Text

Issuance of Amendment Nos. 193, 193, and 193, Adopt Technical Specification Task Force (TSTF)-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360
	ML14115A045
Person / Time
Site:	Palo Verde
Issue date:	06/25/2014
From:	Jennivine Rankin; Plant Licensing Branch IV
To:	Edington R; Arizona Public Service Co
	Rankin J
References
	TAC MF0450, TAC MF0451, TAC MF0452
	Download: ML14115A045 (66)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 25, 2014 Mr. Randall K. Edington Executive Vice President Nuclear/

Chief Nuclear Officer Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3-ISSUANCE OF AMENDMENTS RE: LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)

TRAVELER TSTF-500, REVISION 2, DC ELECTRICAL REWRITE- UPDATE TO TSTF-360 (TAC NOS. MF0450, MF0451, AND MF0452)

Dear Mr. Edington:

The Commission has issued the enclosed Amendment No. 193 to Renewed Facility Operating License No. NPF-41, Amendment No. 193 to Renewed Facility Operating License No. NPF-51, and Amendment No. 193 to Renewed Facility Operating License No. NPF-74 for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated December 26, 2012, as supplemented by letter dated August 26, 2013.

The amendments adopt Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, "DC Electrical Rewrite- Update to TSTF-360." Specifically, the amendments revise the TS requirements related to direct current (DC) electrical systems in limiting condition for operation (LCO) 3.8.4, "DC Sources- Operating," and LCO 3.8.5, "DC Sources- Shutdown,"

and TS LCO 3.8.6, "Battery Parameters." Additionally, a new program TS 5.5.19, "Battery Monitoring and Maintenance Program," was added toTS Section 5.5, "Program and Manuals,"

and a number of surveillance requirements were relocated to the new TS 5.5.19.

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

Sincerely, 2f~~~ki~er Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosures:

1. Amendment No. 193 to NPF-41

2. Amendment No. 193 to NPF-51

3. Amendment No. 193 to NPF-74

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

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ARIZONA PUBLIC SERVICE COMPANY. ET AL.

DOCKET NO. STN 50-528 PALO VERDE NUCLEAR GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 193 License No. NPF-41

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

A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated December 26, 2012, as supplemented by letter dated August 26, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's 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.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2. C(2) of Renewed Facility Operating License No. NPF-41 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 193, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of issuance and shall be implemented within 180 days of the date of issuance. Implementation of the amendment shall include revision of the Updated Final Safety Analysis Report as described in Attachment 2 to the licensee's letter dated December 26, 2012.

