ML050740134
| ML050740134 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/08/2005 |
| From: | Jamil D Duke Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML050740134 (11) | |
Text
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Duke WPowere A Duke Energy Company D.M. JAMIL Vice President Duke Power Catawba Nuclear Station 4800 Concord Rd. / CN01 VP York, SC 29745-9635 803 831 4251 803 831 3221 fax March 8, 2005 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C. 20555
Subject:
Duke Energy Corporation Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Proposed Technical Specifications Amendments 3.8.4, DC Sources -
Operating 3.8.6, Battery Cell Parameters
Reference:
- 1.
Letter from Duke Energy Corporation to NRC, same subject, dated July 19, 2004
- 2.
Letter from NRC to Duke Energy Corporation, dated December 7, 2004 Pursuant to 10 CFR 50.4 and 10 CFR 50.90, and in response to the Request for Additional Information provided by the NRC staff via telephone and Reference 2, please find attached Duke Energy Corporation's response.
The format of the response is to restate the NRC question, followed by the response.
The original No Significant Hazards Analysis and Environmental Analysis contained in Reference 1 are unchanged as a result of this response.
There are no regulatory commitments contained in this letter or its attachment.
Pursuant to 10 CFR 50.91, a copy of this response is being sent to the appropriate state official.
Inquiries on this matter should be directed to L.J. Rudy at (803) 831-3084.
www.dukepower.com 0 0
U.S. Nuclear Regulatory Commission Page 2 March 8, 2005 Very truly Dhiaa M. Jamil LJR/st h
Attachment
F A
U.S. Nuclear Regulatory Commission Page 3 March 8, 2005 Dhiaa M. Jamil affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.
Subscribed and sworn to me:
e7-zoo Date tar Public My commission expires:
0//
/Zo /a Date SEAL-Ifp."-
1 U.S. Nuclear Regulatory Commission Page 4 March 8, 2005 xc (with attachment):
W.D. Travers U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 E.F. Guthrie Senior Resident Inspector (CNS)
U.S. Nuclear Regulatory Commission Catawba Nuclear Station S.E. Peters (addressee only)
NRC Project Manager (CNS)
U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9 Washington, D.C. 20555-0001 H.J. Porter, Director Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201
ATTACHMENT RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION
.9 REQUEST FOR ADDITIONAL INFORMATION DUKE POWER COMPANY CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS.'50-413 AND 50-414 The Nuclear Regulatory Commission (NRC) staff has reviewed the licensee's submittal dated'July 19, 2004, regarding the replacement of the existing nickel cadmium diesel generator (DG) batteries with lead acid batteries.
The NRC staff has identified the following information that is needed to enable the continuation of its review.
Provide a discussion that shows that the design capacities of the DG battery chargers are capable of supporting the proposed DG batteries that utilize lead acid cells (i.e., show that the current DG battery chargers are capable of supplying the largest combined demands of the various steady state loads and that they have the charging capacity to restore the DG lead acid'batteries from the design minimum charge state to the fully charged state, irrespective of plant status during these demand occurrences).
Duke Energy Corporation Response The sizing of the DG battery chargers to recharge the batteries within an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval, as required, is based on the ability of the chargers to replace the ampere-hours of capacity actually removed during a design basis event.
The new lead acid batteries will be higher in overall ampere-hour capacity than the existing nickel cadmium cells.
However, the battery duty cycle will itself not be significantly affected by the modification.
Calculation # CNC-1381.05-00-0050, "125 VDC Diesel Generator Battery and Charger Sizing Calculation", will be revised under the modifications that install these lead acid batteries such that the charger sizing is addressed.
This calculation has already been revised as a limited edition calculation in preparation for the modification installation.
The required charger sizes, as determined and documented in the referenced limited edition calculation, are:
3.
Charger Required Size 1DGBA 56.27 Amperes 1DGBB 40.86 Amperes 2DGBA 60.37 Amperes 2DGBB 52.57 Amperes These charger sizes are based on the current battery duty cycles.
The calculation goes on to consider future load growth.
Assuming a 15% future load growth, the largest required charger size would be 1.15 x (60.37 Amperes) = 69.43 Amperes.
Since the chargers are rated at 75 Amperes, they are adequately sized.
In addition to this response, on March 3, 2005, a telephone discussion was conducted between Duke Energy Corporation and the NRC staff concerning the use of the terminology "and/or" in some of the TS and Bases markup pages.
The NRC indicated that use of this terminology was unacceptable.
Therefore, as agreed to in this telephone conversation, Duke Energy Corporation is revising the affected TS and Bases markup pages to utilize alternate terminology.
The affected pages directly follow.
Note that the final reprinted TS and Bases pages will be provided to the NRC Project Manager just prior to NRC issuance of the proposed amendments.
Battery Cell Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Cell Parameters LCO 3.8.6 cell parameter for the channel of DC battends shall be wit n t limits f Table 3.8.6-1 and the Diesel enerator (DG Train A and Tain B Lp l
bale ries shall be wi in the limits of t mperature an level.
poo II M~i APPLICABILITY:
When associated DC electrical power subsystems are required to be OPERABLE.
ACTIONS Separate Conditio entisalloed fa--NU e
Separate Condition entry is allowed for each battery.
CONDITION J
REQUIRED ACTION COMPLETION TIME OA.L1 O~
rmof-4e (cdiari.J 5'
a cb th n-e~
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> A.1 Verify-pilot cells electrolyte level and float voltage meet Table 3.8.6-1 Category C limits.
AND A.2 Verify battery cell parameters meet Table 3.8.6-1 Category C limits.
