Text

Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion
	ML063450214
Person / Time
Site:	Beaver Valley
Issue date:	12/07/2006
From:	Lash J; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-06-162, LAR-169, LAR-296
	Download: ML063450214 (46)
	v • d • e

FENoc FirstEnergyNuclear OperatingCompany James H. Lash 724-682-5234 Site Vice President Fax: 724-643-8069 December 7, 2006 L-06-162 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion This letter provides updated pages (Revision 5) to the FirstEnergy Nuclear Operating Company (FENOC) License Amendment Request (LAR) Nos. 296 and 169 to convert the Beaver Valley Power Station (BVPS) Unit Nos. 1 and 2 Technical Specifications to the Improved Technical Specifications (ITS) for Westinghouse Plants, NUREG-1431.

The BVPS ITS conversion LAR was originally submitted by FENOC letter L-05-027 dated February 25, 2005.

The purpose of this supplement is to update the BVPS ITS conversion documentation contained in LAR Nos. 296 and 169 (ITS conversion) to incorporate the resolution of NRC comments.

One NRC comment resolution revises proposed ITS Surveillance Requirement (SR) 3.8.1.10, applicable to the Emergency Diesel Generators (EDG). This revision extends the duration of the BVPS specific ITS EDG runtime from > 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to be consistent with the recommendations of IEEE Standard 387-1995. The required EDG loading values for testing beyond the initial 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period have also been added to this SR. Attachment 1 of this submittal contains the revised pages that address the NRC comment involving ITS SR 3.8.1.10.

Another NRC comment resulted in a revision to the Bases of ITS 3.4.20, Steam Generator Tube Integrity. In this ITS Bases, a discussion of the Main Steam Line Break accident was revised to clarify the applicable leak rate limits. Attachment 2 of this submittal contains the revised ITS 3.4.20 Bases page that addresses this NRC comment.

Beaver Valley Power Station, Unit Nos. 1 and 2 Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion L-06-162 Page 2 In addition, this submittal contains the revised pages that address the NRC comments on BVPS ITS Sections 3.8 and 5.5.13 based on the pending rewrite of Technical Specification Task Force (TSTF) 360. This TSTF is incorporated into NUREG-1431, Revision 3.1. The resolution of these NRC comments incorporates changes to ITS 5.5.13, Battery Monitoring and Maintenance Program, that include changes to the Bases of ITS 3.8.4 DC Sources - Operating, and ITS 3.8.6, Battery Parameters, as well as revising the Completion Time specified in ITS 3.8.4 for inoperable battery chargers from 7 days to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Attachment 3 of this submittal contains the revised ITS conversion documentation pages that address the NRC comments related to TSTF-360.

In addition to the comments addressed in Attachments 1 through 3 described above, this letter addresses another NRC comment related to the pending rewrite of TSTF-360 and resulting changes to NUREG- 1431. The NRC requested that BVPS submit a letter from the battery manufacturer(s) that provides confirmation that float current is an acceptable method to determine the state of charge of the battery and that the float current value specified in the ITS (< 2 amps) is adequate to assure a fully charged battery. of this submittal contains the battery manufacturers (i.e., C & D Technologies, Inc. and EnerSys) letters that address these issues. The C & D Technologies letter confirms that float current is an acceptable method for determining the state of charge of the battery and that < 2 amps float current is an accurate indication of a fully charged battery. The EnerSys letter also confirms that the use of float current is an acceptable method for determining the state of charge of the battery, but states that the float current value of* 2 amps indicates 95% available capacity for the 2GN-13 model battery used at BVPS and a 98% available capacity for the 2GN-21 model battery used at BVPS.

In accordance with previous discussions with the NRC, the use of the ITS float current value of _<2 amps to determine a fully, charged battery is dependent on concurrence from the battery manufacturer and that a commitment to maintain battery capacity design margin would be necessary if < 2 amps was not indicative of a fully charged battery.

Therefore, in order to use a consistent value of float current in the ITS (* 2 amps) for all batteries, FENOC is making a regulatory commitment to reserve a 5% design margin for the EnerSys model 2GN-13 batteries (Unit 2 Batteries 2-3 and 2-4) and a 2% design margin for the EnerSys model 2GN-21 batteries (Unit 1 Batteries 1-1 and 1-2 and Unit 2 Batteries 2-1 and 2-2). The requirement to maintain the specified margins will be documented in the Technical Specification Bases of ITS 3.8.4, DC Sources - Operating along with a reference to this letter (see pages 115 and 123 of Attachment 3).

The regulatory commitment contained in this letter is listed in Attachment 5.

Beaver Valley Power Station, Unit Nos. 1 and 2 Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion L-06-162 Page 3 The information provided with this submittal does not change the evaluations or conclusions of the No Significant Hazards Consideration provided with the ITS conversion LAR.

If there are any questions or if additional information is required, please contact Mr. Gregory A. Dunn, Manager, FENOC Fleet Licensing, at (330) 315-7243.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December -7 ,2006.

Sincerely, Ja es H. Lash Attachments:

1. BVPS ITS Conversion (LARs 296 and 169) Revision 5 pages for revision of Emergency Diesel Generator run time.

2. BVPS ITS Conversion (LARs 296 and 169) Revision 5 pages for revision of ITS Bases 3.4.20.

3. BVPS ITS Conversion (LARs 296 and 169) Revision 5 pages for revision of Battery Charger and Battery Monitoring and Maintenance Program Requirements.

4. Letters from battery manufacturers.

5. Commitment list.

c: Mr. T. G. Colburn, NRR Senior Project Manager (2)

Mr. P. C. Cataldo, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. A. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQIUEST (LAR)

Nos. 296 (UNIT 1) & 169 (UNIT 2)

A TTA CHMENT 1 (to L-06-162)

REVISION 5 CHANGES Revision of Emergency Diesel Generator Run Time (ITS Surveillance Requirement 3.8.1.10)

The pages affected by Revision 5 are presented in the following order; ITS markups and associated Justifications for Deviation (JFDs), ITS Bases Markups, Current Technical Specification (CTS) markups and associated Discussion of Change (DOC).

Each affected page is identified as a Revision 5 page. The Revision 5 changes made to each page are further identified by revision bars.

The BVPS ITS Conversion documentation can be updated to Revision 5 by simply replacing the existing page with the corresponding attached Revision 5 page.

The page numbers referenced in the page number index below are the ITS section specific sequential numbers added to the bottom right hand corner of each page.

ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 15 ITS JFDS PAGES: 47, 48 ITS BASES MARKUPS PAGES: 90, 97 ITS BASES JFDS NONE CTS MARKUPS PAGES: 179 (information only), 187 CTS DOCS PAGES: 219, 226

AC Sources - Operating REVISION 5 1 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.44

- NOTES -

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may NUREG-1431, Rev. 3 be performed to reestablish OPERABILITY provided an assessment determines the safety of Credit may be the plant is maintained or enhanced. taken for K2N\ unplanned events 22 3. If performed with DG synchronized with offsite that satisfy this SR.

ower, it shall be performed at a power factor 0.89 < . However, if grid conditions do not permit, the power factor limit is not required to be met.

Under this condition the power factor shall be maintained as close to the limit as practicable. 4 NUREG-1431, Rev. 3 Verify each DG ope.rating at a power.... fc .5 [a A! [181 months operates for ,, 8*s

,hou __8]

a. For -42J-hoursloaded ý [525v] kW a~d.* [_7*250 kW ihd.2-5 Ok W(Unit 1) 9 501kV n 8 Wagf 4ýAjW 1i ) and

b. For the remaining hours of the test loaded 1 r509nn

[4 kIVl a,'d ;5 [5nr*O1 kWA 32i0kW 'and 52600 kW Unitni 1) .

__f.k W a* d 42*73kW (-Ui 2,).

WOG STS 3.8.1 - 12 Rev. 2, 04/30/01 15

BVPS ISTS Conversion REVISION 5 3.8 Electrical Power Systems Enclosure 1 Changes to ISTS SR that states "Only applicable to Unit 1." ITS SR 3.8.1.5.2 states "Check for and remove accumulated water from each day tank." A Note modifies the SR that states "Only applicable to Unit 2." These changes to the SRs are acceptable because only the Unit 1 DGs have both day and engine mounted tanks that must be checked for water.

For Unit 2, the day tank is the appropriate tank to verify because Unit 2 does not have an engine mounted tank.

11. ISTS SR 3.8.1.7 requires the fast start of each DG to rated voltage and frequency every 184 days. This requirement is not added because the units are licensed in accordance with applicable Safety Guide or Regulatory Guide and does not require the performance of this test and a fast start is performed once every 18 months. The Unit 1 DGs will not field flash on fast start unless an undervoltage signal is present. The Unit 1 DGs can not be emergency started from the control room. This change will minimize the fast starts for the DGs. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

12. ISTS SR 3.8.1.11 requires the fast start of each DG to rated voltage and frequency on an actual or simulated loss of offsite power every 18 months. This requirement is not added because the units are licensed in accordance with applicable Safety Guide or Regulatory Guide and do not require the performance of this test and a fast start is performed on a loss of offsite power concurrent with an ESF signal once every 18 months. The loss of offsite power concurrent with an ESF signal performs some of the technical requirements listed in this SR. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

13. ISTS SR 3.8.1.12 requires the fast start of each DG to rated voltage and frequency on an actual or simulated ESF actuation (SI) signal every 18 months. This requirement is not added because the units are licensed in accordance with applicable Safety Guide or Regulatory Guide and do not require the performance of this test and a fast start is performed on a loss of offsite power in conjunction with an ESF signal once every 18 months. This is another fast start of the DG with the machine not loading and the emergency buses continued to be powered from the offsite source. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

14. ISTS SR 3.8.1.14 requires the performance of >_24-hour run for each DG every 18 months. This requires a minimum 2-hour run at 105 % to 110 % of rated load and the remaining time of 90 % to 100 % of rated load. Proposed ITS SR 3.8.1.10 requires _>8-hour DG run for each DG every 18 months. For >_the first 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , ITS SR 3.8.1.10 requires the DGs be run at a load of > 2750 kW for Unit 1 and > 4238 kW for Unit 2 up to the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months load limit for each DG (Unit 1 2850 kW and Unit 2 4535 kW). For the remaining hours of the test, ITS SR 3.8.1.10 requires the DGs be run at a load equivalent to the continuous duty rating of the DG (i.e., > 2340 kW and _<2600 kW for Unit 1 and 2! 3814 kW and < 4238 kW for Unit 2).