FOR THE NUCLEAR REGULATORY COMMISSION

~~~

Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-41 and Technical Specifications Date of Issuance: June 25, 2014

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ARIZONA PUBLIC SERVICE COMPANY. ET AL.

DOCKET NO. STN 50-529 PALO VERDE NUCLEAR GENERATING STATION. UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 193 License No. NPF-51

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

A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated December 26, 2012, as supplemented by letter dated August 26, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's 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.

Enclosure 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2. C(2) of Renewed Facility Operating License No. NPF-51 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 193, and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated into this license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of issuance and shall be implemented within 180 days of the date of issuance. Implementation of the amendment shall include revision of the Updated Final Safety Analysis Report as described in Attachment 2 to the licensee's letter dated December 26, 2012.

FOR THE NUCLEAR REGULATORY COMMISSION ACt_J-z~A-~

Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-51 and Technical Specifications Date of Issuance: June 25, 2014

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ARIZONA PUBLIC SERVICE COMPANY. ET AL.

DOCKET NO. STN 50-530 PALO VERDE NUCLEAR GENERATING STATION. UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 193 License No. NPF-7 4

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

A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated December 26, 2012, as supplemented by letter dated August 26, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's 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.

Enclosure 3

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and Paragraph 2.C(2) of Renewed Facility Operating License No. NPF-74 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 193, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of issuance and shall be implemented within 180 days of the date of issuance. Implementation of the amendment shall include revision of the Updated Final Safety Analysis Report as described in Attachment 2 to the licensee's letter dated December 26, 2012.

FOR THE NUCLEAR REGULATORY COMMISSION

~'t<-.f ~ ~

Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. NPF-74 and Technical Specifications Date of Issuance: June 25 2014

ATTACHMENT TO LICENSE AMENDMENT NOS. 193. 193. AND 193 RENEWED FACILITY OPERATING LICENSE NOS. NPF-41. NPF-51. AND NPF-74 DOCKET NOS. STN 50-528. STN 50-529. AND STN 50-530 Replace the following pages of the Renewed Facility Operating Licenses Nos. NPF-41, NPF-51, and NPF-74, and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Renewed Facility Operating License No. NPF-41 REMOVE INSERT 5 5 Renewed Facility Operating License No. NPF-51 REMOVE INSERT 6 6 Renewed Facility Operating License No. NPF-74 REMOVE INSERT 4 4 Technical Specifications REMOVE INSERT 3.8.4-1 to 3.8.4-4 3.8.4-1 to 3.8.4-3 3.8.5-1 to 3.8.5-2 3.8.5-1 to 3.8.5-2 3.8.6-1 to 3.8.6-4 3.8.6-1 to 3.8.6.4 5.5-18 5.5-18 5.5-19

(1) Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (1 00% power), in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 193, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.

APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed license.

(4) Operating Staff Experience Requirements Deleted (5) Post-Fuel-Loading Initial Test Program (Section 14. SER and SSER 2(

Deleted (6) Environmental Qualification Deleted (7) Fire Protection Program APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 11, subject to the following provision:

APS may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

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

Renewed Facility Operating License No. NPF-41 Amendment No. 193

(1) Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (1 00% power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 193, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.

APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed operating license.

(4) Operating Staff Experience Requirements (Section 13.1.2. SSER g)'

Deleted (5) Initial Test Program (Section 14. SER and SSER 2)

Deleted (6) Fire Protection Program APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 11, subject to the following provision:

APS may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(7) lnservice Inspection Program (Sections 5.2.4 and 6.6. SER and SSER 9)

Deleted

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

Renewed Facility Operating License No. NPF-51 Amendment No. 193

(4) Pursuant to the Act and 10 CFR Part 30, 40, and 70, APS to receive, possess, and use in amounts 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 (5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, APS to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I 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 or incorporated below:

(1) Maximum Power Level Arizona Public Service Company (APS) is authorized to operate the facility at reactor core power levels not in excess of 3990 megawatts thermal (1 00% power), in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 193, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this renewed operating license.

APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Antitrust Conditions This renewed operating license is subject to the antitrust conditions delineated in Appendix C to this renewed operating license.

(4) Initial Test Program (Section 14. SER and SSER 2)

Deleted (5) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. 171, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Additional Conditions.

Renewed Facility Operating License No. NPF-74 Amendment No. 193

DC Sources - Operating 3.8 4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources -Operating LCD 3.8.4 The Train A and Train B DC electr1cal power subsystems shall be OPERABLE.

APPLICABILITY: MODES 1. 2. 3. and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One battery charger on A.l Restore battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months one subsystem terminal voltage to inoperable. greater than or equal to the minimum established float voltage.

AND A 2 Ver1fy battery float Once per 12 currents 2 amps. hours AND A.3 Restore battery 72 hours charger to OPERABLE status.

B. One DC electrical B. 1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power subsystem power subsystem to inoperable for reasons OPERABLE status other than Condition A.

c. Required Action and c.1 Be in MODE 3. 6 hours associated Completion Time not met. AND C.2 Be i n t10DE 5 . 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months PALO VERDE UNITS 1.2.3 3.8.4-1 AMENDMENT NO. +/-+/-+. 193

DC Sources -Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater In accordance than or equal to the minimum established with the float voltage. Surveillance Frequency Control Program SR 3.8.4.2 Deleted SR 3.8.4.3 Deleted SR 3.8.4.4 Deleted SR 3.8.4.5 Deleted SR 3.8.4. 6 Verify each battery charger sup~lies In accordance

~ 400 amps for Batteries A and and with the

~ 300 amps for Batteries C and D at Surveillance greater than or equal to the minimum Frequenc~

established float voltage for ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Control rogram OR Verify each battery charger can recharge the batter~ to the fully charged state within 12 ours while supplying the largest combined demands of the various continuous steady state loads. after a battery discharge to the bounding design basis event discharge state.

<continued)

PALO VERDE UNITS 1.2.3 3.8.4-2 AMENDMENT NO. +88. 193

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.7 -------------------NOTES--------------*----

1. The modified performance discharge test in SR 3.8.6.9 may be performed in lieu of SR 3.8.4.7.

2. This Surveillance shall not be performed in MODE 1. 2. 3. or 4.

Verify battery capacity is adequate to In accordance supply, and maintain in OPERABLE status. with the*

the required emergency loads for the design Surveillance duty cycle when subjected to a battery Frequency service test. Control Program SR 3.8.4.8 Deleted PALO VERDE UNITS 1.2.3 3.8.4-3 AMENDMENT NO. +88, 193

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10. "Distribution Systems- Shutdown."

APPLICABILITY: MODES 5 and 6.

During movement of irradiated fuel assemblies.

ACTIONS

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

In MODES 1. 2. 3. and 4. Required Action A.2.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required DC A.1 Declare affected Immediately electrical power required feature(s) subsystem inoperable. inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.3 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND A.2.4 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status.

(continued)

PALO VERDE UNITS 1.2.3 3.8.5-1 AMENDMENT NO. ++/-+. 193

DC Sources - Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 ---------*****-----NOTE-------------------

The following SRs are not required to be performed: SR 3.8.4.6 and SR 3.8.4.7.

For DC sources required to be OPERABLE. the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.6 SR 3.8.4.7 PALO VERDE UNITS 1.2.3 3.8.5-2 AMENDMENT NO. ~. 193

Battery Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters LCD 3.8.6 Battery parameters for the Train A and Train B electrical power subsystem batteries shall be within limits.

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

ACTIONS

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

Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME A. One battery with one 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 or more battery cells float voltage AND

2.07 V.

A.2 Perform SR 3.8.6.4. 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 voltage> 2.07 V.

B. One battery with float 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 current> 2 amps.

AND B.2 Restore float current 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to::; 2 amps.

(continued)

PALO VERDE UNITS 1.2.3 3.8.6-1 AMENDMENT NO. W. 193

Battery Parameters 3.8.6 ACTIONS (cont4nued)

CONDITION REQUIRED ACTION COMPLETION TIME

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

Requ4red Act4on C.2 Requ4red Act4ons C.1 and shall be completed 4f C.2 are only appl4cable electrolyte level was 4f electrolyte level was below the top of plates. below the top of plates.

C. One battery with one C.1 Restore electrolyte 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or more cells level to above top electrolyte level of plates.

less than m4nimum establ4shed des4gn -AND l i mlts. C.2 Ver4fy no ev4dence 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months of leakage.

-AND C.3 Restore electrolyte 31 days level to greater than or equal to m4n4mum establ4shed des 4gn 14 mlts .

D. One battery w4th p4lot D.1 Restore battery p4lot 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months cell electrolyte cell temperature to temperature less than greater than or equal m4n4mum establ4shed to m4nimum establ4shed des 4gn 14 mlts . des 4gn 14 mlts .

E. One or more batter4es E.1 Restore battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4n redundant parameters for subsystems w4th batter4es 4n one battery parameters not subsystem to w4th4n wlth4 n 14 mlts. l4mlts.

(contlnued)

PALO VERDE UNITS 1.2.3 3.8.6-2 AMENDMENT NO. +/-gg, 193

Battery Parameters 3.8.6 ACTIONS (continued)

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

Time of condition A.

B. C. D or E not met.

OR One battery with one or more battery cells float voltage s 2.07 V and float current

> 2 amps.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 Deleted SR 3.8.6.2 Deleted SR 3.8.6.3 Deleted SR 3.8.6.4 -------------------NOTE--------------------

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

---*---*------~----------------------------

Verify each battery float current is In accordance with s 2 amps. the Surveillance Frequency Control Program SR 3.8.6.5 Verify each battery pilot cell float In accordance with voltage is> 2.07 v. the Surveillance Frequency Control Program SR 3.8.6.6 Verify each battery connected cell In accordance with electrolyte level is greater than or equal the Surveillance to minimum established design limits. Frequency Control Program (continued)

PALO VERDE UNITS 1.2.3 3.8.6-3 AMENDMENT NO. +88. 193

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.7 Verify each battery pilot cell temperature In accordance with is greater than or equal to minimum the Surveillance established design limits. Frequency Control Program SR 3.8.6.8 Verify each battery connected cell float In accordance with voltage is> 2.07 V. the Surveillance Frequency Control Program SR 3.8.6.9 -------------------NOTE--------------------

This Surveillance shall not be performed in MODE 1. 2. 3. or 4. However. credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is ~ 80% of the In accordance with manufacturer's rating when subjected to a the Surveillance performance discharge test or modified Frequency Control performance discharge test. Program AND 12 months when battery shows degradation. or has reached 85% of the expected life with capacity < 100% of manufacturer's rating AND 24 months when battery has reached 85% of the expected life with capacity

~ 100% of manufacturer's rating PALO VERDE UNITS 1.2.3 3.8.6-4 AMENDMENT NO. ~. 193

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.18 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes of the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10. "Risk-Informed Method for Control of Surveillance Frequencies." Revision 1.

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

5.5.19 Battery Monitoring and Maintenance Program This Program provides controls for battery restoration and maintenance. The program shall be in accordance with IEEE Standard CStd) 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 CRG). 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."

(continued)

PALO VERDE UNITS 1.2.3 5.5-18 AMENDMENT NO. +/-gg,193

Programs and Manuals 5.5 5.5 Programs and Manuals Ccontlnued) 5.5.19 Battery Monltoring and Maintenance Program (continued)

4. In Regulatory Guide 1.129. Regulatory Position 3.

Subsection 5.4.1. "State of Charge Indlcator." the following statements in paragraph (d) may be omltted:

"When it has been recorded that the charging current has stabllized 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 Positlon 7. Subsectlon 7.6. "Restoratlon." the followlng may be used: "Followlng the test. record the float voltage of each cell of the strlng."

b. The program shall lnclude the followlng provlslons:

1. Actlons to restore battery cells wlth float voltage

< 2.13 V:

2. Actlons to determine whether the float voltage of the remalning 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 dlscovered with electrolyte level below the top of the plates:

4. Limits on average electrolyte temperature. battery connectlon reslstance. and battery termlnal voltage:

and

5. A requirement to obtaln speciflc gravlty readings of all cells at each dlscharge test. conslstent wlth manufacturer recommendatlons.

PALO VERDE UNITS 1.2.3 5.5-19 AMENDMENT NO. 193

