ML070520398

Supplemental Information Regarding License Amendment Request to Technical Specifications Associated with AC and DC Electrical Power

ML070520398
Person / Time
Site:	Columbia
Issue date:	02/13/2007
From:	Oxenford W Energy Northwest
To:	Document Control Desk, NRC/NRR/ADRO
References
G02-07-027
Download: ML070520398 (18)

Text

EENERGY M\\> NORTHWEST P'eop~e

• Vision

• cOfutions P.O. Box 968 s Richland, WA. 99352-0968 February 13, 2007 G02-07-027 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER

References:

1) Letter dated May 31, 2005, G02-05-099, WS Oxenford (Energy Northwest) to NRC, "License Amendment Request to Technical Specifications Associated with AC and DC Electrical Power"

2) Letter dated February 8, 2006, G02-06-019, WS Oxenford (Energy Northwest) to NRC, "Response to Request for Additional Information Regarding License Amendment Request to Technical Specifications Associated with AC and DC Electrical Power"

3) Letter dated January 5, 2007, G02-07-008, WS Oxenford (Energy Northwest) to NRC, "Response to Request for Additional Information Regarding License Amendment Request to Technical Specifications Associated with AC and DC Electrical Power"

Dear Sir or Madam:

The NRC Staff is reviewing the license amendment request submitted in Reference 1. In References 2 and 3 Energy Northwest provided responses to requests for additional information. In a teleconference on February 7, 2007 additional information was requested by the staff to clarify information provided in Reference 3. Attachment 1 herein provides supplemental information to assist the Staff in this review.

Energy Northwest has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment 1 of Reference 1. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 2 If you have any questions or require additional information, please contact Mr. GV Cullen at (509) 377-6105.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, WS Ox nforc i, Technical Services Attachments:

Enclosures:

1.

2.

3.

1.

2.

Supplemental Information List of Commitments Revised mark-up of Technical Specification pages Letter from EnerSys Letter from C & D Technologies, Inc.

cc:

BS Mallett - NRC RIV CF Lyon - NRC NRR WA Horin - Winston & Strawn NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 1 of 6 Supplemental Information Topic I

1)

NRC staff and industry agreed that a 7-day extension could be allowed if either of the following conditions is met:

a) The spare battery charger being credited is capable of being supplied power from a source independent of the offsite power system b) A risk informed analysis shows that the 7-day extension is acceptable.

Otherwise, a 72-hour Completion Time can be granted provided that the licensee uses the justification of EDG allowed outage times. Either way, the 'alternate means' would need to be identified in the TS Bases.

Supplemental information Energy Northwest is revising its amendment request for Technical Specification (TS) 3.8.4 to request a 72-hour Completion Time in lieu of the 7-day Completion Time originally requested. The 72-hour Completion Time is aligned with the standard 72-hour Completion Time for emergency diesel generators provided in NUREG 1433 and in Columbia's TS. A revised mark-up of the proposed TS pages is included in.

The TS Bases will be revised to add the following description of the "alternate means."

The alternate means will be a charger of sufficient capacity such that it is fully capable of restoring the battery voltage to the minimum acceptable limits, carrying respective DC bus loads, and maintaining the battery in a fully charged condition.

Topic 2 Ensure that the minimum established design limits for the battery are defined in the TS Bases and should be consistent with manufacturer recommendations (Battery Temperature and Level).

Supplemental information The Bases for Technical Specifications LCO 3.8.6 will be revised to contain the following:

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 2 of 6 The minimum established design limit for Cell temperature for the Division 1, 2, and 3 125 VDC systems and for the 250 VDC system is 600 F.

The minimum established design limit for electrolyte level for the Division 1, 2, and 3 125 VDC systems and for the 250 VDC system is the low level mark.

The Bases for Technical Specifications LCO 3.8.4 will be revised to contain the following:

The minimum float voltage for the Division 1, 2, and 3 125 VDC systems is 126 VDC. The minimum float voltage for the 250 VDC system is 252 VDC.

These parameters are consistent with manufacturer's recommendations and station design analysis.

Topic 3 Concurrence letter from battery manufacturer stating that float current monitoring provides an accurate means for determining the Columbia Station's batteries state-of-charge for the expected life of the battery. This may require a Regulatory Commitment to maintain a battery design margin above a set limit.

Supplemental information The concurrence letters from the manufacturers of Columbia's batteries are provided as enclosures to this letter.