The proposed change revising the duration of the required DG run time from 24-hours to 8-hours is acceptable because the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months duration is considered sufficient to demonstrate DG operability. This change is based on the requirements of IEEE Standard 387-1995, "IEEE Standard Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations. The specified DG loading for the 2-hour requirement in ITS SR 3.8.1.10 ensures the capability of the DGs to sustain the full emergency loading requirements without excessive loading. The DG BVPS Units 1 & 2 Page 3 Revision 5, 11/06 47

REVISION 5 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 1 Changes to ISTS loading specified for the remainder of the 8-hour run is consistent with the continuous duty rating of the DGs for each unit.

15. ISTS SR 3.8.1.15 requires the hot fast re-start of each DG to rated voltage and frequency after operating for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months every 18 months. This test is normally associated with the requirement to perform a 24-hour run (to establish the required "hot" conditions). This surveillance requirement is not added to the BVPS ITS because current licensing basis does not require the performance of this test. This is acceptable for Unit 1 because Safety Guide 9, the Unit's current licensing basis, did not require the performance of this surveillance. For Unit 2 this is acceptable because it is the current licensing basis described by the NRC's initial SER and the Unit 2 UFSAR which took exception to such testing requirements as explained in JFD 14 above. The ISTS SRs that follow are re-numbered to reflect this SR deletion.

16. ISTS SR 3.8.1.20 requires the verification that each DG when started simultaneously from a standby condition can achieve rated voltage and frequency within 10 seconds.

ITS SR 3.8.1.15 requires the performance of the test for Unit 2 only. A Note is added to SR to specify that it is applicable to Unit 2 only. This is acceptable because the current licensing basis does not require the SR for Unit 1 and not required by Safety Guide 9, the Unit's current licensing basis.

17. Not used.

18. ISTS LCO 3.8.1 states "The following AC electrical sources shall be OPERABLE: Two qualified circuits between the offsite transmission network and the onsite Class 1 E AC Electrical Power Distribution System, b. Two diesel generators (DGs) capable of supplying the onsite Class 1E power distribution subsystem(s), and c. Automatic load sequencers for Train A and Train B." ITS LCO 3.8.1 states "The following AC electrical sources and sequencer timer(s)shall be OPERABLE: Two qualified circuits between the offsite transmission network and the onsite Class 1 E AC Electrical Power Distribution System, b. Two diesel generators (DGs) capable of supplying the onsite Class 1E power distribution subsystem(s), and c. Automatic load sequencer timer(s) for each required BVPS Units 1 & 2 Page 4 Revision 5, 11/06 48

AC Sources - Operating B 3.8.1 REVISION 5 BASES SURVEILLANCE REQUIREMENTS (continued)

- REVIEWER'S NOTE -

The abo MODE restrictions may be deleted if it can be demo rated to the staff, on ant specific basis, that performing the SR the reactor in any of the restri d MODES can satisfy the followi criteria, as applicable:

a. Performance of the SR wi t ren any safety system or component inoperable,

b. Performance of the S ill not cause pe bations to any of the elcrcldsriuissestat could resu lt a challenge to staysat rton or to plant safety systems,'* .

This Surveillance demonstrates that the DGs c. P rmance of the SR, or failure of the SR, will not cause, r result can start and run 2 n, an AOO with attendant challenge to plant safety systems.

continuously at or near full load conditions for not less than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The SR3. 8.1. 1 Surveillance requires that each DG be run for > 2 w hours loaded from a minimum of the calculated d-emonistration nce Per 18 months that tho *GS Gan start a nd ru in accident load for Unit 1, continuously at full 'Gad capability for an inteR-al of not less than and the continuous duty 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , =z[21 hours of which is at a load equivalent to 110% of the rating of the DG for Unit 2, - --- .. - --- ý up to a maximum loading of the 2000 hour0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months rating for to the contnuou duty...,,, rting ofthe DG The DG starts for this each DG. Additionally, the Surveillance can be performed either from standby or hot conditions. The Surveillance requires that provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and each DG be run for the for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

remainder of the 8-hour requirement loaded to the The load band is provided to avoid routine overloading of the DG.

equivalent of the continuous duty rating of Routine overloading may result in more frequent teardown inspections in the DG. The required run accordance with vendor recommendations in order to maintain DG duration of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is OPERABILITY. I consistent with the recommeindations of IEEE The 118-month] Frequency is consistent with the recommendations of allowance Standard 387-1995 (Ref. Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), takes into such 14).

consideration unit conditions required to perform the Surveillance/ nd is intended to be consistent with expected fuel cycle lengths.

9This Surveillance is modified by three Notes. Note 1 tate that momentary transients due to changing bus loads do not mv outside of test. ýSimilarly, momentary power factor transients the power fac or required range Tm ill not invalidate the test. The reason for Note 2 is that during 90

REVISION 5 AC Sources - Operating U**U,!

13. License Amendment Nos. 268 (Unit 1) and 150 (Unit 2) and associated NRC Safety Evaluation Report issued September 29, 2005.

14. IEEE Standard 387-1995 REFERENCES (continued) I , ........ code for Operation Insert For Action Section of and Maintenance Bases. fhistextisfromtheCfS 10. Regul ory Guide 1.137, Rev.',] [date]. of Nuclear Power Bases as revised by Amendments Plants Nos. 268 (Unit 1)and 150 (Unit 2) issued 9/29/05 for the 14-day DG I.

11. A ' E, Bo...

.e.. ,n Prc.....

ee C. d, .'.

Section XI" AOT. TAC Nos. MC3331 &

MC3332. 12 IEEE Standard 308 Unit 1-1971 and Unit 2-1974 6--

I* Requirements for applying the 14-day DG Completion Time I The ACTION Conditions for inoperable AC sources provide a 14-day Completion Time when one DG is inoperable. The 14 day Completion Time includes the normal 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time which is not risk informed, followed by an 11 day extension period that is based on a plant specific risk analysis performed to establish the overall Completion Time (Ref 13).

As a defense in depth measure, when the option of an extended Completion Time (i.e., a time beyond the normal 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ) for a DG is exercised, alternate AC (AAC) power will be provided with capability of supplying safe shutdown loads during a station blackout without the need for rescheduling of safety system operation in the unaffected unit. For unplanned DG outages, capability to supply AAC power will be available upon entering the Completion Time extension (i.e. by 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months into the Completion Time). For outages planned to exceed an initial 72-hour Completion Time, AAC power will be provided within one hour of entering the Action Condition for an inoperable DG. In any event, if AAC power of the required capacity is not available after entering the extended Completion Time (after 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months into the Completion Time), the Required Actions of Action Condition G become applicable (i.e., Be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Be in MODE 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ).

The following criteria would apply to any AAC source used as a defense in depth measure:

1. An AAC power source may be of a temporary or permanent nature and would not be required to satisfy Class 1 E requirements.

2. Dynamic effects of an AAC power source failure (GDC-4 events) would not adversely affect safety related plant equipment.

3. An AAC power source would not be required to be protected against natural phenomena (GDC-2 events) or abnormal environmental or dynamic effects (GDC-4 events).

4. An AAC power source would be capable of starting and carrying designated loads required for safe shutdown, including maintaining adequate voltage and frequency such that performance of powered equipment is acceptable.

Prior to relying on its availability, a temporary AAC power source would be determined to be available by: (1) starting the AAC source and verifying proper operation; (2) verifying that sufficient fuel is available onsite to support 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation; and (3) ensuring that the AAC source is in the correct electrical alignment to supply power to designated safe shutdown loads. Subsequently, when not in operation, a status check for availability will also be performed once every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This check consists of (1) verifying the AAC source is mechanically and electrically ready for operation; (2) verifying that sufficient fuel is available onsite to support 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation; and (3) ensuring that the AAC source is in the correct electrical alignment to supply power to designated safe shutdown loads.

Prior to relying on its availability, a permanent AAC power source would be determined to be available by starting the AAC source and verifying proper operation. In addition, initial and periodic testing, surveillance, and maintenance conform to NUMARC 87-00, Revision 1, Appendix B, "Alternate AC Power Criteria" guidelines. The guidelines include provisions for quarterly functional testing, timed starts and load capacity testing on a fuel cycle basis, surveillance and maintenance consistent with manufacturer's recommendations, and initial testing of capability to power required shutdown equipment within the necessary time.

WOG STS B 3.8.1 - 33 Rev. 2, 04/30/01 97

ITS 3.8.1 & Included For Completeness Only. Revision 5 Changes Are 3.8.3 Referenced From This Page. See Marked SR Below (ITS SR 3.8.10).

ETEC"TRICTATL POWER SYSTEMS I SURVEILLANCE REQUIREMENTS (Cont:

3. Simu4atfina loss 0 -ffsite po a safety injection signal, and:

SR 3.8.1.14 a) Verifying de-energization of the emergency busses and load shedding from the emergency busses.

b) Verifying the diesel starts from standby conditions+6+ on the auto-start signal, energizes, the emergency busses with permanently connected loads in

10 seconds, energizes the auto-connected emergency loads through the load sequencer and operates for Ž 5 minutes while its IInsert SR note generator is loaded with the emergency loads.

After energization of these loads, the steady state voltage + and frequency+3 shall be maintained at Ž 3994 volts and < 4368 volts, and 59.9 Hz and

60.3 Hz. voltage .

I

4. 4Verifying that on a loss of pere- to the emergency SR 3.8-1-9 busses, all el generator trips, except engine oversbackup phase fault detection, generat L11 erential current, and generator overexcitation e an actual or automatically disabled,

7. Verifying at te automatic oa sequence imer is OPERABLE with each load sequence time within +/-10% of its required value.

c. Check for and remove accumulated water:

SR3.8.1.5.2 III . From]e day tank, at least once per 3 d s a n t L9 SR3.8.3.5 I,2. From the fuel oil storage tank, at least once per 92 J~days.

(3) The values for voltago and frcqucncy arc analysis values. These 1A6value bands sahll be appropriately reducoed to aeecount fer moasuremcnt unccrtaintics.

(6) All diesel generator starts may be preceded by an engine prelube AI7 - period.

BEAVER VALLEY - UNIT 2 3/4 8-5 Amendment No. 105 179

REVISION 5 Inserts 3.8.1 (continued)

Load limits for SR 3.8.1.3 at a load > 2340 kW and < 2600kW (Unit 1),

at a load Ž 3814 kW and < 4238 kW (Unit 2).

Time, load, and Note requirements for SR 3.8.1.10 for 2 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s:

a. For > 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded

Ž250kV1 nwand 2850kW(Unit 1) 4 421ýWad WN k5 ilU2), and

b. For the remaining hours of the test loaded

> 23410 KW~ and *2600 kWV (Unit 1) 3d14k aj,ýd4 2 ~( .IAV ipt-2 Note 1 Momentary transients outside the load and power factor ranges do not invalidate the test. I Note 2 This surveillance shall not normally be performed in MODE 1 or 2. However, the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Note 3 If performed with DG synchronized with offsite power, it shall be performed at a power factor < 0.89. However, ifgrid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as possible.

