ML13150A337

Issuance of Amendments Revision Station Battery Connection Resistances Acceptance Criteria in Technical Specifications

ML13150A337
Person / Time
Site:	Saint Lucie
Issue date:	06/18/2013
From:	Siva Lingam Plant Licensing Branch II
To:	Nazar M Florida Power & Light Co
Lingam S NRR/DORL/LPL2-2
References
TAC ME9297, TAC ME9298
Download: ML13150A337 (23)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 18, 2013 Mr. Mano Nazar Executive Vice President and Chief Nuclear Officer Florida Power and Light Company P.O. Box 14000 Juno Beach. Florida 3340B-0420

SUBJECT:

ST. LUCIE PLANT. UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS REVISING STATION BATIERY CONNECTION RESISTANCES ACCEPTANCE CRITERIA IN TECHNICAL SPECIFICATIONS (TAC NOS. ME9297 AND ME929B)

Dear Mr. Nazar:

The Nuclear Regulatory Commission (Commission. NRC) has issued the enclosed Amendment Nos. 215 and 165 to Renewed Facility Operating License Nos. DPR-67 and NPF-16 for the St. Lucie Plant, Unit Nos. 1 and 2. respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 10. 2012. as supplemented by letter dated February 13, 2013.

The amendments revise the station battery acceptance criteria in the existing St. Lucie Unit 1 TS Surveillance Requirements (SRs) 4.B.2.3.2.b.2 and 4.B.2.3.2.c.3. and St. Lucie Unit 2 TS SRs 4.B.2.1.b.2 and 4.B.2.1.c.3. Specifically. the proposed changes modify the existing TS SRs to revise the station battery connection resistance acceptance criterion for average inter-cell connections and to add new connection resistance acceptance criteria for inter-tier, inter-rack.

and output terminal.

M. Nazar - 2 A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389

Enclosures:

1. Amendment No. 215 to DPR-67

2. Amendment No. 165 to NPF-16

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER & LIGHT COMPANY DOCKET NO. 50-335 S1. LUCIE PLANT UNIT NO.1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 215 Renewed License No. DPR-67

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

A The application for amendment by Florida Power & Light Company (the licensee), dated August 10, 2012, as supplemented by letter dated February 13, 2013, 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, 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 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.

-2

2. Accordingly, Renewed Facility Operating License No. DPR-67 is amended by changes to the Technical Specifications (TSs) as indicated in the attachment to this license amendment, and by amending paragraph 3.B to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 215, are hereby incorporated in the renewed license.

The licensee shall operate the facility in accordance with the TSs.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

~~r-Jessie F. Quichocho, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical Specifications Date of Issuance: June 18, 2013

ATTACHMENT TO LICENSE AMENDMENT NO.2iS TO RENEWED FACILITY OPERATING LICENSE NO. DPR-67 DOCKET NO. 50-335 Replace Page 3 of Renewed Operating License DPR-67 with the attached Page 3.

Replace the following page of the Appendix A Technical Specifications with the attached page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Pages 3/48-11 3/4 8-11 3/48-11a

3 applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A. Maximum Power Level FPL is authorized to operate the facility at steady state reactor core power levels not in excess of 3020 megawatts (thermal).

B. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 215are hereby incorporated in the renewed license.

FPL shall operate the facility in accordance with the Technical Specifications.

Appendix B, the Environmental Protection Plan (Non-Radiological), contains environmental conditions of the renewed license. If significant detrimental effects or evidence of irreversible damage are detected by the monitoring programs required by Appendix B of this license, FPL will provide the Commission with an analysis of the problem and plan of action to be taken subject to Commission approval to eliminate or significantly reduce the detrimental effects or damage.

C. Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d), as revised on March 28, 2003, describes certain future activities to be completed before the period of extended operation. FPL shall complete these activities no later than March 1, 2016, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement as revised on March 28, 2003, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4) , following issuance of this renewed license. Until that update is complete, FPL may make changes to the programs describ~d in such supplement without prior Commission approval, provided that FPL evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

D. Sustained Core Uncoverv Actions Procedural guidance shall be in place to instruct operators to implement actions that are designed to mitigate a small-break loss-of-coolant accident prior to a calculated time of sustained core uncovery.

