under TS Section 3.8.6 and renumber it to become new SR 3.8.6.6.
Revise current SR 3.8.5.1 to delete reference to the SRs relocated from current TS 3.8.4 Evaluation of Proposed Change (2): For the proposed relocation of existing SRs 3.8.4.2, 3.8.4.3, 3.8.4.4, and 3.8.4.5, the licensee stated that failure to meet the SR 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 activity. As stated in the current Bases, SR 3.8.4.4 identifies the removal of visible corrosion and tightening of terminal connections as a preventive maintenance. SR 3.8.4.3, visible inspection for physical damage or deterioration that could potentially degrade battery performance, is not required for the battery to perform its safety function, but again reflects ongoing preventive maintenance activities. These activities are inappropriate for operability SRs, do not meet the requirements of 10 CFR 50.36 for retention in the TSs, and are better controlled under the maintenance programs for batteries consistent with IEEE Standard 450-1995 and Bases in TSTF-360.
The licensee stated that existing SR 3.8.4.2 and SR 3.8.4.5 verify resistance values; these are vendor recommended values at which some action should be taken and are not necessarily values at which the operability of the battery is in question. The safety analyses do not assume a specific battery resistance value, but assume the batteries will supply adequate power.
Therefore, a key parameter is the overall battery resistance. The resistance of each connection varies independently from all the others. The NRC staff agrees that some of these connection resistances may be higher or lower than others, and that the battery may still be able to perform its function, and should not be considered inoperable solely because one connectors resistance is high. The batterys overall resistance has a direct impact on operability; however, it is adequately determined as acceptable through completion of the battery service and discharge tests; however; this does not meet the requirements of 10 CFR 50.36 for retention in the TSs. Based on the foregoing, the NRC staff finds the proposed relocation of these SRs to a licensee-controlled program to be consistent with IEEE Standard 450-1995 and Bases in TSTF-360. The licensee stated that the program is controlled under its battery capacity monitoring programs and is under the umbrella procedure which requires that changes to the procedures under the program will be controlled under 10 CFR 50.59. Therefore, the NRC staff finds the proposed changes acceptable.
New proposed SR 3.8.4.2 [i.e., existing SR 3.8.4.6 renumbered as SR 3.8.4.2] is consistent with TSTF-360 and provides alternate testing criteria for battery charger testing to confirm the charger design capacity. The NRC staffs evaluation of this proposed change is discussed under the proposed change (3) below.
New SR 3.8.4.3 [i.e., existing SR 3.8.4.7 renumbered as SR 3.8.4.3] and related reference changes are editorial or administrative in nature, and do not change any substantive requirements. Therefore, the NRC staff finds the proposed changes acceptable.
Relocating the current SR 3.8.4.8 to TS Section 3.8.6 and renumbering it as SR 3.8.6.6 are changes which are administrative in nature and do not change any substantive requirements.
Therefore, the NRC staff finds this proposed change acceptable.
The current SR 3.8.5.1 is revised to delete reference to the SRs being relocated from TS 3.8.4 and to reflect the remaining SRs in the SR Note. The proposed changes to SR 3.8.5.1, deleting references to the SRs relocated from TS 3.8.4, and renumbering the remaining SRs in the SR Note, are administrative in nature. Therefore, the NRC staff finds this change to be acceptable.
Based on the above review, the NRC staff finds the licensee-proposed change (2) meets 10 CFR 50.36 requirements and is consistent with the intent of NUREG-1431, Revision 2.
Therefore, the revisions under proposed change (2) are acceptable.
Proposed Change (3): The licensee proposed to add alternate testing criteria for battery charger testing in the following manner:
Renumber current SR 3.8.4.6 to become new SR 3.8.4.2 and revise new proposed SR 3.8.4.2 to state the following, with the specific limiting value for float voltage relocated to the TS Bases.