SR 3.8.1.9 surveillance note SR 3.8.1.9-

- NOTE -

This surveillance shall not normally be performed in MODE 1 or 2. However, portion of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

187

REVISION 5 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CTS L. 11 (Category6 - Relaxation Of SurveillanceRequirement Acceptance Criteria)CTS surveillance requirement 4.8.1.1.2.b.5 requires each diesel to be tested every 18 months during shutdown to a specific kW load for >Ž 60 minutes. ITS SR 3.8.1.10 states that each DG is run loaded for >_8 hours. The ITS SR specifies a kW load band that must be met for > 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and a different kW load band that must be met for the remainder of the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Three notes modify the SR. Note 3 is addressed by more restrictive change. Note 1 states "Momentary transients outside the load and power factor ranges do not invalidate this test. Note 2 allows the performance of the SR in MODE 1 or 2 to reestablish OPERABILITY for the DG provided an assessment can determine that the safety of the plant is maintained or enhanced. The effective changes addressed by this DOC are the new allowances provided by Notes 1 and 2. Note 2 changes the CTS by allowing this SR to be performed in Modes 1 or 2 (with the appropriate assessment) and Note 1 provides the allowance for momentary transients outside the required load band to not invalidate the SR.

The purpose of ITS SR Note 2 is to allow the SR to be conducted if it does not reduce plant safety by its performance. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are adequate to verify that the equipment used to meet the LCO can perform its required functions. The allowance to perform the SR in Modes 1 and 2 requires an assessment prior to performing the SR in these Modes to ensure the plant continues to be operated in a safe manner. The purpose of Note 1 is to allow short-term transients of load or power factor to not invalidate the test. This allowance for these parameters is acceptable because the majority of the SR is performed within the stated limits. The ITS requirement is consistent with the ISTS wording for this requirement. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.12 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)CTS surveillance requirement 4.8.1.1.2.b.4 requires each diesel to be tested every 18 months during shutdown to verify specific non-vital trips are bypassed on an emergency start of the diesel. ITS SR 3.8.1.9 states that each DG automatic trips are bypassed on an actual or simulated loss of voltage signal on the emergency bus. A note modifies the SR. The note allows the performance of portions of the SR in MODE 1, 2, 3, or 4 to reestablish OPERABILITY for the DG provides an assessment can determine that the safety of the plant can be maintained or enhanced. This changes the CTS by allowing portions of the SR to be performed in MODE 1, 2, 3 or 4 if an assessment evaluates that the performance of the SR does not reduce plant safety.

The purpose of ITS SR note is to allow the SR to be conducted if it does not reduce plant safety by its performance. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are adequate to verify that the equipment used to meet the LCO can perform its required functions. The allowance to perform the SR in MODE 1, 2, 3, or 4 will be evaluated prior to its performance and the evaluation will ensure plant safety will not be decreased. The ITS requirement is consistent with the ISTS wording for this requirement. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.13 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria) CTS surveillance requirement 4.8.1.1.2.b.3 requires each diesel to be tested every 18 months during shutdown to verify operation of the diesel with a start on a simulated signal a loss of offsite power in conjunction with a safety injection signal. ITS SR 3.8.1.14 requires the DG start with specific actions to be performed on an actual or simulated loss of offsite BVPS Units 1 & 2 Page 7 Revision 5, 11/06 219

BVPS ISTS Conversion REVISION 5 3.8 Electrical Power Systems Enclosure 3 Changes to CTS M.3 Not Used.

10.4 CTS surveillance requirement 4.8.1.1.2.b.5 requires each diesel to be tested every 18 months during shutdown to a specific kW load for >_60 minutes. The required loading for Unit 1 is 2750 kW and for Unit 2 the load is 4238 kW. ITS SR 3.8.1.10 requires that each DG be run for > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months loaded to within specific kW load bands. Unit 1 is required to run for _ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months at a load of >_

2750 kW and < 2850 kW. Unit 2 is required to run for _>2 hours at a load of > 4238 kW and !5 4535 kW. The ITS SR requires the DGs of both units to be run for the remainder of the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months requirement within a load band equivalent to the continuous duty rating of the DGs (-Ž2340 kW and 5 2600 kWfor Unit 1 and ->3814 kW and S 4238 kW for Unit 2). Three notes modify the SR. Notes 1 and 2 are addressed by a less restrictive discussion of change. Note 3 states if the SR is performed with the DG synchronized with offsite power, it shall be performed at a power factor of _ 0.89. Additionally, the note states that if grid conditions do not permit, the power factor limit is not required to be met. The note goes on to state that under this condition, the power factor shall be maintained as close to the limit as possible. This DOC addresses the changes to the CTS of the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months run time with specific loading bands, and the specification of a power factor limit for each DG.

The change extending the required DG run time is acceptable because the test requires the DGs to start and load to required values and run for an additional 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months beyond the CTS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months requirement consistent with the recommendations of IEEE Standard 387-1995 for periodic endurance and load testing of DGs. For the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months requirement, the minimum of 2750 kW is the assumed accident loading value for Unit 1 and the maximum of 2850 kW is the 2000-hour limit for Unit 1. The 2750 kW value is greater than the continuous duty rating and is specified by the CTS requirement. The Unit 2 kW load band for the required 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is from a minimum of the continuous duty rating to a maximum of the 2000-hour limit (which encompasses the accident loading of the DG). Additionally, the ITS SR requires each DG to be run for the remainder of the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months requirement within a load band equivalent to the continuous duty rating of the DGs (2Ž2340 kW and -<2600 kW for Unit 1 and L 3814 kW and -54238 kW for Unit 2). A load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The addition of a power factor limit is acceptable because the load on the DG with a loss of offsite power is inductive and creates volt-amp reactive loading of the DG. This is represented in the limit of the power factor requirement. Therefore, the testing of the DG at this rating is only required every 18 months. These changes are designated more restrictive because additional test conditions are required in the ITS that are not required by the CTS.

M.5 - M.8 Not used.

M.9 CTS surveillance requirements for LCO 3.8.1.1 do not require a test of the diesel generator capability to carry emergency loads, transfer those loads to offsite source upon a simulated restoration of the offsite power, transfer loads to offsite power source, and return to the specified position. ITS SR 3.8.1.11 requires verification for each DG that it is capable of synchronizing with the offsite power source while carrying emergency loads. Upon a simulated restoration of offsite power, the emergency loads would be transferred to the offsite source and the DG would return to a specified condition. The Unit 2 DGs would return to a ready-to-load position and the Unit 1 DGs would be required to proceed through the shutdown sequence. The surveillance is required to be performed every 18 months. A note modify the SR. The note states this surveillance shall not normally be performed in MODE 1, 2, 3, and 4. The note allows the performance of the SR in MODES 1, 2, 3, and 4 to reestablish OPERABILITY for the DG provides an assessment can determine that the safety of the plant can be maintained or enhanced.

This changes the CTS by requiring each DG demonstrate the described requirements every 18 months.

The purpose for the SR is to ensure the DG is capable of performing the required operations. This change is acceptable because the SR ensures that the manual synchronization load transfer from the DG to the offsite source can be made and the DG BVPS Units 1 & 2 Page 14 Revision 5, 11/06 226

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR)

Nos. 296 (UNIT 1) & 1 69 (UNIT 2)

ATTACHMENT 2 (to L-06-162)

REVISION 5 CHANGES Revision of ITS 3.4.20 Bases The pages for each ITS Section affected by Revision 5 are presented in the following order; ITS markups and associated Justifications for Deviation (JFDs), ITS Bases Markups, Current Technical Specification (CTS) markups and associated Discussion of Change (DOC).

Each affected page is identified as a Revision 5 page. The Revision 5 changes made to each page are further identified by revision bars.

The BVPS ITS Conversion documentation can be updated to Revision 5 by simply replacing the existing page with the corresponding attached Revision 5 page.

The page numbers referenced in the page number indexes below are the ITS section specific sequential numbers added to the bottom right hand corner of each page.

ITS SECTION 3.4 (REACTOR COOLANT SYSTEM) INDEX OF AFFECTED PAGES ITS MARKUPS NONE ITS JFDS NONE ITS BASES MARKUPS PAGES: 196H ITS BASES JFDS NONE CTS MARKUPS NONE CTS DOCS NONE

I REVSION 5 BASES INSERTS FOR ITS 3.4.20

1. For accidents that do not involve fuel damage, the primary coolant activity level of DOSE EQUIVALENT 1-131 is assumed to be equal to the LCO 3.4.16, "RCS Specific Activity," limits. Pre-accident and concurrent iodine spikes are assumed in accordance with applicable regulatory guidance. For accidents that assume fuel damage, the primary coolant activity is a function of the amount of activity released from the damaged fuel. The dose consequences of these events are within the limits of 10 CFR 50.67 (Ref. 2) as supplemented by Regulatory Guide 1.183 (Ref. 3) and within GDC-19 (Ref. 4) values.

Unit 1:

The analysis for design basis accidents and transients other than a SGTR assume the SG tubes retain their structural integrity (i.e., they are assumed not to rupture.) In these analyses, the steam discharge to the atmosphere is conservatively assumed to include the total primary to secondary LEAKAGE from all SGs of 450 gpd (i.e., 150 gpd per steam generator) or is assumed to increase to 450 gpd as a result of accident induced conditions. Currently, the Unit 1 safety analyses do not specifically assume additional primary to secondary LEAKAGE due to accident induced conditions.

Unit 2:

The analysis for design basis accidents and transients other than a SGTR assume the SG tubes retain their structural integrity (i.e., they are assumed not to rupture). In these analyses, the steam discharge to the atmosphere is conservatively assumed to include the total primary to secondary LEAKAGE from all SGs of 450 gpd (i.e., 150 gpd per steam generator) or is assumed to increase to 450 gpd as a result of accident induced conditions for all accidents other than the Unit 2 main steam line break (MSLB).

Currently, the Unit 2 MSLB safety analysis is the only analysis that specifically assumes additional primary to secondary LEAKAGE due to accident induced conditions.

For the Unit 2 main steam line break (MSLB) analysis, an increased leakage assumption is applied. In support of voltage based repair criteria pursuant to Generic Letter 95-05 (Ref. 5) analyses were performed to determine the maximum MSLB induced primary to secondary leak rate that could occur without offsite doses exceeding the limits of 10 CFR 50.67 (Ref. 2) as supplemented by Regulatory Guide 1.183 (Ref. 3) and without control room doses exceeding GDC-19 (Ref. 4). An additional 2.1 gpm leakage is assumed in the Unit 2 MSLB analysis resulting from accident conditions. Therefore, in the MSLB analysis, the steam discharge to the atmosphere includes primary to secondary LEAKAGE equivalent to the operational leakage limit of 150 gpd per SG and an additional 2.1 gpm which results in a total assumed accident induced leakage of 2.4 gpm.