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 193. 193. AND 193 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-41 NPF-51 AND NPF-74 I I ARIZONA PUBLIC SERVICE COMPANY, ET AL.

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530

1.0 INTRODUCTION

By application dated December 26, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13002A197), as supplemented by letter dated August 26, 2013 (ADAMS Accession No. ML13242A087), Arizona Public Service Company (APS, the licensee) requested changes to the Technical Specifications (TSs) for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3 to adopt U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) change traveler TSTF-500, Revision 2, "DC [direct current] Electrical Rewrite- Update to TSTF-360." Adoption of TSTF-500, Revision 2, proposed new actions for an inoperable battery charger and a new alternate testing criterion for a battery charger for limiting condition for operation (LCO) 3.8.4, "DC Sources- Operating," and LCO 3.8.5, "DC Sources- Shutdown."

TS changes also include the relocation of a number of Surveillance Requirements (SRs) in TS 3. 8.4 that perform preventive maintenance on the safety-related batteries to a licensee-controlled program. TS LCO 3.8.6, "Battery Parameters," is modified by relocating Table 3.8.6-1, "Battery Cell Parameter Requirements," to a licensee-controlled program; and the specific actions with associated Completion Times (CTs) for out-of-limits conditions for battery cell voltage, electrolyte level, and electrolyte temperature are added toTS 3.8.6. In addition, specific SRs are being proposed for verification of these parameters.

The licensee proposed that the items to be relocated will be contained in the new Administrative Controls TS 5.5.19, "Battery Monitoring and Maintenance Program," for the maintenance and monitoring of station batteries.

The proposed changes include the following:

Specification 3.8.4, "DC Sources- Operating," is revised to replace the existing Conditions for an inoperable battery charger with the TSTF-500 Conditions for an inoperable battery charger. Specification 3.8.4 is also revised to relocate SRs on Enclosure 4

battery corrosion, connection resistance, visual inspection, and terminal connection to the new Administrative Controls TS 5.5.19, "Battery Monitoring and Maintenance Program."

Specification 3.8.5, "DC Sources- Shutdown," is revised to replace the existing Conditions for an inoperable battery charger with the TSTF-500 Conditions for an inoperable battery charger. The list of TS 3.8.5 Surveillances that must be met is also revised to be consistent with the change to TS 3.8.4.

Specification 3.8.6, "Battery Cell Parameters," is renamed "Battery Parameters."

Table 3.8.6-1 is deleted and existing Conditions and Surveillances are replaced.

Maintenance and monitoring of station batteries will be controlled by the new Administrative Controls TS 5.5.19, "Battery Monitoring and Maintenance Program."

Surveillances frequencies and their bases forTS 3.8.4 and TS 3.8.6 SRs, except for the frequencies that are related to specific conditions such as battery degradation and capacity, will be controlled according to the Administrative Controls TS 5.5.18, "Surveillance Frequency Control Program" The Notice of Availability (NOA) for TSTF-500, Revision 2, was published in the Federal Register on September 1, 2011 (76 FR 5451 0), to announce the availability of the model application and model safety evaluation (SE) (ADAMS Accession No. ML111751792) for plant-specific adoption of TSTF-500, Revision 2 (ADAMS Accession No. ML092670242), as part of the consolidated line item improvement process (CLIIP). This NOA was later corrected to clarify that TSTF-500 was available for plant-specific adoption, but not under the CLIIP. The clarifying NOA was published in the FR on November 8, 2011 (76 FR 69296).

The supplemental letter dated August 26, 2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on March 4, 2013 (78 FR 14129). to the license amendment request (LAR) provided revised TS Bases pages to be implemented with the associated TS changes. These pages were provided for information only and will be revised by the licensee in accordance with the TS Bases Control Program discussed in TS 5.5.14, "Technical Specifications (TS) Bases Control Program."

2.0 REGULATORY EVALUATION

The following NRC requirements and guidance documents are applicable to the NRC staff's review of the LAR:

Title 10 of the Code of Federal Regulations, Part 50 (1 0 CFR 50)

The regulation at Appendix A to 10 CFR 50, General Design Criterion (GDC) 17, "Electric power systems," states, in part, that:

An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety ....

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights of way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions ....

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

The regulation at 10 CFR Part 50, Appendix A, GDC 18, "Inspection and testing of electric power systems," states, in part, that "[e]lectric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features .... "

The regulation at 10 CFR Part 50, Appendix A, GDC 1, "Quality standards and records," states, in part, that "[s]tructures, systems, and components important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed."

The regulation at 10 CFR 50.36, "Technical specifications," establishes the requirements related to the content of the TS. Pursuant to 10 CFR 50.36(c) TS are required to include items in five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings, (2) LCOs, (3) SRs, (4) design features; and (5) administrative controls.

Regulatory Guide (RG) 1.75, Revision 3, "Criteria for Independence of Electrical Safety Systems," February 2005 (ADAMS Accession No. ML043630448),

provides guidance with respect to the physical independence requirements of the circuits and electric equipment that comprise or are associated with safety systems.

RG 1.129, Revision 2, "Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plants," February 2007 (ADAMS Accession No. ML063490110), provides guidance with respect to the maintenance, testing, and replacement of vented lead-acid storage batteries in nuclear power plants. This RG endorses, in part, the Institute of Electrical and Electronics Engineers (IEEE) Standard (Std.) 450-2002, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications."

TSTF-500, Revision 2, "DC Electrical Rewrite- Update to TSTF-360," dated September 22, 2009 (ADAMS Accession No. ML092670242).

TSTF-425, Revision 3, "Relocate Surveillance Frequencies to License Control -

RITSTF Initiative 5b," dated March 18, 2009 (ADAMS Accession No. ML090850642).

Model application and SE for plant-specific adoption of TSTF-500, Revision 2 (ADAMS Accession No. ML111751792) as published for availability in the Federal Register on September 1, 2011 (76 FR 5451 0).

3.0 TECHNICAL EVALUATION

3.1 Design Features of the PVNGS Class 1E DC Power System The station Class 1E DC electrical power system provides the alternating current (AC) emergency power system with control power. It also provides both motive and control power to selected safety-related equipment and preferred AC vital bus power (via DC to AC power converters (i.e., inverters)). According to the PVNGS Updated Final Safety Analysis Report (UFSAR), Section 8.3.2, "DC Power Systems," the plant is licensed to 10 CFR Part 50, Appendix A, GDCs 17 and 18, and the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure.

The DC electrical power system at PVNGS consists of two independent and redundant safety-related 125 Volts direct current (VDC) electrical power subsystems A and B (also known as Train A and Train B). Each subsystem consists of two batteries, two battery chargers (one per battery), and all the associated control equipment and interconnecting cabling, thus constituting two independent channels per subsystem. Each subsystem contains one backup Class 1E battery charger, which provides backup service in the event that the normal battery charger is out of service and is manually transferable to either DC channel of the associated subsystem. The transfer mechanism is mechanically interlocked to prevent both DC channels of a subsystem from being connected simultaneously to the backup battery charger.

As described in PVNGS TS Bases B 3.8.4, during normal operation, the DC load is powered from the battery chargers with the batteries floating on the system. In case of loss of normal power to the battery charger, the DC load is automatically powered from the station batteries.

Each battery is housed separately in a ventilated room apart from its charger and distribution centers. Each subsystem is located in an area separated physically and electrically from the other subsystem to ensure that a single failure in one subsystem does not cause a failure in a redundant subsystem. There is no sharing of dedicated components between redundant Class 1E subsystems, such as batteries, battery chargers, or distribution panels.

As described in PVNGS UFSAR, Section 8.3.2, each Class 1E battery has sufficient capacity to independently supply the required loads for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The sizing of each battery is based on a minimum temperature of 60 degrees Fahrenheit (°F) in the battery room for the 2-hour service period. In accordance with the battery replacement criteria of IEEE Std. 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," the initial battery capacity is at least 25 percent greater than required. This margin allows for a battery replacement criterion of 80 percent rated capacity.

The capacity of each Class 1E battery charger is based on the largest combined demand of all the steady-state loads and the charging current required to restore the battery from the design minimum charge state to the fully charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months regardless of the status of the plant during which these demands occur.

Each battery charger is normally in the float-charge mode, in which the charger is supplying the connected loads and the battery cells are receiving adequate current to charge the battery optimally. This assures the internal losses of a battery are overcome and the battery is maintained in a fully charged state.

As stated in the revised TS Bases, "[t]he battery cells are of flooded lead acid construction with a nominal specific gravity of 1.215 +/- 0.01 0. This specific gravity corresponds to an open circuit battery voltage of approximately 123 V for 60 cell battery (i.e., cell voltage of approximately 2.07 volts per cell (Vpc) at the upper circuit range of specific gravity) ... The open circuit voltage is voltage maintained when there is no charging or discharging." The float voltage at the battery terminals is maintained between 2.17 and 2.25 Vpc.

3.2 Evaluation of Proposed Changes The proposed changes to the LCO Conditions, the associated Required Actions and CTs, and SRs are indicated by underlined text for additions/insertions and strikeout text for deletions to the current TS.

3.2.1 TS 3.8.4 (DC Sources - Operating) Changes The licensee proposed to revise TS 3.8.4 Conditions, Required Actions, and SRs and to relocate a number of SRs in TS 3.8.4 that perform preventive maintenance on the safety-related batteries.

TS 3.8.4 LCO requires both DC electrical power subsystems A and 8 to be operable. Currently, TS 3.8.4 contains two Conditions A and 8 for one DC electrical subsystem inoperable and two Conditions C and D for a required DC electrical subsystem battery charger inoperable. The proposed changes would delete Conditions C and D, modify and renumber current Conditions A and 8 as new Conditions 8 and C respectively, and add a new Condition A.

3.2.1.1 TS 3.8.4; New Condition A (Added); Change (1)

The proposed change would add new Condition A to increase the completion time (CT) for an inoperable battery charger from the existing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months as follows:

New Condition A would state:

A. One battery charger on one subsystem inoperable.

New Condition A Required Actions would state:

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

A.2 Verify battery float current s 2 amps.

A.3 Restore battery charger to OPERABLE status.

New Condition A CTs for Required Actions A.1, A.2, and A.3 would state "2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ," "Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ," and "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ," respectively.

Evaluation of TS 3.8.4; New Condition A (Added); Change (1)

New Condition A would apply when one battery charger on one subsystem is inoperable (e.g.,

the voltage limit of SR 3.8.4.1 is not maintained). There are three associated Required Actions for new Condition A. The Required Actions provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to operable status in a specific time period.

New Required Action A.1 provides assurance that the battery terminal voltage will be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The battery charger, in addition to maintaining the battery operable, provides DC control power to AC circuit breakers and thus supports the recovery of AC power following events such as loss-of-offsite power (LOOP) or station blackout (SBO). The 2-hour CT provides an allowance for returning an inoperable charger to operable status or for reestablishing an alternate means (e.g., backup Class 1E battery charger) of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. This provides assurance that the battery will be restored to

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

New Required Action A.2 would require that once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the battery float current be verified to be less than or equal to 2 amperes (amps). This would confirm that if the battery has been discharged as a result of an inoperable battery charger, it had been fully recharged. If, at the expiration of the 12-hour period, the battery float current is greater than 2 amps, then the battery subsystem is considered inoperable (see Section 3.2.3.4 of this SE for a more detailed discussion on the 2 amp float current value). This verification provides assurance that the battery has sufficient capacity to perform its safety function.

New Required Action A.3 requires restoring inoperable battery charger to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . PVNGS would use the back-up Class 1E battery charger as an alternate means of restoring the battery terminal voltage to greater than or equal to the minimum established float voltage during the period the normal battery charger remains inoperable. By a request for information (RAI) dated June 26, 2013 (ADAMS Accession No. ML13177A298), the NRC staff requested the licensee to explain how the 72-hour CT of Required Action A.3 is applicable to the inoperable battery charger at PVNGS. In its letter dated August 26, 2013, the licensee stated that the 72-hour CT provides a period of time for PVNGS to correct the inoperable battery problem commensurate with the importance of maintaining the battery charger in an operable status. The licensee also stated that based on operating experience, the 72-hour CT is a reasonable period of time to perform corrective maintenance.

Based on the above, the NRC staff concludes that the proposed change provides acceptable required actions and CTs for Condition A, as allowed by 10 CFR 50.36 and is, therefore, acceptable.