Verify each battery charger supplies greater than or equal to 300 amps at greater than or equal to the minimum established charger test voltage for greater than or equal to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
OR Verify each battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest combined demands of the various continuous steady state loads after a battery discharge to the bounding design basis event discharge state.
Evaluation of Proposed Change (3): The proposed change states the requirement for verification of specific parameters for battery charger performance testing. This test is intended to confirm the charger design capacity. Alternate acceptance criteria are proposed that allow an actual in-service demonstration that the charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state. This meets the intent of the existing test and allows for a normal in-place demonstration of the charger capability thereby minimizing the time when the charger would be disconnected from the DC bus. Based on the above review, the NRC staff finds the proposed change requires the battery to discharge to the bounding design basis event discharge rate, which is more restrictive than the current TS requirements and, therefore, the proposed change is acceptable.
Proposed Changes (4) and (5): The licensee proposed to replace the requirements of current TS 3.8.6 battery specific gravity monitoring with new proposed TS 3.8.6 float current monitoring and relocate current requirements of TS Table 3.8.6-1 to a licensee-controlled program based on IEEE Standard 450-1995, and/or the TS Bases in the following manner:
The word Cell is deleted from current TS 3.8.6 and the LCO is revised to delete reference to Table 3.8.6-1, "Battery Cell Parameters Requirements."
Existing Condition A is deleted and replaced with the following new Conditions:
Proposed Condition A for one or two battery(ies) with one or more cells with float voltage < 2.07 V Proposed new Condition B for one or two battery(ies) with a float current > 2 amps Proposed new Condition C for one or two battery(ies) with one or more cells with electrolyte level less than minimum established design limits Proposed new Condition D for one or two battery(ies) with pilot cell electrolyte temperature less than minimum established design limits Existing Condition B is renamed Condition F and revised by referencing proposed Conditions A, B, C, D, and E. In addition, the portions of existing Condition B that address electrolyte temperature and battery cell parameters not within Category C values are replaced with a new renamed Condition F that addresses battery cell float voltage and float current.
Existing SR 3.8.6.1, SR 3.8.6.2, SR 3.8.6.3 and Table 3.8.6-1 are deleted and replaced with new SR 3.8.6.1, SR 3.8.6.2, SR 3.8.6.3, SR 3.8.6.4, SR 3.8.6.5 and SR 3.8.6.6
[was existing SR 3.8.4.8 moved from TS Section 3.8.4 and renamed SR 3.8.6.6] for float current, battery pilot, battery cell float voltage, electrolyte level, and pilot cell electrolyte temperature. Existing Category A and B limits for electrolyte level and float voltage, the Category C specific limiting value for electrolyte level, and the specific limiting value for pilot cell electrolyte temperature are relocated to a licensee-controlled program.
Evaluation of Proposed Changes (4) and (5): The NRC staff agrees that deleting the word Cell from existing TS 3.8.6 and the LCO and deleting reference to Table 3.8.6-1 are administrative changes in nature, and do not change substantive requirements and, therefore, the NRC staff finds the proposed changes acceptable.
The licensee proposed to relocate existing TS Table 3.8.6-1 to a licensee-controlled program titled Battery Monitoring and Maintenance Program. This program will be administratively controlled under TS Section 5.5.19. The TS Table 3.8.6-1 has three categories of limitations for the battery cells: 1) electrolyte level, 2) float voltage, and 3) specific gravity. The NRC staff finds that the parameter values in Table 3.8.6-1 will continue to be controlled at their current level in accordance with the new program and actions will be implemented in accordance with the plant corrective action program.
The evaluations of new SR 3.8.6.1, SR 3.8.6.2, SR 3.8.6.3, SR 3.8.6.4, SR 3.8.6.5 and SR 3.8.6.6 are discussed under proposed change (6).