The combined projected leak rate from all sources (i.e., voltage based repair criteria, application of F*, freespan crack, leaking plug, leakage past sleeves, etc.) for each SG must be less than the maximum allowable steam line break leak rate limit inany one steam generator (i.e., 2.2 gpm) in order to maintain a total assumed accident induced leakage of _< 2.4 gpm as explained above.

Maintaining the total assumed accident induced leakage to _*2.4 gpm limits the resulting dose to within the requirements of 10 CFR 50.67 (Ref. 2) as supplemented by Regulatory Guide 1.183 (Ref. 3) and within GDC-1 9 (Ref. 4) values during a postulated steam line break event.

196H

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR)

Nos. 296 (UNIT 1) & 1 69 (UNIT 2)

A TTACHMENT 3 (to L-06-162)

REVISION 5 CHANGES Revision of Battery Charger and Battery Monitoring and Maintenance Program Requirements (ITS 3.8.4, 3.8.6, and 5.5.13)

The pages for each ITS Section affected by Revision 5 are presented in the following order; ITS markups and associated Justifications for Deviation (JFDs), ITS Bases Markups, Current Technical Specification (CTS) markups and associated Discussion of Change (DOC).

Each affected page is identified as a Revision 5 page. The Revision 5 changes made to each page are further identified by revision bars.

The BVPS ITS Conversion documentation can be updated to Revision 5 by simply replacing the existing page with the corresponding attached Revision 5 page.

The page numbers referenced in the page number indexes below are the ITS section specific sequential numbers added to the bottom right hand corner of each page.

ITS SECTION 3.8 (ELECTRICAL POWER SYSTEMS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 27, 28, 35 ITS JFDS PAGES: 57 ITS BASES MARKUPS PAGES: 115, 119,120,121,122,123,134,135,136,138 ITS BASES JFDS PAGES: 166 CTS MARKUPS PAGES: 207 CTS DOCS PAGES: 264, 265, 266, 267, 273, 274 ITS SECTION 5.0 (ADMINISTRATIVE CONTROLS) INDEX OF AFFECTED PAGES ITS MARKUPS PAGES: 23 ITS JFDS PAGES: 63 ITS BASES MARKUPS NONE ITS BASES JFDS NONE CTS MARKUPS PAGES: 123 CTS DOCS NONE

REVISION 5 DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The Train A and Train B DC electrical power subsystems shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One for twol battery A.1 Restore battery terminal 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months chargerfs on one train] voltage to greater than or inoperable. equal to the minimum established float voltage.

AND A.2 Verify battery float current Once per [121 hours

< 2*2amps.

AND (S 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months A.3 Restore battery chargerfe]

to OPERABLE status.

[B. One for two] batter-ylfies B.1 Restore batterfy-]ies] to [21 hours I on one train] inoperable. OPERABLE status.

C. One DC electrical power C.1 Restore DC electrical f21 hours subsystem inoperable for power subsystem to reasons other than OPERABLE status.

Condition A [or B1.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months WOG STS 3.8.4- 1 Rev. 2, 04/30/01 27

DC Sources - Operating 3.8.4 REVISION 5 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or equal 7 days to the minimum established float voltage.

SR 3.8.4.2 Verify each battery charger supplies > [4Q amps at 1181 months greater than or equal to the minimum established float CTS ,,alue's from voltage for > [*] hours.

4.8.2.3.2.c.4 OR Verify each battery charger can recharge the battery to the fully charged state within [241 hours 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.

SR 3.8.4.3

- NOTES -

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.

2. This Surveillance shall not nermanl be performed in MODE 1, 2, 3, or 4. However, potions of the

/

NUREG-1431, Rev. 3 Suweeillan-e may be performed to reestablish OPE6R.ABILITY provided an assersment Credit may be determines the safety of the plant is maintained or taken for unplanned -----

events that satisfy this SR. Veri fy battery capacity is adequate to supply, and [18] months ntain in OPERABLE status, the required emergency loadIs for the design duty cycle when subjected to a battlery service test.

WOG STS 3.8.4 - 2 Rev. 2, 04/30/01 28

Battery Parameters REVISION 5 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.5 Verify each battery connected cell voltage is > 12.071 V. 92 days SR 3.8.6.6

- NOTE -

This Surveillance shall not be performed in MODE 1, 2, NURFG-1,Rev. 3 3, or 4. Hweve,,gedit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is > [80%] of the manufacturer's 60 months rating when subjected to a performance discharge test or a modified performance discharge test. AND 01-2 months when battery shows degradation, or has reached

[851% of the expected life with AND N

batter-*har.

Feached- [851%-oG the-expected WCe with Gapacity

>400% of manufaturr's WOG STS 3.8.6-4 Rev. 2, 04/30/01 35

REVISION 5 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 1 Changes to ISTS ITS 3.8.4 DC Sources - Operating JUSTIFICATION FOR DEVIATION (JFD1 ITS 3.8.4, DC Sources - Operating, is revised to incorporate changes related to the proposed changes to TSTF-360. The proposed changes to TSTF-360 are planned to be incorporated into the ISTS (i.e., NUREG-1431) in the near future. As such, this change to the BVPS ITS is necessary to maintain consistency with NUREG-1431.

BVPS Units 1 & 2 Page 1 Revision 5, 11/06 57

DC Sources - Operating B 3.8.4 I REVISION 5 BASES BACKGROUND (continued)

Each 12 / VDC battery is 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 Based on battery sizing cause a failure in a redundant subsystem. There is no sharing between calculations, a 5% design redundant Class 1 E subsystems, such as batteries, battery chargers, or margin is maintained for the distribution panels. Reference 1 Enersys 2GN-13 model batteries (2-3 and 2-4) and Each battery has adequate storage ca acity to meet the duty cycle(s) a 2% design margin is 4).ef

4. The battery is designed with discussed in h ,GhA p 181 maintained for the Enersys 2GN-21 model batteries additional capacity above that required by the design duty cycle to allow (1-1, 1-2, 2-1, and 2-2). for temperature variations and other factors.

This margin is reserved for the batteries listed above in The batteries for Train A and Train B DC electrical power subsystems are accordance with the battery sized to produce required capacity at 80% of nameplate rating, vendor recommendations corresponding to warranted capacity at end of life cycles and the 100%

and NRC commitment in design demand. The minimum design voltage limit is 105/240 V.

order to use the value of

< 2 amps floa t current to The battery cells are of flooded lead acid construction with a nominal determine a f ully charged specific gravity of 11.2151. This specific gravity corresponds to an open battery (Ref. 11). circuit battery voltage of approximately -1 V for a cell battery (i.e., 124 Scell voltage o volts per cell (Vpc)). The open circult-ae is the voltag-riintained when there is no charging or discharging. Qn4*4:4W*(1" 2 .07 a-'-Fhged ,.i:th otpen cGrc'-!t voltage *-[2.06554,] VpG,,th8 "b!

.4' *G*a'it'for [30] days withe-t f'-,Ft~her harg~ng per V5ý/naR.u,;t:es n-ctuiAienqs. Optimal long term efomv obtained by maintaining a float voltage [2.20 t Vpc. provides 135 -- dequate over-potential, which limits the form ead sulfate and self discha-r . ominal float voltage of [ . Vpc corresponds to a total Refer e float voltage output of -. V for a [W cell battery as discussed in the Reference I-**FSAR, Chapter [1 (Ref. 6041 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 durina 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 1 charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads discussed in the 4h)te.

.S^R Reference The battery charger is normally in the float-charge mode. Float-charge is the condition in which the charger is supplying the connected loads and the battery cells are receiving adequate current to optimally charge the WOG STS B 3.8.4 - 2 Rev. 2, 04/30/01 115

DC Sources - Operating B 3.8.4 REVISION 5 BASES ACTIONS (continuedI) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72-hour Required Acti A.3 limits the r toration time for the inoperable battery charger to - . This action' applicable if an alternate means of restoring battery terminal volt e to greater than or equal to the minimum established float voltage has een used (e.g., balance of plant non-Class 1E battery charger). The Completion Time reflects a reasonable time to effect restoration of the qualified battery charger to OPERABLE status. '*_ý BJ1 In addition, the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of R_1 the remaining DC sources, and the low probability of a DBA occurring during this period.

~- REVIEWER'S NOTE -*

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Comple imes of Required Action and C.1 are in brackets. Any licensee wis reque nger Completion Time will need to demonstrate that the Ion letion Time is appropriate for the plant in accordance e guidance in latory Guide (RG) 1.177, "An Ap;rolr Plant-Specific, Risk-lnforme isionmaking:

Techni ecifications."

8 Condition B represents one train with one for two]-batterfy-fiesl inoperable. With one [or two] batterfy-lies] inoperable, the DC bus is being supplied by the OPERABLE battery charger[--. Any event that results in a loss of the AC bus supporting the battery chargerfs] will also result in loss of DC to that train. Recovery of the AC bus, especially if it is due to a loss of offsite power, will be hampered by the fact that many of the components necessary for the recovery (e.g., diesel generator control and field flash, AC load shed and diesel generator output circuit breakers, etc.) likely rely upon the batterfy]fies]. In addition the energization transients of any DC loads that are beyond the capability of the battery chargerfsj and normally require the assistance of the batterfy-]iesl will not be able to be brought online. The [21 hour limit allows sufficient time to effect restoration of an inoperable battery given that the majority of the conditions that lead to battery inoperability (e.g., loss of battery charger, battery cell voltage less than f2.071 V, etc.) are identified in Specifications 3.8.4, 3.8.5, and 3.8.6 together with additional specific Completion Times.

C.1 Condition C represents one train with a loss of ability to completely respond to an event, and a potential loss of ability to remain energized during normal operation. It is therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected train. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is WOG STS B 3.8.4 - 6 Rev. 2, 04/30/01 119

DC Sources - Operating B 3.8.4 BASI REVISION 5 1 BASES ACTIONS (continued) consistent with the allowed time for an inoperable DC distribution system train.

If one of the required DC electrical power subsystems is inoperable for reasons other than Condition A or B (e.g., inoperable battery charger and associated inoperable battery), the remaining DC electrical power subsystem has the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst- case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, ifthe DC electrical power subsystem is not restored to OPERABLE status, to prepare to effe6t an orderly and safe unit shutdown.

