Text

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8)
	ML102371292
Person / Time
Site:	Kewaunee
Issue date:	08/18/2010
From:	; Dominion Energy Kewaunee
To:	; Office of Nuclear Reactor Regulation
References
	10-457, TAC ME2139
	Download: ML102371292 (138)
	v • d • e

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 1 of 138 ITS NRC Questions Id 1731 NRC Question GMW-006 Number Category Technical ITS Section 3.8 ITS Number 3.8.6 DOC Various Number JFD Number JFD Bases Number Page Various Number(s)

NRC Reviewer Rob Elliott Supervisor Technical M. McConnell Branch POC Conf Call N

Requested NRC There have been several informal phone conversations between the NRC Question and the licensee regarding proposed industry changes related to the D C Sources-Operating, ITS 3.8.4, D C Sources-Shutdown, ITS 3.8.5, and the Battery Monitoring and Maintenance Program, ITS 5.5.16. Kewaunees original ITS submittal was based on NUREG-1430 and industry guidance at the time of the submittal. Since the submittal, industry has proposed modified guidance related to the Technical Specifications and the Program. Kewaunee has expressed a desire to include these changes to ITS 3.8.4, 3.8.5, 3.8.6, and ITS 5.5.16 as applicable to KPS. Please provide the reviewer with the proposed change(s) to the submittal including the affected ITS Bases and all supporting documentation for proposed change (s).

Attach File 1

Attach File 2

Issue Date 2/19/2010 Added By Gerald Waig Date Modified Modified By Date Added 2/19/2010 10:44 AM Notification NRC/LICENSEE Supervision Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 1 of 138 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1731 06/03/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 2 of 138 Licensee Response/NRC Response/NRC Question Closure Id 2291 NRC Question GMW-006 Number Select Licensee Response Application

Response

2/25/2010 10:30 AM Date/Time Closure Statement Response Kewaunee Power Station (KPS) included in the ITS submittal the changes Statement identified in the most current revision of proposed TSTF-500. This is identified in Enclosure 3, page 4 of 4, of the ITS submittal letter. Since the ITS submittal, the NRC and industry have made changes to proposed TSTF-500. The NRC reviewer, during the informal phone conversations, requested that KPS review these changes. KPS has reviewed the changes and agrees to make the requested changes to be consistent with the NRC and industry agreements concerning TSTF-500. A draft markup regarding this change is attached. This change will be reflected in the supplement to this section of the ITS conversion amendment.

Question Closure Date Attachment GMW-006 Markup (2).pdf (1MB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Robert Hanley Jerry Jones Bryan Kays Gerald Waig Added By David Mielke Date Added 2/25/2010 10:35 AM Modified By Date Modified Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 2 of 138 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2291 06/03/2010

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 3 of 138 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES SURVEILLANCE SR 3.8.4.1 for the batteries 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 required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive times the adequate current to optimally charge the battery. The voltage number of requirements are based on the nominal design voltage of the battery and connected cells are consistent with the minimum float voltage established by the battery 10 manufacturer ([2.20] Vpc or [127.6] V at the battery terminals). This for a 59 2 2.22 voltage maintains the battery plates in a condition that supports cell battery 130.98 maintaining the grid life (expected to be approximately 20 years). The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 8). conservative when compared 6 Each of the battery chargers has been sized to recharge its associated partially discharged battery within 24 SR 3.8.4.2 hours, while carrying its normal load.

required 7

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, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensure that these requirements can be satisfied. s 150 This SR provides two options. One option requires that each battery charger be capable of supplying [400] amps at the minimum established 2 float voltage for [8] hours. The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least [2] hours. 2 The other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the combined largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the WOG STS B 3.8.4-8 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 3 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 4 of 138 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) battery service test and will need to be supplemented with additional loads. The duration for 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. The battery is recharged when the measured charging current is

The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these [18 month] 2 intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

SR 3.8.4.3 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 power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4. 6 The Surveillance Frequency of [18 months] is consistent with the 7 2 8 recommendations of Regulatory Guide 1.32 (Ref. 9) and Regulatory Guide 1.129 (Ref. 10), which state that the battery service test should be 7 performed during refueling operations, or at some other outage, with intervals between tests not to exceed [18 months]. 2 This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

The reason for Note 2 is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial WOG STS B 3.8.4-9 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 4 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 5 of 138 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

6 Safety

2. Regulatory Guide 1.6, March 10, 1971.

3. IEEE-308-[1978].

U 3 4. FSAR, Chapter [8].