Categories A and B values represent appropriate monitoring levels and preventive maintenance levels for long term battery quality and extended battery life. As such, they do not meet 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. The licensee thus proposed that these values and the current Required Actions associated with restoration, be relocated to a licensee-controlled program that is under the control of 10 CFR 50.59. This program is based on the recommendations of IEEE Standard 450-1995. The battery parameter values will continue to be controlled at their current level and actions will be implemented in accordance with the plant corrective action program. The battery and its preventive maintenance and monitoring are under the regulatory requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." This relocation will continue to assure the battery is maintained at current levels of performance and any changes in the procedure will be controlled under the licensees umbrella procedures which requires that changes be controlled under 10 CFR 50.59. This allows the TSs and the licensed operators to focus on battery parameter degradations.
Category C specific limiting values for the battery electrolyte temperature and level are also relocated to a licensee-controlled program that is under an umbrella procedure that requires that the licensee control the changes under the 10 CFR 50.59 process. The TS will require the electrolyte temperature and level to be greater than or equal to minimum established design limits. Depending on the available excess capacity of the associated battery, the minimum temperature necessary to support operability of the battery can vary. As such, they do not meet 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." The NRC staff finds the proposed relocation to a licensee-controlled program will allow the flexibility to monitor and control this limit at values directly related to the batterys ability to perform its assumed function.
Based on the above, the NRC staff finds that the proposed changes (4) and (5) maintain compliance with requirements governing the design and operation of the DC electrical power system, provide adequate assurance of system operability, meet 10 CFR 50.36 requirements, and are consistent with NUREG-1431, Revision 2. Therefore, the proposed changes are acceptable.
Proposed Change (6): The licensee proposed to add specific Required Actions and increase CT for out-of-limits conditions for battery cell float voltage, float current, electrolyte level, and electrolyte temperature and associated SRs.
The proposed change deletes existing TS 3.8.6 Condition A and replaces it with the following new Conditions A, B, C, D, and E, which will be added to current TS LCO 3.8.6; and the existing old Condition B would be re-designated as Condition F. In addition, the portions of Condition B that address electrolyte temperature and battery cell parameters not within Category C values are replaced with a condition that addresses battery cell voltage and float current. The Required Actions are related to parameters that have an impact on the battery OPERABILITY. These conditions with their associated Required Actions and CTs will provide the necessary actions for a specific abnormal battery condition.
Evaluation of Proposed Change (6): Proposed new Condition A applies to a battery that has one or more battery cells with a float voltage less than 2.07 V. When the battery is considered degraded the Required Actions are to verify (a) the battery terminal voltage is greater than or equal to minimum established float voltage (SR 3.8.4.1), and (b) the battery float current is less than or equal to 2 amps (SR 3.8.6.1). The NRC staff finds that the proposed actions will assure that there is still sufficient battery capacity to perform its intended function and the battery is not considered INOPERABLE. Continued operations for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are permitted to allow the restoration of the affected cell (cells) voltage to greater than or equal to 2.07 V. The NRC staff concludes that the 24-hour restoration time is a reasonable time and, therefore, finds the proposed change acceptable.
Proposed new Condition B applies to a battery with a float current greater than 2 amps, which indicates that the battery is partially discharged. The Required Action is to verify within two hours that the battery terminal voltage is greater than or equal to the minimum established float voltage (SR 3.8.4.1), confirming battery charger operability. If the terminal voltage is found to be less than the minimum established float voltage, it indicates that the battery charger is inoperable or is operating in the current limit mode. If the battery charger is found to be inoperable, then LCO 3.8.4 Condition A would be entered. If the battery charger is operating in the current limit mode after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, it is an indication that the battery has been substantially discharged and likely cannot perform its required design functions. If the float voltage is found to be satisfactory, but there are one or more battery cells with float voltage less than 2.07 V, the associated OR statement of proposed Condition F is applicable and the battery must be declared inoperable. If the float voltage is satisfactory and there are no cells less than 2.07 V, then there is assurance that within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> the battery will be restored to its fully-charged condition from any discharge that might have occurred due to a temporary loss of the battery charger. Based on the above review, the NRC staff concludes that proposed Condition B meets 10 CFR 50.36 requirements, and is consistent with the intent of NUREG-1431, Revision 2. Therefore the proposed change is acceptable.