D.1 and D.2 If the inoperable DC electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, CTS Values based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 5 is consistent with the time re-i4 in Regulatory Guide 1.93 (Ref. 14,

,T"- NUE-41 Rev 3 SURVEILLANCE SR 3.8.4.1 recommended i 7 REQUIREMENTS Verifying battery terminal voltage while on float charge helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge i.e., 2.13 Vpc or required to overcome the internal losses of a battery and maintain the , measured

> 127.8 volts for 60 cell battery in a fully charged state while supplying the continuous steady at the batteries 1-1 and 1-2, and state loads of the associated DC subsystem. On float charge, ba ry battery

> 125.67 volts for 59 cell cells will receive adequate current to optimally charge the batt . The terminals, batteries 1-3 and 1-4 for voltage requirements are based on the nominal design volt e of the Unit 1 batteries and for battery and are consist6"ith the minimum float voltage stablished by Unit 2 > 127.8 volts is required for each battery). the battery manufacturer ([A291 Vpc 9F [!27.6] V at the baey term!*4s).

This voltage maintains the battery plates in a condition that supports maintaining the grid life (expected to be approximately 20 years). The

\

WOG STS (7 B 3.8.4 - 7 Rev. 2, 04/30/01 120

DC Sources - Operating B 3.8.4 REVISION 5 BASES SURVEILLANCE REQUIREMENTS (continued) 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 8).

SR 3.8.4.2 This SR verifies the design capacity of the battery chargers. According to Regulatory Guide 1.32 (Ref. 9), the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, S Virrespective of the status of the unit during these demand occurrences.

- -reuired amperes and duration ensure that these

..*requirements can b10 SR provides two options. One o; n requires that each battery charger able of supplying [400q amps at the minimum established float voltage for hours. The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the The charger charger voltage level after a response to a loss of AC power. The time" volta(ge requires peFied-f sufficient for the charger temperature to have stabilized and-te

- -- ý - -- I -

a minimum output of 140 The other option requires that each ba carger be capable of volts.

recharging the battery after a se ýe test coincident with supplying the large5st demandd he various continuous steady state loads e+-r-spective of the st s of the plant during which these demands occur). This lev f loading may not normally be available following the battery s3ee test and will need to be supplemented with additional load4 .he duration for this test may be longer than the charger sizing iteria since the battery recharge is affected by float voltage, temperature, athe exponential decay in charging current. The battery i recharged when the measured charging current is -<121 amps.

The minimum established float voltage for Unit 1 is > 127.8 The Surveillance Frequency is acceptable, given the unit conditions volts at the battery terminals required to perform the test and the other administrative controls existing for 60 cell batteries 1-1 and 1- to ensure adequate charger performance during these 118 month]

2, and 125.67 volts at the intervals. In addition, this Frequency is intended to be consistent with battery terminals for 59 cell expected fuel cycle lengths.

batteries 1-3 and 1-4. The minimum established float SR 3.8.4.3 voltage for Unit 2 is > 127.8 volts at the battery terminals.

A battery service test is a special test of the battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical WOG STS B 3.8.4 - 8 Rev. 2, 04/30/01 121

DC Sources - Operating B 3.8.4 REVISION 5 1 BASES SURVEILLANCE REQUIREMENTS (continued) 7 power system. The discharge rate and test length should correspond to of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , using the design duty cycli L/ , as specified in Reference 4.

actual or simulated The Surveillance Frequency of 118 months] is consistent with the emergency loads recommendations of Regulatory Guide 1.32 (Ref. 9) and Regulatory 1 Guide 1.129 (Ref. 10), which state that the battery service test should be performed during refueling operations, or at some other outage, with the SR intervals between tests not to exceed [1noRithts1 . Frequency This SR is modified by two Notes. Note 1 allows the performance of a plus any modified performance discharge test in lieu of a service test. allowed extension.

NU REG-1431, Rev. 3 The reason for Note 2 is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This estriction from normally performing

-II... .. . ... ~t:_*l

/*£.,_ .. ,.1. *,:...

the S'reiI!ance t Jl..- ** . ... ;l1....

in MODE 1 or 2A is

$-- k -- *A."* 4r-'*

Credit may be the purpose of reestablishing OPERABIL ITY (e.g., pst weoFr testiRn taken for unplanned events following corrective maintenance, corrective modification, deficient or that satisfy this SR. incomplete S.....ill..ae testing, and other unanticipated OPERABILITY cnOe\rs) provided an assessmePnt deterimines plant safe*' is maintained oir enha nnc ed. T-his a1.;seP-scssmenRt shall, a s a miimm conidear the potential outcomes and transients associated with a failed partial Su..eillanc, a successful pa.rtial Sur1eillance, and a perturbation of the offsite or onsite system when they are tied taogether o operated independently for the partial Su.veillance; as well as the eperator procedueres available to cope w.ith theseLQAoutcomes. These shall be measured against the avoidled risk of a plant shutdown and startup to deteFrmine that plant safety is maintained or enhan~ed- w.hen~ portions ot

I,- ~ -H-r ~ Q 4wn h~nr-r 1 r--)ý PinI, iinh* Ito deterministic methods may b e used for the assessment.

Unit I UFSAR Appendix 1A, "1971 AEC REFERENCES 1. 1 =OFR.50,Appendix A,^GD* - - General Design Criteria Conformance" and Safety Guide 6 (unit 1) and 2.--*.Regulatory Guide 1.6, March 10, 1971. Unit 2 UFSAR Section 3.1, "Conformance with U. S. Nuclear Regulatory Commission General Design Criteria."

3. IEEE-308-.-78 ... unlL. ____________ _____

4. FSAR, Chapter 181. 1971 for Unit 1 and 1974 for Unit 2.

)

U FSAR, Chapter 16].

-FSAR, Chapter 14 for Unit 1 and Chapter 15 for Unit 2.

WOG STS B 3.8.4 - 9 Rev. 2, 04/30/01 122

DC Sources - Operating REVISION 5 1 B 3.8.4 BASES REFERENCES (continued)

7. Regulatory Guide 1.93, December 1974.

8. IEEE-450-119951.

9. Regulatory Guide 1.32, February 1977.

10. Regulatory Guide 1.129, December 1974.

.,0 3

NRC Regulatory Commitment documented in FENOC Letter L-06-162, "Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion," dated 12/07/06.

11.

WOG STS B 3.8.4 - 10 Rev. 2, 04/30/01 123

Battery Parameters B 3.8.6 REVISION 5 BASES ACTIONS (continued) reasonable 5 of the amount of the previousidischarge and the recharge characteristic of the battery. Thus there is assurance of fully recharging the battery within 1t121 hours, avoiding a premature shutdown with its own attendant risk.

If the condition is due to one or more cells in a low voltage condition but still greater than 12.071 V and float voltage is found to be satisfactory, this is not indication of a substantially discharged battery and f121 hours is a reasonable time prior to declaring the battery inoperable.

Since Required Action B.1 only specifies "perform," a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met.

However, if SR 3.8.4.1 is failed, the appropriate Condition(s), depending on the cause of the failure, is entered.

C.1, C.2, and C.3 (i.e., >_minimum level indication mark)

With one or more batteries in one train with one or more cells electrolyte Accon.i wit level above the top of the plates, but below the minimum established R cdesign limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be Within 31 days.: considered inoperable solely as a result of electrolyte level not met.

I iAthinbe31re-established.

must days the minimum established design limits for electrolyte 13 level m, %1 Condition C is modified by a Note that requires the With electrolyte level below the top of the plates ther is a p/tential for completion of Required Action dryout and plate degradation. Required Actions C.A nd C 2 address this C.2 if the electrolyte level was potential (as well as provisions in Specification 5.5. , Bat ery Monitoring found below the top of the .

plates. In this case, the visual and Maintenance Program). They are modified by a Not that indicates inspection for leakage they are only applicable if electrolyte level is below the to of the plates.

specified in Required Action Within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months level is required to be restored to above t e top of the c.2 must be performed prior plates. The Required Action C.2 requirement to verify t at there is no to exiting Condition C even if lc5. .b ite the electrolyte level is leakage by visual inspection and the Specification 5.5.-b item to initiate restored to greater than or action to equalize and test in accordance with manufacturer's equal to the minimum recommendation are taken from Annex D of IEEE Standard 450-1995.

established design limit. I They ar erformed following the restoration of the electrolyte level to abov e top of the plates. Based on the results of the manufacturer's The visual inspection re mmended testing the batter-y-]ies] may have to be declared and requirements of . operable and the affected cellfs] replaced.

Specification5.5.13.b tTc B.64R.,

WOG STS B 3.8.6 - 4 Rev. 2, 04/30/01 134

REVISION 5 Battery Parameters B 3.8.6 BASES ACTIONS (continued) of 50 IF ID.A With one or more batteries in one train wit lilot cell temperature less than the minimum established design limits, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to restore the temperature to within limits. A low electrolyte temperature limits the current and power available. Since the battery is sized with margin, while battery capacity is degraded, sufficient capacity exists to perform the intended function and the affected battery is not required to be considered inoperable solely as a result of the pilot cell temperature not met.

E.1 With one or more batteries in redundant trains with battery parameters not within limits there is not sufficient assurance that battery capacity has not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved this potential could result in a total loss of function on multiple systems that rely upon the batteries. The longer Completion Times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one train within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

F.1 With one or more batteries with any battery parameter outside the allowances of the Required Actions for Condition A, B, C, D, or E, sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding battery must be declared inoperable.

Additionally, discovering one or more batteries in one train with one or more battery cells float voltage less than J2.071 V and float current greater than 121 amps indicates that the battery capacity may not be sufficient to perform the intended functions. The battery must therefore be declared inoperable immediately.

SURVEILLANCE SR 3.8.6.1 REQUIREMENTS Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state.

The float current requirements are based on the float current indicative of WOG STS B 3.8.6 - 5 Rev. 2, 04/30/01 135

Battery Parameters B 3.8.6 REVISION 5 BASES SURVEILLANCE REQUIREMENTS (continued) a charged battery. Use of float current to determine the state of charge of the battery is consistent with IEEE-450 (Ref. ). The 7 day Frequency is consistent with IEEE-450 (Ref.-l).

This SR is modified by a Note that states the float current requirement is not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. When this float voltage is not maintained the Required Actions of LCO 3.8.4 ACTION A are being taken, which provide the necessary and appropriate verifications of the battery condition. Furthermore, the float current limit of 121 amps is established based on the nominal float voltage value and is not directly applicable when this voltage is not maintained.