3.2.1.2 TS 3.8.4; Current Condition A (Revised and Renumbered as Condition B); Change (2)

The proposed change would revise current Condition A and renumber it as Condition B.

Current Condition A states:

A. One DC electrical power subsystem (exclusive of the battery charger) inoperable.

Revised and renumbered Condition B would state:

B. One DC electrical power subsystem inoperable for reasons other than Condition A.

Current Required Action A.1 states:

A.1 Restore DC electrical power subsystem to OPERABLE status.

Revised and renumbered Required Action 8.1 would state:

B.1 Restore DC electrical power subsystem to OPERABLE status.

The CT for revised and renumbered Required Action B.1 remains unchanged and would state "2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ."

Evaluation of TS 3.8.4; Current Condition A (Revised and Renumbered as Condition B);

Change (2)

The requirement for an inoperable battery charger on one subsystem is provided for the new Condition A. The renumbered Condition B would apply when one DC electrical power subsystem other than the battery charger is inoperable. The changes to the existing Condition A are consistent with the adoption of the new Condition A.

The NRC staff reviewed the proposed change and has determined that the change is editorial in nature and is, therefore, acceptable.

3.2.1.3 TS 3.8.4; Current Condition B (Revised and Renumbered as Condition C); Change (3)

The proposed change would revise current Condition B and renumber it as Condition C.

Current Condition B states:

B. Required Action and associated Completion Time of Condition A not met.

Revised and renumbered Condition C would state:

C. Required Action and associated Completion Time not met.

Current Required Actions B.1 and B.2 state:

B.1 Be in MODE 3.

B.2 Be in MODE 5.

Revised and renumbered Required Actions C.1 and C.2 would state:

C.1 Be in MODE 3.

C.2 Be in MODE 5.

The CTs for revised and renumbered Required Actions C.1 and C.2 remain unchanged and would state "6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months " and "36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ," respectively.

Evaluation of TS 3.8.4; Current Condition B (Revised and Renumbered as Condition C);

Change (3)

Current Condition B applies to only one current Condition A. Deleting "of Condition A" from current Condition B reflects the addition of the new Condition A. The renumbered Condition C applies to both new Condition A and renumbered Condition B.

The NRC staff reviewed the proposed change and has determined that the change is editorial in nature and is, therefore, acceptable.

3.2.1.4 TS 3.8.4; Current Conditions C and D (Deleted); Change (4)

The proposed change would delete current Conditions C and D and their associated Required Actions and CTs. Therefore, the following Conditions would be deleted:

C. Required DC electrical power subsystem battery charger inoperable.

D. Required Action and associated Completion Time of Condition C not met.

Evaluation of TS 3.8.4: Current Conditions C and D (Deleted); Change (4)

Current Conditions C and D are superseded by new Condition A and the renumbered Condition C, respectively.

The NRC staff concludes that the change is editorial in nature and is therefore acceptable.

3.2.1.5 TS 3.8.4; SR 3.8.4.1 (Revised): Change (5)

Current SR 3.8.4.1 states:

SR 3.8.4.1 Verify battery terminal voltage is ~ 129 Von float charge.

Revised SR 3.8.4.1 would state:

SR 3.8.4.1 Verify battery terminal voltage is greater than or equal to the minimum established float charge.

The surveillance frequency remains unchanged and would state "In accordance with the Surveillance Frequency Control Program."

The proposed change would delete the battery minimum established float voltage numerical value from the SR and relocate it to a licensee-controlled program.

Evaluation of TS 3.8.4: SR 3.8.4.1 (Revised); Change (5)

The purpose of SR 3.8.4.1 is to verify battery terminal voltage while the system is on a float charge to ensure the effectiveness of the battery chargers is not degraded. The battery terminal

voltage is the minimum voltage which ensures an optimum float charging voltage is applied to the battery. The voltage requirements are based on the nominal design voltage of the battery.

The revised TS Bases states that long-term performance of the PVNGS batteries is supported by maintaining a float voltage greater than or equal to the minimum float voltage established by the manufacturer, which corresponds to 2.17 Vpc for a 60-cell battery or 130.2 Vat the battery terminals. The minimum established float voltage will maintain the battery plates in a condition that supports optimizing battery grid life and will ensure that the battery is capable of providing its designed safety function.

Relocating the minimum established battery float voltage numerical value (design limit) to a licensee-controlled program will allow flexibility to monitor and control this limit at values directly related to the battery ability to perform its required safety function. In Attachment 2 of the LAR, the licensee provided a commitment to change or verify that the UFSAR states the minimum established design limit for battery terminal float voltage. This provides additional reasonable assurance that the numerical value will be appropriately maintained by the licensee to accurately reflect the design of the plant battery system (see section 4.0 for additional discussion regarding regulatory commitments). To replace relocating the minimum established battery float voltage, the licensee added the requirement to verify the battery terminal voltage

" ... greater than or equal to the minimum established float voltage" to this SR.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained to meet the requirements of the LCOs, and is, therefore, acceptable.

3.2.1.6 TS 3.8.4; Current SRs 3.8.4.2. 3.8.4.3. 3.8.4.4. and 3.8.4.5 (Deleted); Change (6)

The proposed change would delete SRs 3.8.4.2 through 3.8.4.5 (and their associated surveillance frequencies), and mark them "Deleted."

Current SRs 3.8.4.2 through 3.8.4.5 state:

SR 3.8.4.2 Verify no visible corrosion at battery terminals and connectors.

Verify battery connection resistance is

~ 150E-6 ohms for inter-cell connections.

~ 150E-6 ohms for inter-rack connections.

~ 150E-6 ohms for inter-tier connections.

and ~ 150E-6 ohms for terminal connections.

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 and verify battery cell to cell and terminal connections are clean, and are coated with anti-corrosion material.

SR 3.8.4.5 Verify battery connection resistance is

150E-6 ohms for inter-cell connections.

150E-6 ohms for inter-rack connections.

150E-6 ohms for inter-tier connections.

and ::;; 150E-6 ohms for terminal connections.

Revised SRs 3.8.4.2 through 3.8.4.5 would state:

SR 3.8.4.2 Deleted SR 3.8.4.3 Deleted SR 3.8.4.4 Deleted SR 3.8.4.5 Deleted The associated surveillance frequencies for SRs 3.8.4.2 through 3.8.4.5, which state "In accordance with the Surveillance Frequency Control Program," would be deleted.

The proposed change relocates the requirements of the above SRs: 3.8.4.2 (visual inspection for corrosion or verification of connection resistance), 3.8.4.3 (visual inspection for physical damage), 3.8.4.4 (removal of visible terminal corrosion and ensuring clean connections), and 3.8.4.5 (verification of connection resistance) to the new Battery Monitoring and Maintenance Program.

Evaluation of TS 3.8.4; Current SRs 3.8.4.2. 3.8.4.3. 3.8.4.4. and 3.8.4.5 (Deleted); Change (6)

Visual inspection of the battery terminals (SRs 3.8.4.2, 3.8.4.3, and 3.8.4.4) is an important preventive maintenance practice for maintaining a healthy battery (e.g., the early identification and cleaning of battery terminal corrosion can prevent corrosion from spreading between the post and the connector). However, visual inspection of the battery terminals alone does not provide an indication of a battery's capability to perform its design function. The NRC staff concludes that the parameters of these preventive maintenance activities can be adequately controlled in the newTS 5.5.19, "Battery Monitoring and Maintenance Program."

Resistance verification (SRs 3.8.4.2 and 3.8.4.5) represents the minimum acceptable requirements for operability of the battery. In Section 2.2 of the LAR, the licensee stated that the connection resistance limit is 30 micro-ohms. By letter dated August 26, 2013, the licensee clarified that the resistance value of 30 micro-ohms is for each connection including each inter-cell, inter-rack, inter-tier, and terminal connection, and is the sum of the inter-cell resistance of 25.16 micro-ohms (based on a manufacturer assumption of a maximum 20 mV drop assumption for inter-cell battery) and a margin of 4.9 micro-ohms. The 30-micro-ohm value represents a limit at which some actions should be taken, not necessarily when the operability of the battery is in question. The plant safety analyses do not assume a specific battery inter-cell connection resistance value, but typically assume that the batteries will supply adequate power. Therefore, the key operability issue is the overall battery connection resistance. Between surveillances, the resistance of each battery inter-cell connection varies independently from all the others.

Some of these connection resistance values may be higher or lower than others, and the battery will still be able to perform its function and should not be considered inoperable. Overall connection resistance has a direct impact on operability and is adequately determined by completion of the battery service or modified performance discharge tests. Therefore, these activities are more appropriately controlled under the proposed Battery Monitoring and Maintenance Program.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the limiting conditions for operation will be met and is, therefore, acceptable.

3.2.1.7 TS 3.8.4; SR 3.8.4.6 (Revised); Change (7)

Current SR 3.8.4.6 states:

SR 3.8.4.6 - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - -

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

Verify each battery charger supplies ~ 400 amps for Batteries A and B and ~ 300 amps for Batteries C and D at ~ 125 V for

~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Revised SR 3.8.4.6 would state:

SR 3.8.4.6 Verify each battery charger supplies ~ 400 amps for Batteries A and B and ~ 300 amps for Batteries C and D at greater than or equal to the minimum established float voltage for ~ 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Verify each battery charger can recharge the battery to the fully charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

The surveillance frequency remains unchanged and would state "In accordance with the Surveillance Frequency Control Program."

Evaluation of TS 3.8.4; SR 3.8.4.6 (Revised); Change (7)

SR 3.8.4.6 specifies battery charger current requirements for each DC source, and its purpose is to verify the design capacity of each battery charger. The proposed change would revise this SR to be consistent with SR 3.8.4.1 by replacing the specific voltage limits with "greater than or equal to the minimum established float voltage." Battery manufacturers establish this voltage limit to provide the optimum charge on the battery and to maintain the battery plates in a condition that supports maintaining the battery grid life. Maintaining this voltage limit should ensure that the battery will be capable of providing its designed safety function.

As noted above, the licensee also proposed adding a revised alternative criterion to SR 3.8.4.6.

The proposed alternative criterion provides an alternate method for verifying the design capacity of each battery charger because normal battery loads may not be available following the battery service test and may need to be supplemented with additional loads. The 12-hour duration is based on PVNGS Class 1E battery chargers capacity as described in PVNGS UFSAR Section 8.3.2.1.2.2. Each battery charger is capable of recharging its respective battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharges to the design minimum discharge state. Therefore, the proposed alternate testing criteria would satisfy the purpose of SR 3.8.4.6.

SR 3.8.4.6 would also be revised to eliminate a Note. The Note currently states, "This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4 on the charger credited for OPERABILITY. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced." This restriction is eliminated as the alternate method can be performed in MODE 1, 2, 3, or 4 without affecting plant safety.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and is, therefore, acceptable.

3.2.1.8 TS 3.8.4; SR 3.8.4.7 (Revised); Change (8)

Current SR 3.8.4.7 states:

SR 3.8.4.7 - - - - - - - - - - - - - - - - - - - - - - NOTES - - - - - - - - - - - - - - - - - - - -

1. The battery performance discharge test or the modified performance discharge test in SR 3.8.4.8 may be performed in lieu of the service test in SR 3.8.4.7.

2. This Surveillance shall not be performed in MODE 1, 2, 3, or4.

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

Revised SR 3.8.4.7 would state:

SR 3.8.4.7 - - - - - - - - - - - - - - - - - - - - - NOTES - - - - - - - - - - - - - - - - - - - - -

1. The modified performance discharge test in SR 3.8.6.9 may be performed in lieu of SR 3.8.4.7.

2. This Surveillance shall not be performed in MODE 1, 2, 3, or 4.

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

The surveillance frequency remains unchanged and would state "In accordance with the Surveillance Frequency Control Program."

Evaluation of TS 3.8.4; SR 3.8.4.7 (Revised); Change (8)

PVNGS SR 3.8.4.7 Note 1 currently allows the flexibility to perform either the battery performance discharge test or the modified performance discharge test in lieu of the service test at any time. The proposed change would delete the allowance to perform the battery performance discharge test in lieu of the battery service test in Note 1 for consistency with TSTF-500 SR 3.8.4.3. The intent of Note 1 is to allow the flexibility to perform the modified performance discharge test as both the service test and the modified performance discharge test verify the ability of the battery to meet its duty cycle. As stated in the TS Bases for SR 3.8.4. 7, the modified performance discharge test parameters envelope the service test. The allowance in Note 1 to perform the modified performance discharge test to satisfy SR 3.8.4.7 is consistent with IEEE-450. Deleting the allowance to perform the performance discharge test in lieu of the battery service test in Note 1 does not change the intent of SR 3.8.4.7.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and is, therefore, acceptable.

3.2.1.9 TS 3.8.4; Existing SR 3.8.4.8 (Deleted and Relocated toTS 3.8.6); Change (9)

The proposed change would relocate SR 3.8.4.8 to SR 3.8.6.9, and mark SR 3.8.4.8 as "Deleted."

Current SR 3.8.4.8 states:

SR 3.8.4.8 - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - -

This Surveillance shall not be performed in MODE 1, 2, 3, or 4.

Verify battery capacity is ~ 80% of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test.

Revised SR 3.8.4.8 would state:

SR 3.8.4.8 Deleted In addition, the SR 3.8.4.8 surveillance frequency would be relocated to SR 3.8.6.9 and state:

In accordance with the Surveillance Frequency Control Program 12 months when battery shows degradation or has reached 85% of the expected life with capacity < 100% of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity

~ 100% of manufacturer's rating Evaluation of TS 3.8.4; Current SR 3.8.4.8 (Deleted and Relocated toTS 3.8.6); Change (9)

The licensee proposed deleting SR 3.8.4.8 and relocating the requirement to SR 3.8.6.9. The purpose of this SR is to demonstrate the operability of the battery; thus, this surveillance is relocated toTS 3.8.6, "Battery Parameters." This change is discussed further in Section 3.2.3, "TS 3.8.6 (Battery Parameters) Changes," of this SE.

3.2.2 TS 3.8.5 (DC Sources - Shutdown) Changes LCO 3.8.5 requires one DC electrical power subsystem (consisting of two batteries, one battery charger per battery and the corresponding control equipment and interconnecting cabling within the subsystem) to be operable to support the DC electrical power distribution subsystem(s) required by LCO 3.8.1 0, "Distribution Systems- Shutdown." TS 3.8.5 is applicable in MODE 5 and 6 and during movement of irradiated fuel assemblies.

The licensee proposed revising TS 3.8.5 Conditions, Required Actions, and SRs. Currently, TS 3.8.5 contains one Condition A for one or more required DC electrical power subsystems (exclusive of the battery charger) inoperable and two Conditions, Band C, for a required DC electrical subsystem battery charger inoperable. The licensee initially proposed to add a new Condition A to address the condition in which one required battery charger on one subsystem is

inoperable and to modify and renumber current Condition A. However, in its letter dated August 26, 2013, the licensee deleted the proposed new Condition A and submitted updated proposed changes. The updated proposed changes would delete existing Conditions B and C, and modify current Condition A to remove the exclusive statement. The changes toTS 3.8.5 are as follows:

3.2.2.1 TS 3.8.5: Current Condition A (Revised); Change (1)

Current TS 3.8.5 Condition A states:

A. One or more required DC electrical power subsystems (exclusive of the battery charger) inoperable.

Revised TS 3.8.5 Condition A would state:

A. One required DC electrical power subsystem inoperable.

TS 3.8.5 Required Actions remain unchanged and would state:

A.1 Declare affected required feature(s) inoperable.

A.2.1 Suspend CORE ALTERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies.

A.2.3 Initiate action to suspend operations involving positive reactivity additions.

A.2.4 Initiate action to restore required DC electrical power subsystems to OPERABLE status.

The TS 3.8.5 Required Action CTs remain unchanged and would state "Immediately."

Evaluation of TS 3.8.5: Current Condition A (Revised); Change (1)

The licensee proposed to delete "or more" and "exclusive of the battery charger" in the existing Condition A. PVNGS LCO 3.8.5 requires a single DC electrical power subsystem to be operable to support the DC electrical power distribution subsystems required by LCO 3.8.1 0, "Distribution Systems- Shutdown." According to PVNGS TS 3.8.1 0, although redundant required features may require redundant trains of electrical power distribution subsystems to be operable, one operable distribution subsystem is capable of supporting sufficient required

features to allow continuation of Core Alterations and fuel movement. The NRC staff concludes deleting "or more" acceptable because this change is consistent with the requirements of LCO 3.8.1 0, "Distribution Systems- Shutdown," referred in LCO 3.8.5. The revised Condition A would address the condition in which one required DC electrical power subsystem is inoperable.

The condition for an inoperable battery charger is embedded in revised Condition A and therefore, reflects the elimination of current Condition B (see below). The CT requires that one required DC electrical power subsystem (which includes a required battery charger) is returned to operable status immediately.

The Required Actions and Completion Times for current Condition A remain the same for revised Condition A. Declaring the required features inoperable with the associated DC power source also inoperable, restrictions will be implemented in accordance with the affected required features LCO Actions. Sufficiently conservative actions are made (i.e., to suspend Core Alterations, movement of irradiated fuel assemblies, and operations involving positive reactivity additions). The Completion Time "immediately" is consistent with the required times for actions requiring prompt attention.

Based on the above, the NRC staff concludes that the proposed change provides acceptable remedial actions as allowed by 10 CFR 50.36 and is acceptable.

3.2.2.2 TS 3.8.5; Current Conditions Band C (Deleted); Change (2)

The proposed change would delete the following Conditions B and C, the associated Required Actions B.1, B.2, and C.1, as well as their associated Required Action CTs.

Current Conditions B and C state:

B. Required DC electrical power subsystem battery charger inoperable.

C. Required Action and associated Completion Time of Condition B not met.

Current Required Actions B.1, B.2, and C.1 state:

8.1 Verify battery cell parameters meet Table 3.8.6.1 category A limits.

B.2 Restore DC electrical power subsystem battery charger to OPERABLE status.

C.1 Declare associated battery inoperable.

The current Required Action B.1 and B.2 CTs state:

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months The Required Action C.1 CT states:

Immediately Evaluation of TS 3.8.5; Current Conditions Band C (Deleted); Change (2)

Current Condition B applies when a required DC electrical power subsystem battery charger is inoperable. The Required Action B.1 requires verifying battery cell parameters meet TS Table 3.8.6-1 Category A limits. As discussed below, the licensee proposed removing Table 3.8.6-1 from the TS and relocating the Category A limits values to the new Battery Monitoring and Maintenance Program (see Section 3.2.3.3 of this SE for more details).

Accordingly, Condition B is deleted and the condition for an inoperable battery charger is included in revised Condition A by eliminating the exception "exclusive of the battery charger."

Current Condition C is also deleted because it is applicable when Required Action and Completion Time of current Condition B are not met.

Based on the above, the NRC concludes that the elimination of the current TS 3.8.5 Conditions Band Cis consistent with the elimination of Table 3.8.6-1 from the TS and is, therefore, acceptable.

3.2.2.3 TS 3.8.5; SR 3.8.5.1 (Revised); Change (3)

The proposed change would modify SR 3.8.5.1 to reflect the changes previously described in Section 3.2.1 of this SE.

Current SR 3.8.5.1 states:

SR 3.8.5.1 - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - -

The following SRs are not required to be performed: SR 3.8.4.6, SR 3.8.4.7, and SR 3.8.4.8.

For DC sources required to be OPERABLE, the following SRs are applicable:

SR 3.8.4.1 SR 3.8.4.4 SR 3.8.4.7 SR 3.8.4.2 SR 3.8.4.5 SR 3.8.4.8.

SR 3.8.4.3 SR 3.8.4.6 Revised SR 3.8.5.1 would state:

SR 3.8.5.1 - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - -

The following SRs are not required to be performed: SR 3.8.4.6 and SR 3.8.4.7.

For DC sources required to be OPERABLE, the following SRs are applicable:

SR 3.8.4.1 SR 3.8.4.6 SR 3.8.4.7 The SR 3.8.5.1 surveillance frequency remains unchanged and would state "In accordance with applicable SRs."

Evaluation of TS 3.8.5; SR 3.8.5.1 (Revised); Change (3)

The licensee proposed modifying SR 3.8.5.1 to be consistent with the proposed changes to TS 3.8.4. The revised SR 3.8.5.1 would require the licensee to perform SR 3.8.4.1. The Intent of the Note is that SRs 3.8.4.6 and 3.8.4.7 must still be capable of being met, but actual performance is not required. SRs 3.8.4.2, 3.8.4.3, 3.8.4.4, 3.8.4.5, and 3.8.4.8 are to be deleted from TS 3.8.4, and therefore will not be applicable anymore. The NRC staff has reviewed the proposed change and determined that the change is consistent with the proposed changes to TS 3.8.4 and meet the intent of the SR.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and is therefore acceptable.

3.2.3 TS 3.8.6 (Battery Parameters) Changes The licensee proposed replacing the battery specific gravity monitoring with the float current monitoring for determining the state of charge (OPERABILITY). The licensee also proposed revising the LCO, and existing TS 3.8.6 Conditions, Required Actions, SRs, deleting Table 3.8.6-1, and relocating some of the surveillances to the newTS 5.5.19, "Battery Monitoring and Maintenance Program."

3.2.3.1 TS 3.8.6; Title (Revised); Change (1)

The proposed change would revise the title of TS 3.8.6 from "Battery Cell Parameters" to "Battery Parameters."

Evaluation of TS 3.8.6; Title (Revised); Change (1)

The NRC staff concludes that the proposed change is editorial in nature and is, therefore, acceptable.

3.2.3.2 TS 3.8.6; LCO 3.8.6 (Revised); Change (2)

Current LCO 3.8.6 states:

LCO 3.8.6 Battery cell parameters for the Train A and Train B batteries shall be within the limits of Table 3.8.6-1.

Revised LCO 3.8.6 would state:

LCO 3.8.6 Battery parameters for the Train A and Train B electrical power subsystem batteries shall be within limits.

Evaluation of TS 3.8.6; LCO 3.8.6 (Revised); Change (2)

Adding "electrical power subsystem" is consistent with the LCO 3.8.4 and LCO 3.8.5 descriptions of the separate and independent electrical power subsystems. Deleting the reference to Table 3.8.6-1 is consistent with the licensee proposed change to remove the table from the TS. As stated in Section 3.2.3.3 below, the Battery Parameter limits have been relocated toTS 5.5.19 and to new SRs and LCOs (see Section 3.2.3.3 for more details).

The NRC staff reviewed the proposed change to the LCO 3.8.6 and has determined that the change appropriately reflects the PVNGS electrical system nomenclature. The NRC staff also concludes that the change is editorial in nature and consistent with the other proposed changes in TS 3.8.6, and therefore, is acceptable.

3.2.3.3 TS 3.8.6; Table 3.8.6-1 (Deleted); Change (3)

The proposed change would delete Table 3.8.6-1, "Battery Surveillance Requirements."

TS Table 3.8.6-1 specifies the requirements (Categories A, B, and C limits) for the battery cell parameters (electrolyte level, float voltage, and specific gravity).

The proposed change would relocate Category A and B limits of the table and the required actions associated with restoring the battery cell parameters to within limits to TS 5.5.19, and retain Category C limits in the new SRs and LCOs of the TS.

Evaluation of TS 3.8.6; Table 3.8.6-1 (Deleted); Change (3)

TS Table 3.8.6-1 Category A defines the parameters normal limits for each designated pilot cell, Category B defines the normal limits for each connected cell, and Category C defines the allowable limits for each connected cell.

By letter dated August 26, 2013, the licensee clarified that current TS Table 3.8.6-1 Category A and B limits for electrolyte level and float voltage as well as Category B limit for specific gravity will be incorporated into the Battery Monitoring and Maintenance Program. The licensee also stated that TS Table 3.8.6-1 Category A limit for specific gravity will not be relocated because specific gravity is no longer monitored for pilot cells. The licensee proposed to replace specific gravity measurements for pilot cells to determine battery state of charge with float current monitoring (see Section 3.2.3.4 of this SE regarding the NRC staff's evaluation for the licensee's proposed float current monitoring). The Category A and B limits of TS Table 3.8.6-1 represent appropriate monitoring levels and appropriate preventive maintenance levels fo( long-term battery quality and extended battery life. The licensee stated that actions to restore deficient values will be implemented in accordance with PVNGS corrective action program.

The NRC staff concludes relocating Category A and B limits for the battery cell parameters and the required actions associated with restoration to the new TS Battery Monitoring and Maintenance Program acceptable because (1) battery capacity is considered adequate when electrolyte level is above the top of the plates; (2) an individual battery cell float voltage criterion of greater than or equal to 2.13 V is a maintenance limit; (3) specific gravity measurement criteria are being replaced with float current monitoring; and (4) the licensee provided assurance that these battery parameter values will continue to be controlled at their current level, and that actions to restore deficient values will be implemented in accordance with the licensee's corrective action program. This relocation will continue to assure that the battery is maintained at current levels of performance, and that operators appropriately focus on monitoring the battery float current and voltage for indication of degradation.

By letter dated August 26, 2013, the licensee stated that a Category C limit will not be relocated to the Battery Monitoring and Maintenance Program because corrective actions will be initiated at the more restrictive Category B limits; however, Category C limits for electrolyte level and float voltage will be moved to the proposed TS 3.8.6, Conditions C and A, respectively. In addition, the proposed new SRs 3.8.6.4, 3.8.6.6, and 3.8.6.8 will require monitoring of battery float current (instead of cells specific gravity), connected cell electrolyte level, and connected cell float voltage respectively (see Sections 3.2.3.13, 3.2.3.15 and 3.8.17 of this SE for the NRC staff evaluation of the new proposed SRs). These new SRs will satisfy the intent of the Category C limits. Therefore, the NRC staff concludes the elimination of TS Table 3.8.6-1 Category C limits is acceptable.

Based on discussion above, the NRC staff concludes that relocating the battery parameters (Electrolyte Level, Float Voltage, Specific Gravity) to the Battery Monitoring and Maintenance Program and to TS 3.8.6 Conditions A and C are justified since these parameters will continue be controlled at their current level; therefore, the proposed change to delete TS Table 3.8.6-1 is acceptable.

3.2.3.4 TS 3.8.6; Float Current Monitoring (Added to Replace Specific Gravity Measurement); Change (4)

The proposed change would replace requirements to measure specific gravity to determine the battery state of charge with requirements to monitor float current and relocate requirements to obtain specific gravity readings to the new Battery Monitoring and Maintenance Program specified in TS 5.5.19.

Evaluation of TS 3.8.6; Float Current Monitoring (Added to Replace Specific Gravity Measurement); Change (4)

Currently, battery cell specific gravity verification is required by SRs 3.8.6.1 and 3.8.6.2. To determine the battery state of charge, the licensee proposed replacing the requirement to measure specific gravity with the requirement to monitor float current. Float current monitoring is recognized by the industry as being a more direct and expeditious method for determining battery state of charge than specific gravity monitoring. NUREG/CR-7148, "Confirmatory Battery Testing: The use of Float Current Monitoring to Determine Battery State-of-Charge,"