Renewed License No. DPR-67 Amendment No. 215

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

b. At least once per 92 days and within 7 days after a battery dis charge with battery terminal voltage below 110 volts, or battery overcharge with battery terminal voltage above 150 volts, by verifying that:

1. The parameters in Table 4.8-2 meet the Category B limits,

2. There is no visible corrosion at either terminals or connec tors, and

3. The average electrolyte temperature of 10% (60 cells total) of connected cells is above 50°F.

c. At least once per 18 months by verifying that:

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

2. The cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion material,

3. Battery cell inter-connection resistance values are maintained at the values below:

Battery Inter-Connection Measurement Limits Battery Maximum Individual Maximum Inter-Connection Inter-Connection Average Type Resistance Inter-Connection Resistance

[Battery Bank*]

Inter-Cell S 150 x 10-6 ohms S 50 x 10-6 Inter-Tier S 200 x 10-6 ohms ohms Inter-Rack S 200 x 10-6 ohms Output Terminal S 150 x 10-6 ohms

• The battery bank average interconnection resistance limit is the average of all inter-cell, inter-tier, inter-rack and output terminal connection resistance measurements for all series connections in the battery string and,

4. The battery charger will supply at least 300 amperes at 140 volts for at least 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

ST. LUCIE - UNIT 1 3/48-11 Amendment No. e.:t. 215

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

d. At least once per 18 months, during shutdown, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.

e. At least once per 60 months, during shutdown, by verifying that the battery capacity is at least 80% of the manufacturer's rating when subjected to a performance discharge test. This performance dis charge test may be performed in lieu of the battery service test required by Surveillance Requirement 4.8.2.3.2.d.

f. Annual performance discharge tests of battery capacity shall be given to any battery that shows signs of degradation or has reached 85% of the service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% of rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.

ST. LUCIE - UNIT 1 3/48-11a Amendment No. 215

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 FLORIDA POWER & LIGHT COMPANY ORLANDO UTILITIES COMMISSION OF THE CITY OF ORLANDO, FLORIDA AND FLORIDA MUNICIPAL POWER AGENCY DOCKET NO. 50-389 ST. LUCIE PLANT UNIT NO.2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 165 Renewed License No. NPF-16

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

A. The application for amendment by Florida Power & Light Company, et al. (the licensee), dated August 10,2012, as supplemented by letter dated February 13, 2013, 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, 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 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.

-2

2. Accordingly, Renewed Facility Operating License No. NPF-16 is amended by changes to the Technical Specifications (TSs) as indicated in the attachment to this license amendment, and by amending paragraph 3.B to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No.165 , are hereby incorporated in the license. The licensee shall operate the facility in accordance with the TSs.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Jessie F. Quichocho, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Attachment Changes to the Operating License and Technical Specifications Date of Issuance: June 18, 2013

AITACHMENT TO LICENSE AMENDMENT NO.165 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-16 DOCKET NO. 50-389 Replace Page 3 of Renewed Operating License NPF-16 with the attached Page 3.

Replace the following page of the Appendix A Technical Specifications with the attached page.

The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Pages 3/48-11 3/48-11 3/48-11a

- 3 neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required.

D. Pursuant to the Act and 10 CFR Parts 30, 40, and 70, FPL to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and E. Pursuant to the Act and 10 CFR Parts 30,40, and 70, FPL to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission's regulations: 10 CFR Part 20, Section 30.34 of 10 FR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A. Maximum Power Level FPL is authorized to operate the facility at steady state reactor core power levels not in excess of 3020 megawatts (thermal).

B. Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No165 are hereby incorporated in the renewed license.

FPL shall operate the facility in accordance with the Technical Specifications.

Renewed License No. NPF~16 Amendment No. 165

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

b. At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110 volts, or battery overcharge with battery terminal voltage above 150 volts, by verifying that

1. The parameters in Table 4.8-2 meet the Category B limits,

2. There is no visible corrosion at either terminals or connectors, and

3. The average electrolyte temperature of 10% (60 cells total) of connected cells is above 50°F.

c. At least once per 18 months by verifying that:

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

2. The cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion material,

3. Battery cell inter-connection resistance values are maintained at the values below:

Battery Inter-Connection Measurement Limits Battery Maximum Individual Maximum Inter-Connection Inter-Connection Average Type Resistance Inter-Connection Resistance