SR 3.8.6.2 and SR 3.8.6.5 The minimum established float Optimal long term battery performance is obtained by maintaining a float voltage for Unit 1 is _>127.8 voltage greater than or equal to the minimum established design limits volts at t he battery terminals provided by the battery manufacturer, Which correspond* , to [130.5] V at for 60 ce I1batteries 1-1 and 1- the battey terminals, Or [2.251 VPc...This provides adequate over-2, and 1225.67 volts at the potential, which limits the formation of lead sulfate and self discharge, battery t 1-3 and 1f4. The which could eventually render the battery inoperable. Float voltages in batteries minimum established float this range or less, but greater than 12.071 Vpc, are addressed in voltage or Unit 2 is _>127.8 Specification 5.5.41. SRs 3.8.6.2 and 3.8.6.5 require verification that the volts at t he battery terminals, cell float voltages a equal to or greater than the short term absolute minimum voltage of {2-71 V. The Frequency for cell voltage verification every 31 days for pilot c ,l and 92 days for each connected cell is consistent with IEEE-45 f. -.

I SR 3.8.6.3 13 (i.e., _>minimum level indication mark)

Theehlimit specified e diefor eelectrolyte levellýensures that the plates suffer no sical a da mca andd0nfae damage maintains m adequate electron transfer capability.

eh cn rn her que requency is is consistent s with IEEE-450 (Re mcit 3.8.6.

SRi Surveillan This urv I 0 is that the pilot cell temperatur[is gKreater than or verifies e qual T uss I to the t mini g m Iestablished design limit (i.e.,4491 OF). Pilot cell S

it mp r c t pI c olyt temperat electrolyte i maintained above this temperature to assure is the battery can provide v r r the required current and voltage to meet the trtt rv c Drovi design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. The Frequency is consistent with IEEE-450 (Ref. 'ý WOG STS B 3.8.6 - 6 Rev. 2, 04/30/01 136

Battery Parameters B 3.8.6 BASES REVISION 5 1 SURVEILLANCE REQUIREMENTS (continued) shows no degradation but ha.. rec.hd 85% of its expe.tod life, the Surveillance FrFequencY is onlY reduced to 21 monthr, for bteisthat retain capacity 10%of the manufacturer's ratings. Degradation is indicated, according to IEEE-450 (Ref. 3), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is [110%] below the manufacturer's rating.

These Frequencies are consistent with the recommendations in IEEE-450 (Ref. 3).

This SR is modified by a Note. The reason for the Note is that

{NUREG-1431, Rev. 3 performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This restriction from normally Credit may be taken for ,performing the Surveillance in MODE 1 er 2 is further amplified to allo' unplanned events that portions of the Surveillance to be penformed for the purFposeof satisfy this SR. reestablishing OP12ERABILITY (e.g., post work testing following corrective maintenance, corFr*tive mhdification, deficient or incomplete su.eillance teStiRg, an;d otheFunantiipatedo OProERdABarILITY concerna) provided an assessment deteminess plant safety is mairtained or enhanced. This Shall, as a minimum, consider the potential outcomes and asssm en6-M8At-transientAs aso i.atedith a;failed partial SurveillanIeI, a scesu partial Surveillance, and a perturbation of the offsito or onsite system when they are tied together or operated independently forF the partial Surveillance; as well as the operator procedurWýes avfailable to cope with these_ outcoemes. These shall be measur-ed- against the avoided risk of a planct hutdown and staftup to determine that plant safety is maintained or enhanced when portions oftth Suroeil'lance are performed in MODE I or 2. Risk insights or determinis~tic- metho-dsr may be used for the a~sG19ment REFERENCES 1. FSAR, Chapter N6.

ýUý 2. FSAR, Chapter 14 for Unit 1 and Chapter 15 for Unit 2.

3. IEE E-45041995].

1

4. IEEE-485F19831, June 1983

\5. UFSAR, Chapter 8 (Unit 2).

WOG STS B 3.8.6 - 8 Rev. 2, 04/30/01 138

BVPS ISTS Conversion I REVISION 5 3.8 Electrical Power Systems Enclosure 2 Changes to The ISTS Bases ITS 3.8.4 DC Sources - OperatingBases JUSTIFICATION FOR DEVIATION (JFD)

1. Editorial change made to be consistent with the ISTS writers' guide.

2. The BVPS Unit 1 and 2 UFSAR each contain a section that describes how the unit complies with the GDC. The ISTS Bases references to the GDC have been replaced with references to the appropriate section of each BVPS Unit's UFSAR that describes compliance with the GDC. Supplement each reference to the "10 CFR 50, Appendix A General Design Criteria" in the ISTS Bases with the phrase "as discussed in Reference 1".

3. Changes are made (additions, deletion, and or changes) to the ISTS, which reflect the plant specific nomenclature, number reference, system description, analysis, or licensing basis description.

4. Bracketed information is deleted because it is not applicable.

5. Details not required to understand operation of DC sources and is therefore deleted.

6. Section / Chapter references are changed to reflect a unit specific reference (i.e.,

Accident analysis for Unit1 is Chapter 14 and for Unit 2 is Chapter 15), if applicable.

7. The ITS Bases are modified by moving descriptive information moved from the CTS specifications.

8. Editorial change made with the removal of the Reviewer's Note to be consistent with the ISTS writers' guide.

9. Changes are made to the Bases to address changes made to the corresponding technical specification (ITS 3.8.4) and to make the Bases discussion regarding the Completion Time more consistent with other Completion Time discussions. The JFD for the change made to the ITS discusses the reasons for the change in Completion Time.

BVPS Units 1 & 2 Page 5 Revision 5, 11/06 166

REVISION 5 Inserts LCOs 3.8.4, 3.8.6 and 3.8.9 LCO 3.8.9 Action C additional Completion Time Completion Time AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO SI. 3.8.4.2 alternate test allowance Surveillance Requirement SR 3.8.4.2 OR Verify each battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

SR 3.8.4.3 (second note) & SR 3.8.6.6 (only note)

- NOTES -

This Surveillance shall not be performed in MODE 1, 2, 3, or 4. Credit may be taken for unplanned events that satisfy this SR.

LCO 3.8.4 Action A Required Actions and Completion Times Required Action Completion Time A.1 Restore battery terminal 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months voltage to greater than or equal to the minimum established float voltage.

AND A.2 Verify battery float current Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

< 2 amps.

AND A.3 Restore battery charger(s) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to OPERABLE status.

207

BVPS ISTS Conversion REVISION 5 3.8 Electrical Power Systems Enclosure 3 Changes to CTS CTS 3.8.2.3 DC Distribution - Operating ITS 3.8.4 DC Sources - Operating ITS 3.8.6 Battery Parameters ITS 3.8.9 Distribution Systems - Operating DISCUSSION OF CHANGE (DOC)

Less Restrictive Changges (L)

L.1 (Category6 - Relaxation Of Surveillance Requirement Acceptance Criteria)CTS surveillance requirement 4.8.2.3.2.e and 4.8.2.3.2.f require the performance of a discharge tests verifying battery capacity at least every 18 months during shutdown. ITS SR 3.8.6.6 in part requires the verification of battery capacity when subjected to a performance discharge test. A Note modifies the ITS SR. The Note states "This Surveillance shall not be performed in MODE 1, 2, 3, or 4. Credit may be taken for unplanned events that satisfy this SR". This changes the CTS by allowing credit to be taken for unplanned events.

The purpose of ITS SR 3.8.6.6 Note is to allow credit to be taken for unplanned events that satisfy this SR. This change is acceptable because the relaxed SR requirements are adequate to verify that the equipment used to meet the LCO can perform its required functions. The change allows the results from an unplanned event to be used to satisfy the SR. The results of an unplanned event must still conform to the applicable required battery acceptance criteria in order for the results to be used to verify battery operability.

Therefore, the battery would continue to be verified operable utilizing the appropriate SR acceptance criteria. The proposed allowance for credit to be taken for unplanned events is consistent with the ISTS wording. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.2 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)CTS surveillance requirement 4.8.2.3.2.c.4 states that the battery charger will supply at least 100 amps at 140 volts for at least 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS SR 3.8.4.2 requires a verification of each battery charger supplying > 100 amps at greater than or equal to the minimum established float voltage for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In addition, the SR provides an alternative test method that allows a verification of each battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 changes the CTS by allowing an alternate test that is not currently allowed.

The purpose of the ITS alternate test method is to provide a method that can demonstrate the charger capability to supply a recharge to a battery after a battery discharge test has been performed. This change is acceptable because the relaxed BVPS Units 1 & 2 Page 52 Revision 5, 11/06 264

REVISION 5 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CTS Surveillance Requirement acceptance criteria are adequate to verify that the equipment used to meet the LCO can perform its required functions. The alternate test provides an acceptable method for determining charger capability by actually recharging a discharged battery within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying required loads. The ITS requirement is consistent with the ISTS wording for this requirement. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.3 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)CTS surveillance requirement 4.8.2.3.2.d states that battery capacity is verified by subjecting the battery to a service test every 18 months during shutdown. ITS SR 3.8.4.3 requires a service test to be performed to verify the battery capacity. The test must be performed every 18 months. A Note modifies the SR that states "This Surveillance shall not be performed in MODE 1, 2, 3, or 4. Credit may be taken for unplanned events that satisfy this SR." This revises the CTS by allowing credit for unplanned events.

The purpose of ITS SR 3.8.4.3 Note is to allow credit to be taken for unplanned events that satisfy this SR. This change is acceptable because the relaxed SR requirements are adequate to verify that the equipment used to meet the LCO can perform its required functions. The change allows the results from an unplanned event to be used to satisfy the SR. The results of an unplanned event must still conform to the applicable required battery acceptance criteria in order for the results to be used to verify battery operability.

Therefore, the battery would continue to be verified operable utilizing the appropriate SR acceptance criteria. The proposed allowance for credit to be taken for unplanned events is consistent with the ISTS wording. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.4 (Category 4 - Relaxation of Required Action) CTS LCO 3.8.2.3 Action a, in part states with one of the battery banks inoperable, restore the inoperable battery bank to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS LCO 3.8.4 Required Action B requires with one or two batteries on one train inoperable restore the inoperable batteries to OPERABLE status in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by allowing more than one battery to be inoperable if the batteries are on the same train.

The purpose of ITS LCO Required Action B is to limit one train of batteries to be inoperable for only 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a design basis accident occurring during the repair period. This change allows both batteries on the same train to be inoperable for up to two hours. The remaining train of batteries ensures accident analysis assumptions are met for the BVPS Units 1 & 2 Page 53 Revision 5, 11/06 265

REVISION 5 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CTS limited time that the train of batteries is allowed to be inoperable. The ITS requirement is consistent with the ISTS wording for this requirement. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.5 (Category 4 - Relaxation of Required Action) CTS LCO 3.8.2.3 Action b, in part states with one of the battery charger inoperable, restore the inoperable battery charger to OPERABLE status with specific limitations. ITS LCO 3.8.4 Required Action A requires with one or two battery chargers on one train inoperable restore the inoperable battery changers to OPERABLE status within specific limitations. This changes the CTS by allowing more than one battery charger to be inoperable if the battery chargers are on the same train.