November 2012 (ADAMS Accession No. ML12313A413), validated the use of float current as an adequate means to determine battery state-of-charge. In an enclosure to the LAR dated December 26, 2012, the licensee provided a letter from the PVNGS Class 1E battery manufacturer, which stated that the concept of utilizing float current levels of a flooded, stationary string battery to determine a state of charge throughout the life of the battery is reasonable. By letter dated August 26, 2013, the licensee stated that the conclusions of NUREG/CR-7148, which documented specific testing of a different size of the same GNB (PVNGS Class 1E battery manufacturer) battery model NCN used for the PVNGS Class 1E batteries, are applicable to the PVNGS batteries. Furthermore, the licensee stated that based on the NUREG and industry experience, including IEEE-450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations," the use of float current is a reliable and accurate indication of the state-of-charge of PVNGS batteries.

The licensee proposed a float current of 2 amps. In the enclosure to the LAR, the letter from the battery manufacturer stated, in part, the following:

There is a relationship between percentage of ampere-hours returned following a successful discharge capacity test and battery state of charge.

The charge current of each battery can be affected by impurity levels, age, operating environment and maintenance history.

In its letter dated August 26, 2013, the licensee stated that after reviewing the exponential time constant discussed in Appendix A of NUREG/CR-7148, it determined that the proposed 2-amp

float current provides an indication that the batteries are at least 95 percent charged and includes sufficient conservatism to address minor deviations from impurities, age, operating environment and maintenance history. Furthermore, the licensee stated that after adding 5 percent design margin to cover uncertainties related to the 2-amp charging current, the batteries will have sufficient margin to perform their design functions. In Attachment 2 of the LAR, the licensee provided a commitment to change or verify that the UFSAR describes how a 5 percent design margin for the batteries corresponds to a 2-amp float current value indicating that the battery is 95 percent charged (see Section 4.0 of this SE for additional discussion regarding regulatory commitments).

In Section 2.2 of the LAR, the licensee stated that the equipment that will be used to monitor float current under SR 3.8.6.4 will have the necessary accuracy and capability to measure electrical currents in the expected range.

The NRC staff concludes that the licensee's verifications of the battery manufacturer specifications regarding the use of float current measurement to determine the battery's state of charge based on NUREG/CR-7148 and the addition of 5 percent design margin for the batteries to cover the uncertainties related to the 2-amp float current value, which indicates that the battery is at least 95 percent charged, provide adequate assurance that replacing the specific gravity measurements with the float current monitoring will not have a significant impact on the ability to accurately determine the operability of the batteries. The NRC staff concludes that float current monitoring is a suitable replacement for specific gravity monitoring when used to determine a battery's state of charge.

Specific gravity monitoring is appropriate for troubleshooting activities and for periodic trending of the battery's state-of-health. The licensee will continue taking and trending specific gravity measurements during maintenance and testing activities prior to performing a battery service test, battery performance discharge test, or modified performance discharge test in accordance with the new proposed Battery Monitoring and Maintenance Program in TS 5.5.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and is, therefore, acceptable.

3.2.3.5 TS 3.8.6; Current Condition A (Deleted); Change (5)

The proposed change would delete current Condition A with its associated Required Actions and CTs.

Current Condition A states:

A. One or more batteries with one or more battery cell parameters not within Category A or B limits.

Current Condition A Required Actions state:

A.1 Verify pilot cells electrolyte level and float voltage meet Table 3.8.6-1 Category C limits.

A.2 Verify battery cell parameters meet Table 3.8.6-1 Category C limits.

A.3 Restore battery cell parameters to Category A and B limits of Table 3.8.6-1.

Current Required Action CTs to be deleted are "1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ," for A.1, "24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND Once per 7 days thereafter," for A.2, and "31 days" for A.3.

Evaluation of TS 3.8.6; Current Condition A (Deleted); Change (5)

The NRC staff concludes that the elimination of current Condition A with its associated Required Actions and CTs is consistent with the elimination of TS Table 3.8.6-1 (see Section 3.2.3.3 of this SE) and, therefore, is acceptable.

3.2.3.6 TS 3.8.6; New Condition A (Added); Change (6)

The proposed change would add a new Condition A to address what was formerly the Category C limit for float voltage in TS Table 3.8.6-1.

New Condition A would state:

A. One battery with one or more battery cells float voltage s 2. 07V.

New Condition A Required Actions would state:

A.1 Perform SR 3.8.4.1.

A.2 Perform SR 3.8.6.4.

A.3 Restore affected cell voltage> 2.07 V.

New Condition A CTs would state "2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months " for Required Actions A.1 and A.2 and "24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " for Required Action A.3.

Evaluation of TS 3.8.6; New Condition A (Added); Change (6)

In the LAR, the licensee proposed a Condition A that would be applicable when in a battery, one or more battery cells are found with a float voltage less than 2.07 V. In its letter dated August 26, 2013, the licensee updated the new Condition A float voltage limit to less than or equal 2.07 V for consistency with the current TS Table 3.8.6-1 Category C limiting value. This limiting value is based on PVNGS batteries vendors' recommendations which state that a cell voltage of 2.07 V or below, under float conditions and not caused by elevated temperature of the cell, indicates internal cell problems and may require cell replacement. Condition A contains remedial measures (Required Actions) for the condition of a degraded battery cell. The Required Actions require the licensee to verify: (a) the battery terminal voltage to be greater than or equal to the minimum established float voltage (SR 3.8.4.1}, and (b) each battery's float current is less than or equal to 2 amps (SR 3.8.6.4). The above actions ensure that there is still sufficient capacity for the battery to perform its intended function. Continued operations for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months are proposed to allow the restoration of the affected cell(s) voltage to greater than 2.07 V. The NRC staff concludes that the required actions and completion times are reasonable. In attachment 2 of the LAR, the licensee provided a commitment to change or verify that the UFSAR states the minimum established design limit for battery terminal float voltage. This provides additional reasonable assurance that the value will appropriately reflect the design of the plant (see Section 4.0 of this SE for additional discussion regarding regulatory commitments).

Based on the above, the NRC staff concludes that the proposed change provides acceptable remedial actions as allowed by 10 CFR 50.36 and is acceptable.

3.2.3.7 TS 3.8.6; New Condition B (Added); Change (7)

The proposed change would add new Condition B to address the battery state of charge.

New Condition B would state:

B. One battery with float current > 2 amps.

New Condition B Required Actions would state:

B.1 Perform SR 3.8.4.1.

B.2 Restore float current to ::; 2 amps.

New Condition B CTs would state "2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months " for Required Action B.1 and "12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " for Required Action B.2.

Evaluation of TS 3.8.6; New Condition B (Added); Change (7)

The proposed new Condition B would be applicable when one battery is found with a float current greater than 2 amps. A float current of greater than 2 amps provides an indication that a

partial discharge has occurred. The Required Action B.1 is to verify within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months that the battery terminal voltage is greater than or equal to the minimum established float voltage (SR 3.8.4.1 }, thus confirming battery charger operability. Required Action B.2 ensures that within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months the battery will be restored to its fully-charged condition from any discharge that might have occurred due to a temporary loss of the battery charger. By letter dated August 26, 2013, the licensee stated that PVNGS battery charger is required per UFSAR Section 8.3.2.1.2.2 to be capable of restoring the battery to the fully charged state within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The licensee also stated that, "the 12-hour CT takes into account the capacity and capability of the remaining DC sources, a reasonable time for repairs, and the low probability of a design basis accident occurring during this period."

If the terminal voltage is found to be less than the minimum established float voltage, it indicates that the battery charger is either inoperable or is operating in the current limit mode. If the battery charger is operating in the current limit mode for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , it indicates that the battery has been substantially discharged and likely cannot perform its required design functions. In this case, new Condition F would be entered.

Based on the above, the NRC staff concludes that the proposed change provides acceptable remedial actions as allowed by 10 CFR 50.36 and is acceptable.

3.2.3.8 TS 3.8.6; New Condition C (Added); Change (8)

The proposed change would add new Condition C to address the level of the electrolyte in a cell.

New Condition C would state:

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

Required Action C.2 shall be completed if electrolyte level was below the top of plates.

C. One battery with one or more cells electrolyte level less than minimum established design limits.

New Condition C Required Actions would state:

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

Required Actions C.1 and C.2 are only applicable if electrolyte level was below the top of plates.

C.1 Restore electrolyte level to above top of plates.

C.2 Verify no evidence of leakage.

C.3 Restore electrolyte level to greater than or equal to minimum established design limits.

New Condition C CTs would state "8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months " for Required Action C.1, "12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " for Required Action C.2, and "31 days" for Required Action C.3.

Evaluation of TS 3.8.6; New Condition C (Added); Change (8)

The proposed new Condition C would apply when one battery is found with one or more cells with an electrolyte level less than the minimum established design limits. If the electrolyte level is above the top of the battery plates, but below the minimum limit (i.e., minimum level indication mark on the battery cell jar), the battery should still have sufficient capacity to perform its intended safety function. The affected battery is not required to be considered inoperable solely as a result of electrolyte level not met. Required Action C.3 restores the electrolyte level to greater than or equal to the minimum established design limits within 31 days.

With the electrolyte level below the top of the plates, there is a potential for dry-out and plate degradation. New Required Actions C.1 and C.2 restore the electrolyte level to above top of the plates within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and ensure that the cause of the loss of the electrolyte level is not due to a leak in the battery cell jar within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . These actions are modified by a note that indicates they are only applicable if electrolyte level is below the top of the plates. Additionally, provisions in the new Battery Monitoring and Maintenance Program initiate actions to equalize and test the battery cells that have been discovered with an electrolyte level below the top of the plates.

Therefore, the new Required Actions ensure the batteries will be restored to an operable condition in a timely manner.

Based on the above, the NRC staff concludes that the proposed change provides acceptable remedial actions as allowed by 10 CFR 50.36 and is acceptable.

3.2.3.9 TS 3.8.6; New Condition 0 (Added); Change (9)

The proposed change would add new Condition 0 to address the electrolyte temperature of a pilot cell.

New Condition D would state:

D. One battery with pilot cell electrolyte temperature less than minimum established design limits.

New Condition D Required Action D.1 would state:

D.1 Restore battery pilot cell temperature to greater than or equal to minimum established design limits.

New Condition D CT for Required Action D.1 would state "12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ."

Evaluation of TS 3.8.6; New Condition D (Added); Change (9)

The proposed new Condition D would apply when one battery is found with a pilot cell electrolyte temperature less than the minimum established design limit. A low electrolyte temperature limits the current and power available from the battery.

The licensee stated, in its letter dated August 26, 2013, that PVNGS batteries are sized with a temperature correction factor of 1.11 for a loss-of-coolant accident (LOCA) event based on an electrolyte temperature of 60 °F, which is the same as the design basis minimum battery room temperature, and 1.30 for an SBO event based on an assumed room temperature of 40 °F. A 5 percent design margin will also be maintained to ensure that the batteries will perform their design functions at 95 percent charged. Furthermore, the licensee stated that the battery room temperature is monitored at least once a day through operator logs. The functions of the control building heating, ventilation, and air conditioning (HVAC) systems (normal and essential) and the battery room exhaust fans are continually monitored in the control room, and operators respond to trouble alarms in accordance with plant procedures. The UFSAR Section 9.4.1, Table 9.4-2 specifies that the control building HVAC system maintains the battery room temperature between a minimum and maximum of 60-85 °F.

Based on the above considerations and the fact that batteries have very large thermal inertia, the NRC staff concludes that it is highly likely that a room temperature excursion would be corrected by the licensee prior to the battery electrolyte reaching its maximum or minimum design temperature.

Due to the use of pilot cell temperature in lieu of average cell temperature and the use of 2.07 V as the minimum limit for cell voltage, changes are necessary in the method pilot cells are selected. By letter dated August 26, 2013, the licensee stated that the implementation of the battery maintenance and monitoring program will utilize pilot cell selection based on the lowest individual cell voltages for each battery.

