ML110730171

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Supplement Related to the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program
ML110730171
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 03/02/2011
From: Repko R
Duke Energy Carolinas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML110730171 (9)


Text

SDuke REGIS T. REPKO Vice President E* k~nergy McGuire Nuclear Station Duke Energy.

MG01 VP / 12700 Hagers Ferry Rd.

Huntersville, NC 28078 980-875-4111 980-875-4809 fax regis. repko@duke-energy. com March 2, 2011 10 CFR 50.90 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Document Control Desk

Subject:

Duke Energy Carolinas, LLC McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Supplement Related to the Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program This letter provides a supplement to the McGuire License Amendment Request (LAR) dated March 24, 2010 (ADAMS Accession No. ML100890320) applicable to the relocation of specific surveillance frequencies to a licensee controlled program in accordance with TSTF-425 Revision 3 and NEI 04-10 Revision 1.

The Attachment to this supplement contains updated Technical Specification (TS) and Bases marked up pages related to TS 3.8.4. These changes were approved by the NRC on December 20, 2010 (ADAMS Accession No. ML103270096).

As communicated to the NRC in Attachment 1 of the subject LAR, there were six TS LARs pending NRC review and approval that affect surveillances modified by this LAR. Four of those six approved TS changes were transmitted to the NRC by the RAI response letter dated November 18, 2010. This additional approved LAR, the TS 3.8.4 changes, have been implemented at McGuire. The TSTF-490 LAR dated December 15, 2009 remains pending.

As committed in the March 24, 2010 LAR, McGuire is now providing updated marked up copies of TS 3.8.4 and the corresponding Bases pages. The TS 3.8.4 LAR only revised existing surveillance descriptions and did not represent deviations from TSTF-425 or the NRC's model safety evaluation.

The conclusions reached in the original determination that the LAR contains No Significant Hazards Considerations and the basis for the categorical exclusion from performing an Environmental/Impact Statement have not changed as a result of this supplement.

www.duke-energy.corn o /

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March 2, 2011 Nuclear Regulatory Commission Page 2 Please replace the corresponding TS 3.8.4 pages in your LAR files. Contact Lee A. Hentz at 980-875-4187 if additional questions arise regarding this LAR supplement.

Sincerely, Regis T. Repko Attachment cc:

w/attachment V. M. McCree, Regional Administrator U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 J. H. Thompson (addressee only)

Project Manager (MCGuire)

U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 0-8 G9A Rockville, MD, 20852-2738 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station W. L. Cox Ill, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh, NC 27699-1645

March 2, 2011 Nuclear Regulatory Commission Page 3 OATH AND AFFIRMATION Regis T. Repko affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

Regisf.Repko, Sie Vice President Subscribed and sworn to me:

Date A

ry Pub

&4 lic on expires:

7

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1) ), 0/2' Date My commissi

ATTACHMENT UPDATED TECHNICAL SPECIFICATION AND BASES PAGES Date of NRC Affected TS Surveillances Approval December 20, 2010 LAR dated December 14, 2009. TS 3.8.4 revised battery resistance surveillance values.

____________________________ I ______________________________________________________________________________________

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is >_ 125 V on float charge. l SR 3.8.4.2 Verify no visible corrosion at battery terminals and connectors.

OR Verify connection resistance of specific connection(s) meets Table 3.8.4-1 limit.

SR 3.8.4.3 Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration that could degrade battery performance.

SR 3.8.4.4 Remove visible terminal corrosion, verify battery cell to cell and terminal connections are clean and tight, and are coated with anti-corrosion material.

SR 3.8.4.5 Verify all battery connection resistance values meet Table 3.8.4-1 limits.

SR 3.8.4.6 Verify each battery charger supplies _> 400 amps at

_> 125 V for > 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

I (continued)

McGuire Units 1 and 2 3.8.4-2 Amendment Nos.46

DC Sources-Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.2 Visual inspection to detect corrosion of the battery cells and connections, or measurement of the resistance of each intercell, interrack, intertier, and terminal connection, provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. For any connection that shows corrosion, the resistance shall be measured at that connection to verify acceptable connection resistance (Ref. 10). The limits for battery connection resistance are specified in Table 3.8.4-1.

The plant safety analyses do not assume a specific battery connection resistance value, but typically assume that the batteries will supply adequate power for a specified period of time. The resistance of each battery connection varies independently from all the others. Some of these individual connection resistance values may be higher or lower than the others, and the battery will still be able to perform its design function.

Overall connection resistance, which is the sum total of all connection resistances, has a direct impact on battery operability. The values listed in Table 3.8.4-1 are based on the battery manufacturers recommended connection voltage drop. As long as battery connection resistance values are at or below the values listed in Table 3.8.4-1, battery operability will not be in question based on intercell, interrack, intertier, and terminal connection resistance.

The Survei*llance Freq cn'y for these in ctions, which capn etect

, c fon ns that can use poe Iosedu to resistanc ating, is

,{

,2das.Thi Fr~uecyis consi -red acceptable b~d on opera~ting SR 3.8.4.3 Visual inspection of the battery cells, cell plates, and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. The presence of physical damage or deterioration does not necessarily represent a failure of this

~SR, provided an evaluation determines that the physical damage or

~deterioration does not affect the OPERABILITY of the battery (its ability to perform its design function). Oeaigeprenea w

s McGuire Units 1 and 2 B 3.8.4-5 Revision N(.

DC Sources-Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.4 and SR 3.8.4.5 Visual inspection and resistance measurements of intercell, interrack, intertier, terminal connections, and the average intercell connection resistance provide an indication of physical damage or abnormal deterioration that could indicate degraded battery condition. The limits for battery connection resistance are specified in Table 3.8.4-1. Single terminal connection resistance is defined as the measurement from each individual load cable lug to the battery cell post. Average intercell connection resistance is defined as the battery manufacturer's maximum allowed intercell connection voltage drop divided by the maximum battery duty cycle load current. The maximum allowable battery total intercell connection resistance can then be defined as the average intercell connection resistance times the total number of intercell connectors in the battery string. Intercell connection is referring to the 56 copper connection straps between the battery jar posts and the battery terminal connections.

The plant safety analyses do not assume a specific battery connection resistance value, but typically assume that the batteries will supply adequate power for a specified period of time. The resistance of each battery connection varies independently from all the others. Some of these individual connection resistance values may be higher or lower than the others, and the battery will still be able to perform its design function.

Overall connection resistance, which is the sum total of all connection resistances, has a direct impact on battery operability. The values listed in Table 3.8.4-1 are based on the battery manufacturers recommended connection voltage drop. As long as battery connection resistance values are at or below the values listed in Table 3.8.4-1, battery operability will not be in question based on intercell, interrack, intertier, and terminal connection resistance.

The anticorrosion material is used to help ensure good electrical connections and to reduce terminal deterioration. The visual inspection for corrosion is not intended to require removal of and inspection under each terminal connection. The removal of visible corrosion is a preventive maintenance SR. The presence of visible corrosion does not necessarily represent a failure of this SR provided visible corrosion is removed during performance of SR a

.8ting

.xperience has s

w hs opnns"-usua

-"pass the SR ehn perfor0;ed at th 18,oth Freque/.r*cy. Therefor, he Frequen c/as concýd to be ep a l p

eiability standpoint.

-I---

McGuire Units 1 and 2 B 3.8.4-6 Revision Noo

DC Sources-Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.6 This SR requires that each battery charger be capable of supplying 400 amps and 125 V for >_ 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. These requirements are based on the design requirements of the chargers. According to Regulatory Guide 1.32 (Ref. 11), the battery charger supply is required 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 ensures that these requirements can be satisfied.

f SR 3.8.4.7

-A battery service test is a special test of battery capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The discharge rate and test length of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> should correspond to the design duty cycle requirements as specified in Reference 4.

0 i

h ~ e to This SR is modified by a Note. The Note allows the performance of a modified performance discharge test in lieu of a service test.

The modified performance discharge test, as defined by IEEE-450 (Ref.

12) is a simulated duty cycle consisting of just two rates; the one minute rate published for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance test, both of which envelope the duty cycle of the service test. Since the ampere-hours removed by a rated one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance McGuire Units 1 and 2 B 3.8.4-7 Revision N9

DC Sources-Operating B 3.8.4 BASES SURVEILLANCE REQUIREMENTS (continued) discharge test. The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

A modified discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test.

SR 3.8.4.8 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

A battery modified performance discharge test is described in the Bases for SR 3.8.4.7 and in IEEE-450 (Ref. 12). Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.4.8; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.8 while satisfying the requirements of SR 3.8.4.7 at the same time.

The acceptance criteria for this Surveillance are consistent with IEEE-450 (Ref. 12). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturer's rating. A capacity of 80%

shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements.

Jh-eSurvei iance Fre' uency Je~his test-4ý norp~itily 60 mon~thsl If the "attery shows degradation, or if the batter has reached 85 % of its expected life and capacity is < 100% of the manufacturers rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance 7>

Frequency is only reduced to 24 months for batteries that retain capacity >_

100% of the manufacturer's rating. Degradation is indicated, according to IEEE-450 (Ref. 10), when the battery capacity drops by more than 10%

relative to its capacity on the previous performance test when it is _> 10%

cubelow the manufactu1ThPse Fraeqnueciesar.-cosRisint twitht McGuire Units 1 and 2 B 3.8.4-8 Revision N17

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