[Battery Bank*]

i Inter-Cell s 150 x 10-6 ohms s 50 x 10-6

! Inter-Tier s 200 x 10-6 ohms ohms Inter-Rack s 200 x 10-6 ohms i Output Terminal s 150 x 10-6 ohms

• The battery bank average interconnection resistance limit is the average of all inter-cell, inter-tier, inter-rack and output terminal connection resistance measurements for all series connections in the battery string and,

4. The battery charger will supply at least 300 amperes at 140 volts for at least 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

ST. LUCIE - UNIT 2 3/48-11 Amendment No. 165

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

d. At least once per 18 months, during shutdown, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.

e. At least once per 60 months, during shutdown, by verifying that the battery capacity is at least 80% of the manufacturer's rating when subjected to a performance discharge test. This performance discharge test may be performed in lieu of the battery service test required by Surveillance Requirement 4.8.2.1d.

f. Annual performance discharge tests of battery capacity shall be given to any battery that shows signs of degradation or has reached 85% of the service life expected for the application. Degradation is indicated when the battery capacity drops more than 10% of rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.

ST. LUCIE - UNIT 2 3/48-11a Amendment No.165

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 215 AND 165 TO RENEWED FACILITY OPERATING LICENSES NOS. DPR-67 AND NPF-16 FLORIDA POWER AND LIGHT COMPANY, ET AL.

ST. LUCIE PLANT UNIT NOS. 1 AND 2 DOCKET NOS. 50-335 AND 50-389

1.0 INTRODUCTION

By letter dated August 10, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12235A315), as supplemented by letter dated February 13, 2013 (ADAMS Accession No. ML13057A108), Florida Power & Light Company (FPL, the licensee) requested an amendment to Facility Operating License Nos. DPR-67 for st. Lucie Plant Unit 1 and NPF-16 for the St. Lucie Plant Unit 2, and Appendix A, Technical Specifications (TSs), of the Facility Operating License. The proposed changes would revise the station battery connection resistances acceptance criteria in the existing St. Lucie Unit 1 TS Surveillance Requirements (SRs) 4.8.2.3.2.b.2 and 4.8.2.3.2.c.3, and St. Lucie Unit 2 TS SRs 4.8.2.1.b.2, and 4.8.2.1.c.3. Specifically, the proposed changes would modify the existing TS SRs to revise the station battery connection resistance acceptance criterion for average inter-cell connections and to add new connection resistance acceptance criteria for inter-tier, inter-rack, and output terminal.

The supplemental letter dated February 13, 2013, provided additional information that clarified the application, and did not change the Nuclear Regulatory Commission (NRC or the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on October 30, 2012 (77 FR 65724).

2.0 REGULATORY EVALUATION

The regulatory requirements that the NRC staff applied in the review of the application include:

General Design Criterion (GDC) 17, "Electric power systems," of Appendix A, "General Design Criteria for Nuclear Power Plants," to Title 10, Part 50, of the Code of Federal Regulations (CFR) requires, in part, that nuclear power plants have onsite and offsite electric power systems to permit the functioning of structures, systems. and components that are important to safety.

The onsite system is required to have sufficient independence, redundancy, and testability to

- 2 perform its safety function, assuming a single failure. The offsite power system is required to be supplied by two physically independent circuits that are 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. In addition, this criterion requires provisions to minimize the probability of losing electric power from the remaining electric power supplies as a result of loss of power from the unit, the offsite transmission network, or the onsite power supplies.

GDC 18, "Inspection and testing of electric power systems," requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.

Section 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. Section 50.63 of 10 CFR, "Loss of all alternating current power," requires 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 (SBO).

3.0 TECHNICAL EVALUATION

The St. Lucie Plant Units 1 and 2 direct current (DC) electrical power system is described in Updated Final Safety Analysis Report (UFSAR) Section 8.3.2. The St. Lucie Units 1 and 2 Class 1E DC system supplies safety-related loads and certain non-nuclear safety loads. These buses supply control power to the alternating current (AC) emergency power system equipment such as 4.16 kilo Volt (kV) circuit breakers and 480 Volt (V) Load Centers. It also provides DC power for plant control and instrumentation and for operation of DC motor operated equipment such as valve operators and emergency lube oil pumps. As required by GDC 17, the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure.