The purpose of ITS LCO Required Action A is to limit one train of battery chargers to be inoperable. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a design basis accident occurring during the repair period. This change allows both battery chargers on the same train to be inoperable with specific limitations. The remaining train of batteries and battery chargers ensure accident analysis assumptions are met for the limited time that the train of battery chargers is allowed to be inoperable. The ITS requirement is consistent with the ISTS wording for this requirement. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.6 (Category 4 - Relaxation of Required Action) CTS 3.8.2.3 Action b in part states with one of the required full capacity chargers inoperable, demonstrate the OPERABILITY of its associated battery bank by performing Surveillance Requirement 4.8.2.3.2.a.1 within one hour. The requirement goes on to state that the action requires the Surveillance Requirement of 4.8.2.3.2.a.1 to be continued for at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter and if any Category A limit in Table 3.8-1 is not met, declare the battery inoperable. ITS LCO 3.8.4 Condition A states with one or two battery chargers on one train inoperable, restore battery terminal voltage to greater than or equal to the minimum established float voltage with 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (Required Action A.1). Required Action A.2 states a verification of float current of < 2 amps is required once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Required Action A.3 specifies that the inoperable charger(s) must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

This changes the CTS by allowing the battery terminal voltage to be restored to the minimum established float voltage with float current to be _< 2 amps and restoring the charger(s) to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The purpose of ITS Required Actions A.1, A.2, and A.3 is to allow appropriate correct actions with appropriate time limitations to restore inoperable battery chargers to OPERABLE status. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. The allowed Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore a BVPS Units 1 & 2 Page 54 Revision 5, 11/06 266

4.

REVISION 5 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CTS battery charger to operable status is acceptable considering the capacity and capability of the remaining train of operable DC Sources, the low probability of a design basis accident occurring during the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time, as well as the ability to maintain the affected battery operable during this time using non-Class 1 E battery chargers. This change establishes the appropriate actions to be taken with inoperable battery charger(s). The current requirement specifies that all Category A parameters listed in Table 3.8-1 be within limits. The battery charger affect on the associated battery is directly related to the terminal voltage and the charging current in a float condition. With the charger supplying the minimum float voltage and _<2 amps of charging current indicates the battery is capable of performing design requirements and should be considered OPERABLE. Twelve hours is acceptable for the verification of the charging current because it provides a limited time and the charger must be returned to OPERABLE within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L.7 (Category 6 - Relaxation Of Surveillance Requirement Acceptance Criteria)CTS surveillance requirement 4.8.2.3.2.b.3 states the average electrolyte temperature of every tenth cell of connected cells is above 60 IF. ITS SR 3.8.6.4 states "Verify each battery pilot cell temperature is greater than or equal to minimum established design limits." This changes the CTS by replacing the "average" temperature requirement of "every tenth connected cell" with the requirement that "each battery pilot cell temperature is greater than or equal to minimum established design limits." The change of 60 °F to minimum established design limits is discussed in a less restrictive change removal of details in these discussion of changes.

The purpose of ITS SR 3.8.6.4 is to ensure the temperature of the batteries is within design requirements. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are adequate to verify that the equipment used to meet the LCO can perform its required functions. The change allows pilot cells (representative cells) to accurately reflect the temperature of the battery as a whole. In addition, the ambient air temperature of the area where the battery rooms are located is monitored at least daily and actions are required to be taken if the ambient temperature reaches prescribed limits. Thus, sufficient controls exist to assure the ambient air temperature in the area of the battery rooms is maintained within acceptable limits.

The ITS requirement is consistent with the ISTS wording for this requirement. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L.8 (Category 6- Relaxation Of Surveillance RequirementAcceptance Criteria)CTS 4.8.2.3.2.b. 1 states the battery cell parameters in Table 3.8-1 meet the Category B limits every 92 days and within 7 days after a battery discharge or overcharge condition. Category B parameters applies to each connected cell. The cell minimum voltage is stated as 2.13 volts with notation (c) listed.

Notation (c) states "Corrected for average electrolyte temperature." ITS SR 3.8.6.2 states "Verify each battery pilot cell voltage is > 2.07 V" and must be performed every 31 days. This changes the CTS surveillance requirement from each connected cell to the pilot cells. It also changes the voltage requirement from 2.13 to 2.07 V with no electrolyte temperature correction required. This change also eliminates the requirement to verify the Category B parameters within 7 days of a battery overcharge or discharge.

The purpose of ITS SR 3.8.6.2 is to ensure that the battery's cells are maintained above the minimum required cell voltage. The pilot cells are representative of all connected cells. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are adequate to verify that the equipment used to meet the LCO can perform its required functions. ITS SR 3.8.4.1 verifies the minimum battery terminal voltage is maintained. The terminal voltage represents the average cell's voltage times the number of cells. ITS SRs 3.8.6.2 and 3.8.4.1 provide assurance that the battery BVPS Units 1 & 2 Page 55 Revision 5, 11/06 267

BVPS ISTS Conversion I REVISION 5 1 3.8 Electrical Power Systems Enclosure 3 Changes to CTS the minimum established design temperature limit which is 50 OF. The specific temperature limit is decreased from 60 IF to 50 OF.

The purpose of ITS SR 3.8.6.4 minimum established design temperature limit is to ensure the battery can function as designed and required to mitigate the consequences of analyzed event. This change is acceptable because the relaxed Surveillance Requirement acceptance criteria are adequate to verify that the equipment used to meet the LCO can perform its required functions. The change from 60 OF to 50 OF is acceptable because the design temperature stated in the Unit l's UFSAR for the cell's electrolyte temperature is 50 IF. For Unit 2 the proposed change is also aceptable because it is consistent with the design limits of the Unit 2 battery. The ITS requirement is consistent with the ISTS wording for this requirement. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

More Restrictive Changes (M)

M.1 CTS LCO 3.8.2.3 Action a specifies with one of the required battery banks inoperable, restore the inoperable battery bank to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS LCO 3.8.9 Condition C requires with one or more DC electrical power subsystems inoperable, restore the DC electrical power subsystem to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS LCO 3.8.9 Condition C provides an additional limitation on the Completion Time. This specifies the two-hour requirement and 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet the LCO. This changes the CTS by requiring an additional limitation that is not currently required.

This purpose of the additional ITS Completion Time is to ensure the overall electrical distribution systems do not remain in a degraded state for more than 16 total hours. This change is acceptable because the additional requirement provides a reason limit for a degraded electrical distribution subsystem. The ITS requirements are consistent with the ISTS wording for this requirement. This change is designated as more restrictive because it adds additional surveillance requirement that the CTS does not require.

M.2 Unit 2 CTS LCO 3.8.2.3 Action b in part states with one of the required full capacity chargers inoperable, demonstrate the OPERABILITY of its associated battery bank by performing Surveillance Requirement 4.8.2.3.2.a.1 within one hour. The action allows with an inoperable charger in Unit 2, the spare charger to be substituted for an inoperable charger within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with no additional requirements specified. ITS LCO 3.8.4 Condition A states with one or two battery chargers on one train inoperable, 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 is specified by Required Action A. 1.

Required Action A.2 states a verification of float current of _<

2 amps is required once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Required Action A.3 specifies that the inoperable charger(s) must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This changes the Unit 2 CTS by replacing the Action to substitute the spare charger within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with more specific restoration Actions for the battery and the battery charger.

The purpose of ITS 3.8.4 Required Actions A.1, A.2 and A.3 is to provide the appropriate actions to be taken when a charger becomes inoperable. This change is acceptable because the new ITS Actions require the restoration of the battery terminal voltage to _>

the minimum established float voltage and the restoration of the battery charger to operable status. In addition, an inoperable charger may be replaced with an operable spare fully 1E qualified charger of equivalent or greater capacity at any time and the Action Condition for an inoperable charger would no longer be applicable and could be exited. The replacement of an inoperable charger with an operable BVPS Units 1 & 2 Page 61 Revision 5, 11/06 273

REVISION 5 BVPS ISTS Conversion 3.8 Electrical Power Systems Enclosure 3 Changes to CTS spare charger remains an option even if not specifically stated in the Actions. As such, the proposed change continues to provide adequate assurance the battery and charger are maintained operable. This change is designated as more restrictive because more specific restoration Actions are specified in the ITS than the CTS.

M.3 CTS surveillance requirement 4.8.2.3.2.a.1 requires once per 7 days that the battery bank be demonstrated OPERABLE by verifying all Category A parameters, listed in Table 3.8-1, are within specified limits for each pilot cell. The Category A parameters are electrolyte level, float voltage, and specific gravity. Two notes modify specific gravity requirements in CTS Table. Note (a) modifies the general requirement for specific gravity and states "Corrected for electrolyte temperature and level." Note (b) modifies the Category A and the allowable values of the Category B limits and states "Or battery charging current is less than (2) amps when on charge."

The Category B limits apply to each connected cell. Corresponding ITS SR 3.8.6.1 requires that the float current for each battery is verified _2 amps every 7 days. A Note modifies the ITS SR.

The Note states "Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1" This changes the CTS by eliminating the option to use specific gravity measurements in the Technical Specifications and providing an exception for terminal voltage less than the minimum for the use of charging current.

The purpose of ITS SR 3.8.6.1 is to provide the method used to determine the state of charge of the battery provided the minimum battery voltage is met. The change to allow only charging current to be used is acceptable because charging current provides an adequate indication of the state of charge of the battery. Instrumentation with the appropriate accuracy and range for the expected current reading will be used to monitor the battery charging current. The use of instrumentation with the appropriate range and accuracy will assure a valid determination of the state of charge of the battery. In this way a relatively quick and accurate measure of the overall state of the battery is possible as opposed to the more lengthy and complex method of taking electrolyte from each required cell, measuring temperature and than correcting for both temperature and level. The addition of the Note to the SR is acceptable because if the minimum voltage is not met, and the charger is in service, the charging current will normally be greater than 2 amps in order to restore the voltage to the required minimum. Also, once the battery terminal voltage is less than the minimum established float voltage, Technical Specification Actions apply that provide the appropriate verification of the battery condition. In addition, if the battery voltage drops further (< 2.07VPC) the battery must be declared inoperable and only two hours are allowed to restore the battery to OPERABLE status. Therefore, the addition of the Note allowing an exception for when terminal voltage is below the minimum required is acceptable. This change is designated as overall more restrictive because it eliminates an SR option provided by the CTS (the use of specific gravity measurements) that is not included in the ITS.