State of Charqe for Enersys Batteries As described in the letter from Enersys to Columbia Generating Station (CGS)

(Enclosure 1), a specific float current value can be established for a given state of charge for a given battery. Using re-charge data obtained from Enersys, and the method provided in the Kyle Floyd White Paper (ref Attachment 2 of TSTF 360), CGS calculated the remaining charge to be returned to the Division 1 & 2 125 VDC batteries and the Division 1 250 VDC battery (calc E/I-02-91-01). The results of the calculation demonstrate that at a float current of 2 amps (measured at normal operating temperature), 0.26% and 0.13% of total charge, respectfully, remains to be returned to these batteries. Energy Northwest's battery sizing analysis will incorporate a fixed margin to account for the use of the float current limit.

CGS commits to maintaining 1% design margin to support the use of float current monitoring for the Division 1 & 2 125 VDC and Division 1 250 VDC batteries.

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 3 of 6 State of Charcqe for C&D Batteries As described in the letter from C&D to CGS (Enclosure 2), float current monitoring is a reliable and accurate parameter to use to ascertain the state of charge in their batteries.

Using a conservative time constant and the method provided in the Kyle Floyd White Paper (ref Attachment 2 of TSTF 360), CGS calculated the remaining charge to be returned to the Division 3 125 VDC battery. The results of the calculation demonstrate that at a 2 amps float current (measured at normal operating temperature), 3.87%

remains to be returned to this battery. Energy Northwest's battery sizing analysis will incorporate a fixed margin to account for the use of the float current limit.

CGS commits to maintaining 5% design margin to support the use of float current monitoring for the Division 3 125 VDC battery.

Topic 4 Regulatory Commitment to relocate current TS to the Battery Monitoring and Maintenance Program. The licensee stated that 'Portions' will be relocated. We would need a more concrete statement.

Supplemental information The Current Technical Specifications that will be relocated to the Battery Monitoring and Maintenance Program are those described in Energy Northwest's initial submittal dated May 31, 2005 in Sections 2.2.B, C, E, F, and G as described below:

B). Relocate Preventive Maintenance SRs to Licensee-Controlled Programs.

Existing SR 3.8.4.2, SR 3.8.4.3, SR 3.8.4.4, and SR 3.8.4.5 are being deleted from the Columbia TS and relocated to a licensee-controlled program. These SRs are also listed in SR 3.8.5.1 and will be deleted from SR 3.8.5.1. This requires renumbering of SR 3.8.4.6 as SR 3.8.4.2, and SR 3.8.4.7 as SR 3.8.4.3.

C). Relocate Battery Terminal Voltage Values to Licensee-Controlled Programs.

SR 3.8.4.1 is being revised to require verification that battery terminal voltage is greater than or equal to the minimum established float voltage, which will be established in a licensee-controlled program....

E). Replace Battery Specific Gravity Monitoring with Float Current Monitoring The specific gravity limits of Table 3.8.6-1 and associated footnotes (b) and (c) are being deleted. Currently, verification of battery cell specific gravity is required by existing SR 3.8.6.1 and SR 3.8.6.2. Under the proposed changes,

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 4 of 6 specific gravity monitoring will be replaced with float current monitoring. New SR 3.8.6.1 requires verification that each battery float current is less than or equal to two amps when battery terminal voltage is greater than or equal to the minimum established float voltage. The Frequency of new SR 3.8.6.1 is seven days.

F). Relocate Limiting Values for Battery Cell Float Voltage and Electrolyte Level to a Licensee-Controlled Program.

The proposed changes delete Condition A of TS 3.8.6, SR 3.8.6.1, SR 3.8.6.2, SR 3.8.6.3, and the remainder of Table 3.8.6-1 (i.e., the portion not discussed in Section E above) from TS Section 3.8.6. These requirements are being relocated to the licensee-controlled program described in proposed TS Section 5.5.13, with the exception that battery specific gravity monitoring is being replaced with float current monitoring, as described above. In addition, the title of TS Section 3.8.6 is being revised to "Battery Parameters" and the LCO is being revised to read: "Battery parameters for the Division 1, 2, and 3 batteries shall be within limits." A corresponding change to the TS Table of Contents is being made to be consistent with the revised TS Section 3.8.6 title.

G). Create an Administrative Program Under TS Section 5.5.13 to Reference Actions for Cell Voltage and Electrolyte Level.

A new program is being added to TS Section 5.5. Specifically, TS Section 5.5.13, "Battery Monitoring and Maintenance Program," is added to provide for restoration and maintenance actions for station batteries based on the recommendations of Reference 2.

