Text

Issuance of Amendment Nos. 180 and 167 Technical Specification 3/4.8.2 for Batteries and DC Systems
	ML071590171
Person / Time
Site:	South Texas
Issue date:	07/20/2007
From:	Thadani M; NRC/NRR/ADRO/DORL/LPLIV
To:	Sheppard J; South Texas
	Lyon C Fred, NRR/DORL/LPL4, 301-415-2296
Shared Package
ML071590163	List: ML071590171; ML071590179;
References
	TAC MD0333, TAC MD0334
	Download: ML071590171 (22)
	v • d • e

July 20, 2007 Mr. James J. Sheppard President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: TECHNICAL SPECIFICATION 3/4.8.2 FOR BATTERIES AND DC SYSTEMS (TAC NOS. MD0333 AND MD0334)

Dear Mr. Sheppard:

The Commission has issued the enclosed Amendment No. 180 to Facility Operating License No. NPF-76 and Amendment No. 167 to Facility Operating License No. NPF-80 for the South Texas Project, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated February 28, 2006, as supplemented by letters dated April 6, and May 31, 2007, and electronic mail dated July 18, 2007.

The amendments revise TSs 3/4.8.2.1, DC [Direct Current] Sources - Operating, and 3/4.8.2.2, DC Sources - Shutdown, and add a new TS 3/4.8.2.3, Battery Parameters. The amendments revise allowed outage times for battery chargers as well as battery charger testing criteria, and relocate a number of battery surveillance requirements to a licensee-controlled Battery Monitoring and Maintenance Program. The changes are consistent with Standard TS Change Traveler TSTF-360, Revision 1, DC Electrical Rewrite.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosures:

1. Amendment No. 180 to NPF-76

2. Amendment No. 167 to NPF-80

3. Safety Evaluation

cc w/encls: See next page

Pkg ML071590163 (Amdt./License ML071590171, TS Pgs ML071590179) *SE Dated 6/7/07 OFFICE LPL4/PM LPL4/LA EEEB/BC ITSB/BC OGC LPL4/PM LPL4/BC NAME FLyon JBurkhardt GWilson* TKobetz (email) JBonanno/NLO MThadani THiltz: MThadani for THiltz DATE 5/13/07 6/12/07 6/7/07 6/13/07 6/18/07 7/20/07 7/20/07 South Texas Project, Units 1 & 2 cc:

Senior Resident Inspector E. D. Halpin U.S. Nuclear Regulatory Commission Site Vice President P.O. Box 289 STP Nuclear Operating Company Wadsworth, TX 77483 South Texas Project Electric Generating Station C. M. Canady P.O. Box 289 City of Austin Wadsworth, TX 77483 Electric Utility Department 721 Barton Springs Road S. M. Head, Manager, Licensing Austin, TX 78704 STP Nuclear Operating Company P.O. Box 289, Mail Code: N5014 J. J. Nesrsta/R. K. Temple Wadsworth, TX 77483 E. Alercon/Kevin Pollo City Public Service Board C. T. Bowman P.O. Box 1771 General Manager, Oversight San Antonio, TX 78296 STP Nuclear Operating Company P.O Box 389 INPO Wadsworth, TX 77483 Records Center 700 Galleria Parkway Marilyn Kistler Atlanta, GA 30339-3064 Sr. Staff Specialist, Licensing STP Nuclear Operating Company Regional Administrator, Region IV P.O. Box 289, Mail Code 5014 U.S. Nuclear Regulatory Commission Wadsworth, TX 77483 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Environmental and Natural Resources Policy Director Steve Winn/Christie Jacobs P.O. Box 12428 Eddy Daniels/Marty Ryan Austin, TX 78711-3189 NRC Energy, Inc.

211 Carnegie Center Jon C. Wood Princeton, NJ 08540 Cox, Smith, & Matthews 112 East Pecan, Suite 1800 Judge, Matagorda County San Antonio, TX 78205 Matagorda County Courthouse 1700 Seventh Street Director Bay City, TX 77414 Division of Compliance & Inspection Bureau of Radiation Control A. H. Gutterman, Esq. Texas Department of State Health Services Morgan, Lewis & Bockius 1100 West 49th Street 1111 Pennsylvania Avenue, NW Austin, TX 78756 Washington, DC 20004 March 2007

South Texas Project, Units 1 & 2 cc:

Mr. Ted Enos Ken Coates 4200 South Hulen Plant General Manager Suite 422 STP Nuclear Operating Company Ft. Worth, TX 76109 South Texas Project Electric Generating Station Brian Almon P.O. Box 289 Public Utility Commission Wadsworth, TX 77483 William B. Travis Building P.O. Box 13326 Mr. Terry Parks, Chief Inspector 1701 North Congress Avenue Texas Department of Licensing Austin, TX 78701-3326 and Regulation Boiler Division Susan M. Jablonski P.O. Box 12157 Office of Permitting, Remediation Austin, TX 78711 and Registration Texas Commission on Environmental Quality MC-122 P.O. Box 13087 Austin, TX 78711-3087 March 2007

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 180 License No. NPF-76

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by STP Nuclear Operating Company* acting on behalf of itself and for Texas Genco, LP, the City Public Service Board of San Antonio (CPS), AEP Texas Central Company, and the City of Austin, Texas (COA) (the licensees), dated February 28, 2006, as supplemented by letters dated April 6 and May 31, 2007, and electronic mail dated July 18, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

STP Nuclear Operating Company is authorized to act for Texas Genco, LP, the City Public Service Board of San Antonio, AEP Texas Central Company, and the City of Austin, Texas, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

2. Accordingly, the license is amended by changes to the Technical Specifications and Paragraph 2.C.(2) of Facility Operating License No. NPF-76 as indicated in the attachment to this license amendment.

3. The license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA Mohan C. Thadani for T. Hiltz/

Thomas G. Hiltz, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-76 and the Technical Specifications Date of Issuance: July 20, 2007

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-499 SOUTH TEXAS PROJECT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 167 License No. NPF-80

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by STP Nuclear Operating Company* acting on behalf of itself and for NRG South Texas LP, the City Public Service Board of San Antonio (CPS), AEP Texas Central Company, and the City of Austin, Texas (COA) (the licensees), dated February 28, 2006, as supplemented by letters dated April 6 and May 31, 2007, and electronic mail dated July 18, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

STP Nuclear Operating Company is authorized to act for NRG South Texas LP, the City Public Service Board of San Antonio, AEP Texas Central Company, and the City of Austin, Texas, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

2. Accordingly, the license is amended by changes to the Technical Specifications and Paragraph 2.C.(2) of Facility Operating License No. NPF-80 as indicated in the attachment to this license amendment.

3. The license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA Mohan C. Thadani for T. Hiltz/

Thomas G. Hiltz, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-80 and the Technical Specifications Date of Issuance: July 20, 2007

ATTACHMENT TO LICENSE AMENDMENT NOS. 180 AND 167 FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 DOCKET NOS. 50-498 AND 50-499 Replace the following pages of the Facility Operating Licenses, Nos. NPF-76 and NPF-80, and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License No. NPF-76 REMOVE INSERT 4 4 Facility Operating License No. NPF-80 REMOVE INSERT 4 4 Technical Specifications REMOVE INSERT x x 3/4 8-10 3/4 8-10 3/4 8-11 3/4 8-11 3/4 8-12 3/4 8-12 3/4 8-13 3/4 8-13

-- 3/4 8-13a

-- 3/4 8-13b

-- 3/4 8-13c 6-12c 6-12c

SOUTH TEXAS LICENSE (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 180, and the Environmental Protection Plan contained in l Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Not Used (4) Initial Startup Test Program (Section 14, SER)*

Any changes to the Initial Test Program described in Section 14 of the Final Safety Analysis Report made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

(5) Safety Parameter Display System (Section 18, SSER No. 4)*

Before startup after the first refueling outage, HL&P[**] shall perform the necessary activities, provide acceptable responses, and implement all proposed corrective actions related to issues as described in Section 18.2 of SER Supplement 4.

(6) Supplementary Containment Purge Isolation (Section 11.5, SSER No. 4)

HL&P shall provide, prior to startup from the first refueling outage, control room indication of the normal and supplemental containment purge sample line isolation valve position.

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

- The original licensee authorized to possess, use and operate the facility was HL&P.

Consequently, historical references to certain obligations of HL&P remain in the license conditions.