The St. Lucie Plant Units 1 and 2 125 V DC distribution system consists of two redundant and independent supply trains, each with its own AC to DC power supplies (I.e., battery chargers), a battery for backup, and an additional swing battery charger.

The station batteries are normally connected to the essential distribution panels for charging; therefore they will maintain voltage to the 125 V DC system in the event of loss of the battery chargers as a power source.

During an NRC Component Design Basis Inspection (CDBI) at St. Lucie, an NRC observation identified that the 150 micro ohm inter-cell connection resistance criteria described in TS SR 4.8.2.3.2.c.3 for Unit 1 and SR 4.8.2.1.c.3 for Unit 2 is considered the allowable limiting value for which all cell connections in the nuclear safety-related batteries could be allowed to degrade prior to declaring the battery inoperable. The total battery internal voltage drop, which could result from all 60 of the battery cells having inter-cell connection resistances of 150 micro ohms or greater, would lead to reduced margins for battery voltage performance and not leave acceptable capacity to cope with other battery cell degradations. Based on this observation, FPL proposed revising the St. Lucie TS SRs associated with the DC battery inter-cell and

-3 inter-tier connection resistance values to ensure that the Class 1E station batteries are capable of performing all required functions. The revised values were obtained from the battery monitoring and maintenance programs (implemented via preventive maintenance (PM) procedures) at St. Lucie Plant, Units 1 and 2, which is based on the Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1995 methodology to maintain the battery cells and connections.

The design function of the battery connections (i.e., inter-cell, terminal, inter-tier, and inter-bank) is to facilitate operation of the safety-related batteries in order to meet their design-basis event functions (Le., capable of supporting the safety functions of their design-bases loads).

Sf. Lucie Unit 1 (St. Lucie Unit 2) TS SR 4.B.2.3.2.b.2 (SR 4.B.2.1.b.2) currently requires the verification of no visible corrosion at either terminals or connectors, or the connection resistance of these items is less than 150 micro ohms.

St. Lucie Unit 1 (St. Lucie Unit 2) TS SR 4.B.2.3.2.c.3 (SR 4.B.2.1.c.3) currently requires the verification of the resistance of each cell-to-cell and terminal connection is less than or equal to 150 micro ohms.

In the August 10, 2012, letter, the licensee proposed changing the above SRs to state as follows:

1. St. Lucie Unit 1 (Sf. Lucie Unit 2) TS SR 4.B.2.3.2.b.2 (SR 4.B.2.1.b.2) is being revised as follows: There is no visible corrosion at either terminals or connectors, and

2. Sf. Lucie Unit 1 (Sf. Lucie Unit 2) TS SR 4.B.2.3.2.c.3 (SR 4.B.2.1.c.3) is being revised as follows: battery inter-cell and inter-tier connection resistance values are less than or equal to the values below:

Battery Connection Connection Resistance Resistance Value Measurement Inter-cell I Maximum Average Inter-cell 50 micro ohms Resistance Maximum Single Inter-cell 150 micro ohms Resistance Inter-tier Maximum Single Inter-tier 200 micro ohms Resistance In addition, the licensee provided the actual upper design limit (average for all 60 cells for St . Lucie Unit 1 and S1. Lucie Unit 2, based on the existing battery load profile) from the battery manufacturer (C&D Technologies, Inc.), which provides a margin above the +20 percent baseline-value specified in IEEE Standard 450-1995 for inter-cell connection resistance. The NRC staff reviewed the history of the inter-cell connection resistance measurements for both S1. Lucie Units since 2003. After reviewing the information provided by the licensee in its license amendment request (LAR) dated August 10, 2012, the NRC staff issued a Request for Additional Information (RAI) dated December 31,2012 (ADAMS Accession No. ML12356A501),

to obtain clarification in several areas as discussed below.