Proposed new Condition C relates to the level of the electrolyte in a cell (cells) less than a minimum established design limit. If the level is above the top of the battery plates, but below the minimum limit, the battery still has sufficient capacity and is not considered inoperable.
With electrolyte level below the top of the plates, there is a potential for dry-out and plate degradation. Required Actions C.1 and C.2 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. The NRC staff finds these actions adequate to ensure that minimum electrolyte levels are maintained, therefore, the proposed change is acceptable.
In addition, the "Battery Monitoring and Maintenance Program" described in proposed TS Section 5.5.19 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. Based on the above evaluation, the NRC staff concludes that proposed Condition C is acceptable.
Proposed new Condition D applies to a battery found with a pilot cell electrolyte temperature less than the minimum established design limit. A low electrolyte temperature limits the current and power available. Because the battery is sized with an adequate margin to perform its intended functions as stated in the CPSES Updated FSAR, the NRC staff finds that the proposed 12-hour CT is reasonable to restore the battery electrolyte temperature. Therefore, the NRC staff concludes that the proposed change is acceptable.
Proposed new Condition E relates to batteries with battery parameters not within limits. If this condition exists, there is not sufficient assurance that the battery capacity has not been affected. There is the possibility that the batteries involved will not be able to perform their intended function. Thus, the licensee proposes that battery parameters be restored to within limits on at least one division within two hours. Based on its review, the NRC staff concludes that this proposal is reasonable for assuring safety, and is acceptable.
Renumbered Condition F (from current Condition B) for one or more batteries with battery parameters outside the allowance of the Required Action for Condition A, B, C, D, or E indicates that sufficient capacity to supply the maximum expected load requirement is not assured, or if one battery with one or more cells with float voltage < 2.07 V and float current
>2 amps, the corresponding DC battery must be declared inoperable immediately. The NRC staff concludes that this change is reasonable and, therefore, is acceptable.
In addition to the above proposed new Conditions added to current LCO 3.8.6, the licensee also proposed the following revision to SRs associated with current LCO 3.8.6. Current SR 3.8.6.1, SR 3.8.6.2, and SR 3.8.6.3 are deleted and replaced by the following proposed new SRs, SR 3.8.6.1, SR 3.8.6.2, SR 3.8.6.3, SR 3.8.6.4, SR 3.8.6.5, and SR 3.8.6.6 with a new NOTE Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.
SR 3.8.6.1 requires verification that float current for each battery is less than or equal to 2 amps every 7 days. The float current indicates the battery conditions. These current requirements are based on a fully-charged battery. This is consistent with IEEE Standard 450-1995 and manufacturers recommendations, and is acceptable to the NRC staff as explained previously in this SE.
SR 3.8.6.2 requires verification that pilot cell voltage for each battery is greater than or equal to 2.07 V every 31 days. This is consistent with IEEE Standard 450-1995 450 and manufacturers recommendations, and is acceptable to the NRC staff as explained previously in this SE.
SR 3.8.6.3 requires verification every 31 days that the connected cell electrolyte level for each battery is greater than or equal to minimum established design limits. This is consistent with IEEE Standard 450-1995 and manufacturers recommendations and is acceptable to the NRC staff as explained previously in this SE.
SR 3.8.6.4 requires verification every 31 days that the temperature of each battery pilot cell is greater than or equal to the minimum established design limits. The design limits will be provided in TS 5.5.19, Battery Monitoring and Maintenance Program.
The program proposed under TS 5.5.19 is based on IEEE Standard 450-1995, and requires actions to restore battery cells with float voltage < 2.13 V and actions to equalize and test battery cells that have been discovered with electrolyte level below the top of the cell plates.