Amendment No. 180

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 167, and the Environmental Protection Plan contained in l Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Not Used (4) Initial Startup Test Program (Section 14, SR)*

Any changes to the Initial Test Program described in Section 14 of the Final Safety Analysis Report made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

(5) License Transfer Texas Genco, LP shall provide decommissioning funding assurance, to be held in decommissioning trusts for the South Texas Project, Unit 2 (Unit 2) upon the direct transfer of the Unit 2 license to Texas Genco, LP, in an amount equal to or greater than the balance in the Unit 2 decommissioning trust immediately prior to the transfer. In addition, Texas Genco, LP shall ensure that all contractual arrangements referred to in the application for approval of the transfer of the Unit 2 license to Texas Genco, LP to obtain necessary decommissioning funds for Unit 2 through a non-bypassable charge are executed and will be maintained until the decommissioning trusts are fully funded, or shall ensure that other mechanisms that provide equivalent assurance of decommissioning funding in accordance with the Commissions regulations are maintained.

(6) License Transfer The master decommissioning trust agreement for Unit 2, at the time the direct transfer of Unit 2 to Texas Genco, LP is effected and thereafter, is subject to the following:

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 167

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 180 AND 167 TO FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 STP NUCLEAR OPERATING COMPANY, ET AL.

SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499

1.0 INTRODUCTION

By application dated February 28, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML060660218), as supplemented by letters dated April 6, and May 31, 2007 (ADAMS Accession Nos. ML071060176 and ML071590112, respectively), and electronic mail dated July 18, 2007 (ADAMS Accession No. ML072010270), STP Nuclear Operating Company (STPNOC, or the licensee), requested changes to the Technical Specifications (TSs) for South Texas Project (STP), Units 1 and 2.

The proposed changes modify TSs 3/4.8.2.1, DC [Direct Current] Sources - Operating, and 3/4.8.2.2, DC Sources - Shutdown, and add a new TS 3/4.8.2.3, Battery Parameters. The changes revise allowed outage times for battery chargers as well as battery charger testing criteria, and relocate a number of battery surveillance requirements (SRs) to a licensee-controlled Battery Monitoring and Maintenance Program. The changes are consistent with Standard TS Change Traveler TSTF-360, Revision 1, DC Electrical Rewrite.

The supplemental letters dated April 6 and May 31, 2007, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on September 12, 2006 (71 FR 53721).

2.0 REGULATORY EVALUATION

The following NRC requirements and guidance documents are applicable to the staffs review of the licensees amendment request:

C Title 10 of the Code of Federal Regulations (10 CFR), Appendix A of Part 50, General Design Criterion (GDC) 17, Electric power systems, requires, in part, that An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence,

redundancy, and testability to perform their safety functions assuming a single failure. Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

C GDC 18, Inspection and testing of electric power systems, requires, in part, that Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features C Section 50.63 of 10 CFR, Loss of all alternating current power, requires, in part, that Each light-water-cooled nuclear power plant licensed to operate must be able to withstand for a specified duration and recover from a station blackout as defined in §50.2 C Paragraph 50.65(a)(3) of 10 CFR, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, requires, in part, that Performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months Adjustments shall be made where necessary to ensure that the objective of preventing failures of structures, systems, and components through maintenance is appropriately balanced against the objective of minimizing unavailability of structures, systems, and components due to monitoring or preventive maintenance.

C Paragraph 50.36(c)(2)(ii) of 10 CFR, Technical specifications, requires that [a]

technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the [criteria set forth in 10 CFR 50.36(c)(2)(ii)(A)-(D)].

C Paragraph 50.36(c)(3) of 10 CFR, Technical specifications, requires that TSs include SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

C Regulatory Guide (RG) 1.129, Revision 2, Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plants, provides guidance for complying with GDCs 1, 17, and 18 with respect to the maintenance, testing, and replacement of vented lead-acid storage batteries in nuclear power plants.

C RG 1.32, Revision 3, Criteria For Power Systems For Nuclear Power Plants, provides guidance for complying with GDCs 17 and 18 with respect to the design, operation, and testing of safety-related electric power systems of all types of nuclear power plants.

3.0 TECHNICAL EVALUATION

3.1 Design Features of STP, Units 1 and 2, Class 1E 125 volt (V) Direct Current (DC) Power Systems The Class 1E 125 V DC battery system for each STP unit consists of four independent, physically separated buses, each energized by one of the two available battery chargers and one battery. Voltage on any separate bus varies between 105 and 137.5 V DC depending on the operating mode of battery charging equipment and system loads.

During normal operation, the 125 V DC loads are powered from the battery chargers with the batteries floating on the system. In case of a loss of normal power to the battery charger, the DC load is automatically powered from the station batteries. Batteries supply emergency power required for plant protection and control without interruption whenever the power from alternating current (AC) sources is interrupted.