2

5. FSAR, Chapter [6].

14 4

6. FSAR, Chapter [15]. 2 U

5 7. Regulatory Guide 1.93, December 1974.

1987 6

8. IEEE-450-[1995]. 2 6 7

9. Regulatory Guide 1.32, February 1977.

7 8

10. Regulatory Guide 1.129, December 1974.

WOG STS B 3.8.4-10 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 5 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 6 of 138 Battery Parameters CTS 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters

REVIEWER'S NOTE-------------------------------------------------

Licensees must implement a program, as specified in Specification 5.5.17, to monitor battery parameters that is based on the recommendations of IEEE Standard 450-1995, "IEEE 1 Recommended Practice For Maintenance, Testing, And Replacement Of Vented Lead-Acid Batteries For Stationary Applications."

DOC A02, LCO 3.8.6 Battery parameters for Train A and Train B batteries shall be within limits.

3.7.a.6 electrical power subsystem 3.7.a APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE.

ACTIONS

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

DOC L01 Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A. One [or two] batter[y][ies A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months on one train] with one or 2 more battery cells float AND voltage < [2.07] V.

A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND A.3 Restore affected cell 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 2

voltage

DOC L01 B. One [or two] batter[y][ies B.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2

on one train] with float current > [2] amps. AND B.2 Restore battery float current [12] hours 2 to

WOG STS 3.8.6-1 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 6 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 7 of 138 Battery Parameters CTS 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 F. Required Action and F.1 Declare associated battery Immediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met.

OR One [or two] batter[y][ies 2 on one train] with one or more battery cells float OR voltage < [2.07] V and 2 4

float current > [2] amps. SR 3.8.6.6 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M02 SR 3.8.6.1 -------------------------------NOTE------------------------------

Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.

2 Verify each battery float current is 7 days float 4.6.b.1 SR 3.8.6.2 Verify each battery pilot cell voltage is 31 days 2 4.6.b.2 SR 3.8.6.3 Verify each battery connected cell electrolyte level is 31 days greater than or equal to minimum established design limits.

4.6.b.1 SR 3.8.6.4 Verify each battery pilot cell temperature is greater 31 days than or equal to minimum established design limits.

WOG STS 3.8.6-3 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 7 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 8 of 138 Battery Parameters CTS 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.6.b.1 SR 3.8.6.5 Verify each battery connected cell voltage is 92 days 2

[2.07] V.

float 4.6.b.4 SR 3.8.6.6 -------------------------------NOTE------------------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines 5 the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is 60 months 2 manufacturer's rating when subjected to a performance discharge test or a modified AND performance discharge test.

12 months when battery shows degradation, or has reached 2

expected life with

of manufacturer's rating AND 24 months when battery has

2 the expected life with capacity

manufacturer's rating WOG STS 3.8.6-4 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 8 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 9 of 138 Battery Parameters B 3.8.6 BASES ACTIONS (continued)

A discharged battery with float voltage (the charger setpoint) across its terminals indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus there is good assurance of fully recharging the battery 1

within [12] 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 [2.07] V and float voltage is found to be satisfactory, this 1 is not indication of a substantially discharged battery and [12] 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.

y C.1, C.2, and C.3 With one or more batteries in one train with one or more cells electrolyte 8 level above the top of the plates, but below the minimum established design limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of electrolyte level not met.

Within 31 days the minimum established design limits for electrolyte level must be re-established.

With electrolyte level below the top of the plates there is a potential for dryout and plate degradation. Required Actions C.1 and C.2 address this " 7 potential (as well as provisions in Specification 5.5.17, Battery Monitoring 2 15 and Maintenance Program). They are modified by a Note that indicates they are only applicable if electrolyte level is below the top of the plates.