Based on this information, the NRC staff concludes that the pilot cell temperature is a sufficiently accurate representation of the temperature of the battery bank because:

( 1) batteries have very large thermal inertia; (2) PVNGS batteries are designed with sufficient margins (i.e., temperature, aging, and design); and (3) the licensee monitors and corrects low battery room temperatures. Therefore, the proposed 12-hour CT provides adequate time to restore the electrolyte temperature within established limits.

Based on the above, the NRC staff concludes that the proposed change provides acceptable remedial actions as allowed by 10 CFR 50.36 and is acceptable.

3.2.3.1 0 TS 3.8.6; New Condition E (Added); Change (1 0)

The proposed change would add new Condition E to address battery parameters.

New Condition E would state:

E. One or more batteries in redundant subsystems with battery parameters not within limits.

New Condition E Required Action E.1 would state:

E.1 Restore battery parameter for batteries in one subsystem to within limits.

New ConditionE CT for Required Action E.1 would state "2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ."

Evaluation of TS 3.8.6; New Condition E (Added); Change (1 0)

The licensee proposed adding newTS 3.8.6 ConditionE to address the condition where one or more batteries in redundant subsystems have battery parameters not within limits. If this condition exists, there is not sufficient assurance that the batteries will be capable of performing their intended safety function. With redundant batteries involved, loss of function is possible for multiple systems that depend upon the batteries. The licensee proposed that battery parameters for the affected battery in one subsystem be restored to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

The NRC staff considers the 2-hour time period to be consistent with similar LCOs established by the TS (i.e., TS 3.8.9 Distribution Systems- Operating) and reasonable considering the potential for loss of function of components that depend on the batteries (i.e., AC vital bus subsystem(s), electrical breaker control/position indication power). Accordingly, a relatively short duration is provided to resolve the condition.

Based on the above, the NRC staff concludes that the proposed change provides acceptable remedial actions as allowed by 10 CFR 50.36 and is, therefore, acceptable.

3.2.3.11 TS 3.8.6; Current Condition B (Revised and Renumbered as Condition F); Change (11)

The proposed change would revise current Condition B to address conditions of battery inoperability and renumber it as Condition F.

Current Condition B states:

B. Required Action and associated Completion Time of Condition A not met.

One or more batteries with average electrolyte temperature of the representative cells< 60°F.

One or more batteries with one or more battery cell parameters not within Category C limits.

Revised and renumbered Condition F would state:

F. Required Action and associated Completion Time of Condition A, B, C, D orE not met.

One battery with one or more battery cell float voltage:::;; 2.07 V and float current > 2 amps.

Current Required Action 8.1 states:

8.1 Declare associated battery inoperable.

Revised and renumbered Required Action F.1 would st~te:

F.1 Declare associated battery inoperable.

The CT for Required Action 8.1 renumbered as Required Action F.1 CT remains unchanged and would state "Immediately."

Evaluation of TS 3.8.6; Current Condition 8 (Revised and Renumbered as Condition F);

Change (11)

Current Condition 8 describes three Conditions of battery inoperability. The last two entry Conditions (i.e., average electrolyte temperature of the representative cells less than 60°F or, battery cells parameters not within Category C limits) are deleted. The licensee proposed to monitor pilot cell electrolyte temperature (newTS 3.8.6 Condition D and SR 3.8.6.7) instead of the average electrolyte temperature and remove TS Table 3.8.6-1 Category C limits from the TS. The NRC staff concludes the elimination of the last two entries of current Condition 8 is consistent with the licensee's proposed changes and therefore acceptable.

The revised current Condition 8 is renumbered as Condition F. The renumbered Condition F provides a default condition for battery parameters that fall outside the allowance of the

Required Actions for Condition A, B, C, D, or E. Under this condition, it is assumed that there is insufficient capacity to supply the maximum expected load requirements. Condition F also addresses a new alternate condition where one battery is found with one or more battery cells having a float voltage less than or equal to 2.07 V (newTS 3.8.6 Condition A) and a float current greater than 2 amps (new TS 3.8.6 Condition B). In this case, the battery may not have sufficient capacity to perform its intended design function. The Required Action for either of these entry conditions is to declare the associated battery inoperable immediately. The Required Action and associated CT are reasonable and consistent with battery inoperability specified in new Condition F.

Based on the above, the NRC staff concludes that the proposed change provides acceptable remedial actions as allowed by 10 CFR 50.36 and is acceptable.

3.2.3.12 TS 3.8.6; Existing SRs 3.8.6.1. 3.8.6.2, and 3.8.6.3 (Deleted); Change (12)

The proposed change would delete requirements in SR 3.8.6.1 to verify battery cell parameters meet TS Table 3.8.6-1 Category A limits; SR 3.8.6.2 to verify battery cell parameters meet Table 3.8.6-1 Category B limits; and SR 3.8.6.3 to verify average electrolyte temperature of representative cells.

Current SRs 3.8.6.1 through 3.8.6.3 state:

SR 3.8.6.1 Verify battery cell parameters meet Table 3.8.6-1 Category A limits.

SR 3.8.6.2 Verify battery cell parameter meet Table 3.8.6-1 Category B limits.

SR 3.8.6.3 Verify average electrolyte temperature of representative cells is

60°F.

Revised SRs 3.8.6.1 through 3.8.6.3 would state:

SR 3.8.6.1 Deleted SR 3.8.6.2 Deleted SR 3.8.6.3 Deleted The associated surveillance frequencies for SRs 3.8.6.1 and 3.8.6.3, which state "In accordance with the Surveillance Frequency Control Program," would be deleted. The associated surveillance frequency for SR 3.8.6.2, which states "In accordance with the Surveillance Frequency Control Program AND Once within 7 days after battery discharge < 105 V AND Once within 7 days after battery overcharge > 150 V," would be deleted.

Evaluation of TS 3.8.6; Current SRs 3.8.6.1, 3.8.6.2. and 3.8.6.3 (Deleted); Change (12)

The Table 3.8.6-1, Category A and B limits do not represent a condition in which the batteries cannot perform their function. As discussed in Section 3.2.3.3, the NRC staff concludes

relocating the TS Table 3.8.6-1 Category A and B limits for electrolyte level and individual battery cell float voltage and Category B limits for specific gravity and the remedial actions associated with restoring the battery cell parameters to within limits is acceptable. The proposed change ensures the battery parameters (maintenance, testing, and monitoring levels) are appropriately monitored and maintained in accordance with the new Battery Monitoring and Maintenance Program, as specified in TS Section 5.5.19. In addition, the proposed float current monitoring (See Section 3.2.3.4 of this SE for the NRC staff's evaluation) satisfies the intent of SRs 3.8.6.1 and 3.8.6.2.

The NRC staff concludes the elimination of current SR 3.8.6.1 and SR 3.8.6.2 is consistent with the elimination of TS Table 3.8.6.1 from the TS and therefore acceptable.

Current SR 3.8.6.3 will be replaced with new SR 3.8.6.7 (see Section 3.2.3.16 of this SE for more details).

The NRC staff concludes that the proposed change discussed above and the new SRs described in the following sections provide assurance that battery quality and operability will continue to be maintained; therefore, the proposed change is acceptable.

3.2.3.13 TS 3.8.6; New SR 3.8.6.4 (Added); Change (13)

The proposed change would add new SR 3.8.6.4.

New SR 3.8.6.4 would state:

SR 3.8.6.4 - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - -

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

Verify each battery float current iss 2 amps.

New SR 3.8.6.4 surveillance frequency would state:

In accordance with the Surveillance Frequency Control Program Evaluation of TS 3.8.6; New SR 3.8.6.4 (Added); Change (13)

The purpose of this SR is to determine the state of charge of the battery. Float charge is the condition in which the battery charger is supplying the continuous small amount of current (i.e., less than or equal to 2 amps) required to overcome the internal losses of a battery to maintain the battery in a fully charged state. The float current requirements are based on the float current indicative of a charged battery. As stated above in Section 3.2.3.4, the use of float current to determine the state of charge of the battery is consistent with the battery manufacturer recommendations.

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.4 in the Surveillance Frequency Control Program (SFCP) required by TS 5.5.18, for consistency

with PVNGS adoption of TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control- RITSTF Initiative 5b." The current PVNGS TSs have incorporated TSTF-425, which allows the licensee to relocate most periodic frequencies of TS surveillances and their bases to the SFCP required by TS 5.5.18. According to TSTF-425, all frequencies can be relocated to the SFCP except:

Frequencies that reference other approved programs for the specific interval (such as the In-Service Testing Program or the Primary Containment Leakage Rate Testing Program);

Frequencies that are purely event-driven (e.g., "each time the control rod is withdrawn to the 'full out' position");

Frequencies that are event-driven, but have a time component for performing the surveillance on a one-time basis once the event occurs (e.g., "within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after thermal power reaching > 95 percent RTP [rated thermal power]"); and

Frequencies that are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of a surveillance requirement (e.g., "drywell to suppression chamber differential pressure decrease").

In addition, the TS Bases of the affected surveillances are to be revised to state that the frequency is set in accordance with the SFCP. The surveillance frequency for new SR 3.8.6.4 is for verification of float current. The frequency does not reference other approved programs, is not event-driven, and is not related to a specific condition of the battery. TS Bases for new SR 3.8.6.4 are revised to state that the surveillance frequency is controlled under the SFCP.

Furthermore, as stated in TS 5.5.18, changes to the frequencies listed in the SFCP shall be made in accordance with NEI 04-10, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies," Revision 1. Controlling new SR 3.8.6.4 frequency under the SFCP is consistent with TSTF-425 requirements, and the SFCP provides assurance that the frequency will effectively be changed in accordance with NEI 04-10.

This SR is modified by a Note which states that SR 3.8.6.4 is not required to be met when the battery terminal voltage is less than the minimum established float voltage of SR 3.8.4.1. When this float voltage is not maintained, the Required Actions of LCO 3.8.4 Action A are being taken, which provide the necessary and appropriate verifications of the battery condition. Furthermore, the float current limit of 2 amps is established based on the nominal float voltage value and is not directly applicable when this voltage is not maintained.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and it is, therefore, acceptable.

3.2.3.14 TS 3.8.6; New SR 3.8.6.5 (Added); Change (14)

The proposed change would add new SR 3.8.6.5.

New SR 3.8.6.5 would state:

SR 3.8.6.5 Verify each battery pilot cell float voltage is> 2.07 V.

New SR 3.8.6.5 surveillance frequency would state:

In accordance with the Surveillance Frequency Control Program Evaluation of TS 3.8.6; New SR 3.8.6.5 (Added); Change (14)

The voltage level of the new SR 3.8.6.5 represents the point at which battery operability cannot be assured. Optimal long-term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to 130.2 V at the battery terminals, or 2.17 Vpc per cell for 60-cell battery. This provides adequate over-potential, which limits the formation of lead sulfate and self-discharge, which could eventually render the battery inoperable. As stated in the revised TS Bases forTS 3.8.6, the float voltage at the battery terminals is maintained between 2.17 and 2.25 Vpc. Float voltages in this range or less, but greater than 2.07 Vpc, are addressed in the revised Battery Monitoring and Maintenance Program. The program includes actions to restore battery cells with float voltage less than 2.13 V and actions to verify that the remaining cells are greater than or equal to 2.13 V when a cell or cells have been found to be less than 2.13 V. The 2.07 V individual cell limit reflects the operability limit for the batteries.

With all battery cells above 2.07 V, there is adequate assurance that that the terminal voltage is at an acceptable threshold for establishing battery operability.

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.5 in the SFCP required by TS 5.5.18. The surveillance frequency for new SR 3.8.6.5 is for verification of pilot cell float voltage. The frequency does not reference other approved programs, is not event-driven, and is not related to a specific condition of the battery. TS Bases for new SR 3.8.6.5 are revised to state that the surveillance frequency is controlled under the SFCP. Additional details of the NRC staff evaluation for this similar change can be found in Section 3.2.3.13 of this SE.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and is, therefore, acceptable.

3.2.3.15 TS 3.8.6; New SR 3.8.6.6 (Added); Change (15)

The proposed change would add new SR 3.8.6.6.

New SR 3.8.6.6 would state:

SR 3.8.6.6 Verify each battery connected cell electrolyte level is greater than or equal to minimum established design limits.

New SR 3.8.6.6 surveillance frequency would state:

In accordance with the Surveillance Frequency Control Program The proposed change would relocate the minimum established design limits for the battery electrolyte level to a licensee-controlled program.

Evaluation of TS 3.8.6; New SR 3.8.6.6 (Added); Change (15)

New SR 3.8.6.6 would require the connected cells electrolyte level to be greater than or equal to the "minimum established design limits." Operation of the batteries at electrolyte levels greater than the minimum established design limit ensures that the battery plates do not suffer physical damage and continue to maintain adequate electron transfer capability.

Relocating the minimum established design limits for the battery electrolyte level to a licensee-controlled program will allow flexibility to monitor and control this limit at values directly related to the battery ability to perform its required safety function. In Attachment 2 of the LAR, the licensee provided a commitment to change or verify that the UFSAR states the minimum established design level limit for electrolyte level. This provides additional reasonable assurance that the value will be appropriately maintained by the licensee to accurately reflect the design of the plant battery system (see section 4.0 for additional discussion regarding regulatory commitments).