M.4 CTS 4.8.2.3.2.b.1 states the parameters in Table 3.8-1 meet the Category B limits every 92 days and within 7 days after a battery discharge or overcharge condition. Category B parameters apply to each connected cell. ITS SR 3.8.6.3 states "Verify each battery connected cell electrolyte level is greater than or equal to minimum established design limits," every 31 days. This changes the CTS by requiring each connected cell electrolyte level be verified every 31 days instead of 92 days.

The purpose of ITS SR 3.8.6.3 is to periodically verify that each battery cell has sufficient electrolyte fluid to perform its required function. This change is acceptable because the limit specified for electrolyte level ensures that the plates suffer no physical damage and maintains adequate electron transfer capability. The frequency of the SR is consistent with the recommendations of the IEEE standard. The ITS requirements are consistent with the ISTS wording for this requirement. This change is designated as more restrictive because the surveillance requirement is more frequency in the ITS than in the CTS.

BVPS Units 1 & 2 Page 62 Revision 5, 11/06 274

REVISION 5 Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 '*--,-- tainment Leaka e Rate Testin Proqram (continued)

e. The provisions o 3 are e to the Containment Leakage Rate Testing Program. 22 ing in these Technical Specifications s b const odify the testina Freauencies reauired by 10 CFR 50. Appendix J.

Battery Monitoring and Maintenance Program which includes This Program provides for battery restoration and maintenance, based-on [the recommendations of IEEE Standard 450 1995, "IEEE Recommended Practice for ManeacTesting, and Replacemnent of Ven-ted Lo-ad Acid Batteries for Stationary Applications," or of the battery; manufacturer]icldn the following:

a. Actions to restore battery cells with float voltage < [2.131 V, ai41

b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established A,;-gn limit.

top of the plates, and

c. Actions to verify the remaining cells are > 2.07 V when a cell or cells have been found to be < 2.13 V.

WOG STS 5.5- 15 Rev. 2, 04/30/01 23

REVISION 5 BVPS ISTS Conversion 5.0 Administrative Controls Enclosure 1 Changes to ISTS The proposed change is based on approved TSTF-479 as modified by agreement with the NRC. The agreed change deviates from the approved TSTF-479 in that it restricts the test interval extension provided by SR 3.0.2 to inservice test intervals of 2 years or less. The change to TSTF-479 is based on the fact that the inservice test intervals > 2 years provide adequate time to schedule the required testing without the additional extension provided by SR 3.0.2.

35. This change revises the acceptance criteria for the containment Leakage Rate Testing Program (ITS 5.5.12.d.1). Currently the affected portion of the acceptance criteria (first sentence of part d.1) states the following: "Containment leakage rate acceptance criterion is 1.0 La." The BVPS CTS states this acceptance criteria as "< 1.0 La." In addition, this portion of NUREG-1431 was added by TSTF-52, Rev. 3. TSTF-52 introduced the "A & B Options" from 10 CFR 50 Appendix J into the Containment Leakage Rate Testing Program and was incorporated into Revision 2 of NUREG-1431. However, TSTF-52 also specifies the affected portion of the part d.1 acceptance criterion as "< 1.0 La." TSTF-52 introduced three options in the program, Option A, Option B, and Option A/B. Each of these options had a separate Acceptance criteria section (which contained part d.1 or c.1 in Option A). In TSTF-52, the affected sentence of Part d.1/c.1 for all options was stated as "Containment leakage rate acceptance criterion is <1.0 La." However, when TSTF-52 was incorporated into NUREG-1431 part d.1 of Option B was incorporated without the <_symbol. The other two options introduced by TSTF-52 were correctly incorporated into NUREG-1431 with the affected portion of the acceptance criteria being stated as: "Containment leakage rate acceptance criterion is <1.0 La." BVPS utilizes the Option B portion of the program which is missing the < symbol. Therefore, this change is necessary to make the BVPS ITS consistent with the corresponding BVPS CTS requirement and with the original intent of TSTF-52.

36. ITS Section 5.5.13, Battery Monitoring Program, is revised to incorporate changes consistent with the proposed changes to TSTF-360. These proposed changes are planned to be incorporated into the ISTS (i.e., NUREG-1431) in the near future. As such, these changes to the BVPS ITS are necessary to maintain consistency with NUREG-1431.

BVPS Units 1 and 2 Page 7 Revision 5,11/06 63

I REVISION 5

c. The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

INSERT 3 5.5.13 Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, which includes the following:

a. Actions to restore battery cells with float voltage < 2.13 V,

b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates, and

c. Actions to verify the remaining cells are _>2.07 V when a cell or cells have been found to be < 2.13 V.

INSERT 4 5.5.9 Diesel Fuel Oil Testing Program A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing requirements, and acceptance criteria, all in accordance with applicable ASTM Standards. The purpose of the program is to establish the following:

INSERT 5 5.6.5 Post Accident Monitoring Report When a report is required by Condition B or F of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

123

BVPS UNITS 1 & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR)

NoS. 296 (UNIT 1) & 1 69 (UNIT 2)

A TTA CHMENT 4 (to L-06-162)

LETTERS FROM BATTERY MANUFACTURERS

C=m TECHNOLOGIES, INC.

P o w e r S o l u t io n s 1400 Union Meeting Road P.O. Box 3053 Blue Bell, PA 19422-0858 Telephone (215) 619-2700 Fax (215) 619-7840 November 17, 2006 Mr. Jeffrey Redmond First Energy Beaver Valley Nuclear Power Plant Route 168 Shippingport, PA 15077

Subject:

Float Current Used as an Indicator of Battery Charge State

Reference:

Beaver Valley Nuclear Power Plant

Dear Mr. Redmond:

Confirming our telephone conversation of today, I wish to re-state C&D's concurrence that a float current value of _*2.0 Amps is a both a reliable and an accurate parameter to use to ascertain a state of full charge for the 125-V dc Station Batteries installed at Beaver Valley Nuclear Power Plant. That is to say, a float current value of *<2.0 Amps on these batteries is a reasonable indicator of a full state of charge. The accuracy and reliability of this reading will hold true over the expected life of these batteries (i.e. 20-years).

I trust this information addresses your concerns. Please contact me if you have any questions at telephone 215-619-2700 extension 365 or via e-mail at ihohenstein ccdtechno.com.

1J4. Hohenstein Manager, Nuclear Applications Engineering RS-896

EnerSys P.O. Box 14145 E

nei Reading, PA 19612-4145 800-538-3627 x 1680 7Fax 610-208-1971 owerXFull .So/Email: _ an.reberenersys.com lub'ons'-WWW. enersys,com Jan G. Reber Directorof Engineering RP Flooded Products Technology &Engineering 11/29/06 Jeff Redmond Plant Engineering Beaver Valley Power Station Route 168 Shippingport, PA 15077 Mail Stop: BV-SOSB-6 Re: Stabilized Float Current for EnerSys GN Batteries

Dear Mr. Redmond,

EnerSys confirms that a stabilized float current is a necessary condition to determine if a battery has achieved a full state of charge. This value, however, is a variable of battery size and float voltage. It is also dependant on temperature and to a lesser degree on battery age and manufacturing process variation. Due to the asymptotic nature of the charge current to state of charge relationship, EnerSys states that there exists a float current value that can be selected for each battery type that, given no other extraneous conditions, can be used to justify that the monitored battery has achieved more than a particular state of charge. It would be ideal to develop this value for each individual battery specifically. However, given the limits of 2.25 VPC nominal string average cell voltage and an average 72-80°F battery temperature, a reasonable estimate of the capacity returned to the battery can be made based on a particular float current by battery type. This value is referenced to the full charge capacity that the battery is capable of at the time the measurement is taken. With the above stipulations as prerequisites, it can be reasonably assumed that when the float current is less than or equal to a 2 amp threshold the 125 VDC station batteries located at Beaver Valley NPS will have achieved a nominal returned capacity. The capacity values for the two types are as listed below. These values are expected to be valid for the service life of the batteries. Note: this evaluation requires that a positive float current is verified, i.e. that the battery has not been opened, resulting in zero float current.

Basic Battery Type Percentage of Available Capacity Returned (Measured Float Current is < or = 2 amps) 2GN-13 95 2GN-21 98 If you have any questions regarding this letter, please contact me.

Jan G. Reber Cc: File 352, J. Gagge, S. Weik, B. Ross

BVPS UNITS I & 2 ITS CONVERSION LICENSE AMENDMENT REQUEST (LAR)

Nos. 296 (UNIT 1) & 1 69 (UNIT 2)

A TTA CHMENT 5 (to L-06-162)

Beaver Valley Power Station, Unit Nos. 1 and 2 Commitment Summary

Commitment List The following identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for Beaver Valley Power Station (BVPS)

Unit Nos. 1 and 2 in this document. Any other actions discussed in the submittal represent intended or planned actions by FENOC. They are described only as information and are not regulatory commitments. Please notify Mr. Gregory A. Dunn, Manager - FENOC Fleet Licensing, at (330) 315-7243 of any questions regarding this document or associated regulatory commitments.

COMMITMENT DUE DATE Include in the Bases for ITS 3.8.4, DC Upon Implementation of BVPS Sources - Operating the requirement to ITS Conversion License maintain at least a 5% design margin for the Amendment Request Nos. 296 EnerSys model 2GN- 13 batteries (Unit 2 (Unit 1) and 169 (Unit 2).

Batteries 2-3 and 2-4) and a least a 2%

design margin for the EnerSys model 2GN-21 batteries (Unit 1 Batteries 1-1 and 1-2 and Unit 2 Batteries 2-1 and 2-2).

v t e Letter Sequence Supplement
TAC:MC6285, Increase Flexibility in Mode Restraints, Steam Generator Tube Integrity, Addition of New Tech Spec on RCS Boron Limits and Revisions to Tech Spec 3.3.1 to Address Rwfs, Implement 10 CFR 50, Appendix J, Option B, Provide Actions for One Steam Supply to Turbine Driven Afw/Efw Pump Inoperable, Changes to Reflect Revision of 10 CFR 50.55A, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors, TSTF-1, Allow Time for Stabilization After Reducing Power Due to Qptr Out of Limit, Correct Bases Change Made by TSTF-283, TSTF-21, TSTF-38 (Approved, Closed)
Initiation Request Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement, Supplement, Supplement Administration Questions Answers Results Approval, Approval, Approval Other: L-07-086, Implementation of Beaver Valley, Units 1 & 2, Improved Technical Specification Amendment Nos. 278 (Unit 1) and 161 (Unit 2), ML060940413, ML060940429, ML061220200, ML070240291, ML070390057, ML070390061, ML070390530
MONTHYEAR2006-05-09 [Table View]

L-06-162, Supplement to License Amendment Request Nos. 296 and 169, Improved Standard Technical Specification Conversion

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