The NRC staff finds the proposed program meets the actions required by IEEE Standard 450-1995. The licensee also proposed to delete the reference year (1995) from the IEEE Standard 450-1995. This change will validate the TS for future revisions of the IEEE Standard. The licensee explained that this change is reasonable, because the specific commitment to IEEE Standard 450-1995 is included in the licensees commitments and in the revised bases. The NRC staff concludes that the change is more restrictive and that the program will achieve safe conditions, and is, therefore, acceptable.
SR 3.8.6.5 requires verification every 92 days that the connected cell voltage for each battery is greater than or equal to 2.07 V. A voltage of 2.07 V represents the minimum voltage at which battery operability is assured. The surveillance frequency and minimum established design limits for optimal long-term battery performance are based on operational experience and are acceptable to the NRC staff.
SR 3.8.6.6 is a relocated item from current SR 3.8.4.8, and thus is an administrative change.
The NRC staff finds the above SRs are designed to maintain battery parameters within acceptable limits and to ensure availability of the required DC power to shut down the reactor and to maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA. The NRC staff finds the proposed changes acceptable.
Proposed Change (7): The licensee proposed to revise the TS Bases to TS 3.8.4, TS 3.8.5, and TS 3.8.6 to incorporate the information and discussion presented in TSTF-360, Revision 1 and to reflect other proposed editorial changes.
Evaluation of Proposed Change (7): The NRC staff reviewed the licensees justifications for adopting the various elements of TSTF-360, Revision 1, for consistency with the revised wording in the Bases submittal by the licensee and with the Bases of the NRC staff-approved TSTF-360. The associated Bases provided in the licensee's June 6, 2003, submittal were reviewed against those Bases that were accepted by the NRC staff during the review of TSTF-360, Revision 0, and TSTF-360, Revision 1. The NRC staff finds the proposed revised Bases to contain wording that is consistent with that of the NRC staff-approved wording in TSTF-360, Revision 1. Therefore, the NRC staff has no objection to the proposed Bases.
Information In (8): The licensee provided information that the elimination of the once per 60 month restriction on replacing the battery service test with the battery modified performance test as described in TSTF-360, Revision 1 is not included in this amendment request because this has already been previously incorporated in current SR 3.8.4.7, previously approved by the NRC staff by Amendment 75.
Evaluation of Information in (8): The NRC staff agrees with the licensee's statement.
Proposed Change (9): The licensee proposed to move the current SR 3.8.4.8 to TS 3.8.6 on battery operability. This proposed change is an administrative change that will move current SR 3.8.4.8, which is a test of battery capacity, to be directly associated with TS 3.8.6 on Battery Parameters, which defines the operability requirements of the DC electrical power system batteries.
Evaluation of Proposed Change (9): This change has been discussed under proposed change (6) for SR 3.8.6.6 Proposed Change (10): The licensee proposed to delete the reference to "Cell" in LCO 3.8.6.
This LCO is intended to require and define the operability requirements of the DC electrical power subsystem batteries, and is not limited to battery cell parameters or performance.
Evaluation of Proposed Change (10): This change has been discussed under proposed changes (4) and (5).
3.2 Summary of Evaluation of Proposed Changes The proposed changes to the DC electrical power subsystems specifications TS 3.8.4, TS 3.8.5, TS 3.8.6, and TS 5.5.19 requirements for a "Battery Maintenance and Monitoring Program" based on the recommendations of IEEE Standard 450-1995, are consistent, except for noted plant-specific difference, with the considerations and proposed changes provided in NRC-approved TSTF-360, Revision 1, as incorporated in recently issued NUREG-1431, Revision 2. Each of the proposed changes was evaluated in accordance with the requirements of 10 CFR 50.36 and determined not to adversely affect nuclear safety or continued safe plant operations and, therefore, the changes proposed by the licensee are acceptable.