There are no other SRs being deleted outside of those described above.

Topic 5 Describe the accuracy of the float current monitoring equipment and the basis. The licensee stated that the float current monitoring equipment would be within 10% of the float current reading. We would need the technical basis for this figure.

Supplemental information Energy Northwest has committed to monitor float current with monitoring equipment capable of measuring within +/- 10% of the current reading. The basis for this value is that a reading error of this magnitude is within the margin specified in the calculation that supports the 2 amp float current value. Sensitivity analysis has demonstrated that a 10% error in float current measurement only causes a variation of 0.02 percentage points (Div. 1 & 2) or 0.37 percentage points (Div. 3) in available battery capacity.

These variations are bounded by station design analysis.

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 5 of 6 Topic 6 Revise TS 5.5 to be consistent with previously issued TSTF-360 license amendment requests (e.g., LaSalle).

Supplemental information Energy Northwest is revising its amendment request for the wording of the new TS 5.5.13 to align with previously approved amendment requests. The new proposed wording for 5.5.13 is below:

5.5.13 Battery Monitoring and Maintenance Proqram This Program provides for 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 that the remaining cells are Ž 2.07 V when a cell or cells have been found to be < 2.13 V.

A revised mark-up of this proposed TS is included in Attachment 3.

Topic 7 The staffs intent was not to have the licensee remove references to IEEE 450 from the TS Bases.

Supplemental information In commitment 5 in Attachment 2 to the response to a request for additional information, dated January 5, 2007, Energy Northwest provided a commitment to implement revisions to the TS Bases that would remove specific reference to IEEE 450.

To provide an underlying basis for the TS, we now understand the TS Bases may reference IEEE 450. Consequently, Energy Northwest withdraws its commitment to revise the Bases. Energy Northwest has removed references to IEEE 450 from the TS.

Topic 8 Provide technical justification for using the Note in SRs 3.8.4.3 and 3.8.6.6 containing "Portions of the Surveillance may be performed."

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 6 of 6 Supplemental information Energy Northwest is revising its amendment request to withdraw the request for the change to the Note in the SRs re-numbered as 3.8.4.3 and 3.8.6.6 related to performance of portions of the surveillance. Revised marked-up pages for the TS are included in Attachment 3.

The request for modification of the Notes to limit the Mode restrictions to the Division 1 and 2 125 VDC batteries is retained. For the Division 3 125 VDC and the Division 1 250 VDC batteries it is appropriate to cascade to the individual system LOOs. This is in alignment with the Columbia TS requirement for an inoperable battery (and its associated Bases), which requires that the supported features be declared inoperable and the applicable conditions and required actions for those supported features be entered (TS 3.8.4 Actions B.1 and C.1, re-numbered as H.1 and 1.1).

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 1 of 1 List of Commitments

1. The TS Bases will be revised to add the following description of the "alternate means."

The alternate means will be a charger of sufficient capacity such that it is fully capable of restoring the battery voltage to the minimum acceptable limits, carrying respective DC bus loads, and maintaining the battery in a fully charged condition.

2. The Bases for Technical Specifications LCO 3.8.6 will be revised to contain the following:

The minimum established design limit for cell temperature for the Division 1, 2, and 3 and 250 VDC system is 600 F.

The minimum established design limit for electrolyte level for the Division 1, 2, and 3 and 250 VDC systems is the low level mark.

The Bases for Technical Specifications LCO 3.8.4 will be revised to contain the following:

The minimum float voltage for the Division 1, 2, and 3 systems is 126 VDC. The minimum float voltage for the 250 VDC system is 252 VDC.

3. CGS commits to maintaining 1 % design margin to support the use of float current monitoring for the Division 1 & 2 125 VDC and Division 1 250 VDC batteries.

4. CGS commits to maintaining 5% design margin to support the use of float current monitoring for the Division 3 125 VDC battery.

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 1 of I Revised Mark-up of Technical Specification Pages

Insert to Page 3.8.4-1 CONDITION F-REQUIRED ACTION COMPLETION TIME A.

n required Division I or 2 1 5V DC baeychrr inoperable.

A.1 Restore battery terminal voltage to greater than or equal to the minimum established float voltage.

AND A.2 Verify battery float current

<2 amps.

AND i

A.3 Restorbattery charger

.to OPERABLE status.

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Z/6-36/07 eW-Sj,7, $y 7

hZ(iors 7

B.