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 the top of the requirement plates. The Required Action C.2 requirement to verify that there is no 2 7 leakage by visual inspection and the Specification 5.5.17.b item to initiate Appendix action to equalize and test in accordance with manufacturer's 15 recommendation are taken from Annex D of IEEE Standard 450-1995.

They are performed following the restoration of the electrolyte level to 1987 above the top of the plates. Based on the results of the manufacturer's recommended testing the batter[y][ies] may have to be declared 8 inoperable and the affected cell[s] replaced.

(s)

WOG STS B 3.8.6-4 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 9 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 10 of 138 Battery Parameters B 3.8.6 BASES ACTIONS (continued) y D.1 With one or more batteries in one train with pilot cell temperature less 8 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 two With one or more batteries in redundant trains with battery parameters 8 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 8 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 .

subsystem F.1 y or SR 3.8.6.6 With one or more batteries with any battery parameter outside the not met, allowances of the Required Actions for Condition A, B, C, D, or E, 8 sufficient capacity to supply the maximum expected load requirement is not assured and the corresponding battery must be declared inoperable. y Additionally, discovering one or more batteries in one train with one or more battery cells float voltage less than [2.07] V and float current greater 1 than [2] amps indicates that the battery capacity may not be sufficient to 1 perform the intended functions. The battery must therefore be declared inoperable immediately.

WOG STS B 3.8.6-5 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 10 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 11 of 138 Battery Parameters B 3.8.6 BASES 1

REFERENCES 1. IEEE-450-[1995].

-1987 U 4

2. FSAR, Chapter 8.

3. FSAR, Chapter [6].

U 14 1 3

4. FSAR, Chapter [15].

4 4

5. IEEE-485-[1983], June 1983.

WOG STS B 3.8.6-9 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 11 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 12 of 138 CTS Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 Containment Leakage Rate Testing Program (continued) 6 14

1. Containment leakage rate acceptance criterion is 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and C tests and [< 0.75 La for Option A Type A tests] [ 0.75 La for Option B Type A tests].

2. Air lock testing acceptance criteria are:

a) Overall air lock leakage rate is [0.05 La] when tested at Pa. 19 b) For each door, leakage rate is [0.01 La] when pressurized to

[ 10 psig].

e. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

f. Nothing in these Technical Specifications shall be construed to modify the testing Frequencies required by 10 CFR 50, Appendix J.

DOC 5.5.17 15 Battery Monitoring and Maintenance Program 6 M10 This Program provides for battery restoration and maintenance, based on [the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for 24 Stationary Applications," or of the battery manufacturer] including the following:

which includes

a. Actions to restore battery cells with float voltage < [2.13] V, and 1 INSERT 8A 24

b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit. top of the plates; DOC 25 26 INSERT 8 M11

c. Actions to verify that the remaining cells are > 2.07 V when a pilot cell or cells have been found to be < [2.13] V. 1

d. Limits on average electrolyte temperature, battery connection resistance, and battery terminal voltage; and, 24

e. A requirement to obtain specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations.

WOG STS 5.5-18 Rev. 3.1, 12/01/05 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 12 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 13 of 138 INSERT 8A This Program provides controls for battery restoration and maintenance. The program shall be in accordance with IEEE Standard (Std) 450-2002, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," as endorsed by Regulatory Guide 1.129, Revision 2 (RG), with RG exceptions and program provisions as identified below:

a. The program allows the following RG 1.129, Revision 2 exceptions:

1. Battery temperature correction may be performed before or after conducting discharge tests.

2. RG 1.129, Regulatory Position 1, Subsection 2, "References," is not applicable to this program.

3. In lieu of RG 1.129, Regulatory Position 2, Subsection 5.2, "Inspections," the following shall be used: "Where reference is made to the pilot cell, pilot cell selection shall be based on the lowest voltage cell in the battery.

4 In Regulatory Guide 1.129, Regulatory Position 3, Subsection 5.4.1, "State of Charge Indicator," the following statements in paragraph (d) may be omitted: "When it has been recorded that the charging current has stabilized at the charging voltage for three consecutive hourly measurements, the battery is near full charge. These measurements shall be made after the initially high charging current decreases sharply and the battery voltage rises to approach the charger output voltage."

5. In lieu of RG 1.129, Regulatory Position 7, Subsection 7.6, "Restoration", the following may be used: "Following the test, record the float voltage of each cell of the string."

b. The program shall include the following provisions:

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

2. Actions to determine whether the float voltage of the remaining battery cells is 2.13 V when the float voltage of a battery cell has been found to be < 2.13 V;

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

4. Limits on average electrolyte temperature, battery connection resistance, and battery terminal voltage; and

5. A requirement to obtain specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations.

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 13 of 138

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 14 of 138 Licensee Response/NRC Response/NRC Question Closure Id 2901 NRC Question GMW-006 Number Select Application NRC Question Closure

Response

Date/Time Closure Statement Additional information, if required, will be requested via a separate Kewaunee ITS Conversion Database question.

Response

Statement Question Closure 5/10/2010 Date Attachment 1 Attachment 2 Notification NRC/LICENSEE Supervision Added By Gerald Waig Date Added 5/10/2010 3:56 PM Modified By Date Modified Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 14 of 138 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2901 06/03/2010

Kewaunee ITS Conversion Database Page 1 of 1 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 15 of 138 ITS NRC Questions Id 1931 NRC Question GMW-007 Number Category Technical ITS Section 3.8 ITS Number DOC Various Number JFD Number JFD Bases Number Page Various Number(s)

NRC Reviewer Rob Elliott Supervisor Technical M. McConnell Branch POC Conf Call N

Requested NRC In response to a request for additional information (GMW-006) dated Question 2/19/2010, Kewaunee Power Station (KPS) provided a marked-up copy of Standard Technical Specification (STS) Section 3.8, DC Sources, the affected STS 3.8 Bases, and STS Section 5.5, Battery Monitoring and Maintenance Program, proposing changes to the original submittal. Please provide the reviewer with documentation to support the requested changes, specifically: a discussion of the proposed change (DOC) and, in all cases where a deviation from STS is proposed, a justification for the deviation (JFD). This information is needed by staff to evaluate the proposed changes and deviations.

Attach File 1 Attach File 2 Issue Date 3/18/2010 Added By Gerald Waig Date Modified Modified By Date Added 3/18/2010 3:46 PM Notification NRC/LICENSEE Supervision Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 15 of 138 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=1931 07/08/2010

Kewaunee ITS Conversion Database Page 1 of 4 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 16 of 138 Licensee Response/NRC Response/NRC Question Closure Id 2751 NRC Question GMW-007 Number Select Licensee Response Application

Response

4/12/2010 1:00 PM Date/Time Closure Statement

Response

Statement Changes to ISTS 3.8.4, "DC-Sources - Operating," ISTS 3.8.5, "DC Sources -

Shutdown," ISTS 3.8.6, "Battery Parameters," and ISTS 5.5.17, "Battery Monitoring and Maintenance Program," were added to NUREG-1431, Rev. 2 as part of TSTF-360, Rev. 1, which was approved by the NRC on December 18, 2000 (documented in a letter from W. D. Beckner, NRC to A. R. Pietrangelo, NEI). In a subsequent NRC letter to the Technical Specification Task Force (TSTF), dated April 11, 2006, the NRC expressed concerns about certain aspects of the changes approved in TSTF-360, Rev.1. Since that time, the NRC and TSTF have had ongoing discussions concerning this program, and a new TSTF, proposed TSTF-500, Rev.

2, has been generated to resolve the NRC concerns. In the proposed TSTF, Section 4.7.1, there is a list of verifications required to adopt TSTF-500, Rev. 2. In addition, in Section 4.7.2 of the proposed TSTF, there is a list of Commitments required to adopt the TSTF. Listed below is each Verification and Commitment, and the KPS response to the Verifications and Commitments.

Section 4.7.1 Verifications

1. In an attachment to the LAR, the licensee must provide letters from the manufactures of the batteries used at the plant verifying the acceptability of using float current monitoring instead of specific gravity monitoring as a reliable and accurate indication of the state-of-charge of the battery and that this will hold true over the life of the battery.

KPS Response: KPS has requested a letter from the manufacturer of the batteries specified in ITS 3.8.4 and will be provided in a future response.

2. The licensee must verify that battery room temperature is routinely monitored such that a room temperature excursion could reasonably expect to be detected and corrected prior to the average battery electrolyte temperature dropping below the minimum electrolyte temperature.

KPS Response: The temperature of the battery rooms are checked twice daily (during day shift and night shift) and logged in the Equipment Operator logs.

The acceptance band for the temperature is 67ºF to 83ºF. If the temperature is outside this band, the procedure directs entry into the abnormal ventilation procedure, which identifies OPERABILITY limits for the batteries. The minimum electrolyte temperature is 67ºF. Thus, since the battery electrolyte temperature is not reasonably expected to decrease faster than the ambient room temperature, taking action when the room temperature is less than 67ºF should ensure the actual electrolyte temperature does not decrease below Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 16 of 138 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2751 07/08/2010

Kewaunee ITS Conversion Database Page 2 of 4 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 17 of 138 67ºF.

3. The licensee must verify that the equipment that will be used to monitor float current under SR 3.8.6.1 will have the necessary accuracy and capability to measure electrical currents in the expected range.

KPS Response: KPS has procured a Fluke handheld unit with an accuracy of

+ 0.2 amps in the float current range (< 10 amps). KPS has performed field testing to verify that the meter can be used to monitor float current IAW SR 3.8.6.1 to assure that the meter has the necessary accuracy and capability to measure electrical currents in the expected range. The meter has been entered into the station maintenance and test equipment program to assure that accuracy and capability is maintained.

4. If the licensee requests a Completion Time greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for TS 3.8.4, Required Action A.3, and / or TS 3.8.5, Required Action A.3, the licensee must verify the availability of a spare battery charger that is appropriately sized. As stated in a Reviewer's Note in the Bases, a licensee wishing to adopt a longer Completion Time must also demonstrate that the Completion Time is appropriate for the plant in accordance with the guidance in Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking:

Technical Specifications," and Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis." Alternatively, the 7 day Completion Time can be justified by an acceptable alternate method, such as a regulatory commitment that an means to charge the batteries will be available that is capable of being supplied power from a power source that is independent of the offsite power supply.

KPS Response: KPS has not requested a Completion Time greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for the above Required Actions.

5. If the licensee requests a Completion Time greater than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for TS 3.8.4, Required Action B.1 or C.1, the licensee must demonstrate that the Completion Time is appropriate for the plant in accordance with the guidance in Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," and Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis."

KPS Response: KPS has not requested a Completion Time greater than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the above Required Actions.

6. The cell resistance limits in existing SR 3.8.4.5 are relocated to the Battery Monitoring and Maintenance Program. Licensees must provide a brief description of the basis for the cell connection resistance limit based on the vendor specification of inter-cell resistance, voltage drop at the connection, or overall battery resistance.

KPS Response: Calculation C11723, Revision 1, Addendum B - "Inter-Tier and Inter-Rack Resistance Clarification" specifies " the inter-tier and inter-rack resistance of the batteries is to be no more than 90 µ§ for BRA-101 and 90

µ§ for BRB-101 per connection. There are 2 inter-tier connections and 1 inter-rack connection used for each battery resulting in a total inter-tier / inter-Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 17 of 138 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2751 07/08/2010

Kewaunee ITS Conversion Database Page 3 of 4 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 18 of 138 rack resistance of 270 µ§ per battery. This value will be used for each battery in the ETAP model." Calculation C11723, Revision 1 supplies the basis for the specification of inter-cell resistance for overall battery resistance. The battery connections were also base lined during the initial installation (2008).

7. In order to delete the SR 3.8.4.7 (now SR 3.8.4.3) Note "once per 60 months" restriction on performing the modified performance discharge test instead of the service test, the licensee must confirm that the modified performance discharge test completely encompasses the load profile of the battery service test and that it adequately confirms the intent of the service test to verify the battery capacity to supply the design basis load profile.

KPS Response: Calculation Number: C11723, "125VDC Battery BRA-101 and BRB -101 Sizing, Voltage Drop, Short Circuit and Charger Sizing," defines the station battery design. Table 6.2.1 on page 25 of 333 contains the battery sizing summary. This calculation bounds the battery performance. KPS replaced the batteries in 2008 to the design specifications of C11723. These batteries satisfy the requirements of IEEE STD 450-2002 , which specifies that the modified performance discharge test completely encompass the load profile of the battery service test.

Section 4.7.2 Commitments

1. The [2] amp float current value is an indication that the battery is [95] percent charged. The licensee must provide a regulatory commitment to maintain a

[5] percent design margin for the batteries.

KPS Response: ITS SR 3.8.6.1 requires each battery float current to be < 2 amps and the 2 amp value is an indication that the battery is 95 percent charged. KPS will provide a commitment to maintain a 5% design margin for the batteries required by ITS 3.8.4 to ensure the 2 amp float current limit is conservative. The commitment will be provided in the supplement of the ITS conversion amendment.

2. The licensee-controlled program, required and described in TS Section 5.5, "Programs and Manuals," and titled the "Battery Monitoring and Maintenance Program," will require verification of the selection of the pilot cell or cells when performing SR 3.8.6.5.

KPS Response: KPS will provide a commitment that the pilot cell selection criteria will be consistent with ITS 5.5.15.a.3. This section requires the battery pilot cell selection to be based on the lowest cell in the battery. Therefore, after each performance of ITS SR 3.8.6.5, the pilot cell will be evaluated based on the results of the SR. The commitment will be provided in the supplement of the ITS conversion amendment.

In addition, a new draft markup of the changes related to TSTF-500 is being provided. These changes supersede the markup provided in the KPS response to GMW-006. The only difference in the two markups is that the one attached to this response provides a revised JFD for the change to the Battery Monitoring and Maintenance Program. A revised DOC (which justifies changes from the TS requirements to the new ITS requirements) is not necessary since the change is a More Restrictive change and all issues related to TSTF-500 are discussed above.

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 18 of 138 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2751 07/08/2010

Kewaunee ITS Conversion Database Page 4 of 4 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 19 of 138 This change will be reflected in the supplement to these sections of the ITS conversion amendment.

Question Closure Date Attachment GMW-007 Markup rev 3.pdf (1MB) 1 Attachment 2

Notification NRC/LICENSEE Supervision Jerry Jones Bryan Kays Gerald Waig Added By Robert Hanley Date Added 4/12/2010 1:08 PM Modified By Date Modified Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 19 of 138 http://www.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=2751 07/08/2010

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 20 of 138 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES SURVEILLANCE SR 3.8.4.1 for the batteries 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 required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive times the adequate current to optimally charge the battery. The voltage number of requirements are based on the nominal design voltage of the battery and connected cells are consistent with the minimum float voltage established by the battery 10 manufacturer ([2.20] Vpc or [127.6] V at the battery terminals). This for a 59 2 2.22 voltage maintains the battery plates in a condition that supports cell battery 130.98 maintaining the grid life (expected to be approximately 20 years). The 7 day Frequency is consistent with manufacturer recommendations and IEEE-450 (Ref. 8). conservative when compared 6 Each of the battery chargers has been sized to recharge its associated partially discharged battery within 24 SR 3.8.4.2 hours, while carrying its normal load.

required 7

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, irrespective of the status of the unit during these demand occurrences.

The minimum required amperes and duration ensure that these requirements can be satisfied. s 150 This SR provides two options. One option requires that each battery charger be capable of supplying [400] amps at the minimum established 2 float voltage for [8] hours. The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least [2] hours. 2 The other option requires that each battery charger be capable of recharging the battery after a service test coincident with supplying the combined largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur). This level of loading may not normally be available following the WOG STS B 3.8.4-8 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 20 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 21 of 138 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) battery service test and will need to be supplemented with additional loads. The duration for 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. The battery is recharged when the measured charging current is

The Surveillance Frequency is acceptable, given the unit conditions required to perform the test and the other administrative controls existing to ensure adequate charger performance during these [18 month] 2 intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

SR 3.8.4.3 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 power system. The discharge rate and test length should correspond to the design duty cycle requirements as specified in Reference 4. 6 The Surveillance Frequency of [18 months] is consistent with the 7 2 8 recommendations of Regulatory Guide 1.32 (Ref. 9) and Regulatory Guide 1.129 (Ref. 10), which state that the battery service test should be 7 performed during refueling operations, or at some other outage, with intervals between tests not to exceed [18 months]. 2 This SR is modified by two Notes. Note 1 allows the performance of a modified performance discharge test in lieu of a service test.

The reason for Note 2 is that performing the Surveillance would perturb the electrical distribution system and challenge safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial WOG STS B 3.8.4-9 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 21 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 22 of 138 All changes are 1 DC Sources - Operating unless otherwise noted B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

6 Safety

2. Regulatory Guide 1.6, March 10, 1971.

3. IEEE-308-[1978].

U 3 4. FSAR, Chapter [8].

2

5. FSAR, Chapter [6].

14 4

6. FSAR, Chapter [15]. 2 U

5 7. Regulatory Guide 1.93, December 1974.

1987 6

8. IEEE-450-[1995]. 2 6 7

9. Regulatory Guide 1.32, February 1977.

7 8

10. Regulatory Guide 1.129, December 1974.

WOG STS B 3.8.4-10 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 22 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 23 of 138 Battery Parameters CTS 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters

REVIEWER'S NOTE-------------------------------------------------

Licensees must implement a program, as specified in Specification 5.5.17, to monitor battery parameters that is based on the recommendations of IEEE Standard 450-1995, "IEEE 1 Recommended Practice For Maintenance, Testing, And Replacement Of Vented Lead-Acid Batteries For Stationary Applications."

DOC A02, LCO 3.8.6 Battery parameters for Train A and Train B batteries shall be within limits.

3.7.a.6 electrical power subsystem 3.7.a APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE.

ACTIONS

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

DOC L01 Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 A. One [or two] batter[y][ies A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months on one train] with one or 2 more battery cells float AND voltage < [2.07] V.

A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND A.3 Restore affected cell 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 2

voltage

DOC L01 B. One [or two] batter[y][ies B.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2

on one train] with float current > [2] amps. AND B.2 Restore battery float current [12] hours 2 to

WOG STS 3.8.6-1 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 23 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 24 of 138 Battery Parameters CTS 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME DOC L01 F. Required Action and F.1 Declare associated battery Immediately associated Completion inoperable.

Time of Condition A, B, C, D, or E not met.

OR One [or two] batter[y][ies 2 on one train] with one or more battery cells float OR voltage < [2.07] V and 2 4

float current > [2] amps. SR 3.8.6.6 not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY DOC M02 SR 3.8.6.1 -------------------------------NOTE------------------------------

Not required to be met when battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1.

2 Verify each battery float current is 7 days float 4.6.b.1 SR 3.8.6.2 Verify each battery pilot cell voltage is 31 days 2 4.6.b.2 SR 3.8.6.3 Verify each battery connected cell electrolyte level is 31 days greater than or equal to minimum established design limits.

4.6.b.1 SR 3.8.6.4 Verify each battery pilot cell temperature is greater 31 days than or equal to minimum established design limits.

WOG STS 3.8.6-3 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 24 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 25 of 138 Battery Parameters CTS 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.6.b.1 SR 3.8.6.5 Verify each battery connected cell voltage is 92 days 2

[2.07] V.

float 4.6.b.4 SR 3.8.6.6 -------------------------------NOTE------------------------------

This Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines 5 the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is 60 months 2 manufacturer's rating when subjected to a performance discharge test or a modified AND performance discharge test.

12 months when battery shows degradation, or has reached 2

expected life with

of manufacturer's rating AND 24 months when battery has

2 the expected life with capacity

manufacturer's rating WOG STS 3.8.6-4 Rev. 3.0, 03/31/04 Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 25 of 138

Enclosure (3 of 4), Q&A to Attachment 1, Volume 13 (Section 3.8) Page 26 of 138 Battery Parameters B 3.8.6 BASES ACTIONS (continued)