Upon loss of power from the AC system to the battery chargers, the batteries automatically assume the load without switching. In the event all offsite AC sources are lost, AC power is supplied to the battery chargers by the onsite emergency diesel generators.

Each battery system also supplies power to its associated inverter system, which converts the DC power to AC power for the vital instrumentation and protection system. The ampere-hour capacity of each battery is sufficient to provide, for a minimum of two hours, the power required by emergency DC controls and the vital AC instrumentation and protection system.

The four 125 V DC batteries are each located in separate rooms in a seismic Category I building. Battery chargers and distribution panels associated with a given battery are located outside the battery room. The heating, ventilation, and air conditioning system supplies each battery room using fans energized from the engineered safety feature buses. The Class 1E DC power systems are designed to withstand the effects of tornadoes, fires, and the safe shutdown earthquake without loss of function.

Each DC electrical power subsystem has sufficient power output capacity for steady-state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger has sufficient capacity to restore the battery from its design minimum charge to its fully charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while supplying normal steady-state loads.

DC electrical power subsystems are required to be operable to ensure availability of the required power to shut down the reactor and maintain it in a safe condition after an Anticipated Operational Occurrence or a postulated Design-Basis Accident. Loss of any DC electrical power subsystem does not prevent the minimum safety function from being performed. An

operable DC electrical power subsystem requires the battery and one associated charger to be operating and connected to the associated DC bus.

The Class 1E battery system is designed to comply with requirements of RG 1.6, "Independence Between Redundant Standby (Onsite) Power Sources and Between Their Distribution Systems," and RG 1.32, Criteria for Safety-Related Electric Power Systems for Nuclear Power Plants.

The STP electrical distribution system is further described in the STP Updated Final Safety Analysis Report (UFSAR), Chapter 8, Section 8.3, Onsite Power Systems.

3.2 Evaluation of Proposed Changes In its letter dated February 28, 2006, the licensee proposed a license amendment to the TSs for STP, Units 1 and 2, using TSTF-360, Revision 1. The proposed changes would revise TSs 3/4.8.2.1, DC Sources - Operating, and 3/4.8.2.2, DC Sources - Shutdown.

Additionally, the proposed change would relocate a number of battery SRs to a licensee-controlled Battery Monitoring and Maintenance Program and create new TS 3/4.8.2.3, which incorporates surveillances for verification of battery parameters and actions for responding to parameters outside of established limits.

The staff reviewed and evaluated each of the proposed changes to the STP, Units 1 and 2, TSs as follows:

3.2.1 TS 3/4.8.2.1 (DC Sources - Operating) Changes 3.2.1.1 TS 3/4.8.2.1 Change (1)

Limiting Condition for Operation (LCO) 3.8.2.1 establishes the minimum requirements for operable DC electrical sources. The licensee proposes the following changes to LCO 3.8.2.1, Action b:

b. With no battery charger for a channel operable:

1. Restore battery terminal voltage to greater than or equal to the minimum established float voltage within two hours, and

2. Verify float current for the affected battery does not exceed two amps once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and

3. Restore one battery charger to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

If the battery terminal voltage cannot be restored in the allowed time, float current is excessive, or a battery charger is not restored to operability in the time allowed, the affected reactor unit is to be in at least hot standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in cold shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The licensee also proposes new Action c for the condition of one channel inoperable due to reasons other than an inoperable battery bank, or no operable battery chargers for a channel, as follows:

c. With one of the required channels inoperable for reasons other than (a) or (b) above, restore the channel to operable status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or be in at least hot standby within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in cold shutdown within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Evaluation of TS 3/4.8.2.1 Change (1)

The proposed change to LCO 3.8.2.1 addresses the condition where no battery chargers on a channel are operable. The licensee proposes to increase the battery charger Completion Time (CT) from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided that they are able to 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 , and are able to verify that battery float current for the affected battery does not exceed 2 amps once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The STP design includes standby chargers to support continued battery capability. If both battery chargers became inoperable, the STP operators are directed by procedure to take action to minimize battery discharge (i.e., load shed). Loads required for support of plant shutdown would be left on the bus. The licensee stated that these actions are covered by procedure for responding to annunciator lampbox indications of battery function parameters.