AND A.3 Restore battery cell parameters to Category A and B limits of Table 3.8.6-1.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND Once per 7 days thereafter 31 days (continued)
Catawba Units 1 and 2 3.8.6-1 Amendment No<
F
.^
Battery Cell Parameters 3.8.6 ACTIONS (continued)
CONDITION f
REQUIRED ACTION J
COMPLETION TIME B.
Required Action and associated Completion Ore or rno.
Time of Condition A not tes lmet.
(>lE keelts I
l 3
G S e
/On orem re ch nnel )
o Cb fersfith of r ar ag a
e ectrolyte temperature of the representative cells nre or C ro
< 60°F.
tbe1tcs
(
6 afnet¢)
OR Dc c
On or rech nnel*)
1G bcn Le-ei of C eries ithone (5
k or more attery cell ac C
ce\\ls parameters not within or Category C values.
B.1 Declare associated battery inoperable.
0A'W
+~
~ 1h or LCD
~
AC oo.rces-Or)u'o" cgtcrbLcO3.i.
fOr f.
C r :ix 3J. 8.P a fArC Q.
meet r c.W w n JL~~
srtctVC Immediately
/eme QU kC
- 4.
1
C.
C.1 Enter applicable Condition(s) and Required Action(s) of LCO 3.8.1, "AC Sources - Operating",
- Shutdownn for the associated DG made inoperable.
Immediately Catawba Units 1 and 2 3.8.6-2 Amendment Nos.6jqi
Battery Cell Parameters B 3.8.6 BASES APPLICABILITY The battery cell parameters are required solely for the support of the associated DC electrical power subsystemis. Therefore, battery electrolyte is only required when the DC power source is required to be OPERABLE. Refer to the Applicability discussion in Bases for LCO 3.8.4 and LCO 3.8.5.
ACTIONS dk-eves tDG br-l* cer LIa. Ws A.1, A.2, and A.3 y L. &.
aA. cas, orbo+I0)
With one or more cells in one or more batteries not within limits (i.e.,
Category A limits not met, Category B limits not met, or Category A and B limits not met) but within the Category C limits specified in Table 3.8.6-1 in the accompanying LCO, the battery is degraded but there is still sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of Category A or B limits not met and operation is permitted for a limited period.
The pilot cell electrolyte level and float voltage are required to be verified to meet the Category C limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (Required Action A.1). This check will provide a quick indication of the status of the remainder of the battery cells. One hour provides time to inspect the electrolyte level and to confirm the float voltage of the pilot cells. One hour is considered a reasonable amount of time to perform the required verification.
Verification that the Category C limits are met (Required Action A.2) provides assurance that during the time needed to restore the parameters to the Category A and B limits, the battery is still capable of performing its intended function. A period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to complete the initial verification because specific gravity measurements must be obtained for each connected cell. Taking into consideration both the time required to perform the required verification and the assurance that the battery cell parameters are not severely degraded, this time is considered reasonable. The verification is repeated at 7 day intervals until the parameters are restored to Category A or B limits. This periodic verification is consistent with the normal Frequency of pilot cell Surveillances.
Continued operation is only permitted for 31 days before battery cell parameters must be restored to within Category A and B limits. With the consideration that, while battery capacity is degraded, sufficient capacity exists to perform the intended function and to allow time to fully restore the battery cell parameters to normal limits, this time is acceptable prior to declaring the battery inoperable.
Catawba Units 1 and 2 B 3.8.6-2 Revision No.0 I
Battery Cell Parameters B 3.8.6 BASES ACTIONS (continued)
/Sti frate
[)
bo+6Ze AeZ vfIt )
( lean acL ceAls} or Bog )
With one or more batteries ith one or more battery cell parameters outside the Category C limit for any connected cell, sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding DC electrical power subsystem must be declared 6
k DC bArc inoperable. Additionally, other potentially extreme conditions, such as not r ocompleting the Required Actions of Condition A within the required 6 t
~f' ad Completion Time or average electrolyte temperature of representative vcellsfalling below 600F, are also cause for immediately declaring the associated DC electrical power subsystem inoperable n%
\\-(
A pet etrn ceT3 C.1 (Ca 4
ctls-fk 8,a With one or more DG batteries with one or more battery cell(s) not within the limits of levee rnratr sufficient capacity to supply the required load for the DG is not assumed and the corresponding DC electrical power subsystem must be declared inoperable immediately.
Appropriate LCO(s) must then be entered for the DG supported by the inoperable DC subsystem. If the plant is in MODES 1 through 4, LCO 3.8.1, NAC Sources-Operating is required to be entered.
If the DG is required to support equipment during MODES 5 or 6 or movement of irradiated fuel assemblies, regardless of operating mode, LCO 3.8.2, "AC Sources-Shutdown,' is the appropriate LCO.
SURVEILLANCE SR 3.8.6.1 REQUIREMENTS This SR verifies that Category A battery cell parameters are consistent with IEEE-450 (Ref. 4), which recommends regular battery inspections (at least one per month) including voltage, specific gravity, and electrolyte flat~Zs s-ic r apmj 4 1a.
temperature of pilot cells.)
s 7s ct re c_
(
cCgrvQ{.Jw vf 11jA Le acsC This SR verifies the DG battery cell parameter of level via regular battery Sinspection (at least once every 7 days). The electrolyte level is monitored X,
in order to maintain battery performance and effectiveness. The 7 day Frequency has been shown acceptable through operating experience.
Catawba Units 1 and 2 B 3.8.6-3 Revision No.0,