-4 In its letter dated August 10, 2012, the licensee proposed adding resistance value acceptance criteria for "Inter-cell" and "Inter-tier" battery connections in a Table in the TS. However, other types of battery connections such as battery terminal connections and terminal connection resistance acceptance criteria were not included in the proposed TS SRs. The NRC staff requested the licensee to: 1) provide a list of all battery connections; 2) explain why terminal connection resistance was deleted from the existing St. Lucie Unit 1 TS SR 4.B.2.3.2.c.3 and St. Lucie Unit 2 TS SR 4.B.2.1.c.3, and not re-inserted in the proposed TS Table; and 3) provide a typical drawing of the station battery cell connections arrangement showing all types of battery connections. In its February 13, 2013, response to the NRC staff's RAI, the licensee provided a list of all the battery connections, clarified that the acceptance criterion for "Output Terminal" will be re-inserted into the st. Lucie Unit 1 TS SR 4.B.2.3.2.c.3 and S1. Lucie Unit 2 TS SR 4.B.2.1.c.3, provided a detailed drawing showing the battery connections, and provided a copy of the revised TS. The NRC staff reviewed the proposed revised TS changes and verified that the "Output Terminal" and associated connection resistance acceptance criteria had been inserted. The NRC staff finds the response to this question acceptable since it provided a clear depiction and description of all battery connections.

The NRC staff also asked the licensee to confirm that resistances for all battery connections are considered in the DC system calculations for battery sizing and voltage drop, and to provide a summary of changes that were made to the station battery sizing calculation to support this LAR. In its February 13, 2013, response to the NRC staffs RAI, the licensee confirmed that the resistances of the st. Lucie safety-related batteries have been considered in the DC system calculations for sizing and voltage drop. The licensee used the battery manufacturer (C&D Technologies, Inc.) criterion to ensure that the rated performance (current and voltage) is provided by the 60-string battery bank set. The licensee's DC system calculations conclude that each battery cell, as well as the 60-cell string battery bank as a unit, was tested, qualified and rated with a manufacturer's connection resistance inherent as part of its qualification. In its February 2013, letter, the licensee stated that the battery manufacturer has formally advised St. Lucie that as long as the maximum DC profile voltage drop is less than or equal to 33.66 milli-volts between each and every cell (on average), that the battery output is qualified and guaranteed to provide the required current at the rated voltage to the output terminals of the battery. Based on its review of the licensee's response to this RAI, the NRC staff finds that the licensee adequately responded by providing calculations that validate the existing battery sizing and voltage drop calculations as supplemented by the battery manufacturer letters.

The NRC staff also requested that the licensee provide: 1) a summary of the calculations, including station battery connection resistance calculations, that show how the values in the proposed TS Table were derived; 2) the battery design duty cycle profiles; 3) the assumptions and supporting documentation to demonstrate that: a) the station batteries will perform their intended safety functions when operating within the proposed limits, and b) the safe shutdown equipment will have the required minimum voltage to perform their required safety functions for the postulated design-basis accident and SBO scenarios. In its February 13, 2013, response to the NRC staff's RAI, the licensee stated that the St. Lucie DC battery sizing calculations provide the basis for the methodology for determining the maximum "average" inter-cell connection resistance for their calculated maximum current profiles. The licensee stated that the actual field measurements for the inter-cell connection resistances historically run below the vendor limit on average (Le., 20 to 30 micro ohms range on average), and the TS average of 50 micro ohms. Typically, the inter-cell connection resistances are intrinsic in the DC battery

- 5 sizing calculation. Therefore, the licensee concluded that there is no need to add external resistance values to the connection resistances that have already been analyzed by the manufacturer as integral to the battery performance. As a result, the licensee determined that there is no impact to the Class 1E Battery sizing calculations. Based on its review of the licensee's response to this RAI, the NRC staff finds that the licensee adequately responded by providing a summary of the calculations, as supported by field measurements that show there would be no adverse impact on the current battery sizing and voltage drop calculations, or on the design-basis functions. Furthermore, the NRC staff reviewed the licensee's response and finds that the licensee has demonstrated that the station batteries will perform their intended safety functions when operating within the proposed limits and that the safe shutdown equipment will have the required minimum voltage to perform their required safety functions for the postulated design-basis accident and SBO scenarios.

The NRC staff also requested the licensee to explain the parameter "Average Inter-cell Connection" that was used in the proposed TS Table. The NRC staff requested this information because it was concerned that the lack of any definition or details for this parameter could create confusion in the future. As part of its request, the NRC staff asked the licensee to provide a Regulatory Commitment to include a definition and details of this new parameter in the St. Lucie TS Bases. In its February 13, 2013, response to the NRC staffs RAI, the licensee provided clarification to the proposed new parameter "Average Inter-cell Connection Resistance" and provided a Regulatory Commitment to include the definition in the St. Lucie TS bases. This Regulatory Commitment can be found in the Regulatory Commitments Section of this safety evaluation.