The battery charger, in addition to maintaining battery operability, provides DC control power to AC circuit breakers and thus supports the recovery of AC power following events such as a loss of offsite power or station blackout. Therefore, it is essential that each battery charger has the capability to be supplied by a back-up power source (e.g., Class 1E diesel generator). New LCO Action b.1 would provide assurance that a battery discharge is terminated, by requiring that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage (i.e., 128 V DC) in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time period provides an allowance for returning an inoperable charger to operable status or for reestablishing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage.

New LCO Action b.1 provides assurance that the battery will be restored to its fully charged condition from any discharge that might have occurred due to the battery charger being inoperable. At the end of the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , a terminal voltage of at least the minimum established float voltage provides an indication that the battery is on the exponential charging current portion of its recharging cycle.

New LCO Action b.2 would require that once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the battery float current be verified to be less than or equal to 2 amps. This provides an indication that, if the battery has been discharged as the result of an inoperable battery charger, it has now been fully charged. If, at the expiration of the 12-hour period, the battery float current is not less than or equal to 2 amps, there may be additional problems and the battery must be declared inoperable (see safety evaluation Section 3.2.2.3 below for a more detailed discussion on the 2-amp float current

value). This verification provides assurance that the battery has sufficient capacity to perform its safety function.

New LCO Action b.3 would extend the CT for the battery chargers to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided that the battery float voltage is restored to meet or exceed the minimum established float voltage by using an alternate method. Given that (1) the DC bus remains energized, (2) the battery discharge is terminated based on restoration of the battery terminal voltage (New LCO Action b.1), and (3) the battery is fully recharged based upon battery float current (New LCO Action b.2), the licensee has established a reasonable basis for extending the restoration time for an inoperable battery charger beyond the existing 2-hour limit to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (New LCO Action b.3). In addition, the NRC staffs approval of the extended CT for the STP battery chargers is based on the availability of a fully capable auxiliary battery charger (i.e., alternate method) that is capable of being powered by a diesel generator.

New LCO Action 3.8.2.1.c expands the actions in response to inoperability of a required channel for any reason other than an inoperable battery bank or battery chargers to a channel inoperable for any other reason. The staff finds that this new Action is clarifying in nature, and therefore, is acceptable.

Based on the above, the staff concludes that there is reasonable assurance that safe plant conditions will continue to be maintained; therefore, the proposed changes are acceptable.

3.2.1.2 TS 3/4.8.2.1 Change (2)

The licensee proposed deleting current SR 4.8.2.1.b and portions of SR 4.8.2.1.c from the TSs and relocating these surveillances to a licensee-controlled Battery Monitoring and Maintenance Program. The SRs would be the same, with some slight rewording, to read as follows:

(SR 4.8.2.1.b) At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110 V, or a battery overcharge with battery voltage above 135 V, verify:

- There is no visible corrosion at either cell-to-cell or terminal connections, or the connection resistance of these items is less than or equal to 150x10-6 ohm; and

- The average electrolyte temperature at six connected cells is above 65EF.

(SR 4.8.2.1.c) At least once per 18 months, verify:

- The cells, cell plates, and battery racks show no visual indication of physical damage or abnormal deterioration.

- The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material.

- The resistance of each cell-to-cell and terminal connection is less than or equal to 150x10-6 ohm.

Evaluation of TS 3/4.8.2.1 Change (2)

In accordance with SR 4.0.1, SRs shall be met for conditions specified for individual LCOs; this is because the SRs represent the minimum acceptable requirements for operability of the required equipment. However, for SR 4.8.2.1.b and SR 4.8.2.1.c, failure to meet the SR does not necessarily mean that the equipment is not capable of performing its safety function.

Furthermore, the corrective action is generally a routine or preventive maintenance-type activity.

Therefore, these activities are inappropriate for SRs and can be controlled in the administrative maintenance program for batteries.

Visual inspection for physical damage or deterioration (SR 4.8.2.1.b) that could potentially degrade battery performance is not required for the battery to perform its safety function; it reflects ongoing preventive maintenance activities. Maintenance activities prevent degradation that could affect battery operability. The verification of battery electrolyte temperature will be covered by new SR 4.8.2.3.e. The details of this new SR are provided below in Section 3.2.6 of this safety evaluation.

With regard to the resistance verifications of SR 4.8.2.1.c, the values are nominal values and represent limits at which some corrective action should be taken, but do not necessarily represent limits meaning that the operability of the battery is in question.