One required Division 3 125 V DC battery charger inoperable.

B. 1 Restore battery terminalvoltage to greater than or equal to the minimum established float voltage.

AND B.2 Verify battery float current

< 2 amps.

AND 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

-?es 7 our3 B.3 Restore required battery charger to OPERABLE status.

I 72kow3 C.1 C.

One required Division 1 250 V DC battery charger inoperable.

Restore battery terminal voltage to greater than or equal to the minimum established float voltage.

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND C.2 Verify battery float current

< 2 amps.

AND C.3 Restore required battery charger to OPERABLE status.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> q--d8ar =7,Z how3 I

SURVEILLANCE REQUIREMENTS DC Sources-Operating 3.8.4 SURVEILLANCE FREQUENCY i

SR 3

- - -- - - - -NOTES -

1.

The modified perf; mance discharge test in SR 3.8.4-.-

may be performed in lieu of the service tect in SR 3.8.4.-r3 oncc per 609 monathz.

2.

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

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

Xp t r k-, ZIA5 VDC-24 months (continued)

Columbia Generating Station 3.8.4-4 Amendment No. 149,160 1691

SURVEILLANCE REQUIREMENTS DC Sources-Operating 3.8.4 SURVEILLANCE FREQUENCY i

SR 3.8.4-

---

NOTE------------------

This Surveillance shall not be performed in 5MODE 1, 2, or However, credit may be taken for unplanned events that satisfy I

this SR.

IOA 2 125 V Verify battery capacity is > 80% of the

• rr-5 manufacturer's rating for the 125 V batteries and > 83.4% of the manufacturer's rating for the 250 V battery, when subjected to a performance discharge test or a modified performance discharge test.

M~ove-5P?,

2(le.

60 months AND 12 months when battery shows degradation or has reached 85%

of expected life with capacity < 100%

of manufacturer's rating AND 24 months when battery has reached 85% of the expected life with capacity > 100%

of manufacturer's rating Columbia Generating Station 3.8.4-5 Amendment No. 149,169 1691

Insert to Page 5.5-12 5.5.13 Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance, which includes the following:

a.

Actions to restore battery cells with float voltage < 2.13 V; and

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 that the remaining cells are ; 2.07 V when a cell or cells have been found to be < 2.13 V.

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 1 of 1 Letter from EnerSys

EnerSys.

P.O.:Box14145 Reading,' PA 19612-4145 800-538,3627 x 1680 Fax 610-208-1971

• ,"F.,

Swww.enersys.com Jan G: Reber Director of Engineering RP Flooded Products Technology & Engineering 02102/07 Mr. Robert McQuoid C/O Energy Northwest P.O. Box 968 Richiand, WA.99352 MairDrop PE28 Dear Mr. McQuoid".

EnerS*s confirms that a stabilized float current is a necessary~condition to determine if a battery has'achieved alfu1l1state, of charge.. This value, however," is a va`riae.of battery size and float voltage.: ltiis also dependant on temperature and to a lesser;degree on battery age,and,:

manufacturing process variation. Due to the as'ymptotic.nature of the charge currentto fstate of charge relationship, EnerSys states that there:exists.a float.current value that can-b-e selected for eachý battery type that, given no other extraneous condi'fitions, can be used to justify thatf the monitored battery has achieved :more thana particular state of charge. It would be ideal to develop this value for each individualtbattery specifically. However, given thejlimits of 2.25 VPC nOminal string average cell voltage and an&average72-80°F battery temperature a re, asonble 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 theý batteryiS 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 Columbia Generating Station will have achieved a nominal returned-capacity.

If you have any questions regarding this letter, please contact me.

CC: File3 52, J. Gagge, S. WeikB.

BRoss

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO TECHNICAL SPECIFICATIONS ASSOCIATED WITH AC AND DC ELECTRICAL POWER Page 1 of 1 Letter from C & D Technologies, Inc.

CW IDTE CH NO LOGIES, INC.

STANDBY POWER DIVISION l'o* w e r S o l Itt i oti 1400 Union Meetin6R&

P.O. Bax505 BlueBA, PA194058 February 2, 2007 Energy Northwest Robert McQuoid MD PE28 P.O. Box 968 Richland, WA 99352

Subject:

Float Current Used as an Indicator of Battery Charge State

Dear Mr. McQuoid:

Confirming our recent telephone conversation, 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 C&D batteries installed at Columbia Generating Station. 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@),cdtechno.com.

Nuclear Applications Engineering