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.6 in the SFCP required by TS 5.5.18. The surveillance frequency for new SR 3.8.6.6 is for verification of each battery connected cell electrolyte level. The frequency does not reference other approved programs, is not event-driven, and is not related to a specific condition of the battery. TS Bases for new SR 3.8.6.6 are revised to state that the surveillance frequency is controlled under the SFCP. Additional details of the NRC staff evaluation for this similar change can be found in Section 3.2.3.13 of this SE.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and is, therefore, acceptable.

3.2.3.16 TS 3.8.6; New SR 3.8.6.7 (Added); Change (16)

The proposed change would add new SR 3.8.6.7.

New SR 3.8.6.7 would state:

SR 3.8.6.7 Verify each battery pilot cell temperature is greater than or equal to minimum established design limits.

New SR 3.8.6. 7 surveillance frequency would state:

In accordance with the Surveillance Frequency Control Program The proposed change would relocate the minimum established design limits for the pilot cell temperature to a licensee-controlled program.

Evaluation of TS 3.8.6; New SR 3.8.6.7 (Added); Change (16)

New SR 3.8.6.7 would replace existing SR 3.8.6.3, which required verifying the average (versus pilot cell) electrolyte temperature for every frequency interval specified in the Surveillance Frequency Control Program. Batteries have very large thermal inertia, PVNGS batteries are designed with margins to account for factors affecting performance (i.e.,

temperature, aging), and there is monitoring to maintain optimum battery room temperatures.

As a result, the pilot cell temperature is an accurate representation of the temperature of the battery bank and is adequate to ensure that the minimum electrolyte temperature is maintained.

Depending on the available excess capacity of the associated battery, the minimum temperature necessary to support operability of the battery can vary. Relocating the minimum established design limit for the battery electrolyte temperature to the Battery Monitoring and Maintenance Program will allow flexibility to monitor and control this limit at values directly related to the battery ability to perform its intended function. In Attachment 2 of the LAR, the licensee provided a commitment to change or verify that the USFAR states the minimum established design limit for electrolyte temperature. This provides additional reasonable assurance that the value will be appropriately maintained by the licensee to accurately reflect the design of the plant battery system (see Section 4.0 of this SE for additional discussion regarding regulatory commitments).

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.7 in the SFCP required by TS 5.5.18. The surveillance frequency for new SR 3.8.6.7 is for verification of each battery pilot cell temperature. The frequency does not reference other approved programs, is not event-driven, and is not related to a specific condition of the battery. TS Bases for new SR 3.8.6.7 are revised to state that the surveillance frequency is controlled under the SFCP.

Additional details of the NRC staff evaluation for this similar change can be found in Section 3. 2. 3.13 of this SE.

Based on the above, the NRC staff concludes that the pilot cell temperature is an accurate representation of the temperature of the battery bank. The NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the

necessary quality of systems and components is maintained and that the LCOs will be met and is therefore acceptable.

3.2.3.17 TS 3.8.6; New SR 3.8.6.8 (Added); Change (17)

The proposed change would add new SR 3.8.6.8.

New SR 3.8.6.8 would state:

SR 3.8.6.8 Verify each battery connected cell float voltage is> 2.07 V.

New SR 3.8.6.8 surveillance frequency would state:

In accordance with the Surveillance Frequency Control Program Evaluation of TS 3.8.6; New SR 3.8.6.8 (Added); Change (17)

This voltage level of the new SR 3.8.6.8 represents the point at which battery operability cannot be assured. Optimal long term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to 130.2 V at the battery terminals, or 2.17 Vpc. This provides adequate over-potential, which limits the formation of lead sulfate and self-discharge, which could eventually render the battery inoperable. As stated in the revised TS Bases forTS 3.8.6, the float voltage at the battery terminals is maintained between 2.17 and 2.25 Vpc. Float voltages in this range or less, but greater than 2.07 Vpc, are addressed in the revised Battery Monitoring and Maintenance Program. The program will include actions to restore battery cells with float voltage less than 2.13 V and actions to verify that the remaining cells are greater than or equal to 2.13 V when a cell or cells have been found to be less than 2.13 V. The 2. 07 V individual cell limit reflects the operability limit for the batteries. With all battery cells above 2.07 V, there is adequate assurance that the terminal voltage is at an acceptable threshold for establishing battery operability.

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.8 in the SFCP required by TS 5.5.18. The surveillance frequency for new SR 3.8.6.8 is for verification of each battery connected cell float voltage. The frequency does not reference other approved programs, is not event-driven, and is not related to a specific condition of the battery. TS Bases for new SR 3.8.6.8 are revised to state that the surveillance frequency is controlled under the SFCP. Additional details of the NRC staff evaluation for this similar change can be found in Section 3.2.3.13 of this SE.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and is, therefore, acceptable.

3.2.3.18 TS 3.8.6; New SR 3.8.6.9 (Relocated - Existing SR 3.8.4.8); Change (18)

The proposed change would relocate current SR 3.8.4.8 to new SR 3.8.6.9 as follows:

New SR 3.8.6.9 would state:

SR 3.8.6.9 - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - -

This Surveillance shall not be performed in MODE 1, 2, 3, or 4.

However, credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is ~ 80% of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test.

New SR 3.8.6.9 surveillance frequency would state:

In accordance with the Surveillance Frequency Control Program 12 months when battery shows degradation or has reached 85% of the expected life with capacity <1 00% of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity

~ 100% of manufacturer's rating Evaluation of TS 3.8.6; New SR 3.8.6.9 (Relocated- Existing SR 3.8.4.8); Change (18)

The purpose of this SR is to demonstrate the operability of the battery; thus, this surveillance is relocated toTS 3.8.6, "Battery Parameters." The surveillance frequencies are based on guidance provided in the IEEE Std. 450-2002. These frequencies are based on the qualified life of safety-related batteries (typically 20 years) and known historical performance characteristics for vented lead-acid batteries. The SR 3.8.6.9 surveillance frequencies will provide adequate data points for trending in order to determine the state-of-health of the safety-related batteries given the expected service life. The surveillance frequencies are appropriate given the condition of the battery, allows sufficient time for corrective actions to be taken, and is consistent with the safety significance of safety-related batteries.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and is, therefore, acceptable.

3.2.4 TS 5.5.19, Battery Monitoring and Maintenance Program The proposed change would add a new Battery Monitoring and Maintenance Program as TS Section 5.5.19.

NewTS 5.5.19 would state:

5.5.19 Battery Monitoring and Maintenance Program 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.

Evaluation of TS 5.5.19; New Battery Monitoring and Maintenance Program (Added)

The TS Battery Maintenance and Monitoring Program will be in accordance with IEEE Standard 450-2002, as endorsed by RG 1.129, Revision 2. RG 1.129, Revision 2 provides guidance with respect to the maintenance, testing, and replacement of vented lead-acid storage batteries in nuclear power plants. The exceptions to RG 1.129, Revision 2 (listed in TS 5.5.19) are needed to make the RG requirements consistent with the proposed TS requirements, allow reasonable technical approaches, and be applicable to operating plants.

The licensee stated that monitoring of the current battery parameters (i.e., specific gravity, electrolyte level, cell temperature, float voltage, connection resistance, and physical condition) will be relocated to this program. The TS Battery Maintenance and Monitoring Program will ensure that the above battery parameters will be maintained and that actions will be implemented should the battery parameter(s) not be met. In the LAR, the licensee proposed a float voltage limit of 2.07 V. In its letter dated August 26, 2013, the licensee revised the float voltage limit to 2.13 V. The licensee stated that 2.13 V is a threshold value at which corrective actions will be taken to ensure that individual cell voltage does not drop below 2.07 V to ensure battery performance.

TS 5.4, "Procedures" requires written procedures be established, implemented, and maintained for the TS 5.5.19 Battery Monitoring and Maintenance Program. The TS 5.5.19 Battery Monitoring and Maintenance Program provides assurance that the battery parameters will be monitored and controlled in accordance with the program, and that actions to restore deficient parameters will be implemented in accordance with the licensee's corrective action program.

The NRC staff concludes that this change provides assurance that the battery is maintained at required levels of performance and that pertinent battery parameters are monitored. Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36 requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and is, therefore, acceptable.

3.3 Summary and Conclusion Based on the above, the NRC staff concludes the proposed changes to the PVNGS TS to adopt TSTF-500, Revision 2, provides assurance of the continued availability of the required DC power to shut down the reactor and to maintain the reactor in a safe condition after an anticipated operational occurrence or a postulated design-basis accident. The NRC staff also concludes that the proposed TS changes are in accordance with 10 CFR 50.36 and meet the intent of GDCs 1, 17, and 18. Therefore, the NRC staff concludes the proposed changes acceptable.

4.0 REGULATORY COMMITMENTS By letter dated December 26, 2012, the licensee made the following regulatory commitments, to be implemented with the amendment:

1. APS commits to change or verify the UFSAR descriptions listed in Attachment 2 to this letter, consistent with the model application referenced in the TSTF-500 notice of availability in the September 1, 2011, Federal Register (76 FR 54510).

2. In order to be consistent with the PVNGS TS Amendment No. 188 and Revision 4 of NUREG-1432, upon implementation of the approved TSTF-500 TS amendment, the surveillance frequencies and their bases shown in TSTF-500, Revision 2, for the LCO 3.8.4 and 3.8.6 SRs, except for the frequencies that are related to specific conditions such as battery degradation and capacity, will be specified in the Surveillance Frequency Control Program required by TS 5.5.18.

As discussed in Section 4.4.1 of the NRC's Office of Nuclear Reactor Regulation (NRR) Office Instruction UC-1 01, Revision 4, "License Amendment Review Procedures" (ADAMS Accession No. ML113200053), since commitments made by a licensee in support of a license amendment request are not legally binding, the NRC staff's SE should not rely on commitments as a basis for any part of the NRC staff's approval of a proposed amendment. However, the staff may rely on a commitment if it is escalated into an obligation (e.g., license condition) or subsequently incorporated into a mandated licensing basis document (e.g., UFSAR). As discussed in this SE, the NRC staff has relied, in part, on the above commitment No. 1 as part of the NRC staff's acceptance of the proposed amendment. Consistent with the guidance in NRR Office Instruction LIC-1 01, the NRC staff has determined that the commitment should be incorporated into the UFSAR. As such, the NRC staff, has added the following words as a condition of the amendment to ensure that the UFSAR is revised as part of the amendment implementation:

Implementation of the amendment shall include revision of the Updated Final Safety Analysis Report as described in Attachment 2 to the licensee's letter dated December 26, 2012.

The NRC staff notes that, following incorporation of the commitments listed in Attachment 2 into the UFSAR, future changes to the program will be under the provisions of 10 CFR 50.59.

The NRC staff considered the above commitment No. 2 as part of its review of the LAR and considers it acceptable.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Arizona State official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The 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 changes 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 published in the Federal Register on March 4, 2013 (78 FR 14126).

Accordingly, the 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 the 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) there is reasonable assurance that 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 Contributor: Adakou Foli, NRRIDE/EEEB Date: June 25, 2014

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

Sincerely, IRA/

Jennivine K. Rankin, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosures:

1. Amendment No. 193 to NPF-41

2. Amendment No. 193 to NPF-51

3. Amendment No. 193 to NPF-74

4. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDorllp14-1 Resource LPL4-1 r/f RidsNrrPMPaloVerde Resource RidsAcrsAcnw_MaiiCTR Resource RidsNrrLAJBurkhardt Resource RidsNrrDeEeeb Resource RidsRgn4MaiiCenter Resource RidsNrrDssStsb Resource AFoli, NRR/DE/EEEB RidsNrrDoriDpr Resource VGoel, NRR/DE/EEEB ADAMS Accession No. ML14115A045 *via memo OFFICE NRR/DORULPL4-1/PM NRR/DORULPL4-1/LA NRR/DSS/STSB/BC NRR/DE/EEEB/BC*

NAME JRankin JBurkhardt REIIiott JZimmerman DATE 5/6/14 5/6/14 5/5/14 4/16/14 OFFICE OGC-NLO NRR/DORULPL4-1/BC NRR/DORULPL4-1/PM NAME SUttal MMarkley JRankin DATE 6/11/14 6/25/14 6/25/14 OFFICIAL AGENCY RECORD

v t e Letter Sequence Approval
TAC:MF0450, DC Electrical Rewrite - Update to TSTF-360, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B, DC Electrical Rewrite (Approved, Closed) TAC:MF0451, DC Electrical Rewrite - Update to TSTF-360, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B, DC Electrical Rewrite (Approved, Closed) TAC:MF0452, DC Electrical Rewrite - Update to TSTF-360, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B, DC Electrical Rewrite (Approved, Closed)
Initiation Request Acceptance Administration Questions 26 June 2013 Answers Results Approval Other:
MONTHYEAR2013-02-01 [Table View]

ML14115A045

Text

SUBJECT:

Dear Mr. Edington:

Enclosures:

Attachment:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

5.0 STATE CONSULTATION

6.0 ENVIRONMENTAL CONSIDERATION

7.0 CONCLUSION

Enclosures:

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