The licensees safety analyses do not assume a specific battery resistance value, but typically assume the batteries will supply adequate power. Therefore, the key issue is the overall battery resistance. Between the performance of SRs, the resistance of each battery cell connection varies independently from all the others. Some of these connection resistance values may be higher or lower than others, and the battery may still be able to perform its function and should not be considered inoperable. Overall resistance has a direct impact on operability and is adequately determined as acceptable through completion of the battery service and discharge tests. Therefore, these activities are more appropriately controlled under the maintenance program for batteries. Specifically, these surveillances will be addressed by the new Battery Monitoring and Maintenance Program (proposed new TS 6.8.3.p) which is described below in Section 3.2.4 of this safety evaluation.

Based on the above, the staff concludes that SR 4.8.2.1.b and the portions of SR 4.8.2.1.c described above do not meet the criteria of 10 CFR 50.36(c)(2)(ii) or (c)(3) for inclusion in the TSs and may be relocated to a licensee-controlled program. Proposed changes to the program will be subject to evaluation under 10 CFR 50.59, Changes, tests, and experiments, to dtermine whether the proposed changes require prior NRC review and approval, as discussed below in Section 3.2.4. The staff also concludes that there is reasonable assurance that safe plant conditions will continue to be maintained. Therefore, SR 4.8.2.1.b and the portions of SR 4.8.2.1.c described above may be relocated from the TSs to a licensee-controlled program.

3.2.1.3 TS 3/4.8.2.1 Change (3)

The licensee proposes to add an alternative criterion to current SR 4.8.2.1.c that would allow the battery charger operability to be verified at least once per 18 months by recharging its associated battery to the fully charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-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.

Evaluation of TS 3/4.8.2.1 Change (3)

SR 4.8.2.1.c specifies battery charger current requirements, and its purpose is to verify the design capacity of each battery charger. SR 4.8.2.1.c requires verification once per 18 months that each battery charger is capable of supplying 300 amps for greater than or equal to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

The licensee proposes adding an alternate acceptance criterion to SR 4.8.2.1.c to verify that each battery charger can recharge the battery to the fully charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-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 proposed test is an alternate method for verifying the design capacity of each battery charger. The proposed wording accurately reflects the battery charger design capacity as it is detailed in the STP UFSAR.

As described in the proposed revision to the TS Bases for SR 4.8.2.1.c, this test would occur following a service test. The level of loading required may not normally be available following the battery service test and may need to be supplemented with additional loads. The duration of this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. Based on this information, the staff finds there is reasonable assurance that safe plant conditions will continue to be maintained; therefore, the proposed change to add the alternate criterion to SR 4.8.2.1.c is acceptable.

3.2.1.4 TS 3/4.8.2.1 Change (4)

The licensee proposes the following:

Replace the specific gravity monitoring and its associated allowable value in Table 4.8-2 with float current monitoring (new Action 3.8.2.3.b and SR 4.8.2.3.a).

Evaluation of TS 3/4.8.2.1 Change (4)

The licensee proposes to replace the requirements to measure specific gravity with requirements to monitor float current (new Action 3.8.2.3.b and SR 4.8.2.3.a). Use of float current to determine the state-of-charge of the battery is consistent with RG 1.129, which endorses the Institute of Electrical and Electronics Engineers (IEEE) Standard 450-2002, IEEE recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications. Section 5.4 of IEEE Standard 450-2002 describes available methods for determining the state-of-charge of a vented lead-acid battery.

In Attachment 7 to its April 6, 2007, supplemental letter, the licensee provided a letter from its battery manufacturer (GNB Industrial Power), which concurred with the use of float current monitoring for the purpose of determining the state-of-charge throughout the life of the STP batteries. The licensee also provided a regulatory commitment to maintain a 5 percent design margin for each battery to ensure that the 2-amp float current value provides an indication that the battery is fully charged.

Furthermore, in its April 6, 2007, supplemental letter, the licensee stated that the accuracy and capability of the float current monitoring equipment will provide adequate assurance that the deletion of the requirement for specific gravity measurements will not have a significant impact on safety or the ability to accurately determine the operability of the STP batteries. Based on its review of the information provided by the licensee, the NRC staff has reasonable assurance that the equipment for monitoring battery float current will have the necessary accuracy and capability to measure electrical currents in the expected range.