In addition, the licensee proposed modifying the initially-proposed Table and text in the TS SRs (St. Lucie Unit 1 TS SR 4.8.2.3.2.c.3 and St. Lucie Unit 2 TS SR 4.8.2.1.c.3) in the proposed LAR to add the definition of the 50 micro ohm per cell "average" value, as shown below:

Btt n er- Connecf Ion Measurement L'I mls a ery It 't Maximum Battery Maximum Individual Average Inter-Connection Inter-Connection Interconnection Type Resistance

[Battery-Bank*]

Inter-Cell s150x10*6 ohms Inter-Rack S200x10*6 ohms s50x10*6 ohms Inter-Tier s200x10*6 ohms Output Terminal s150x10*6 ohms

• The battery bank average interconnection resistance limit is the average of all inter-cell, inter-rack, inter-tier and output terminal connection resistance measurements for all series connections in the battery string.

- 6 Based on its review, the NRC staff finds that the licensee has adequately defined the term "Average Inter-cell Connection" and that it will be placed in the appropriate TS Bases Section.

The NRC staff also finds that the licensee adequately identified all battery connection types in the proposed table above that would be inserted in St. Lucie TS page 3/4.8-11.

During its review, the NRC staff noted that on page 15 of Attachment 1 of the LAR dated August 10, 2012, the proposed maximum value of "Single Inter-cell Connection" resistance listed in the proposed TS Table on page 3/4.8-11 was approximately 300 percent or 100 micro ohms above the "Average Inter-cell Connection" resistance. The NRC staff requested that the licensee explain why the "Single Inter-cell Connection" resistance is much higher than the "Average Inter-Cell Connection" resistance. In its February 13, 2013, response to the NRC staff's RAI, the licensee stated that for the Inter-Tier (and Inter-Rack) connections, a maximum TS resistance limit of 200 micro ohms is proposed to incorporate the existing 150 micro ohm value used for the inter-cell connections, and to add 50 micro ohms to accommodate the additional resistance inherent in cables and cable connections versus the inter-cell bus-bar type connections. The licensee concluded that this proposed measurement threshold level is considered more appropriate for entry into a TS Action statement for inter-tier connections. Based on its review of the licensee's response to this RAI, the NRC staff finds that the licensee adequately responded by providing the technical basis for the proposed resistance limit and finds that it accurately reflects the resistance limit for operability determinations.

Additionally, with respect to the St. Lucie Unit 2 TS SRs, the NRC staff noticed a discrepancy between the TS SR numbers described in Section 1, "Summary Description," and Section 2, "Detailed Description," of the proposed LAR (page 2 of 20, Enclosure). Based on this, the NRC staff requested the licensee to clarify the discrepancy. In its February 13, 2013, response to the NRC staff's RAI, the licensee agreed with the NRC staff and revised the amendment request submittal to reflect the correct St. Lucie Unit 2 SR references (I.e., SR 4.8.2.1.b.2 and SR 4.8.2.1.c.3). Based on its review of the licensee's response to this RAI, the NRC staff finds that the licensee adequately responded by correcting the discrepancy.

Based on its review of the information provided by the licensee, the NRC staff determined that the St. Lucie Units 1 and 2 Class 1E batteries will perform their intended design functions for a 60-cell battery configuration when operating within the proposed inter-connection resistance limits, and therefore, finds the proposed revision to the TS battery connection resistance acceptance criteria acceptable.

The NRC staff evaluated the licensee's request to modify the St. Lucie Unit 1 (St. Lucie Unit 2)

TS SR 4.8.2.3.2.b.2 (SR 4.8.2.1.b.2), and St. Lucie Unit 1 (St. Lucie Unit 2) TS SR 4.8.2.3.2.c.3 (SR 4.8.2.1.c.3) by requiring verification of no visible corrosion at the battery terminals and connectors, and verification that battery connections for a 60-cell battery configuration are less than or equal to (S) 150 micro ohms for inter-cell connections, S 200 micro ohms for inter-rack connections, S 200 micro ohms for inter-tier connections, and S 150 micro ohms for terminal connections, and that the maximum average battery-bank connection resistance is S 50 micro ohms.