Based on the above evaluation, the NRC staff concludes that the above proposed changes have adequately addressed the following areas as required in TSTF-360, Revision 1:
(1) provided a specific Action and increased CT for an inoperable battery charger, (2) relocated preventive maintenance SRs to licensee-controlled programs, (3) proposed alternate testing criteria for battery charger testing, (4) replaced battery specific gravity monitoring with float current monitoring, (5) relocated maintenance surveillance for cell voltages and electrolyte levels to a licensee-controlled program based on recommendations from IEEE Standard 450-1995, (6) provided specific Actions and increased restoration times for out-of-limits conditions for battery cell voltages, electrolyte levels, and electrolyte temperatures, (7) provided enhanced TS Bases for each of the newly proposed TSs 3.8.4 and 3.8.5, and (8) eliminated the once per 60-month restriction on replacing the battery service test with the battery modified performance discharge test.
3.3 The Licensees Commitments The licensees application (Reference 1) contained the following new commitments to be implemented following the approval by the NRC of the licensees request for amendments.
A "Battery Monitoring and Maintenance Program" will be implemented to control the items relocated from current TS Table 3.8.6-1, "Battery Cell Parameters Requirements," and the relocated Surveillance Requirement (SR) activities from TS 3.8.4 that perform preventive maintenance on the safety-related batteries.
The Battery Monitoring and Maintenance Program will be based on the recommendations of 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,"
and will implement the requirements of new TS Administrative Controls Program 5.5.19.
The NRC staff finds that reasonable controls for the implementation and subsequent evaluation of proposed changes pertaining to the above regulatory commitments are best provided by the licensees administrative processes, including its commitment management program. The above regulatory commitments do not warrant the creation of regulatory requirements.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (68 FR 40721 dated July 8, 2003). Accordingly, the amendments meet 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 need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (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 amendments will not be inimical to the common defense and security or to the health and safety of the public.
7.0 REFERENCES
1.
Letter from C. Lance Terry (the licensee) to USNRC, "Comanche Peak Steam Electric Station (CPSES) Docket Nos. 50-445 and 50-446, License Amendment Request (LAR) 02-06 Revision to Technical Specifications associated with DC Electrical Power Systems," dated June 6, 2003.
2.
Letter from Mike Blevins (the licensee) to USNRC, "Comanche Peak Steam Electric Station (CPSES) Docket Nos. 50-445 and 50-446 Response to Request for Additional Information related to License Amendment Request (LAR) 02-06 Revision to Technical Specification associated with DC Electrical Power Systems," dated February 24, 2004.
3.
Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-360, Revision 1, "DC Electrical Rewrite," dated November 3, 2000 (including Attachment 1, "Battery Primer For Nuclear Power Plants," dated January 7, 2000, Attachment 2, "Kyle Floyd White Paper, A proposed Method for Selecting the Return to Service Current Limit for Safety-Related Batteries, Draft C for SCC-29 Meeting," dated March 29, 2000, Attachment 3, "Forwarding Response to Battery TSTF Proposal," dated September 18, 2000, and Attachment 4, "Response to NEI Comments (9/18/00) on Revised Version of TSTF-360 (Battery TS)," dated October 18, 2000).
4.
IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," dated 1995.
5.
NUREG-1431, Revision 2, "Standard Technical Specifications, Westinghouse Plants,"
dated June 2001.
Principal Contributor: N. B. Le Date: July 1, 2004
April 2004 Comanche Peak Steam Electric Station cc:
Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 2159 Glen Rose, TX 76403-2159 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. Fred W. Madden Regulatory Affairs Manager TXU Generation Company LP P. O. Box 1002 Glen Rose, TX 76043 George L. Edgar, Esq.
Morgan Lewis 1111 Pennsylvania Avenue, NW Washington, DC 20004 County Judge P. O. Box 851 Glen Rose, TX 76043 Environmental and Natural Resources Policy Director Office of the Governor P. O. Box 12428 Austin, TX 78711-3189 Mr. Richard A. Ratliff, Chief Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189 Mr. Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326 Ms. Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122 P. O. Box 13087 Austin, TX 78711-3087 Terry Parks, Chief Inspector Texas Department of Licensing and Regulation Boiler Program P. O. Box 12157 Austin, TX 78711