The staff finds that the concurrence of the battery manufacturer coupled with the licensees statement concerning the accuracy and capability of the float monitoring equipment provides reasonable assurance that the deletion of the requirement to monitor specific gravity will not have a significant impact on safety or the ability to accurately determine the operability of the STP batteries; therefore, the proposed change is acceptable.

3.2.1.5 TS 3/4.8.2.1 Change (5):

TS Table 4.8-2, Battery Surveillance Requirements, specifies limits for electrolyte level and float charge. The licensee proposes to relocate the SRs for float current, pilot and connected cell float voltage, electrolyte level, and pilot cell electrolyte values to TS 3/4.8.2.3, and delete references to Table 4.8-2. The licensee proposes to relocate the following requirements to the licensee-controlled Battery Monitoring and Maintenance Program:

The limits for electrolyte level and float voltage for each designated pilot cell (Category A) and the limits for each connected cell (Category B);

The allowable value for connected cell electrolyte level;

The associated compensatory actions for battery cell electrolyte level, float voltage, and specific gravity not within limits; and

The allowable value for the minimum battery charging float voltage of each connected cell.

In addition, the licensee proposes to revise SRs 4.8.2.1.a and 4.8.2.1.c by replacing the specific voltage limits of 129 V and 125 V, respectively, with "greater than or equal to the minimum established float voltage.

Evaluation of TS 3/4.8.2.1 Change (5)

The Category A and B values of TS Table 4.8-2 represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery

life. Paragraph 50.36(c)(2)(i) of 10 CFR states, in part, [LCOs] are the lowest functional capability or performance levels of equipment required for safe operation of the facility. As such, the Category A and B limits for cell voltage and electrolyte level are not necessary to meet the 10 CFR 50.36 criteria for LCOs. The licensee proposed that these values and the LCO Actions associated with restoration be relocated to the Battery Monitoring and Maintenance Program, a licensee-controlled program under the control of 10 CFR 50.59, Changes, tests, and experiments. The licensee stated that the battery parameters will be controlled at an acceptable level, and necessary remedial actions will be implemented in accordance with the plant corrective action program. Furthermore, the battery and its preventive maintenance and monitoring program are under the regulatory requirements of 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants. This proposed relocation will continue to assure the battery is maintained at current levels of performance.

The licensee also proposes to relocate the allowable value for each connected cell of TS Table 4.8-2 for the battery electrolyte level to the licensee-controlled Battery Monitoring and Maintenance Program. However, proposed new LCO 3.8.2.3 Actions c and d will require the electrolyte level (any battery cell) and temperature (pilot cell only) to be greater than or equal to minimum established design limits. Depending on the available excess capacity of the associated battery, the minimum temperature necessary to support operability of the battery can vary. Relocation to a licensee-controlled program will provide the licensee with flexibility to monitor and control this limit at values directly related to the batterys ability to perform its assumed function.

The licensee proposes revising SRs 4.8.2.1.a and 4.8.2.1.c by replacing the specific voltage limit with "greater than or equal to the minimum established float voltage." The voltage requirements are based on the battery charger voltage level after a response to a loss of AC power. Additionally, the battery manufacturer establishes this voltage limit to provide the optimum charge on the battery and to maintain the battery plates in a condition that supports maintaining the battery grid life. Maintaining the battery plates in a condition that supports maintaining the battery grid life provides assurance that the battery will be capable of providing its designed safety function.

The minimum float voltage allowed per cell is 2.17 V DC which results in a minimum battery float voltage of 128 V DC for a 59-cell string. The licensee stated that the minimum float voltage per cell will be included in the TS Bases as background information for 3/4.8.2, DC Sources.

The licensees proposed changes ensure that the battery parameters (maintenance, testing, and monitoring) are addressed in accordance with the Battery Monitoring and Maintenance Program, as specified in proposed new TS 6.8.3.p. The staff finds there is reasonable assurance that safe plant conditions will continue to be maintained; therefore, the proposed changes are acceptable.

3.2.1.6 TS 3/4.8.2.1 Change (6)

The licensee proposes to eliminate the once per 60 month restriction of SR 4.8.2.1.e on replacing the battery service test with the modified performance discharge test.

Evaluation of TS 3/4.8.2.1 Change (6)

The licensee proposes removing the once per 60 month restriction of SR 4.8.2.1.e. Since the modified performance discharge test envelopes the duty cycle of the service test, the once per 60 month restriction is no longer necessary. Therefore, the staff finds it acceptable to remove the wording once per 60 month from SR 4.8.2.1.e.