Based on the above evaluation, the NRC staff finds the proposed changes to the St. Lucie Units 1 and 2 TS provides reasonable assurance of the continued availability of the electrical power required to shut down the reactor and to maintain the reactor in a safe condition after an

-7 anticipated operational occurrence or a postulated design-basis accident. Furthermore, the NRC staff concludes that the proposed TS changes are in accordance with 10 CFR 50.36 and 10 CFR 50.63, and meet the requirements of GDC 17 and 18. Therefore, the NRC staff finds the proposed changes acceptable.

4.0 REGULATORY COMMITMENTS The licensee provided a Regulatory Commitment in its letter dated February 13, 2013, to include the following description of its method for averaging inter-cell connections in Section 3/4.8 of the St. Lucie TS Bases:

The Surveillance Requirements for demonstrating the OPERABILTY of the DC system battery cell interconnection resistances are based on criteria recommended by the manufacturer. The table contained in TS SR 4.8.2.1.c.3 is provided to define the maximum individual and maximum average allowable values for battery cell interconnection resistances.

The maximum individual battery cell interconnection resistance values are based on the negligible impact of voltage drop and connection heating, during peak DC system load conditions. A maximum individual battery interconnection resistance value of S 150 x 10.6 ohms is used for connections, which use inter-cell (bus-bar type) connections and for the battery set output terminal connections. The maximum individual battery interconnection resistance value of S 200 x 10.6 ohms is used for the inter-tier and inter-rack connections, which are subject to additional resistance of the cables used to extend between the different level tiers of each battery rack and of the adjacent battery rack.

The maximum average battery cell interconnection resistance value of S 50 x 10.6 ohms is the average of the interconnection resistance limit for all inter-cell, inter-tier, inter-rack and output terminals in the series-connected battery bank string. The S 50 x 10.6 ohms criteria was selected in order to ensure that the battery cell interconnection voltage drop does not exceed the vendor criteria limit of less than 33.66 mV (average) for each battery cell interconnection, during the maximum design current load profile. The battery manufacturer has rated the battery bank set for full rated output, given adherence to limiting the average interconnection resistance to less than 33.66 mV drop between cells. For battery cell interconnections, which are monitored via multiple measurement points between two adjacent cells, these measurements must first be averaged for the connection between the affected adjacent celis, before averaging the values for all cells used in the full battery bank set.

The licensee included in its supplemental letter dated February 13, 2013, the revised TS Bases to be implemented with the TS change. The NRC staff finds that the TS Bases Control Program is the appropriate process for updating the affected TS Bases pages and has, therefore, not included the affected Bases pages with this amendment.

- 8

5.0 STATE CONSULTATION

Based upon a letter dated May 2, 2003, from Michael N. Stephens of the Florida Department of Health, Bureau of Radiation Control, to Brenda L. Mozafari, Senior Project Manager, U.S. Nuclear Regulatory Commission, the State of Florida does not desire notification of issuance of license amendments.

6.0 ENVIRONMENTAL CONSIDERATION

These amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (77 FR 65724, dated October 30,2012). Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: T. Martinez-Navedo P. Sahay Date: June 18, 2013

M. Nazar -2 A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, IRA!

Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-335 and 50-389

Enclosures:

1. Amendment No. 215 to DPR-67

2. Amendment No. 165 to NPF-16

3. Safety Evaluation cc wtencls: Distribution via Listserv Distribution:

PUBLIC LPL2-2 RtF RidsAcrsAcnw_MaiICTR RidsNrrDorlDpr RidsNrrDorlLpl2-2 RidsNrrPMSt.Lucie RidsNrrLABClayton RidsNrrDeEeeb RidsNrrDssStsb RidsRgn2MailCenter RRodriguez, NRR TMartinez-Navedo, NRR PSahay, NRR GWaig, NRR ADAMS A ccesslon N0.: ML13150A337 *b)y memo OFFICE LPL2-21PM LPL2-2/LA EEEB/BC (A)* iSTSB/BC OGC (NLO) LPL2-21BC LPL2-21PM CGratton for NAME SLingam BClayton RMathew REliiott EHouseman SLingam JQuichocho DATE 6/17113 6/4/13 5/22/13 6/14/13 6/13/13 6/18113 6/18/13 OFFICIAL RECORD COpy