The licensee also proposes relocating the requirement of SR 4.8.2.1.e to SR 4.8.2.3.f. The relocation of the requirement to SR 4.8.2.3.f is administrative and does not change how the tests are actually performed; therefore, the staff finds the change acceptable.

3.2.2 TS 3/4.8.2.2 (DC Sources - Shutdown) Changes 3.2.2.1 TS 3/4.8.2.2 Change (1)

The licensee proposes adding the following Action b to LCO 3.8.2.2 to be consistent with the proposed changes for LCO 3.8.2.1 and to provide additional actions in case the battery terminal voltage cannot be restored within the allowed time, or a battery charger is not restored to operable status within the allowed time:

b. With no battery chargers for a required channel operable:

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

2. Verify float current for the affected battery does not exceed 2 amps once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and

3. Restore one battery charger to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

If the battery terminal voltage cannot be restored within the allowed time, float current is excessive, or a battery charger is not restored to operabilty in the time allowed:

Initiate action to suspend operation with a potential for draining the reactor vessel, and

Suspend all operations involving core alterations, operations involving positive reactivity additions that could result in loss of required shutdown margin or required boron concentration, or movement of irradiated fuel, and

Initiate corrective action to restore the required DC electrical power subsystems to operable status as soon as possible.

Evaluation of TS 3/4.8.2.2 Change (1)

The proposed change to LCO 3.8.2.2 addresses the condition where no battery chargers on a channel are operable. The licensee proposes increasing the battery charger CT from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months provided that they are able to 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 , and are able to verify that battery float current for the affected battery does not exceed 2 amps once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The basis for this change is the same as that provided for the proposed change to LCO 3.8.2.1 above.

Therefore, given that (1) the DC bus remains energized, (2) the battery discharge is terminated based on restoration of the battery terminal voltage (New LCO 3.8.2.2 Action b.1), and (3) the battery is fully recharged based upon battery float current (New LCO 3.8.2.2 Action b.2), the licensee has established a reasonable basis for extending the restoration time for an inoperable battery charger beyond the existing 2-hour limit to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (New LCO 3.8.2.2 Action b.3). In addition, the NRC staffs approval of the extended CT for the STP battery chargers is based on the availability of a fully capable auxiliary battery charger (i.e., alternate method) that is capable of being powered by a diesel generator.

The licensee also proposes rewording the existing Action for LCO 3.8.2.2 and designating it as new Action a. The proposed change is administrative in nature and does not change any substantive requirement, and therefore, is acceptable.

3.2.2.2 TS 3/4.8.2.2 Change (2)

The licensee proposes to add requirements to SR 4.8.2.2 to be consistent with SR 4.8.2.1, and to relocate existing SR 4.8.2.1.d to new SR 4.8.2.2.c, because the requirement is applicable under shutdown conditions.

Evaluation of TS 3/4.8.2.2 Change (2)

The licensee proposed adding requirements to SR 4.8.2.2 for consistency with new SR 4.8.2.1.

The requirements for monitoring specific gravity while in Modes 5 and 6 are the same as those in Modes 1, 2, 3, and 4. The justification for replacing specific gravity monitoring with float current monitoring is described in the staffs evaluation of SR 4.8.2.1 Change (3) above. The staff finds the proposed changes to SR 4.8.2.2 reasonable and consistent with new SR 4.8.2.1; therefore, the proposed changes are acceptable.

The licensee proposed relocating SR 4.8.2.1.d to SR 4.8.2.2.c since the requirement applies to shutdown conditions. Relocation of the requirements for the battery service test is consistent with the actual modes of operation in which it is performed. Since the relocation does not change how the test is actually performed and the test is more appropriately located in the TS for shutdown conditions, the NRC staff finds the proposed change acceptable.

3.2.3 (New) TS 3/4.8.2.3 (Battery Parameters) 3.2.3.1 TS 3/4.8.2.3 Change (1)

The licensee proposes adding a new LCO 3.8.2.3 to address battery parameters as follows:

3.8.2.3 Parameters for the Class 1E batteries shall be within the specified limits.

APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE.

ACTION:

a. If a battery has one or more cells with float voltage < 2.07 V:

1. Perform surveillance requirement 4.8.2.1.a within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , AND

2. Perform surveillance requirement 4.8.2.3.a within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , AND

3. Restore float voltage of the affected cell(s) to $ 2.07 volts within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .