ML17208A231

From kanterella
Jump to navigation Jump to search

Issuance of Amendments Regarding the Adoption of TSTF 500, DC Electrical Rewrite - Update to TSTF 360
ML17208A231
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 08/29/2017
From: Hall J
Plant Licensing Branch II
To: Hutto J
Southern Nuclear Operating Co
Hall J
References
CAC MF6611, CAC MF6612
Download: ML17208A231 (134)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 29, 2017 Mr. J. J. Hutto Regulatory Affairs Director Southern Nuclear Operating Company, Inc.

P. 0. Box 1295, Bin B038 Birmingham, AL 35201-1295

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNITS 1AND2 - ISSUANCE OF AMENDMENTS REGARDING THE ADOPTION OF TSTF-500, "DC ELECTRICAL REWRITE - UPDATE TO TSTF-360" (CAC NOS. MF6611 AND MF6612)

Dear Mr. Hutto:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 287 to Renewed Facility Operating License No. DPR-57 and Amendment No. 232 to Renewed Facility Operating License No. NPF-5 for the Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 11, 2015, as supplemented by letters dated October 27, 2015; March 16, April 4, June 17, August 12, September 20, and November 16, 2016; and February 6, April 4, and May 11, 2017.

The amendments revise the requirements related to direct current (DC) electrical systems in TS Limiting Condition for Operation (LCO) 3.8.4, "DC Sources - Operating," LCO 3.8.5, "DC Sources - Shutdown," and LCO 3.8.6, "Battery Cell Parameters." The amendments also add a new requirement, "Battery Monitoring and Maintenance Program," to TS 5.5, "Administrative Controls - Programs and Manuals." These amendments revise the TS requirements for HNP Units 1 and 2, in accordance with the NRG-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications change traveler, TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360."

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

Sincerely~ ,,_ / , /JJf 14 JaJ:. Hall, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosures:

1. Amendment No. 287 to DPR-57
2. Amendment No. 232 to NPF-5
3. Safety Evaluation cc w/enclosures: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-321 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 287 Renewed License No. DPR-57

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

A. The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 1 (the facility) Renewed Facility Operating License No. DPR-57 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated August 11, 2015, as supplemented by letters dated October 27, 2015; March 16, April 4, June 17, August 12, September 20, and November 16, 2016; and February 6, April 4, and May 11, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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 hereby amended by page changes as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-57 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 287, are hereby incorporated in the renewed license.

Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance. Implementation of the amendment shall include revision of the Final Safety Analysis Report as described in Attachment 2 to the licensee's letter dated August 11, 2015.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. DPR-57 and Technical Specifications Date of Issuance: August 29, 201 7

ATTACHMENT TO LICENSE AMENDMENT NO. 287 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-57 DOCKET NO. 50-321 Replace the following pages of the license and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License 4 4 TSs iii iii iv iv 3.8-26 3.8-26 3.8-27 3.8-27 3.8-28 3.8-28 3.8-29 3.8-29 3.8-30 3.8-30 3.8-31 3.8-31 3.8-32 3.8-32 3.8-33 3.8-33 3.8-34 3.8-34 3.8-35 3.8-35 3.8-36 3.8-36 3.8-37 3.8-37 3.8-38 3.8-38 3.8-39 3.8-39 3.8-40 3.8-40 3.8-41 3.8-42 3.8-43 3.8-44 5.0-18 5.0-18 5.0-19 5.0-19 5.0-20 5.0-20 5.0-21 5.0-21 5.0-22 5.0-22 5.0-23 5.0-23 5.0-24

for sample analysis or instrumentation calibration, or associated with radioactive apparatus or components; (6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

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

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady state reactor core power levels not in excess of 2804 megawatts thermal.

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 287 ,

are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance Requirement (SR) contained in the Technical Specifications and listed below, is not required to be performed immediately upon implementation of Amendment No. 195. The SR listed below shall be successfully demonstrated before the time and condition specified:

SR 3.8.1.18 shall be successfully demonstrated at its next regularly scheduled performance.

(3) Fire Protection Southern Nuclear shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report for the facility, as contained in the updated Fire Hazards Analysis and Fire Protection Program for the Edwin I. Hatch Nuclear Plant, Units 1 and 2, which was originally submitted by letter dated July 22, 1986. Southern Nuclear may make changes to the fire protection program without prior Commission approval only if the changes Renewed License No. DPR-57 Amendment No. 287

TABLE OF CONTENTS (continued}

3.6 CONTAINMENT SYSTEMS (continued) 3.6.1.6 Low-Low Set (LLS) Valves ............................................................................ 3.6-15 3.6.1.7 Reactor Building-to-Suppression Chamber Vacuum Breakers ..................... 3.6-17 3.6.1.8 Suppression Chamber-to-Drywall Vacuum Breakers .................................... 3.6-19 3.6.2.1 Suppression Pool Average Temperature ...................................................... 3.6-21 3.6.2.2 Suppression Pool Water Level ...................................................................... 3.6-24 3.6.2.3 Residual Heat Removal (RHR) Suppression Pool Cooling ........................... 3.6-25 3.6.2.4 Residual Heat Removal (RHR) Suppression Pool Spray .............................. 3.6-27 3.6.2.5 Residual Heat Removal (RHR) Drywall Spray .............................................. 3.6.29 3.6.3.1 Containment Atmosphere Dilution (CAD) System ......................................... 3.6-31 3.6.3.2 Primary Containment Oxygen Concentration ................................................ 3.6-33 3.6.4.1 Secondary Containment.. .............................................................................. 3.6-34 3.6.4.2 Secondary Containment Isolation Valves (SCIVs) ........................................ 3.6-37 3.6.4.3 Standby Gas Treatment (SGT) System ....................................................... 3.6-40 3.7 PLANT SYSTEMS ...................................................................................... 3.7-1 3.7.1 Residual Heat Removal Service Water (RHRSW) System ........................... 3.7-1 3.7.2 Plant Service Water (PSW) System and Ultimate Heat Sink (UHS} ............. 3.7-3 3.7.3 Diesel Generator (DG) 1B Standby Service Water (SSW) System ............... 3.7-6 3.7.4 Main Control Room Environmental Control (MCREC) System .................... 3. 7-8 3.7.5 Control Room Air Conditioning (AC) System ............................................... 3. 7-12 3.7.6 Main Condenser Offgas ................................................................................ 3.7-16 3.7.7 Main Turbine Bypass System ...................................................................... 3.7-18 3.7.8 Spent Fuel Storage Pool Water Level. .......................................................... 3.7-19 3.7.9 Turbine Building Ventilation (TB HVAC) Exhaust System Fans .................... 3.7-20 3.8 ELECTRICAL POWER SYSTEMS ............................................................... 3.8-1 3.8.1 AC Sources - Operating ................................................................................ 3.8-1 3.8.2 AC Sources - Shutdown ................................................................................ 3.8-20 3.8.3 Diesel Fuel Oil and Transfer, Lube Oil, and Starting Air ............................... 3.8-23 3.8.4 DC Sources - Operating ................................................................................ 3.8-26 3.8.5 DC Sources - Shutdown ................................................................................. 3.8-31 3.8.6 Battery Cell Parameters ................................................................................ 3.8-35 3.8.7 Distribution Systems - Operating ................................................................... 3.8-40 3.8.8 Distribution Systems - Shutdown .................................................................. 3.8-43 3.9 REFUELING OPERATIONS ......................................................................... 3.9-1 3.9.1 Refueling Equipment Interlocks ..................................................................... 3.9-1 3.9.2 Refuel Position One-Rod-Out Interlock ......................................................... 3.9-3 3.9.3 Control Rod Position ..................................................................................... 3.9-4 3.9.4 Control Rod Position Indication ..................................................................... 3.9-5 3.9.5 Control Rod OPERABILITY - Refueling ........................................................ 3.9-7 (continued)

HATCH UNIT 1 iii Amendment No. 287

TABLE OF CONTENTS (continued) 3.9 REFUELING OPERATIONS (continued) 3.9.6 Reactor Pressure Vessel (RPV) Water Level. ............................................... 3.9-8 3.9.7 Residual Heat Removal (RHR) - High Water Level. ...................................... 3.9-9 3.9.8 Residual Heat Removal (RHR) - Low Water Level ....................................... 3.9-11 3.10 SPECIAL OPERATIONS .............................................................................. 3.10-1 3.10.1 lnservice Leak and Hydrostatic Testing Operation ........................................ 3.10-1 3.10.2 Reactor Mode Switch Interlock Testing ......................................................... 3.10-3 3.10.3 Single Control Rod Withdrawal - Hot Shutdown ............................................ 3.10-5 3.10.4 Single Control Rod Withdrawal - Cold Shutdown .......................................... 3.10-8 3.10.5 Single Control Rod Drive (CRD) Removal - Refueling .................................. 3.10-12 3.10.6 Multiple Control Rod Withdrawal - Refueling ................................................. 3.10-14 3.10.7 Control Rod Testing - Operating ................................................................... 3.10-16 3.10.8 SHUTDOWN MARGIN (SOM) Test- Refueling ............................................ 3.10-18 DESIGN FEATURES .................................................................................... 4.0-1 4.1 Site ................................................................................................................ 4.0-1 4.2 Reactor Core ................................................................................................. 4.0-1 4.3 Fuel Storage .................................................................................................. 4.0-2 5.0 ADMINISTRATIVE CONTROLS ................................................................... 5.0-1 5.1 Responsibility ................................................................................................ 5.0-1 5.2 Organization .................................................................................................. 5.0-2 5.3 Unit Staff Qualifications ................................................................................. 5.0-5 5.4 Procedures .................................................................................................... 5.0-6 5.5 Programs and Manuals ................................................................................. 5.0-7 5.6 Reporting Requirements ............................................................................... 5.0-20 5.7 High Radiation Area ...................................................................................... 5.0-24 (continued)

HATCH UNIT 1 iv Amendment No. 287

DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The following DC electrical power subsystems shall be OPERABLE:

a. The Unit 1 Division 1 and Division 2 station service DC electrical power subsystems;
b. The Unit 1 and the swing DGs DC electrical power subsystems; and
c. The Unit 2 DG DC electrical power subsystems needed to support the equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System,"

and LCO 3.8.1, "AC Sources - Oper~ting."

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Swing DG DC electrical A.1 Restore DG DC 7 days power subsystem electrical power inoperable due to subsystem to performance of SR 3.8.4.3 OPERABLE status.

or SR 3.8.6.6.

OR One or more required Unit 2 DG DC electrical power subsystems inoperable.

B. Required Unit 1 DG DC 8.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> battery charger on one voltage to greater than or subsystem inoperable. equal to the minimum established float voltage.

OR AND Required swing DG DC battery charger inoperable B.2 Verify battery float Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for reasons other than current is s 5 amps.

Condition A.

AND B.3 Restore battery 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> charger(s) to OPERABLE status.

(continued)

HATCH UNIT 1 3.8-26 Amendment No. 287

DC Sources - Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One Unit 1 DG DC C.1 Restore DG DC 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> electrical power subsystem electrical power inoperable for reasons subsystem to other than Condition B. OPERABLE status.

OR Swing DG DC electrical power subsystem inoperable for reasons other than Condition A or B.

D. One or more required Unit D.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1 station service DC battery voltage to greater than or chargers on one subsystem equal to the minimum inoperable. established float voltage.

AND D.2 Verify battery float Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> current is s 20 amps.

AND D.3 Restore battery 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> charger(s) to OPERABLE status.

E. One Unit 1 station service E.1 Restore station service 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> DC electrical power DC electrical power subsystem inoperable for subsystem to reasons other than OPERABLE status.

Condition D.

F. Required Action and F.1 ------------NOTE---------

Associated Completion LCO 3.0.4.a is not Time of Condition A, B, C, applicable when entering D, or E not met. MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> G. Two or more DC electrical G.1 Enter LCO 3.0.3. Immediately power subsystems inoperable that result in a loss of function.

HATCH UNIT 1 3.8-27 Amendment No. 287

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS


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

SR 3.8.4.1 through SR 3.8.4.3 are applicable only to the Unit 1 DC sources. SR 3.8.4.4 is applicable only to the Unit 2 DC sources.

SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or In accordance with equal to the minimum established float voltage. the Surveillance Frequency Control Program SR 3.8.4.2 Verify each required battery charger supplies In accordance with 2: 400 amps for station service subsystems, and the Surveillance 2: 100 amps for DG subsystems at greater than or Frequency Control equal to the minimum established float voltage for Program 2: 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Verify each battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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)

HATCH UNIT 1 3.8-28 Amendment No. 287

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued)

SURVEILLANCE FREQUENCY SR 3.8.4.3 -----------------------------NOTES----------------------------

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.
2. This Surveillance shall not normally be performed in MODE 1, 2, or 3, except for the swing DG battery. However, portions of the surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and In accordance with maintain in OPERABLE status, the required the Surveillance emergency loads for the design duty cycle when Frequency Control subjected to a battery service test. Program (continued)

HATCH UNIT 1 3.8-29 Amendment No. 287

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 For required Unit 2 DC sources, the SRs of Unit 2 In accordance with Specification 3.8.4 are applicable. applicable SRs HATCH UNIT 1 3.8-30 Amendment No. 287

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 The following DC electrical power subsystems shall be OPERABLE:

a. The Unit 1 DC electrical power subsystems needed to support the DC electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems - Shutdown"; and
b. The Unit 2 DG DC electrical power subsystems needed to support the equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System"; and LCO 3.8.2, "AC Sources - Shutdown."

APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required battery A.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> charger on one or more voltage to greater than required DG DC or equal to the minimum subsystems inoperable. established float voltage.

AND AND The redundant required DG A.2 Verify battery float Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> DC subsystem battery and current :s: 5 amps.

required charger OPERABLE. AND A.3 Restore battery 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> charger(s) to OPERABLE status.

(continued)

HATCH UNIT 1 3.8-31 Amendment No. 287

DC Sources - Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

8. One or more required 8.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> battery chargers on one voltage to greater than required station service DC or equal to the minimum subsystem inoperable. established float voltage.

AND AND The redundant required 8.2 Verify battery float Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> station service DC current ::;:; 20 amps.

subsystem battery and required chargers AND OPERABLE.

8.3 Restore battery 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> charger(s) to OPERABLE status.

c. One or more required DG c. 1 Declare affected Immediately DC electrical power required feature(s) subsystems inoperable for inoperable.

reasons other than Condition A. OR OR C.2.1 Suspend CORE Immediately ALTERATIONS.

Required Actions and associated Completion AND Times of Condition A not met. C.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND (continued)

HATCH UNIT 1 3.8-32 Amendment No. 287

DC Sources - Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

c. (continued) C.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

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

D. One or more required D.1 Declare affected Immediately station service DC required feature(s) electrical power inoperable.

subsystems inoperable for reasons other than OR Condition B.

D.2.1 Suspend CORE Immediately OR AL TERA TIONS.

Required Actions and AND associated Completion Times of Condition B not 0.2.2 Suspend movement of Immediately met. irradiated fuel assemblies in the secondary containment.

AND D.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

AND D.2.4 Initiate action to restore Immediately required station service DC electrical power subsystems to OPERABLE status.

HATCH UNIT 1 3.8-33 Amendment No. 287

DC Sources - Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 --~----------~----~--~-----N()TE-----~---~-~-----~-~~-

The following SRs are not required to be performed: SR 3.8.4.2 and SR 3.8.4.3.

For required Unit 1 DC sources, the following SRs In accordance with are applicable:* applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 SR 3.8.5.2 For required Unit 2 DC sources, SR 3.8.5.1 of In accordance with Unit 2 Specification 3.8.5 is applicable. Unit 2 SR 3.8.5.1 HATCH UNIT 1 3.8-34 Amendment No. 287

Battery Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters LCO 3.8.6 Battery parameters for the station service and DG electrical power subsystem batteries shall be within limits.

APPLICABILITY: When associated DC electrical power subsystem is required to be OPERABLE.

ACTIONS


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

Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME A. One DG or station service A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> battery on one subsystem with one or more battery AND cells float voltages 2.07 V.

A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND A.3 Restore affected cell 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> voltage > 2.07 V.

B. One DG battery on one 8.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> subsystem with float current > 5 amps. AND 8.2 Restore battery float 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> current to s 5 amps.

C. One station service battery C.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on one subsystem with float current > 20 amps. AND C.2 Restore battery float 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> current to s 20 amps.

(continued)

HATCH UNIT 1 3.8-35 Amendment No. 287

Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME


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

Required Action D.2 shall be Required Actions D.1 and D.2 completed if electrolyte level was are only applicable if electrolyte below top of plates. level was below the top of


plates.

D. One DG or station service battery on one subsystem D.1 Restore electrolyte level 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with one or more cells to above top of plates.

electrolyte level less than minimum established AND design limits.

D.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> leakage.

AND D.3 Restore electrolyte level 31 days to greater than or equal to minimum established design limits.

E. One DG or station service E.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> battery on one subsystem temperature to greater with pilot cell electrolyte than or equal to temperature less than minimum established minimum established design limits.

design limits.

F. One or more batteries in F.1 Restore battery 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> redundant subsystems with parameters for batteries battery parameters not in one subsystem to within limits. within limits.

(continued)

HATCH UNIT 1 3.8-36 Amendment No. 287

Battery Parameters 3.8.6 ACTIONS (continued)

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

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

One DG battery on one subsystem with one or more battery cells float voltage :5 2.07 V and float current > 5 amps.

One station service battery on one subsystem with one or more battery cells float voltage :5 2.07 V and float current > 20 amps.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 ---------------------------NOTE--------------------------

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

Verify each DG battery float current is :5 5 amps In accordance with and each station service battery float current is the Surveillance

5 20 amps. Frequency Control Program SR 3.8.6.2 Verify each DG and each station service battery In accordance with pilot cell float voltage is > 2.07 V. the Surveillance Frequency Control Program (continued)

HATCH UNIT 1 3.8-37 Amendment No. 287

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.3 Verify each DG and each station service battery In accordance with connected cell electrolyte level is greater than or the Surveillance equal to minimum established design limits. Frequency Control Program SR 3.8.6.4 Verify each DG and each station service battery In accordance with pilot cell temperature is greater than or equal to the Surveillance minimum established design limits. Frequency Control Program SR 3.8.6.5 Verify each DG and each station service battery In accordance with connected cell float voltage is > 2.07 V. the Surveillance Frequency Control Program (continued)

HATCH UNIT 1 3.8-38 Amendment No. 287

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.6 ---------------------------N 0 TE--------------------------

T he Surveillance shall not normally be performed in MODE 1, 2, or 3 except for the swing DG battery. However, portions of the surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify DG and station service battery capacity is In accordance with

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

of manufacturer's rating HATCH UNIT 1 3.8-39 Amendment No. 287

Distribution Systems - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Distribution Systems - Operating LCO 3.8.7 The following AC and DC electrical power distribution subsystems shall be OPERABLE:

a. Unit 1 AC and DC electrical power distribution subsystems comprised of:
1. 4160 V essential buses 1E, 1F, and 1G;
2. 600 V essential buses 1C and 1D;
3. 120/208 V essential cabinets 1A and 1B;
4. 120/208 V instrument buses 1A and 18;
5. 125/250 V DC station service buses 1A and 1B;
6. OG DC electrical power distribution subsystems;
7. Critical Instrumentation Buses 1A and 1 B; and
b. Unit 2 AC and DC electrical power distribution subsystems needed to support equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System," and LCO 3.8.1, "AC Sources - Operating."

APPLICABI UTY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 7 days Unit 2 AC or DC electrical Unit 2 AC and DC power distribution subsystem(s) to subsystems inoperable. OPERABLE status.

(continued)

HATCH UNIT 1 3.8-40 Amendment No. 287

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more (Unit 1 or B.1 Restore DG DC 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> swing bus) DG DC electrical power electrical power distribution distribution subsystem subsystems inoperable. to OPERABLE status.

C. One or more (Unit 1 or c. 1 Restore AC electrical 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> swing bus) AC electrical power distribution power distribution subsystem to subsystems inoperable. OPERABLE status.

D. One Unit 1 station service D.1 Restore Unit 1 station 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> DC electrical power service DC electrical distribution subsystem power distribution inoperable. subsystem to OPERABLE status.

E. Required Action and E.1 ------------NO'TE-----------

associated Completion LCO 3.0.4.a is not Time of Condition A, B, C, applicable when or D not met. entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. Two or more electrical F.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

HATCH UNIT 1 3.8-41 Amendment No. 287

Distribution Systems - Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and voltage to In accordance with required AC and DC electrical power distribution the Surveillance subsystems. Frequency Control Program HATCH UNIT 1 3.8-42 Amendment No. 287

Distribution Systems - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Distribution Systems - Shutdown LCO 3.8.8 The necessary portions of the *following AC and DC electrical power distribution subsystems shall be OPERABLE:

a. The Unit 1 AC and DC electrical power distribution subsystems needed to support equipment required to be OPERABLE; and
b. The Unit 2 AC and DC electrical power distribution subsystems needed to support equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System," and LCO 3.8.2, "AC Sources - Shutdown."

APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required AC A.1 Declare associated Immediately or DC electrical power supported required distribution subsystems feature(s) inoperable.

inoperable.

A.2.1 Suspend CORE Immediately ALTERATIONS.

A.2.2 Suspend handling of Immediately irradiated fuel assemblies in the secondary containment.

(continued)

HATCH UNIT 1 3.8-43 Amendment No. 287 I

Distribution Systems - Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued} A.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

A.2.4 Initiate actions to Immediately restore required AC and DC electrical power distribution subsystem(s) to OPERABLE status.

A.2.5 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and voltage to In accordance with required AC and DC electrical power distribution the Surveillance subsystems. Frequency Control Program HATCH UNIT 1 3.8-44 Amendment No. 287

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Habitability Program (continued)

Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision O.

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the MCREC System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CRE boundary.
e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.15 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."

(continued)

HATCH UNIT 1 5.0-18 Amendment No. 287

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Battery Monitoring and Maintenance Program (continued)

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 AG 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! 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.

HATCH UNIT 1 5.0-19 Amendment No. 287

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Deleted.

5.6.2 Annual Radiological Environmental Operating Report


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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.8.2, IV.8.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the (continued)

HATCH UNIT 1 5.0-20 Amendment No. 287

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report (continued) format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Effluent Release Report


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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

The Radioactive Effluent Release Report covering the operation of the unit shall be submitted in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and the Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.B.1.

5.6.4 Deleted.

5.6.5 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:
1) The Average Planar Linear Heat Generation Rate for Specification 3.2.1.
2) The Minimum Critical Power Ratio for Specification 3.2.2.
3) The Linear Heat Generation Rate for Specification 3.2.3.

(continued)

HATCH UNIT 1 5.0-21 Amendment No. 287

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel," (applicable amendment specified in the COLR).
c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SOM, transient analysis limits and accident analysis limits) of the safety analysis are met.
d. The COLR, including any mid-cycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Post Accident Monitoring (PAM) Instrumentation Report When a report is required by LCO 3.3.3.1, "Post Accident Monitoring (PAM)

Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and hydrostatic testing, as well as heatup and cooldown rates, shall be established and documented in the PTLR for the following:
i. Limiting Conditions for Operating Section 3.4.9 "RCS Pressure and Temperature (PIT) Limits."

ii. Surveillance Requirements Section 3.4.9, "RCS Pressure and Temperature (PIT) Limits."

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
i. BWROG-TP-11-022-A, Revision 1 (SIR-05-044, Revision 1-A),

"Pressure-Temperature Limits Report Methodology for Boiling Water Reactors," dated June 2013.

(continued)

HATCH UNIT 1 5.0-22 Amendment No. 287

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.7 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) (continued) ii. BWROG-TP-11-023-A, Revision 0 (0900876.401, Revision 0-A),

"Linear Elastic Fracture Mechanics Evaluation of General Electric Bailing Water Reactor Water Level Instrument Nozzles for Pressure-Temperature Curve Evaluations," dated May 2013.

c. The PTLR shall be provided to the NRG upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

HATCH UNIT 1 5.0-23 Amendment No. 287

Reporting Requirements 5.7 5.0 ADMINISTRATIVE CONTROLS

5. 7 High Radiation Area 5.7.1 Pursuant to 10 CFR 20, paragraph 20.1601, in lieu of the requirements of 10 CFR 20.1601a, each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is > 100 mrem/hr but < 1000 mrem/hr, measured at 30 cm from the radiation source or from any surface the radiation penetrates, shall be barricaded and conspicuously posted as a high radiation area.

Entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures (e.g.,

radiation protection technician) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates

< 1000 mrem/hr, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device that continuously indicates the radiation dose rate in the area.
b. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel are aware of them.
c. An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility radiation protection supervision in the RWP.

5.7.2 In addition to the requirements of Specification 5. 7.1, areas with radiation levels

~ 1000 mrem/hr, measured at 30 cm from the radiation source or from any surface the radiation penetrates, but less than 500 Rads in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> measured at 1 meter from the radiation source or from any surface that the radiation penetrates, shall be provided with locked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the Shift Supervision on duty or radiation protection supervision.

HATCH UNIT 1 5.0-24 Amendment No. 287

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-366 EDWIN I. HATCH NUCLEAR PLANT. UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 232 Renewed License No. NPF-5

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

A. The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 2 (the facility) Renewed Facility Operating License No. NPF-5 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated August 11, 2015, as supplemented by letters dated October 27, 2015; March 16, April 4, June 17, August 12, September 20, November 16, 2016; and February 6, April 4, and May 11, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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 hereby amended by page changes as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-5 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 232 are hereby incorporated in the renewed license.

Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance. Implementation of the amendment shall include revision of the Final Safety Analysis Report as described in Attachment 2 to the licensee's letter dated August 11, 2015.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-5 and Technical Specifications Date of Issuance: August 2 9, 2O1 7

ATTACHMENT TO LICENSE AMENDMENT NO. 232 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-5 DOCKET NO. 50-366 Replace the following pages of the license and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License 4 4 TSs iv iv v v 3.8-26 3.8-26 3.8-27 3.8-27 3.8-28 3.8-28 3.8-29 3.8-29 3.8-30 3.8-30 3.8-31 3.8-31 3.8-32 3.8-32 3.8-33 3.8-33 3.8-34 3.8-34 3.8-35 3.8-35 3.8-36 3.8-36 3.8-37 3.8-37 3.8-38 3.8-38 3.8-39 3.8-39 3.8-40 3.8-40 3.8-41 3.8-41 3.8-42 3.8-43 3.8-44 5.0-18 5.0-18 5.0-19 5.0-19 5.0-20 5.0-20 5.0-21 5.0-21 5.0-22 5.0-22 5.0-23 5.0-23 5.0-24

(6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain, and is subject to, the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions 2 specified or incorporated below:

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady state reactor core power levels not in excess of 2,804 megawatts thermal, in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix 8), as revised through Amendment No. 232 ,

are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the license supported by a favorable evaluation by the Commission.

(a) Fire Protection Southern Nuclear shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report for the facility, as contained 2 The original licensee authorized to possess, use, and operate the facility with Georgia Power Company (GPC). Consequently, certain historical references to GPC remain in certain license conditions.

Renewed License No. NPF-5 Amendment No. 232

TABLE OF CONTENTS 3.8 ELECTRICAL POWER SYSTEMS (continued) 3.8.6 Battery Cell Parameters ................................................................................ 3.8-35 3.8.7 Distribution Systems - Operating ................................................................... 3.8-40 3.8.8 Distribution Systems - Shutdown .................................................................. 3.8-43 3.9 REFUELING OPERATIONS ......................................................................... 3.9-1 3.9.1 Refueling Equipment Interlocks ..................................................................... 3.9-1 3.9.2 Refuel Position One-Rod-Out Interlock ......................................................... 3.9-3 3.9.3 Control Rod Position ..................................................................................... 3.9-5 3.9.4 Control Rod Position Indication ..................................................................... 3.9-6 3.9.5 Control Rod OPERABILITY - Refueling ........................................................ 3.9-8 3.9.6 Reactor Pressure Vessel (RPV) Water Level... ............................................. 3.9-9 3.9.7 Residual Heat Removal (RHR) - High Water Level. ...................................... 3.9-10 3.9.8 Residual Heat Removal (RHR) - Low Water Level ....................................... 3.9-12 3.10 SPECIAL OPERATIONS .............................................................................. 3.10-1 3.10.1 lnservice Leak and Hydrostatic Testing Operation ........................................ 3.10-1 3.10.2 Reactor Mode Switch Interlock Testing ......................................................... 3 .10-3 3.10.3 Single Control Rod Withdrawal - Hot Shutdown ............................................ 3 .10-5 3.10.4 Single Control Rod Withdrawal - Cold Shutdown .......................................... 3.10-8 3.10.5 Single Control Rod Drive (CRD)

Removal - Refueling ................................................................................ 3.10-12 3.10.6 Multiple Control Rod Withdrawal - Refueling ................................................. 3.10-14 3.10.7 Control Rod Testing - Operating ................................................................... 3.10-16 3.10.8 SHUTDOWN MARGIN (SOM) Test - Refueling ............................................ 3.10-18 4.0 DESIGN FEATURES .................................................................................... 4.0-1 4.1 Site ................................................................................................................ 4.0-1 4.2 Reactor Core ................................................................................................. 4.0-1 4.3 Fuel Storage .................................................................................................. 4.0-2 (continued)

HATCH UNIT 2 iv Amendment No. 232

TABLE OF CONTENTS (continued) 5.0 ADMINISTRATIVE CONTROLS ................................................................... 5.0-1 5.1 Responsibility ................................................................................................ 5.0-1 5.2 Organization .................................................................................................. 5.0-2 5.3 Unit Staff Qualifications ................................................................................. 5.0-5 5.4 Procedures .................................................................................................... 5.0-6 5.5 Programs and Manuals ................................................................................. 5.0-7 5.6 Reporting Requirements ............................................................................... 5.0-20 5.7 High Radiation Area ...................................................................................... 5.0-24 (continued)

HATCH UNIT 2 v Amendment No. 232

DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 The following DC electrical power subsystems shall be OPERABLE:

a. The Unit 2 Division 1 and Division 2 station service DC electrical power subsystems;
b. The Unit 2 and the swing DGs DC electrical power subsystems; and
c. The Unit 1 DG DC electrical power subsystems needed to support the equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System";

LCO 3.7.4, "Main Control Room Environmental Control (MCREC)

System"; LCO 3.7.5, "Control Room Air Conditioning (AC) System";

and LCO 3.8.1, "AC Sources - Operating."

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Swing DG DC electrical A.1 Restore DG DC 7 days power subsystem electrical power inoperable due to subsystem to performance of SR 3.8.4.3 OPERABLE status.

or SR 3.8.6.6.

OR One or more required Unit 1 DG DC electrical power subsystems inoperable.

B. Required Unit 2 DG DC 8.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> battery charger on one voltage to greater than or subsystem inoperable. equal to the minimum established float voltage.

OR AND Required swing DG DC battery charger inoperable 8.2 Verify battery float current Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for reasons other than is s 5 amps.

Condition A.

AND 8.3 Restore battery charger(s) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to OPERABLE status.

(continued)

HATCH UNIT 2 3.8-26 Amendment No. 232

DC Sources - Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

c. One Unit 2 DG DC C.1 Restore DG DC 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> electrical power subsystem electrical power inoperable for reasons subsystem to other than Condition B. OPERABLE status.

OR Swing DG DC electrical power subsystem inoperable for reasons other than Condition A or B.

D. One or more required Unit D.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 2 station service DC battery voltage to greater than or chargers on one equal to the minimum subsystem inoperable. established float voltage.

AND D.2 Verify battery float Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> current is ~ 20 amps.

AND D.3 Restore battery 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> charger(s) to OPERABLE status.

E. One Unit 2 station service E.1 Restore station service 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> DC electrical power DC electrical power subsystem inoperable for subsystem to reasons other than OPERABLE status.

Condition D.

F. Required Action and F.1 --~--------NOTE---~----

Associated Completion LCO 3.0.4.a is not Time of Condition A, B, C, applicable when entering D, or E not met. MODE 3. .

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> G. Two or more DC electrical G.1 Enter LCO 3.0.3. Immediately power subsystems inoperable that result in a loss of function.

HATCH UNIT 2 3.8-27 Amendment No. 232

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS


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

SR 3.8.4.1 through SR 3.8.4.3 are applicable only to the Unit 2 DC sources. SR 3.8.4.4 is applicable only to the Unit 1 DC sources.

SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater than or In accordance with equal to the minimum established float voltage. the Surveillance Frequency Control Program SR 3.8.4.2 Verify each required battery charger supplies In accordance with

=:: 400 amps for station service subsystems, and the Surveillance

=:: 100 amps for DG subsystems at greater than or Frequency Control equal to the minimum established float voltage for Program

=:: 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Verify each battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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)

HATCH UNIT 2 3.8-28 Amendment No. 232

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.4.3 -----------------------------N 0 TES---------------------------

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.
2. This Surveillance shall not normally be performed in MODE 1, 2, or 3, except for the swing DG battery. However, portions of the surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is adequate to supply, and In accordance with maintain in OPERABLE status, the required the Surveillance emergency loads for the design duty cycle when Frequency Control subjected to a battery service test. Program (continued)

HATCH UNIT2 3.8-29 Amendment No. 232

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.4.4 For required Unit 1 DC sources, the SRs of Unit 1 In accordance with Specification 3.8.4 are applicable. applicable SRs HATCH UNIT 2 3.8-30 Amendment No. 232

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 The following DC electrical power subsystems shall be OPERABLE:

a. The Unit 2 DC electrical power subsystems needed to support the DC electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems - Shutdown"; and
b. The Unit 1 DG DC electrical power subsystems needed to support the equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System"; and LCO 3.7.4, "Main Control Room Environmental Control (MCREC) System";

LCO 3.7.5, "Control Room Air Conditioning (AC) System"; and LCO 3.8.2, "AC Sources - Shutdown."

APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required battery A.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> charger on one or more voltage to greater than required DG DC or equal to the minimum subsystems inoperable. established float voltage.

AND AND The redundant required DG A.2 Verify battery float Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> DC subsystem battery and current ::;; 5 amps.

required charger OPERABLE. AND A.3 Restore battery 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> charger(s) to OPERABLE status.

(continued)

HATCH UNIT 2 3.8-31 Amendment No. 232

DC Sources - Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Restore battery terminal 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> battery chargers on one voltage to greater than required station service DC or equal to the minimum subsystem inoperable. established float voltage.

AND AND The redundant required B.2 Verify battery float Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> station service DC current s 20 amps.

subsystem battery and required chargers AND OPERABLE.

B.3 Restore battery 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> charger(s) to OPERABLE status.

C. One or more required DG c. 1 Declare affected Immediately DC electrical power required feature(s) subsystems inoperable for inoperable.

reasons other than Condition A. OR OR C.2.1 Suspend CORE Immediately ALTERATIONS.

Required Actions and associated Completion AND Times of Condition A not met. C.2.2 Suspend movement of Immediately irradiated fuel assemblies in the secondary containment.

AND (continued)

HATCH UNIT 2 3.8-32 Amendment No. 232

DC Sources - Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

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

D. One or more required D. 1 Declare affected Immediately station service DC required feature(s) electrical power inoperable.

subsystems inoperable for reasons other than OR Condition B.

D.2.1 Suspend CORE Immediately OR ALTERATIONS.

Required Actions and AND associated Completion Times of Condition B not D.2.2 Suspend movement of Immediately met. irradiated fuel assemblies in the secondary containment.

AND D.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

AND D.2.4 Initiate action to restore Immediately required station service DC electrical power subsystems to OPERABLE status.

HATCH UNIT 2 3.8-33 Amendment No. 232

DC Sources - Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 -----------------------------N()"f E------------------------------

The following SRs are not required to be performed: SR 3.8.4.2 and SR 3.8.4.3.

For required Unit 2 DC sources, the following SRs In accordance with are applicable: applicable SRs SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 SR 3.8.5.2 For required Unit 1 DC sources, SR 3.8.5.1 of In accordance with Unit 1 Specification 3.8.5 is applicable. Unit 1 SR 3.8.5.1 HATCH UNIT 2 3.8-34 Amendment No. 232

Battery Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters LCO 3.8.6 Battery parameters for the station service and DG electrical power subsystem batteries shall be within limits.

APPLICABILITY: When associated DC electrical power subsystem is required to be OPERABLE.

ACTIONS


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

Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME A. One DG or station service A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> battery on one subsystem with one or more battery AND cells float voltages 2.07 V.

A.2 Perform SR 3.8.6.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND A.3 Restore affected cell 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> voltage > 2.07 V.

B. One DG battery on one B.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> subsystem with float current > 5 amps. AND 8.2 Restore battery float 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> current to s 5 amps.

C. One station service battery C.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on one subsystem with float current > 20 amps. AND C.2 Restore battery float 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> current to s 20 amps.

(continued)

HATCH UNIT 2 3.8-35 Amendment No. 232

Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

~----~---------NOTE---------------- -----------------NOTE------------------

Required Action D.2 shall be Required Actions D.1 and D.2 completed if electrolyte level was are only applicable if electrolyte below the top of plates. level was below the top of


plates.

D. One DG or station service -------------------------------------------

battery on one subsystem D.1 Restore electrolyte level 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with one or more cells to above top of plates.

electrolyte level less than minimum established AND design limits.

0.2 Verify no evidence of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> leakage.

AND D.3 Restore electrolyte level 31 days to greater than or equal to minimum established design limits.

E. One DG or station service E.1 Restore battery pilot cell 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> battery on one subsystem temperature to greater with pilot cell electrolyte than or equal to minimum temperature less than established design limits.

minimum established design limits.

F. One or more batteries in F.1 Restore battery 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> redundant subsystems with parameters for batteries battery parameters not in one subsystem to within limits. within limits.

(continued)

HATCH UNIT 2 3.8-36 Amendment No. 232

Battery Parameters 3.8.6 ACTIONS {continued)

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

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

One DG battery on one subsystem with one or more battery cells float voltage s 2.07 V and float current > 5 amps.

One station service battery on one subsystem with one or more battery cells float voltage s 2.07 V and float current > 20 amps.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.1 --------------------------NOTE-------------------------------

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

Verify each DG battery float current is s 5 amps In accordance with and each station service battery float current is the Surveillance s 20 amps. Frequency Control Program SR 3.8.6.2 Verify each DG and each station service battery In accordance with pilot cell float voltage is > 2.07 V. the Surveillance Frequency Control Program (continued)

HATCH UNIT 2 3.8-37 Amendment No. 232

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.3 Verify each DG and each station service battery In accordance with connected cell electrolyte level is greater than or the Surveillance equal to minimum established design limits. Frequency Control Program SR 3.8.6.4 Verify each DG and each station service battery In accordance with pilot cell temperature is greater than or equal to the Surveillance minimum established design limits. Frequency Control Program SR 3.8.6.5 Verify each DG and each station service battery In accordance with connected cell float voltage is > 2.07 V. the Surveillance Frequency Control Program (continued)

HATCH UNIT 2 3.8-38 Amendment No. 232

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.8.6.6 ---------------------------NOTE------------------------------

The Surveillance shall not normally be performed in MODE 1, 2, or 3, except for the swing DG battery. However, portions of the surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify DG and station service battery capacity is In accordance with 2: 80% of the manufacturer's rating when the Surveillance subjected to a performance discharge test or a Frequency Control modified performance discharge test. Program 12 months when battery shows degradation or has reached 85% of expected life with capacity < 100% of manufacturer's rating 24 months when battery has reached 85% of expected life with capacity 2: 100% of manufacturer's rating HATCH UNIT2 3.8-39 Amendment No. 232

Distribution Systems - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Distribution Systems - Operating LCO 3.8.7 The following AC and DC electrical power distribution subsystems shall be OPERABLE:

a. Unit 2 AC and DC electrical power distribution subsystems comprised of:
1. 4160 Vessential buses 2E, 2F, and 2G;
2. 600 V essential buses 2C and 2D;
3. 120/208 V essential cabinets 2A and 2B;
4. 120/208 V instrument buses 2A and 2B;
5. 125/250 V DC station service buses 2A and 2B;
6. DG DC electrical power d.istribution subsystems;
7. Critical instrumentation Buses 2A and 28; and
b. Unit 1 AC and DC electrical power distribution subsystems needed to support equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System"; LCO 3.7.4, "Main Control Room Environmental Control (MCREC) System";

LCO 3.7.5, "Control Room Air Conditioning (AC) System"; and LCO 3.8.1, "AC Sources - Operating."

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required 7 days Unit 1 AC or DC electrical Unit 1 AC and DC power distribution subsystem(s) to subsystems inoperable. OPERABLE status.

(continued)

HATCH UNIT2 3.8-40 Amendment No. 232 I

Distribution Systems - Operating 3.8.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

8. One or more (Unit 2 or 8.1 Restore DG DC 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> swing bus) DG DC electrical power electrical power distribution distribution subsystem subsystems inoperable. to OPERABLE status.

C. One or more (Unit 2 or C. 1 Restore AC electrical 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> swing bus) AC electrical power distribution power distribution subsystem to subsystems inoperable. OPERABLE status.

D. One Unit 2 station service D.1 Restore Unit 2 station 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> DC electrical power service DC electrical distribution subsystem power distribution inoperable. subsystem to OPERABLE status.

E. Required Action and E.1 ------------NOTE---------

associated Completion LCO 3.0.4.a is not Time of Condition A, B, C, applicable when or D not met. entering MODE 3.

Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. Two or more electrical F.1 Enter LCO 3.0.3. Immediately power distribution subsystems inoperable that result in a loss of function.

HATCH UNIT 2 3.8-41 Amendment No. 232

Distribution Systems - Operating 3.8.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and voltage to In accordance with required AC and DC electrical power distribution the Surveillance subsystems. Frequency Control Program HATCH UNIT 2 3.8-42 Amendment No. 232

Distribution Systems - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Distribution Systems - Shutdown LCO 3.8.8 The necessary portions of the following AC and DC electrical power distribution subsystems shall be OPERABLE:

a. The Unit 2 AC and DC electrical power distribution subsystems needed to support equipment required to be OPERABLE; and
b. The Unit 1 AC and DC electrical power distribution subsystems needed to support equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System"; LCO 3.7.4, "Main Control Room Environmental Control (MCREC) System";

LCO 3.7.5, "Control Room Air Conditioning (AC) System"; and LCO 3.8.2, "AC Sources- Shutdown."

APPLICABILITY: MODES 4 and 5, During movement of irradiated fuel assemblies in the secondary containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required AC A.1 Declare associated Immediately or DC electrical power supported required distribution subsystems feature(s) inoperable.

inoperable.

OR A.2.1 Suspend CORE Immediately ALTE RATIONS.

A.2.2 Suspend handling of Immediately irradiated fuel assemblies in the secondary containment.

(continued)

HATCH UNIT 2 3.8-43 Amendment No. 232 [

Distribution Systems - Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

A.2.4 Initiate actions to Immediately restore required AC and DC electrical power distribution subsystem(s) to OPERABLE status.

A.2.5 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and voltage to ln accordance with required AC and DC electrical power distribution the Surveillance subsystems. Frequency Control Program HATCH UNIT 2 3.8-44 Amendment No. 232

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 Control Room Envelope Habitability Program (continued)

Frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0.

d. Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the MCREC System, operating at the flow rate required by the VFTP, at a Frequency of 24 months on a STAGGERED TEST BASIS. The results shall be trended and used as part of the 24 month assessment of the CRE boundary.
e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.15 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."

(continued)

HATCH UNIT 2 5.0-18 Amendment No. 232

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Battery Monitoring and Maintenance Program (continued)

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: 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.

HATCH UNIT2 5.0-19 Amendment No. 232

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.6.1 Deleted.

5.6.2 Annual Radiological Environmental Operating Report


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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.8.2, IV.8.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the (continued)

HATCH UNIT 2 5.0-20 Amendment No. 232

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Operating Report {continued) table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

5.6.3 Radioactive Effluent Release Report


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

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station; however, for units with separate radwaste systems, the submittal shall specify the releases of radioactive material from each unit.

The Radioactive Effluent Release Report covering the operation of the unit shall be submitted in accordance with 10 CFR 50.36a. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and the Process Control Program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I, Section IV.8.1.

5.6.4 Deleted.

5.6.5 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the ('.OLR for the following:
1) The Average Planar Linear Heat Generation Rate for Specification 3.2.1.
2) The Minimum Critical Power Ratio for Specification 3.2.2.
3) The Linear Heat Generation Rate for Specification 3.2.3.

(continued)

HATCH UNIT2 5.0-21 Amendment No. 232

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel," (applicable amendment specified in the COLR).
c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits.

Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SOM, transient analysis limits and accident analysis limits) of the safety analysis are met.

d. The COLR, including any mid-cycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 Post Accident Monitoring (PAM} Instrumentation Report When a report is required by LCO 3.3.3.1, "Post Accident Monitoring (PAM)

Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT CPTLR)

a. RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and hydrostatic testing, as well as heatup and cooldown rates, shall be established and documented in the PTLR for the following:
i. Limiting Conditions for Operating Section 3.4.9 "RCS Pressure and Temperature (PT) Limits" ii. Surveillance Requirements Section 3.4.9, "RCS Pressure and Temperature (Pfr) Limits"
b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
i. BWROG-TP-11-022-A, Revision 1 (SI R-05-044, Revision 1-A),

"Pressure-Temperature Limits Report Methodology for Boiling Water Reactors," dated June 2013.

(continued)

HATCH UNIT 2 5.0-22 Amendment No. 232

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.7 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) (continued) ii. BWROG-TP-11-023-A, Revision 0 (0900876.401, Revision 0-A),

"Linear Elastic Fracture Mechanics Evaluation of General Electric Boiling Water Reactor Water Level Instrument Nozzles for Pressure-Temperature Curve Evaluations," dated May 2013.

c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

HATCH UNIT2 5.0-23 Amendment No. 232

Reporting Requirements 5.7 5.0 ADM!NfSTRATIVE CONTROLS

5. 7 High Radiation Area 5.7.1 Pursuant to 10 CFR 20, paragraph 20.1601, in lieu of the requirements of 10 CFR 20.1601a, each high radiation area, as defined in 10 CFR 20, in which the intensity of radiation is > 100 mrem/hr but < 1000 mrem/hr, measured at 30 cm from the radiation source or from any surface the radiation penetrates, shall be barricaded and conspicuously posted as a high radiation area.

Entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP). Individuals qualified in radiation protection procedures (e.g.,

radiation protection technician) or personnel continuously escorted by such individuals may be exempt from the RWP issuance requirement during the performance of their assigned duties in high radiation areas with exposure rates

< 1000 mrem/hr, provided they are otherwise following plant radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device that continuously indicates the radiation dose rate in the area.
b. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel are aware of them.
c. An individual qualified in radiation protection procedures with a radiation dose rate monitoring devlce, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility radiation protection supervision in the RWP.
5. 7 2 In addition to the requirements of Specification 5. 7 .1, areas with radiation levels 2= 1000 mrem/hr, measured at 30 cm from the radiation source or from any surface the radiation penetrates, but less than 500 Rads in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> measured at 1 meter from the radiation source or from any surface that the radiation penetrates, shall be provided with tocked or continuously guarded doors to prevent unauthorized entry and the keys shall be maintained under the administrative control of the Shift Supervision on duty or radiation protection supervision.

HATCH UNlT 2 5.0-24 Amendment No. 232

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 287 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-57 AND AMENDMENT NO. 232 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-5 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366

1.0 INTRODUCTION

By application dated August 11, 2015 (Reference 1), as supplemented by letters dated October 27, 2015; March 16, April 4, June 17, August 12, September 20, and November 16, 2016; and February 6, April 4, and May 11, 2017 (References 2 through 11 ), Southern Nuclear Operating Company, Inc. (SNC, the licensee), requested changes to the Technical Specifications (TSs) for the Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2. The supplements dated October 27, 2015; March 16, April 4, June 17, August 12, September 20, and November 16, 2016; and February 6, April 4, and May 11, 2017, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on June 7, 2016 (81 FR 36623).

The proposed changes in this license amendment request (LAR) would revise the requirements related to direct current (DC) electrical systems in TS Limiting Condition for Operation (LCO) 3.8.4, "DC Sources - Operating," LCO 3.8.5, "DC Sources - Shutdown, and LCO 3.8.6, "Battery Cell Parameters." The LAR also proposes to add a new requirement, "Battery Monitoring and Maintenance Program, to TS 5.5, "Administrative Controls - Programs and Manuals." The licensee proposed to adopt these changes in accordance with the NRC-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) change traveler, TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360."

By letter dated June 17, 2016, SNC revised the LAR to withdraw the proposed change related to proposed TS 3.8.4, Condition E, to increase the completion time (CT) from 2 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for restoring one station service battery to operable status. Thus, the proposed changes related to TS 3.8.4 in the letter dated June 17, 2016, superseded the proposed changes related to TS 3.8.4 in the letter dated August 11, 2015. Similarly, the proposed changes related to TS 3.8.5 and TS 3.8.6 provided in the licensee's letter dated September 20, 2016, superseded Enclosure 3

the proposed changes related to TS 3.8.5 and TS 3.8.6 in the original LAR dated August 11, 2015.

The proposed changes include the following:

  • The addition of new actions for an inoperable battery charger and alternate battery charger testing criteria for LCO 3.8.4, "DC Sources - Operating," and LCO 3.8.5, "DC Sources - Shutdown."
  • The relocation of a number of Surveillance Requirements (SRs) in TS 3.8.4 for performing preventative maintenance on the safety-related batteries to a licensee-controlled program.
  • The modification of LCO 3.8.6, "Battery Cell Parameters," by relocating Table 3.8.6-1, "Battery Cell Parameter Requirements," to a licensee-controlled program, and the addition to TS 3.8.6 of specific actions with associated CTs for out-of-limit conditions for battery cell voltage, electrolyte level, and electrolyte temperature.
  • The addition of specific SRs for verification of battery parameters.
  • The addition of a new program (new TS 5.5.15, "Battery Monitoring and Maintenance Program") in TS Section 5.0, "Administrative Controls," for the maintenance and monitoring of station service and diesel generator batteries, and for the relocation of other identified TS items.

The Notice of Availability for TSTF-500, Revision 2, was published in the Federal Register on September 1, 2011 (76 FR 54510), to announce the availability of the model application and model safety evaluation (SE) (Reference 12) for plant-specific adoption of TSTF-500, Revision 2 (Reference 13), as part of the consolidated line item improvement process. This Notice of Availability was later corrected to clarify that TSTF-500 was available for plant-specific adoption, but not under the consolidated line item improvement process. The clarifying Notice of Availability was published in the Federal Register on November 8, 2011 (76 FR 69296).

Attachment B, "Revisions to Revision 1 of the ISTS [improved standard TS] NUREGs," to TSTF-500, Revision 2, provides the changes to Revision 1 of the ISTS NUREGs to incorporate TSTF-500. Revision 2 of TSTF-500 stated that the changes in Attachment B should be used for plants that have not adopted TSTF-360, "DC Electrical Rewrite." Since HNP has not adopted TSTF-360, and the HNP TSs are based on NUREG-1433, "Standard Technical Specifications

[STS] General Electric BWR/4 Plants," April 2012 (Reference 14), the NRC staff used the changes to the BWR/4 STS in Attachment B to TSTF-500, Revision 2, as the model for evaluating the proposed HNP TS changes.

2.0 REGULATORY EVALUATION

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

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), TSs are required to include items in the following 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 (Reference 15), 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 (Reference 16), 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" (Reference 17).

  • RG 1.6 (Safety Guide 6), "Independence Between Redundant Standby (Onsite)

Power Sources and Between their Distribution Systems," dated March 10, 1971 (Reference 18), provides guidance with respect to separate DC subsystems providing power to each load group, so that a loss of either one of these subsystems does not prevent the minimum safety functions from being performed.

  • RG 1.32, Revision 3, "Criteria for Power Systems for Nuclear Power Plants,"

March 2004 (Reference 19), provides guidance with respect to physical separation, electrical isolation, and redundancy for DC systems to prevent the occurrence of common mode failures. This RG endorses, in part, the IEEE Std. 308-2001, "IEEE Standard Criteria for Class 1E Power Systems for Nuclear Power Generating Stations" (Reference 20).

  • TSTF-500, Revision 2, "DC Electrical Rewrite - Update to TSTF-360," dated September 22, 2009 (Reference 13).
  • TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control -

RITSTF Initiative 5b," dated March 18, 2009 (Reference 21 ).

  • Model application and SE for plant-specific adoption of traveler TSTF-500, Revision 2 (Reference 12), as published for availability in the Federal Register on September 1, 2011 (76 FR 54510).

HNP Unit 2, is licensed to 10 CFR Part 50, Appendix A, "General Design Criteria." HNP Unit 1, is licensed to the 1967 version of 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plant Construction Permits" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML043310029). Appendix F of the HNP Unit 1 Final Safety Analysis Report (FSAR) describes the relevant licensing bases for Unit 1, and discusses the differences between the Unit 1 licensing bases and the specific GDC cited above.

3.0 TECHNICAL EVALUATION

3.1 Design Features of the HNP 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 the emergency AC power systems (via DC to AC power converters (i.e., inverters)). According to the HNP Units 1 and 2, TS Bases, Section B3.8.4, "DC Sources - Operating, the DC electrical power system, as required by 10 CFR Part 50, Appendix A, GDC 17, is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure. The DC electrical power system also conforms to the recommendations of RG 1.6 and IEEE 308-1971. According to the HNP FSAR, the safety objective of the 125 volt (V) DC diesel generator (DG) and the 125/250 VDC station service power systems is to provide an uninterruptible source of power to all normal and emergency 125 VDC control and 250 VDC power loads under all conditions. The 125 VDC DG power system supplies control power for the emergency DGs, the DGs' feeder breakers, and the 4160 V switchgear bus feeder associated with a particular DG. The 125/250 VDC power systems and the 125 voe emergency system are arranged so that no single component failure prevents the system from providing power to a sufficient number of DC loads necessary for safe shutdown.

Each battery is separately housed 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.

Each battery charger is normally in the float-charge mode. Float-charge is the condition 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.

The 125/250 VDC Station Service Battery Power System According to the HNP FSAR, Chapter 8.0, "Electric Power," the 125/250 VDC station service system for each HNP unit is made up of two separate and independent subsystems. Each subsystem consists of one 120-cell, 250 V, lead acid type battery (consisting of two 60-cell, 125 V batteries in series) and three 125 V, 400-ampere battery chargers. Two of the three chargers are normally in service, with one in standby. Each set of battery chargers exclusively associated with a 125/250 VDC subsystem cannot be interconnected with any other 125/250 VDC subsystem. The HNP Unit 1 station service batteries (1A and 1B) are 120-cell lead-calcium type with a continuous discharge rating of 1410 ampere-hours and 1513 ampere-hours, respectively, for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 77 degrees Fahrenheit (°F) to 1. 75 V final average cell voltage. The HNP Unit 2 station service batteries (2A and 2B) are 120-cell lead-calcium type, with a continuous discharge rating of 1254 ampere-hours and 1513 ampere-hours, respectively, for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 77 °F to 1. 75 V per cell average. Each of the 125/250 V batteries has adequate capacity to supply the vital unit loads without recharging for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

There are six battery chargers, each rated at 400 amperes, with adequate capacity and capability to restore its battery to full charge within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from a minimum discharged

condition while carrying the normal unit steady state DC load. Each set of battery chargers exclusively associated with a 125/250 VDC subsystem cannot be interconnected with any other 125/250 VDC subsystem. According to the HNP TS Bases, a subsystem of the station service DC system is considered operable when the 125/250 VDC battery and two of the three battery chargers (two normally in-service chargers and one standby charger) are operable.

The 125 VDC Diesel Generator Auxiliary Power System According to the HNP FSAR, Chapter 8.0, the 125 VDC DG power system for each HNP unit includes two DG DC subsystems and one shared [swing] DG DC subsystem. The swing DG is shared between Unit 1 and Unit 2 and is capable of supplying either Unit 1 or Unit 2. Each DG DC subsystem includes one 125 V battery and two 125 V battery chargers (one normally in-service charger and one standby charger). The 125 VDC batteries are 60-cell lead-calcium type with a discharge rating of 410 ampere-hour for the unit DG batteries and 495 ampere-hour for the swing DG battery for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at 77°F to 1. 75 V final average cell voltage. Each battery has adequate storage capacity to carry the required load for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without recharging.

According to the HNP TS Bases, the 125 VDC DG chargers are rated at 100 amperes. The DG DC system is considered operable when its battery and one of its two battery chargers are operable.

3.2 Evaluation of Proposed Changes The HNP Unit 1 and Unit 2 DC systems include a shared swing DG DC subsystem that is plant-specific. The NRC staff used the specifications for the DG DC subsystem provided in TSTF-500 (Reference 13) to review the proposed changes related to the swing DG DC subsystem. In addition, the licensee applied the term "required" to the battery charger to differentiate between the in-service battery charger(s) and the standby battery charger in the DC subsystem.

3.2.1 TS 3.8.4 (DC Sources - Operating) Changes The current TS 3.8.4 for HNP Unit 1 and Unit 2 have slight differences in the LCOs and the TS Action statements from those in the ISTS for BWR/4 plants. The HNP TSs specify operability requirements and actions for certain components in each unit's DC electrical subsystem. For example, in TS 3.8.4 for HNP Unit 1, the LCO requires that the Unit 2 DG DC electrical power subsystems be operable, as specified. These differences have been addressed by the licensee and the NRC staff in assessing the conformance of the proposed TS changes to TSTF-500.

The HNP Unit 1 TS LCO 3.8.4 requires the following DC electrical power subsystems to be operable: (1) the Unit 1 Division 1 and Division 2 station service DC electrical power subsystems (with each station service DC subsystem consisting of one 125/250 V station service battery (two 125 V batteries in series), two battery chargers in service, and the corresponding control equipment and interconnecting cabling supplying power to the associated bus); (2) the Unit 1 DGs and swing DG DC electrical power subsystems (with each DG DC subsystem consisting of one battery bank, one battery charger in service, and the corresponding control equipment and interconnecting cabling); and (3) the Unit 2 DG DC electrical power subsystems needed to support the equipment required to be operable by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System," and LCO 3.8.1, "AC Sources -

Operating." The HNP Unit 1 TS 3.8.4 is applicable in MODES 1, 2, and 3.

The HNP Unit 2 TS 3.8.4 LCO requires the following DC electrical power subsystems to be operable: ( 1) the Unit 2 Division 1 and Division 2 station service DC electrical power subsystems (with each station service DC subsystem consisting of one 125/250 V station service battery (two 125 V batteries in series), two battery chargers in service, and the corresponding control equipment and interconnecting cabling); (2) the Unit 2 DGs and swing DG DC electrical power subsystems (with each DG DC subsystem consisting of one battery bank, one battery charger in service, and the corresponding control equipment and interconnecting cabling); and (3) the Unit 1 DG DC electrical power subsystems needed to support the equipment required to be operable by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System,"

LCO 3.7.4, "Main Control Room Environmental Control (MCREC) System," LCO 3.7.5, "Control Room Air Conditioning (AC) System," and LCO 3.8.1, "AC Sources - Operating." The HNP Unit 2 TS 3.8.4 is applicable in MODES 1, 2, and 3.

The proposed changes to the TS 3.8.4 Actions and SRs for HNP Units 1 and 2 are similar. The licensee proposed to revise HNP Unit 1 and Unit 2 TS 3.8.4 Conditions, Required Actions, and SRs. The proposed changes would: (1) add new conditions to address the operability of the HNP Units' DG DC, swing DG DC, and station service DC battery chargers, (2) modify current SRs that require verification of battery and charger design capabilities and battery terminal voltage, and (3) relocate current preventive maintenance SRs and a current SR that requires verification of a battery capacity.

The following NRC staff evaluation for the proposed changes to HNP TS 3.8.4 is applicable to both Unit 1 and 2.

3.2.1.1 HNP Unit 1 and Unit 2 TS 3.8.4; Current Condition A (Revised);

Change (1)

HNP Unit 1 TS 3.8.4; Current Condition A (Revised)

Current HNP Unit 1 TS 3.8.4 Condition A states:

A. Swing DG DC electrical power subsystem inoperable due to performance of SR 3.8.4.7 or SR 3.8.4.8.

One or more required Unit 2 DG DC electrical power subsystems inoperable.

Revised HNP Unit 1 TS 3.8.4 Condition A would state:

A. Swing DG DC electrical power subsystem inoperable due to performance of SR 3.8.4.3 or SR 3.8.6.6.

One or more required Unit 2 DG DC electrical power subsystems inoperable.

The Required Action A.1 and associated CT for HNP Unit 1 TS 3.8.4 revised Condition A would be unchanged and would state "Restore DG DC electrical power subsystem to OPERABLE status," and "7 days," respectively.

HNP Unit 2 TS 3.8.4; Current Condition A (Revised)

Current HNP Unit 2 TS 3.8.4 Condition A states:

A. Swing DG DC electrical power subsystem inoperable due to performance of SR 3.8.4.7 or SR 3.8.4.8.

One or more required Unit 1 DG DC electrical power subsystems inoperable.

Revised HNP Unit 2 TS 3.8.4 Condition A would state:

A. Swing DG DC electrical power subsystem inoperable due to performance of SR 3.8.4.3 or SR 3.8.6.6.

One or more required Unit 1 DG DC electrical power subsystems inoperable.

The Required Action A.1 and associated CT for HNP Unit 2 TS 3.8.4 revised Condition A would be unchanged and would state "Restore DG DC electrical power subsystem to OPERABLE status" and "7 days," respectively.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Condition A (Revised); Change (1)

Current Condition A is specific to HNP. The current Condition A applies if one or more of the required opposite unit's DG DC electrical power subsystems is/are inoperable or if the swing DG DC electrical power subsystem is inoperable due to performance of SR 3.8.4.7 or SR 3.8.4.8.

The proposed change would revise current Condition A by renumbering SR 3.8.4.7 and SR 3.8.4.8 as SR 3.8.4.3 and SR 3.8.6.6, respectively. The current Required Action A.1 and associated CT would remain unchanged for the revised Condition A.

Current SR 3.8.4.7 (battery service test) requires verification of the battery as-found capability to satisfy the design requirements of the DC electrical power system. The licensee proposed revising SR 3.8.4. 7 by renumbering it as SR 3.8.4.3 and modifying its notes. In Section 3.2.1.12 of this SE, the NRC staff finds that the proposed changes to current SR 3.8.4. 7 are editorial and do not impact the intent of the SR as the required battery as-found capability test will continue to be performed per revised SR 3.8.4.3 (see Section 3.2.1.12 of this SE for more details).

Current SR 3.8.4.8 (battery capacity test) is performed to demonstrate the operability of the battery. The licensee proposed deleting SR 3.8.4.8 (battery capacity test) from TS 3.8.4 and relocating it to TS 3.8.6 as SR 3.8.6.6. In Section 3.2.1.13 of this SE, the NRC staff finds that the relocation of SR 3.8.4.8 does not impact the intent of the SR as the current battery capacity

test will continue to be performed per SR 3.8.6.6 (see Section 3.2.4.19 of this SE for more details).

Since SR 3.8.4.7 and SR 3.8.4.8 are being renumbered as SR 3.8.4.3 and SR 3.8.6.6, respectively, as discussed above, the NRC staff concludes that the proposed change to current TS 3.8.4 Condition A is editorial in nature and, therefore, is acceptable.

The current Required Action A.1 requires the inoperable DG (opposite unit DG or swing DG) DC electrical power subsystem(s) to be restored to operable status within 7 days. If any of the opposite unit's DGs or swing DG DC electrical power subsystems are inoperable for reasons specified in revised Condition A, the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. But, since a subsequent postulated worst-case single failure could result in the loss of certain safety functions (e.g., SGT System and low-pressure coolant injection valve load centers) and/or the loss of the minimum necessary DC electrical subsystems to mitigate a postulated accident, continued power operation should not exceed 7 days. The 7-day CT takes into account the capacity and capability of the remaining DC sources, and is based on the shortest restoration time allowed for the systems affected by the inoperable DC source.

Based on the above, the NRC staff concludes that the proposed revised TS 3.8.4 Condition A continues to provide acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.1.2 HNP Unit 1 and Unit 2 TS 3.8.4; New Condition B (Added); Change (2)

HNP Unit 1 TS 3.8.4; New Condition B (Added)

New HNP Unit 1 TS 3.8.4 Condition B would state:

B. Required Unit 1 DG DC battery charger on one subsystem inoperable.

Required swing DG DC battery charger inoperable for reasons other than Condition A.

New HNP Unit 1 TS 3.8.4 Required Actions B.1, B.2, and B.3 would state:

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

B.2 Verify battery float current is:::; 5 amps.

B.3 Restore battery charger(s) to OPERABLE status.

New CTs for HNP Unit 1 TS 3.8.4 Required Actions B.1, B.2, and B.3 would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />,"

"Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," and "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />," respectively.

HNP Unit 2 TS 3.8.4; New Condition B (Added)

New HNP Unit 2 TS 3.8.4 Condition B would state:

B. Required Unit 2 DG DC battery charger on one subsystem inoperable.

Required swing DG DC battery charger inoperable for reasons other than Condition A.

New HNP Unit 2 TS 3.8.4 Required Actions B.1, B.2, and B.3 would state:

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

B.2 Verify battery float current is s 5 amps.

AND B.3 Restore battery charger(s) to OPERABLE status.

New CTs for HNP Unit 2 TS 3.8.4 Required Actions B.1, B.2, and B.3 would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />,"

"Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," and "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />," respectively.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; New Condition B (Added);

Change (2)

New Condition B would apply when a required battery charger in one unit's (Unit 1 or Unit 2) DG DC subsystem is inoperable or a required battery charger in the swing DG DC subsystem is inoperable for reasons other than Condition A. The alternate condition for the swing DG DC battery charger is specific to HNP. There are three associated Required Actions for new Condition B. 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 B.1 would require the affected DG battery terminal voltage to be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. 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., spare battery charger) of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. At the end of the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 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. This provides assurance that the battery can be restored to its fully charged condition from any discharge that might have occurred due to the charger inoperability. The action to restore battery terminal voltage to greater than or equal to the

minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is consistent with TSTF-500. The NRC staff finds the proposed new Required Action B.1 and its associated CT acceptable.

New Required Action B.2 would require that once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the affected DG battery float current be verified as less than or equal to 5 amps. This would confirm that if the battery has been discharged as a result of an inoperable battery charger, it had been fully recharged. In to the LAR, the licensee stated that the discharged battery with terminal voltage of at least the minimum established float voltage (new Required Action B.1 ), can be fully recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> since the time to fully charge the battery in this condition depends on the previous discharge and the recharge characteristic of the battery. If at the expiration of the 12-hour period, the battery float current is greater than 5 amps, then the battery is considered inoperable (see Section 3.2.3.3 of this SE for a more detailed discussion on the 5-amp float current value). This verification provides assurance that the battery has sufficient capacity to perform its safety function. The action to verify battery float current once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is consistent with TSTF-500, and the 12-hour CT is applicable to HNP. The NRC staff finds the proposed new Required Action B.2 and its associated CT acceptable.

New Required Action B.3 would limit the restoration time for the inoperable required unit DG or swing DG battery charger to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used. In Question 4 of its request for additional information (RAI) dated October 17, 2016 (Reference 22), the NRC staff requested the licensee to provide the HNP basis for the 72-hour CT. By letter dated November 16, 2016 (Reference 8), the licensee stated that the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> will allow, in many cases, a sufficient period of time to correct a charger problem. The 72-hour CT is commensurate with the importance of maintaining the DC system's capability to adequately respond to a design basis event. The 72-hour CT reflects a reasonable time to effect restoration of the qualified battery charger to operable status, because there is an available spare charger with the same capacity and capability of performing its design function.

The action to restore the battery chargers to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is consistent with TSTF-500, and the 72-hour CT is applicable to HNP. The NRC staff finds the proposed new Required Action B.3 and its associated CT acceptable.

Based on the above, the NRC staff concludes that the proposed new TS 3.8.4 Condition B provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.1.3 HNP Unit 1 and Unit 2 TS 3.8.4; Current Condition B (Revised and Renumbered as Condition C); Change (3)

HNP Unit 1 TS 3.8.4; Current Condition B (Revised and Renumbered as Condition C)

Current HNP Unit 1 TS 3.8.4 Condition B states:

B. One Unit 1 DG DC electrical power subsystem inoperable.

Swing DG DC electrical power subsystem inoperable for reasons other than Condition A.

Revised and renumbered HNP Unit 1 TS 3.8.4 Condition C would state:

C. One Unit 1 DG DC electrical power subsystem inoperable for reasons other than Condition B.

Swing DG DC electrical power subsystem inoperable for reasons other than Condition A or B.

Current HNP Unit 1 TS 3.8.4 Required Action B.1 states:

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

Renumbered HNP Unit 1 TS 3.8.4 Required Action C.1 would state:

C.1 Restore DG DC electrical power subsystem to OPERABLE status.

The CT for revised and renumbered HNP Unit 1 TS 3.8.4 Required Actions C.1 would remain unchanged and would state "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

HNP Unit 2 TS 3.8.4; Current Condition B (Revised and Renumbered as Condition C)

Current HNP Unit 2 TS 3.8.4 Condition B states:

B. One Unit 2 DG DC electrical power subsystem inoperable.

Swing DG DC electrical power subsystem inoperable for reasons other than Condition A.

Revised and renumbered HNP Unit 2 TS 3.8.4 Condition C would state:

C. One Unit 2 DG DC electrical power subsystem inoperable for reasons other than Condition B.

Swing DG DC electrical power subsystem inoperable for reasons other than Condition A or B.

Current HNP Unit 2 TS 3.8.4 Required Action B.1 states:

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

Renumbered HNP Unit 2 TS 3.8.4 Required Action C.1 would state:

C.1 Restore DG DC electrical power subsystem to OPERABLE status.

The CT for revised and renumbered HNP Unit 1 TS 3.8.4 Required Action C.1 would remain unchanged and would state "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Current Condition B (Revised and Renumbered as Condition C); Change (3)

Revised and renumbered Condition C would apply when one unit's (Unit 1 or Unit 2) DG DC subsystem is inoperable for reasons other than new Condition B or the swing DG DC electrical power subsystem is inoperable for reasons other than Condition A or new Condition B.

Condition B addresses the inoperability of a required unit's (Unit 1 or Unit 2) DG or a swing DG DC battery charger, since an inoperable required DG DC battery charger renders the associated DG DC subsystem inoperable. Since new Condition B already addresses a case of an inoperable DG DC subsystem, the NRC staff finds it acceptable to revise current Condition B to exclude new Condition B from reasons for having an inoperable DG DC subsystem. The NRC staff also finds that renumbering revised current Condition B as Condition C is editorial in nature, and is, therefore, acceptable.

Renumbered Required Action C.1 would require the inoperable DG DC electrical power subsystem to be restored to operable status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. If a unit DG or swing DG DC subsystem is inoperable for reasons specified in renumbered Condition C, the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent postulated worst-case single failure could result in the loss of the minimum necessary DC electrical subsystem to mitigate a postulated worst-case accident, the CT to restore the inoperable DG DC electrical power subsystem is limited to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The 12-hour CT provides a period of time to correct the problem commensurate with the importance of maintaining the DG DC electrical power subsystem operable. The NRC staff finds that renumbering Required Action 8.1 as C.1 is editorial in nature and is acceptable.

Based on the above, the NRC staff concludes that the proposed TS 3.8.4 Condition C provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.1.4 HNP Unit 1 and Unit 2 TS 3.8.4; New Condition D (Added); Change (4)

HNP Unit 1 TS 3.8.4 New Condition D (Added)

New HNP Unit 1 TS 3.8.4 Condition D would state:

D. One or more required Unit 1 station service DC battery chargers on one subsystem inoperable.

New HNP Unit 1 TS 3.8.4 Required Actions D.1, D.2, and D.3 would state:

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

AND D.2 Verify battery float current is :::; 20 amps.

D.3 Restore battery charger(s) to OPERABLE status.

New CTs for HNP Unit 1 TS 3.8.4 Required Actions D.1, D.2, and D.3 would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />,"

"Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," and "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />," respectively.

HNP Unit 2 TS 3.8.4 New Condition D (Added)

New HNP Unit 2 TS 3.8.4 Condition D would state:

D. One or more required Unit 2 station service DC battery chargers on one subsystem inoperable.

New HNP Unit 2 TS 3.8.4 Required Actions D.1, D.2, and D.3 would state:

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

D.2 Verify battery float current is :::; 20 amps.

D.3 Restore battery charger(s) to OPERABLE status.

New CTs for HNP Unit 2 TS 3.8.4 Required Actions D.1, D.2, and D.3 would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />,"

"Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," and "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />," respectively.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; New Condition D (Added);

Change (4)

New Condition D would apply when one or more required unit (Unit 1 or Unit 2) station service DC battery chargers on one subsystem are inoperable. The new Condition D would provide new Required Actions D.1, D.2, and D.3 that focus on returning the station service battery to the fully charged state and restoring a required fully qualified charger to operable status.

New Required Action D.1 would require that the terminal voltage of the station service battery associated with one or more required station service chargers be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The station battery chargers, in addition to maintaining the battery operable, provide DC control power to AC circuit breakers

and thus support the recovery of AC power following events such as LOOP or SBO. Each HNP station service DC subsystem includes one spare battery charger in standby. If one required battery charger in one station service DC subsystem is inoperable, the 2-hour CT would provide time for returning the inoperable station service battery charger to operable status or for placing the station service standby (spare) battery charger in service to restore the associated battery terminal voltage to at least the minimum established float voltage. At the end of the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, a battery 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. This provides assurance that the battery can be restored to its fully charged condition from any discharge that might have occurred due to the charger inoperability. The NRC staff finds that, when one required battery charger becomes inoperable, the proposed Required Action D.1 and associated 2-hour CT are consistent with TSTF-500. This will ensure that the battery can be fully recharged using the spare battery charger.

In the case of two inoperable required battery chargers in one station service DC subsystem, in Question 4 of its RAI dated October 17, 2016 (Reference 22), the NRC staff requested the licensee to explain how HNP will restore the terminal voltages of both 125 V batteries to greater than or equal to the minimum established float voltage, since the HNP station service DC subsystem includes only one spare battery charger. By letter dated November 16, 2016 (Reference 8), the licensee stated that in a situation where one of the three station service battery chargers was to become inoperable, a spare charger could be staged nearby the battery room, ready to be connected to the batteries should a second battery charger become inoperable. However, the staff requested more detail about the second spare charger, including capacity, capability, classification, and when it would be available. By letter dated February 6, 2017 (Reference 9), the licensee explained that the second spare charger is a Class 1E battery charger with the same capacity as the other spare charger and it could be available and ready for service within the 72-hour period. The TSTF-500 explains that the 72-hour CT for restoring an inoperable battery charger is based on the availability of a spare charger. Therefore, the NRC staff finds that its concern related to the availability of a second spare charger when there are two inoperable battery chargers has been adequately addressed.

New Required Action D.2 would require that once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the affected station service battery float current be verified as less than or equal to 20 amps. This would confirm that, if the battery had been discharged as the result of the inoperable battery charger, it had been fully recharged to supply the maximum expected load requirement. The 20-amp value is based on returning the battery to 95 percent charge, and assumes a 5 percent design margin for the battery. In the LAR, the licensee stated that the discharged station service battery with terminal voltage of at least at the minimum established float voltage (new Required Action D.1 ), can be fully recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> because the time to fully charge a battery in this condition depends on the previous discharge and the recharge characteristics of the battery. If at the expiration of the 12-hour period, the battery float current is greater than 20 amps, then the station service battery is considered inoperable (see Section 3.2.3.3 of this SE for a more detailed discussion on the 20-amp float current value). This verification provides assurance that the battery has sufficient capacity to perform its required safety function. The action to verify battery float current once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is consistent with TSTF-500, and the 12-hour CT is applicable to HNP. The NRC staff finds the proposed new Required Action D.2 and its associated CT acceptable.

New Required Action D.3 would limit the restoration time for an inoperable station service battery charger to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been

used. In Question 4 of its RAI dated October 17, 2016 (Reference 22), the NRC staff requested the licensee to provide the HNP basis for the 72-hour CT. By letters dated November 16, 2016, and February 6, 2017 (Reference 8 and 9), the licensee explained that the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> will allow, in most cases, a sufficient period of time to correct a charger problem. In addition, the 72-hour CTs are commensurate with the importance of maintaining the DC system's capability to adequately respond to a design basis event. The TSTF-500 explains that if the battery terminal voltage is restored to within minimum limits and the battery is fully recharged based upon battery float current, then the 72-hour CT is reasonable for restoration of an inoperable battery charger. The NRC staff finds that the 72-hour CT reflects a reasonable time to effect restoration of the qualified battery charger to operable status because a spare charger with the same capacity and capability of performing its required design function can be installed during this period.

Based on the above, the NRC staff concludes that the proposed TS 3.8.4 new Condition D, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.1.5 HNP Unit 1 and Unit 2 TS 3.8.4; Current Condition C (Revised and Renumbered as Condition E); Change (5)

HNP Unit 1 TS 3.8.4; Current Condition C (Revised and Renumbered as Condition E)

Current HNP Unit 1 TS 3.8.4 Condition C states:

C. One Unit 1 station service DC electrical power subsystem inoperable.

Revised and renumbered HNP Unit 1 TS 3.8.4 Condition E would state:

E. One Unit 1 station service DC electrical power subsystem inoperable for reasons other than Condition D.

Current HNP Unit 1 TS 3.8.4 Required Action C.1 states:

C.1 Restore station service DC electrical power subsystem to OPERABLE status.

Renumbered HNP Unit 1 TS 3.8.4 Required Action E.1 would state:

E.1 Restore station service DC electrical power subsystem to OPERABLE status.

The CT for HNP Unit 1 TS 3.8.4 renumbered Required Action E.1 would remain unchanged and would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />."

HNP Unit 2 TS 3.8.4; Current Condition C (Revised and Renumbered as Condition E)

Current HNP Unit 2 TS 3.8.4 Condition C states:

C. One Unit 2 station service DC electrical power subsystem inoperable.

Revised and renumbered HNP Unit 2 TS 3.8.4 Condition E would state:

E. One Unit 2 station service DC electrical power subsystem inoperable for reasons other than Condition D.

Current HNP Unit 2 TS 3.8.4 Required Action C.1 states:

C.1 Restore station service DC electrical power subsystem to OPERABLE status.

Renumbered HNP Unit 2 TS 3.8.4 Required Action E.1 would state:

E.1 Restore station service DC electrical power subsystem to OPERABLE status.

The CT for HNP Unit 2 TS 3.8.4 renumbered Required Action E.1 would remain unchanged and would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Current Condition C (Revised and Renumbered as Condition E); Change (5)

Current TS 3.8.4 Condition C (for Unit 1 or Unit 2) applies when one of that unit's station service DC subsystems is inoperable. A station service DC subsystem is inoperable when any of its required components, such as a battery charger, is inoperable. Since the inoperability of station service battery chargers will be addressed by new Condition D, current Condition C is revised as new Condition E, to exclude an inoperable battery charger from the reasons for an inoperable station service DC subsystem by adding the statement "for reasons other than Condition D." The NRC staff finds that the revised Condition C (renumbered as Condition E) retains the previous conditions, with the addition of new Condition D to HNP Unit 1 and Unit 2 TS 3.8.4, and is, therefore, acceptable.

Current Required Action C.1 would require restoration of the inoperable station service DC electrical power subsystem to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. If one of the required station service DC electrical power subsystems is inoperable, the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition.

Since a subsequent postulated worst-case single failure could result in the loss of minimum necessary DC electrical subsystems to mitigate a postulated worst-case accident, the CT to restore the inoperable station service DC electrical power subsystem in this condition is limited to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The current Required Action C.1 would be renumbered as Required Action E.1 and is unchanged (i.e., the Required Action is unchanged, although the applicable condition is now limited to station service DC electrical power subsystem inoperability for reasons other than an inoperable station service battery charger). The NRC staff finds that renumbering Required Action C.1 as E.1 is editorial in nature and is acceptable. The inoperability of a station service DC subsystem due to the inoperability of station service battery chargers is addressed by new Condition D, as discussed in Section 3.2.1.4 of this SE.

Based on the above, the NRC staff concludes that the proposed TS 3.8.4 Condition E provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.1.6 HNP Unit 1 and Unit 2 TS 3.8.4; Current Condition D (Revised and Renumbered as Condition F); Change (6)

Current HNP Unit 1 and Unit 2 TS 3.8.4 Condition D states:

D. Required Action and Associated Completion Time of Condition A, B, or C not met.

Revised and renumbered HNP Unit 1 and Unit 2 TS 3.8.4 Condition F would state:

F. Required Action and Associated Completion Time of Condition A, B, C, D, or E not met.

Current HNP Unit 1 and Unit 2 TS 3.8.4 Required Action D.1 states:

D.1 Be in MODE 3 (with a NOTE stating that LCO 3.0.4.a is not applicable when entering MODE 3].

Renumbered HNP Unit 1 and Unit 2 TS 3.8.4 Required Action F.1 would state:

F.1 Be in MODE 3 [with a NOTE stating that LCO 3.0.4.a is not applicable when entering MODE 3].

The CTs for HNP Unit 1 and Unit 2 TS 3.8.4 renumbered Required Action F.1 would remain unchanged and would state "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Current Condition D (Revised and Renumbered as Condition F); Change (6)

Current Condition D would apply when the Required Action and associated CT of any of the current conditions (i.e., inoperable swing or opposite unit's DG DC subsystem, inoperable unit DG DC subsystems, or inoperable unit station service DC subsystems) are not met. In this condition, the unit is required to be in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The current Condition D would be revised and renumbered as Condition F to include the proposed TS 3.8.4 new Conditions B and D, which are related to inoperable DG DC battery chargers and station service DC battery chargers, respectively. The revised Condition D would be renumbered as Condition F. The NRC staff finds that renumbering the revised Condition D as Condition F is editorial in nature and is, therefore, acceptable.

Renumbered TS 3.8.4 Condition F would apply when the Required Action and associated CT of any of the revised TS 3.8.4 Conditions A, B, C, D, or E are not met. This means that an inoperable DG DC or station service DC electrical power subsystem, or the associated battery chargers, cannot be restored to operable status within the required CTs of Conditions A, B, C, D, or E. In this case, the renumbered Required Action F.1 requires that the unit be brought to MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The 12-hour allowed CT is reasonable to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The NRC staff finds that the entry into renumbered Condition F when any of the Required Actions and associated CTs of Conditions A, C or Eis not met is consistent with the HNP current licensing basis (TS 3.8.4 current Condition D). The NRC staff also finds that bringing the plant in MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, when the Required Action and associated CT of

new Condition D (inoperable required unit station service DC battery charger(s)) cannot be met is consistent with TSTF-500.

For the case when an inoperable required unit or swing DG DC battery charger cannot be restored to operable status within the 72-hour CT, as required by new Condition B, the renumbered Condition F would require the unit to be in MODE 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. However, TSTF-500 TS 3.8.4 specifies that the DG associated with the battery charger be declared inoperable immediately in this case. Therefore, in Question 6 of an RAI dated July 13, 2016 (Reference 23), the NRC staff requested the licensee to provide justification for the deviation from the TSTF-500 TS 3.8.4 guidance. In its response letter dated August 12, 2016 (Reference 6), the licensee provided a response that focused primarily on inoperable DG DC batteries rather than inoperable DG DC battery chargers as requested. Thus, the staff requested further clarification from the licensee in Question 3 of a follow-up RAI dated October 17, 2016 (Reference 22). In its response letter dated November 16, 2016 (Reference 8), the licensee explained that the requirements of HNP renumbered Condition F are more conservative than that of the TSTF-500 because renumbered Condition F would require commencement of an immediate shutdown, whereas the TSTF traveler would provide at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of operation if the HNP DG associated with the charger is declared inoperable.

HNP TS 3.8.1, Condition B requires an inoperable unit or swing DG to be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 14 days depending on the alignment and maintenance restrictions of the swing DG. On the other hand, when an inoperable DG charger cannot be restored to operable status, renumbered Condition F would require the plant to be in MODE 3 (hot shutdown) in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Since shutting down the plant within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is more restrictive than continuing operation for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the NRC staff finds that applying renumbered Condition F for instances when the Required Action and associated CT of new Condition B is not met is acceptable.

Based on the above, the NRC staff concludes that the proposed TS 3.8.4 Condition F provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.1.7 HNP Unit 1 and Unit 2 TS 3.8.4; Current Condition E (Renumbered as Condition G); Change (7)

Current HNP Unit 1 and Unit 2 TS 3.8.4 Condition E states:

E. Two or more DC electrical power subsystems inoperable that result in a loss of function.

Renumbered HNP Unit 1 and Unit 2 TS 3.8.4 Condition G would state:

G. Two or more DC electrical power subsystems inoperable that result in a loss of function.

Current HNP Unit 1 and Unit 2 TS 3.8.4 Required Action E.1 states:

E.1 Enter LCO 3.0.3.

Renumbered HNP Unit 1 and Unit 2 TS 3.8.4 Required Action G.1 would state:

G.1 Enter LCO 3.0.3.

The CT for Current Required Action E.1 would remain the same for renumbered Required Action G.1 and would state "Immediately."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Current Condition E (Renumbered as Condition G); Change (7)

The requirements for current Condition E would remain the same for renumbered Condition G.

When the loss of two or more DC electrical power subsystem causes the loss of a required safety function, the plant is in a condition outside the accident analysis. Therefore, LCO 3.0.3 must be entered immediately to start a controlled shutdown.

The NRC staff finds that renumbering the current Condition E as Condition G is editorial in nature and is acceptable.

Based on the above, the NRC staff concludes that the proposed Condition G provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.1.8 HNP Unit 1 and Unit 2 TS 3.8.4, Current SRs Note (Revised);

Change (8)

HNP Unit 1 TS 3.8.4, Current SRs Note (Revised)

Current HNP Unit 1 TS 3.8.4 SRs Note states:


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

SR 3.8.4.1 through SR 3.8.4.8 are applicable only to the Unit 1 DC sources.

SR 3.8.4.9 is applicable only to the Unit 2 DC sources.

Revised HNP Unit 1 TS 3.8.4 SRs Note would state:


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

SR 3.8.4.1 through SR 3:8.4.3 are applicable only to the Unit 1 DC sources.

SR 3.8.4.4 is applicable only to the Unit 2 DC sources.

HNP Unit 2 TS 3.8.4, Current SRs Note (Revised)

Current HNP Unit 2 TS 3.8.4 SRs Note states:


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

SR 3.8.4.1 through SR 3.8.4.8 are applicable only to the Unit 2 DC sources.

SR 3.8.4.9 is applicable only to the Unit 1 DC sources.

Revised HNP Unit 2 TS 3.8.4 SRs Note would state:


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

SR 3.8.4.1 through SR 3.8.4.3 are applicable only to the Unit 2 DC sources.

SR 3.8.4.4 is applicable only to the Unit 1 DC sources.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Current SRs Note (Revised);

Change (8)

The proposed change would renumber SR 3.8.4.8 as SR 3.8.4.3 and SR 3.8.4.9 as SR 3.8.4.4 in the current SRs Note in TS 3.8.4. Currently, each HNP unit TS 3.8.4 includes nine SRs, of which eight (SR 3.8.4.1 - SR 3.8.4.8) are applicable to that unit's DC sources, and one (SR 3.8.4.9) is applicable to the other unit's DC sources. Section 3.2.1.10 of this SE discusses the proposed deletion of SRs 3.8.4.2 - SR 3.8.4.5, and Section 3.2.1.13 of this SE discusses the proposed deletion of SR 3.8.4.8 from TS 3.8.4, and renumbering the remaining SRs. Of the remaining four SRs, three (renumbered SR 3.8.4.1 - SR 3.8.4.3) would be applicable to that HNP unit and the fourth (renumbered SR 3.8.4.4) would apply to the other unit. Based on this information, the NRC staff finds that the proposed change to the Note in the Surveillance Requirements section of TS 3.8.4 is editorial in nature.

Based on the above, the NRC staff concludes that the proposed revised SR note meets 10 CFR 50.36(c)(3) 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.

3.2.1.9 HNP Unit 1 and Unit 2 TS 3.8.4; Current SR 3.8.4.1 (Revised);

Change (9)

Current HNP Unit 1 and Unit 2 SR 3.8.4.1 states:

SR 3.8.4.1 Verify battery terminal voltage is ~ 125 Von float charge.

Revised HNP Unit 1 and Unit 2 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 voltage.

The frequency for revised SR 3.8.4.1 would remain unchanged and would state "In accordance with the Surveillance Frequency Control Program."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Current SR 3.8.4.1 (Revised);

Change (9)

The purpose of SR 3.8.4.1 is to verify the battery terminal voltage while the system is on a float charge to ensure that the battery chargers are not degraded. The battery terminal voltage is the minimum voltage which ensures an optimum float charging voltage is applied to the battery. As discussed in the LAR, the HNP batteries' voltage requirements are based on the nominal design voltage of the batteries and are consistent with the minimum float voltage established by the battery manufacturer, which corresponds to 2.20 Volts per cell (Vpc) for a 58-cell battery or 127.6 Vat the battery terminals. This voltage will maintain the battery plates in a condition that

supports maintaining the battery grid life and will ensure that the battery is capable of providing its designed safety function.

The SR 3.8.4.1 would be revised to verify the battery terminal voltage is greater than or equal to the minimum established float voltage. The minimum established battery float voltage numerical value (design limit) would be relocated to a licensee-controlled program. This will allow flexibility to monitor and control this limit at values directly related to each battery's ability to perform its required safety function. In Attachment 1 to the LAR, the licensee stated that the FSAR will be revised to include the minimum established design limit for battery terminal float voltage, as part of the adoption of TSTF-500, Revision 2. This provides additional reasonable assurance that the numerical value will be appropriately maintained by the licensee to accurately reflect the design and ensure the function of the plant battery system. The NRC staff finds that the relocation of the TS numerical value of the battery's terminal float voltage to a licensee-controlled program allows adequate monitoring of the battery's ability to perform its safety function and is consistent with TSTF-500.

Based on the above, the NRC staff concludes that the proposed revised SR 3.8.4.1 meets 10 CFR 50.36(c)(3) 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.

3.2.1.10 HNP Unit 1 and Unit 2 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 (10)

Current HNP Unit 1 and Unit 2 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 within limits SR 3.8.4.3 Verify battery cells, cell plates, and racks show no visual indication of physical damage or abnormal deterioration.

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

SR 3.8.4.5 Verify battery connection resistance is within limits.

Evaluation of HNP Unit 1 and Unit 2 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 (10)

The proposed change would relocate the requirements of the above SR 3.8.4.2 (visual inspection and connection resistance), SR 3.8.4.3 (visual inspection for physical damage),

SR 3.8.4.4 (remove visible corrosion and ensure that connections are clean and tight), and SR 3.8.4.5 (verification of connection resistance) to the new Battery Monitoring and Maintenance Program proposed to be added as TS 5.5.15.

Visual inspection of the battery terminals (SR 3.8.4.2, SR 3.8.4.3, and SR 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. Therefore, the NRC staff finds that the parameters of the above preventive maintenance SRs 3.8.4.2, 3.8.4.3, and 3.8.4.4 can be adequately controlled in the proposed new TS 5.5.15, "Battery Monitoring and Maintenance Program."

With regard to the resistance verifications of SR 3.8.4.2 and SR 3.8.4.5, the existing values represent limits at which some action should be taken, not necessarily when the operability of the battery is in question. Currently, the specific battery connection resistance values are not provided in SR 3.8.4.2 and SR 3.8.4.5. In its letter dated June 17, 2016 (Reference 5), the licensee stated that the current connection resistance limits are provided in Technical Requirements Manual (a licensee-controlled document), Table T9.1-1.

In general, 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 requirement 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, battery connection resistance verifications are more appropriately controlled under the proposed new Battery Monitoring and Maintenance Program.

Based on the above, the NRC staff concludes that the proposed change is consistent with TSTF-500 and meets 10 CFR 50.36(c)(3) 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.

3.2.1.11 HNP Unit 1 and Unit 2 TS 3.8.4; Current SR 3.8.4.6 (Revised and Renumbered as SR 3.8.4.2); Change (11)

Current HNP Unit 1 and Unit 2 SR 3.8.4.6 states:

Verify each required battery charger supplies ~ 400 amps for station service subsystems, and ~ 100 amps for DG subsystems at ~ 129 V for ~ 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Revised and renumbered HNP Unit 1 and Unit 2 SR 3.8.4.2 would state:

Verify each required battery charger supplies~ 400 amps for station service subsystems, and ~ 100 amps for DG subsystems at greater than or equal to the minimum established float voltage for~ 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Verify each battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 frequency for revised and renumbered SR 3.8.4.2 would remain unchanged and would state "In accordance with the Surveillance Frequency Control Program."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Current SR 3.8.4.6 (Revised and Renumbered as SR 3.8.4.2); Change (11)

Current SR 3.8.4.6 verifies the design capacity of each required battery charger based on ampere and voltage requirements of the chargers. The proposed change would revise this SR by replacing the voltage requirements with the phrase "greater than or equal to the minimum established float voltage," and adding an alternate testing criterion. In addition, the revised SR 3.8.4.6 would be renumbered as SR 3.8.4.2. The NRC staff finds that renumbering SR 3.8.4.6 as SR 3.8.4.2 is editorial in nature and is, therefore, acceptable.

The renumbered SR 3.8.4.2 would provide two options. The first option would require that each battery charger be capable of supplying greater than or equal to 400 amps for station service subsystems and greater than or equal to 100 amps for DG subsystems at the minimum established float voltage for greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The ampere requirements are based on the output rating of the chargers. The minimum established battery float voltage would be relocated to the proposed new Battery Monitoring and Maintenance Program in TS 5.5.15. The battery manufacturers establish this float 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. Relocating this float voltage design limit to a licensee-controlled program will allow flexibility to monitor and control this limit at values directly related to the battery's ability to perform its required safety function. In addition, in Attachment 1 to the LAR, the licensee stated that the HNP FSAR will include the minimum established design limit for the 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. The NRC staff concludes that relocating the numeric value of the battery float voltage limit to the proposed new Battery Monitoring and Maintenance Program is, therefore, acceptable.

The second option of renumbered SR 3.8.4.2 would require that each battery charger be capable of recharging the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 battery is discharged to the bounding design event discharge state after a service test. This option provides an alternate method for verifying the design capacity of each charger because battery normal loading may not be available following the battery service test and will need to be supplemented with additional loads. In Question 9 of its RAI dated July 13, 2016 (Reference 23), the NRC staff requested the licensee to explain the basis for the proposed 24-hour battery recharge time since 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a bracketed value in TSTF-500. In its response letter dated August 12, 2016 (Reference 6), the licensee stated that the battery chargers are capable of fully charging the batteries within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while simultaneously supporting the connected loads, according to the HNP battery sizing calculations for the station service and emergency DG batteries. In addition, the licensee clarified that the station service and DG batteries are required to be recharged following a battery load profile discharge test (or service test). In FSAR Section 8.5 (Unit 1) and Section 8.3 (Unit 2), the licensee stated that each battery charger has adequate capacity to restore its associated battery to full charge within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the minimum discharged condition while carrying the normal unit steady state DC loads. Based on the above, the NRC staff finds that the HNP battery chargers are capable of recharging the battery to the fully charged state within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, consistent with the HNP current licensing basis, 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. Therefore, the NRC staff concludes that the proposed alternate testing criterion for renumbered SR 3.8.4.2 will confirm the battery charger design capacity after a service test, and as such, will satisfy the purpose of current SR 3.8.4.6.

The surveillance frequency for renumbered SR 3.8.4.2 would continue to be controlled by the Surveillance Frequency Control Program (SFCP). In its letter dated June 17, 2016 (Reference 5), the licensee explained that HNP has implemented the SFCP per the provisions of TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control- RITSTF Initiative Sb" (Reference 21 ), which allows the licensee to relocate most periodic frequencies of TS surveillances and their bases to the SFCP. In the current HNP TS, the surveillance frequency of current SR 3.8.4.6, which verifies the design capacity of each battery charger, is controlled by the SFCP. Since the renumbered SR 3.8.4.2 would verify the battery charger's design capacities, the NRC staff finds that controlling the frequency of renumbered SR 3.8.4.2 in accordance with the SFCP is, therefore, acceptable.

In summary, the NRC staff finds the proposed renumbered SR 3.8.4.2 acceptable because the proposed testing criteria for renumbered SR 3.8.4.2 continue to satisfy the intent of current SR 3.8.4.6. Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36(c)(3) 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.

3.2.1.12 HNP Unit 1 and Unit 2 TS 3.8.4; Current SR 3.8.4. 7 (Revised and Renumbered as SR 3.8.4.3); Change (12)

Current HNP Unit 1 and Unit 2 SR 3.8.4.7 states:


NOTE:S------------------------------------------------

1. 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 normally be performed in MODE: 1, 2, or 3, except for the swing DG battery. However, portions of the surveillance may be performed to reestablish OPE:RABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

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

Revised and renumbered HNP Unit 1 and Unit 2 SR 3.8.4.3 would state:


N()l"E:S------------------------------------------------

1. l"he modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.3.
2. l"his Surveillance shall not normally be performed in M()DE: 1, 2, or 3, except for the swing DG battery. However, portions of the surveillance may be performed to reestablish ()PERABILll"Y provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

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

l"he surveillance frequency for revised and renumbered HNP Unit 1 and Unit 2 SR 3.8.4.3 would remain unchanged and would state "In accordance with the Surveillance Frequency Control Program."

Evaluation of HNP Unit 1 and Unit 2 l"S 3.8.4; Current SR 3.8.4.7 (Revised and Renumbered as SR 3.8.4.3); Change (12)

Current SR 3.8.4.7 requires verification of the battery's design capacity and ability to supply and maintain in an operable status all emergency loads for the design duty cycle when subjected to a battery service test. Current SR 3.8.4.7 is modified by two notes, Notes 1 and 2. Note 1 provides the allowance to perform the battery's modified performance discharge test in current SR 3.8.4.8 instead of the battery's service test in current SR 3.8.4.7. Note 2 prohibits the performance of SR 3.8.4.7 in M()DE 1, 2, or 3, except for the swing DG battery, and except when portions of the surveillance may be performed to reestablish component operability, provided an assessment determines the safety of the plant is maintained or enhanced. Note 2 also allows credit to be taken for unplanned events that satisfy SR 3.8.4.7. Note 1 would be revised and Note 2 would remain unchanged.

l"he proposed change would revise Note 1 by renumbering current SR 3.8.4.7 and SR 3.8.4.8 as SR 3.8.4.3 and SR 3.8.6.6, respectively. Renumbering current SR 3.8.4.7 as SR 3.8.4.3 is consistent with the proposed changes to SR 3.8.4.2 through SR 3.8.4.6 (see Sections 3.2.1.10 and 3.2.1.11 of this SE for discussions regarding the changes to SR 3.8.4.2 through SR 3.8.4.6). Also, renumbering current SR 3.8.4.8 to SR 3.8.6.6 is consistent with the proposed relocation and renumbering of current SR 3.8.4.8 (see Section 3.2.1.13 of this SE for further discussion regarding the changes to SR 3.8.4.8). l"he NRC staff concludes that replacing SR 3.8.4.7 and SR 3.8.4.8 with SR 3.8.4.3 and SR 3.8.6.6, respectively, in Note 1 is editorial in nature and is, therefore, acceptable.

Note 1 would also be revised by deleting the words "the service test in." l"his is an editorial change that will continue to allow the modified performance discharge test in renumbered SR 3.8.6.6 to be used in lieu of renumbered SR 3.8.4.3. l"he NRC staff concludes that this proposed change is, therefore, acceptable.

In summary, the NRC staff finds the proposed renumbered SR 3.8.4.3 acceptable because the renumbered SR 3.8.4.3 satisfies the intent of current SR 3.8.4.7. Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36(c)(3) 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.

3.2.1.13 HNP Unit 1 and Unit 2 TS 3.8.4; Current SR 3.8.4.8 (Deleted and Relocated to SR 3.8.6.6); Change (13)

The proposed change would delete SR 3.8.4.8 and relocate the requirement to SR 3.8.6.6.

Current HNP Unit 1 and Unit 2 SR 3.8.4.8 states:


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

This Surveillance shall not be performed in MODE 1, 2, or 3, except for the swing DG battery. However, portions of the surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify battery capacity is 2: 80% of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test.

Current HNP Unit 1 and Unit 2 SR 3.8.4.8 surveillance frequency states:

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 AND 24 months when battery has reached 85% of the expected life with capacity 2: 100% of manufacturer's rating Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Current SR 3.8.4.8 (Deleted and Relocated to SR 3.8.6.6); Change (13)

The licensee proposed deleting SR 3.8.4.8 and relocating the requirement to SR 3.8.6.6. The purpose of this SR is to demonstrate the operability of the battery; thus, this surveillance is appropriately relocated to TS 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.

3.2.1.14 HNP Unit 1 and Unit 2 TS 3.8.4; Current SR 3.8.4.9 (Renumbered as SR 3.8.4.4); Change (14)

HNP Unit 1 TS 3.8.4; Current SR 3.8.4.9 (Renumbered as SR 3.8.4.4)

Current HNP Unit 1 SR 3.8.4.9 states:

For the required Unit 2 DC sources, the SRs of Unit 2 Specification 3.8.4 are applicable.

Renumbered HNP Unit 1 SR 3.8.4.4 would state:

For the required Unit 2 DC sources, the SRs of Unit 2 Specification 3.8.4 are applicable.

The surveillance frequency of renumbered HNP Unit 1 SR 3.8.4.4 would remain unchanged and would state "In accordance with applicable SRs."

HNP Unit 2 TS 3.8.4; Current SR 3.8.4.9 (Renumbered as SR 3.8.4.4)

Current HNP Unit 2 SR 3.8.4.9 states:

For the required Unit 1 DC sources, the SRs of Unit 1 Specification 3.8.4 are applicable.

Renumbered HNP Unit 2 SR 3.8.4.4 would state:

For the required Unit 1 DC sources, the SRs of Unit 1 Specification 3.8.4 are applicable.

The surveillance frequency of renumbered HNP Unit 2 SR 3.8.4.4 would remain unchanged and would state "In accordance with applicable SRs."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.4; Current SR 3.8.4.9 (Renumbered as SR 3.8.4.4); Change (14)

The proposed change would renumber current SR 3.8.4.9 as SR 3.8.4.4. The NRC staff finds that renumbering current SR 3.8.4.9 as SR 3.8.4.4 is editorial in nature and is consistent with the above proposed changes to TS 3.8.4.

Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36(c)(3) 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.

3.2.2 HNP Units 1 and 2 TS 3.8.5 (DC Sources - Shutdown) Changes This section addresses the proposed changes to both HNP Unit 1 TS 3.8.5 and HNP Unit 2 TS 3.8.5. HNP TS 3.8.5 requirements are similar for both Unit 1 and Unit 2, except for the LCO.

The HNP Unit 1 TS LCO 3.8.5 requires the following DC electrical power subsystems to be operable: (a) the Unit 1 DC electrical power subsystems needed to support the DC electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems - Shutdown"; and (b) the Unit 2 DG DC electrical power subsystems needed to support the equipment required to be operable by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System"; and LCO 3.8.2, "AC Sources - Shutdown." Each station service DC subsystem consists of one 125/250 V station service battery (two 125 V batteries in series), two of the three battery chargers in service, and the corresponding control equipment and interconnecting cabling. Each DG DC subsystem consists of one battery bank, one battery charger in service, and the corresponding control equipment and interconnecting cabling. The HNP Unit 1 TS 3.8.5 is applicable in MODES 4 and 5, and during movement of irradiated fuel assemblies in the secondary containment.

The HNP Unit 2 TS LCO 3.8.5 requires the following DC electrical power subsystems to be operable: (a) the Unit 2 DC electrical power subsystems needed to support the DC electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems - Shutdown"; and (b) the Unit 1 DG DC electrical power subsystems needed to support the equipment required to be operable by LCO 3.6.4.3, "Standby Gas Treatment (SGT) System"; and LCO 3.7.4, "Main Control Room Environmental Control (MCREC) System"; LCO 3.7.5, "Control Room Air Conditioning (AC) System"; and LCO 3.8.2, "AC Sources - Shutdown." Each station service DC subsystem consists of one 125/250 V station service battery (two 125 V batteries in series), two of the three battery chargers in service, and the corresponding control equipment and interconnecting cabling. Each DG DC subsystem consists of one battery bank, one battery charger in service, and the corresponding control equipment and interconnecting cabling. The HNP Unit 2 TS 3.8.5 is applicable in MODES 4 and 5, and during movement of irradiated fuel assemblies in the secondary containment.

The licensee proposed to revise TS 3.8.5 Conditions, Required Actions, and SRs for both HNP units. Currently, both HNP Unit 1 and Unit 2 TS 3.8.5 only contain one Condition A for one or more inoperable required DC electrical power subsystems.

The licensee initially proposed to ( 1) add a new Condition A to address the inoperability of required battery charger(s) on one or more required DG DC subsystem(s) while the redundant subsystem battery and required chargers are operable; (2) add a new Condition B to address the inoperability of required battery charger(s) on one required station service DC subsystem while the redundant subsystem battery and required chargers are operable; and (3) revise current Condition A to address the inoperability of both required DG DC subsystem(s) and required station service DC subsystem(s) due to reasons other than new Conditions A and B, respectively. In its letter dated September 20, 2016 (Reference 7), the licensee provided updated changes associated with its letter dated August 12, 2016 (Reference 6), related to RAI Questions 1 and 7. The updated proposed changes would revise TS 3.8.5 to: (1) add the new Conditions A and B, with the terms "required DG DC, and "required station service DC,

provided for clarification for the redundant subsystems; (2) revise current Condition A to address only the inoperability of required DG DC subsystem(s); and (3) add a separate new Condition D for inoperable required station service DC subsystem(s).

The following NRC staff evaluation for the changes proposed to TS 3.8.5 in the licensee's letter dated September 20, 2016, is applicable to both HNP Unit 1 and Unit 2.

3.2.2.1 HNP Unit 1 and Unit 2 TS 3.8.5; New Condition A (Added); Change (1)

New HNP Unit 1 and Unit 2 TS 3.8.5 Condition A would state:

A. One required battery charger on one or more required DG DC electrical subsystems inoperable.

The redundant required DG DC subsystem battery and required charger OPERABLE.

New HNP Unit 1 and Unit 2 TS 3.8.5 Required Actions A.1, A.2, and A.3 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 :5 5 amps.

A.3 Restore battery charger(s) to OPERABLE status.

New CTs for HNP Unit 1 and Unit 2 TS 3.8.5 Required Actions A.1, A.2, and A.3 would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />," "Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," and "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />," respectively.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.5; New Condition A (Added); Change (1)

New Condition A would be applicable when required battery charger(s) on one or more required DG DC subsystem(s) are inoperable and the redundant required DG DC subsystem battery and required chargers are operable. The statements of new Condition A are based on the adoption of TSTF-500, of NUREG-1433, "Standard Technical Specifications for General Electric BWR/4 Plants," TS 3.8.5 Condition A. According to TSTF-500, Condition A is included in the TS only when the plant-specific implementation of TS 3.8.5 may require both a DC electrical subsystem and its redundant subsystem to be operable. The licensee explained that new Condition A would be entered when redundant systems are required to be operable at some point during a scheduled or unscheduled outage.

If the redundant system is not operable during a particular shutdown, then the provisions of new Condition A cannot be used and proposed revised current Condition A (renumbered as Condition C) must be entered upon the inoperability of a required DG DC subsystem. The NRC staff finds that since the HNP TS 3.8.5 may require both DG DC subsystems to be operable during a particular shutdown, the addition of new Condition A to HNP TS 3.8.5 is consistent with TSTF-500, and is, therefore, acceptable.

New Required Action A.1 would provide assurance that the terminal voltage for the battery associated with the inoperable DG DC charger will be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The DG DC 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 LOOP or SBO. The 2-hour CT would provide time for returning an inoperable charger to operable status or for reestablishing an alternate means (e.g., spare 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 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 once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the float current for the battery associated with the inoperable charger be verified as less than or equal to 5 amps. This would confirm that if the battery has been discharged as the result of an inoperable battery charger, it had been fully recharged. In the LAR, the licensee stated that the discharged battery with terminal voltage of at least the minimum established float voltage (new Required Action A.1),

can be fully recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> since the time to fully charge the battery in this condition depends on the previous discharge and the recharge characteristic of the battery. If at the expiration of the 12-hour period, the battery float current is greater than 5 amps, then the battery would be considered inoperable (see Section 3.2.3.3 of this SE for a more detailed discussion on the 5-amp float current value). This verification provides assurance that the battery has sufficient capacity to perform its safety function.

New Required Action A.3 would limit the restoration time for the inoperable required unit DG battery charger to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used. In Question 4 of the RAI dated October 17, 2016 (Reference 22), the NRC staff requested the licensee to provide the HNP basis for the 72-hour CT. By letter dated November 16, 2016 (Reference 8), the licensee stated that the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> will allow, in many cases, a sufficient period of time to correct a charger problem. The staff noted that the 72-hour CT is commensurate with the importance of maintaining the DC system's capability to adequately respond to a design basis event. The 72-hour CT reflects a reasonable time to effect restoration of the qualified battery charger to operable status, because a spare charger with the same capacity and capability of performing its design function can be installed during this period.

Based on the above, the NRC staff concludes that the proposed TS 3.8.5 new Condition A, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.2.2 HNP Unit 1 and Unit 2 TS 3.8.5; New Condition B (Added); Change (2)

New HNP Unit 1 and Unit 2 TS 3.8.5 Condition B would state:

B. One or more required battery chargers on one required station service DC subsystem inoperable.

The redundant required station service DC subsystem battery and required chargers OPERABLE.

New HNP Unit 1 and Unit 2 TS 3.8.5 Required Actions B.1, B.2, and B.3 would state:

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

AND B.2 Verify battery float current :::; 20 amps.

B.3 Restore battery charger(s) to OPERABLE status.

New CTs for HNP Unit 1 and Unit 2 TS 3.8.5 Required Actions B.1, B.2 and B.3 are "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />," "Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," and "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />," respectively.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.5; New Condition B (Added);

Change (2)

New Condition B would be applicable when the required battery charger(s) on one required station service DC subsystem are inoperable and the redundant required station service DC subsystem battery and required chargers are operable. The statements of new Condition B are based on the adoption of TSTF-500, of NUREG-1433, TS 3.8.5 Condition A. According to TSTF-500, NUREG-1433, Condition A is included in the TS only when the plant-specific implementation of TS 3.8.5 may require both DC electrical subsystems to be operable. The license explained that new Condition B would be entered when redundant systems are required to be operable at some point during a scheduled or unscheduled outage. If the redundant system is not operable during a particular shutdown, then the provisions of new Condition B cannot be used and proposed Condition D must be entered upon the inoperability of a required station service DC subsystem. The NRC staff finds that since the HNP TS 3.8.5 may require both station service DC subsystems to be operable during a particular shutdown, the addition of new Condition B to HNP TS 3.8.5 is consistent with TSTF-500, and is, therefore, acceptable.

The associated Required Actions for new Condition B 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. A station service DC subsystem includes two 125 V batteries connected in series, two battery chargers normally in service, and one battery charger in standby (spare).

New Required Action B.1 would provide assurance that the terminal voltage for the battery associated with the inoperable station service DC charger will be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The station service DC battery charger, in addition to maintaining the battery operable, provides DC control power to selected safety-related and non-safety-related components, and thus supports the recovery of AC power following events such as LOOP or SBO. If one required station service DC battery charger is inoperable, the 2-hour CT would provide time for returning an inoperable charger to operable status or for reestablishing an alternate means (e.g., spare 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 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.

During shutdown operation, in the case of two inoperable required battery chargers in one station service DC subsystem, the NRC staff, in Question 4 of the RAI dated October 17, 2016 (Reference 22), requested the licensee to explain how HNP will restore the terminal voltages of both 125 V batteries to greater than or equal to the minimum established float voltage since an HNP station service DC subsystem includes only one spare battery charger. By letter dated November 16, 2016 (Reference 8), the licensee stated that in a situation where one of the three station service battery chargers was to become inoperable, then a spare charger could be staged nearby the battery room, ready to be connected to the batteries should a second battery charger become inoperable. By letter dated February 6, 2017 (Reference 9), the licensee explained that the second spare charger is a Class 1E battery with the same capacity as the other spare charger and that it could be available and ready for service within the 72-hour period. The TSTF-500 explains that the 72-hour CT for restoring an inoperable battery charger is based on the availability of a spare charger. Therefore, the NRC staff finds that its concern related to the availability of a second spare charger when there are two inoperable battery chargers, has been sufficiently addressed.

New Required Action B.2 would require once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the float current for the battery associated with the inoperable charger be verified as less than or equal to 20 amps. This would confirm that if the battery has been discharged as a result of an inoperable battery charger, it had been fully recharged. In the LAR, the licensee stated that the discharged battery with terminal voltage of at least the minimum established float voltage (new Required Action B.1 ),

can be fully recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> since the time to fully charge the battery in this condition depends on the previous discharge and the recharge characteristic of the battery. If at the expiration of the 12-hour period, the battery float current is greater than 20 amps, then the battery would be considered inoperable (see Section 3.2.3.3 of this SE for a more detailed discussion on the 20-amp float current value). This verification provides assurance that the battery has sufficient capacity to perform its safety function.

New Required Action B.3 would limit the restoration time for the inoperable station service battery charger to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used. In Question 4 of the RAI dated October 17, 2016 (Reference 22), the NRC staff requested the licensee to provide the HNP basis for the 72-hour CT. By letters dated November 16, 2016, and February 6, 2017 (References 8 and 9), the licensee explained that the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> will allow in most cases a sufficient period of time to correct a charger problem. In addition, the 72-hour CT is commensurate with the importance of maintaining the DC system's capability to adequately respond to a design basis event. The TSTF-500 explains that if the battery terminal voltage is restored to within minimum limits and the battery is fully recharged based upon battery float current, then the 72-hour CT is reasonable for restoration of an inoperable battery charger. The staff finds that the 72-hour CT provides reasonable time to effect restoration of the battery charger to operable status because a spare charger with the same capacity and capability of performing its required design function can be installed during this period.

Based on the above, the NRC staff concludes that the proposed TS 3.8.5 new Condition B, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.2.3 HNP Unit 1 and Unit 2 TS 3.8.5; Current Condition A (Revised and Renumbered as Condition C); Change (3)

Current HNP Unit 1 and Unit 2 TS 3.8.5, Condition A states:

A. One or more required DC electrical power subsystems inoperable.

Revised and renumbered HNP Unit 1 and Unit 2 TS 3.8.5, Condition C would state:

C. One or more required DG DC electrical power subsystems inoperable for reasons other than Condition A.

Required Actions and associated Completion Times of Condition A not met.

Current HNP Unit 1 and Unit 2 TS 3.8.5, Required Actions A.1, A.2.1, A.2.2, A.2.3, and A.2.4 state:

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

OR A.2.1 Suspend CORE AL TERATIONS.

AND A.2.2 Suspend movement of irradiated fuel assemblies in the secondary containment.

A.2.3 Initiate action to suspend operations with a potential for draining the reactor vessel.

AND.

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

Revised and renumbered HNP Unit 1 and Unit 2 TS 3.8.5, Required Actions C.1, C.2.1, C.2.2, C.2.3, and C.2.4 would state:

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

OR C.2.1 Suspend CORE ALTERATIONS.

AND C.2.2 Suspend movement of irradiated fuel assemblies in the secondary containment.

C.2.3 Initiate action to suspend operations with a potential for draining the reactor vessel.

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

The CTs for HNP Unit 1 and Unit 2 TS 3.8.5, renumbered Required Actions C.1, C.2.1, C.2.2, C.2.3, and C.2.4 would remain unchanged and would each state "Immediately."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.5; Current Condition A (Revised and Renumbered as Condition C); Change (3)

The purpose of this change is to reflect the addition of new Condition A, which would address the inoperability of DG DC battery charger(s). The Required Actions and CTs for current Condition A remain the same for revised Condition A, renumbered as Condition C. If more than one DG DC distribution subsystem is required by LCO 3.8.8, "Distribution Systems -

Shutdown," the remaining subsystem(s) with DG DC power available may be capable of supporting sufficient required features to allow continuation of Core Alterations, irradiated fuel movement, and operations with a potential for draining the reactor vessel. Therefore, the option of declaring the required features inoperable with the associated DC power source(s) also inoperable is made with restrictions implemented in accordance with the affected required features LCO Actions. Otherwise, sufficiently conservative actions are taken (i.e., to suspend Core Alterations, movement of irradiated fuel assemblies, and operations with a potential for draining the reactor vessel) to minimize the probability of the occurrence of postulated events.

Suspension of these activities does not preclude completion of actions to establish a safe, conservative condition. It is further required to initiate action to immediately restore required DG DC electrical power subsystem(s) to operable status. The CT of immediately is consistent with the required times for actions requiring prompt attention. The NRC staff finds the Required Actions and associated CTs for the proposed Condition C acceptable because they are consistent with the HNP current licensing basis for inoperable DC electrical power subsystems at shutdown conditions.

Based on the above, the NRC staff concludes that the proposed TS 3.8.5 Condition C, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.2.4 HNP Unit 1 and Unit 2 TS 3.8.5; New Condition D (Added); Change (4)

New HNP Unit 1 and Unit 2 TS 3.8.5, Condition D would state:

D. One or more required station service DC electrical power subsystems inoperable for reasons other than Condition B.

Required Actions and associated Completion Times of Condition B not met.

New HNP Unit 1 and Unit 2 TS 3.8.5, Required Actions D.1, D.2.1, D.2.2, D.2.3, and D.2.4 would state:

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

D.2.1 Suspend CORE AL TERATIONS.

AND D.2.2 Suspend movement of irradiated fuel assemblies in the secondary containment.

D.2.3 Initiate action to suspend operations with a potential for draining the reactor vessel.

D.2.4 Initiate action to restore required station service DC electrical power subsystems to OPERABLE status.

The CTs for new HNP Unit 1 and Unit 2 TS 3.8.5, Required Actions D.1, D.2.1, D.2.2, D.2.3, and D.2.4 would each state "Immediately."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.5; New Condition D (Added);

Change (4)

The purpose of this change is to reflect the addition of new Condition B, which would address the inoperability of station service DC battery charger(s). New Condition D is similar to TS 3.8.5 renumbered Condition C, with the only difference being that the new Condition D would apply to inoperable required station service DC subsystem(s}, while the renumbered Condition C would address the inoperability of required DG DC subsystem(s). The Required Actions and CTs for

new Condition Dare the same as those for TS 3.8.5, renumbered Condition C. As discussed in Section 3.2.2.3 of this SE, the NRC staff finds that the Required Actions and associated CTs are acceptable because they are consistent with the HNP current licensing basis for inoperable DC electrical power subsystems at shutdown conditions.

Based on the above, the NRC staff concludes that the proposed TS 3.8.5 new Condition D, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.2.5 HNP Unit 1 and Unit 2 TS 3.8.5; SR 3.8.5.1 (Revised); Change (5)

HNP Unit 1 TS 3.8.5; SR 3.8.5.1 (Revised)

Current HNP Unit 1 SR 3.8.5.1 states:

SR 3.8.5.1 ----------------------------------------N()TE----------------------------------------

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

For required Unit 1 DC sources, 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 HNP Unit 1 SR 3.8.5.1 would state:

SR 3.8.5.1 ----------------------------------------N()TE----------------------------------------

The following SRs are not required to be performed: SR 3.8.4.2 and SR 3.8.4.3.

For required Unit 1 DC sources, the following SRs are applicable:

SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 The frequency for revised HNP Unit 1 SR 3.8.5.1 would remain unchanged and would state "In accordance with applicable SRs."

HNP Unit 2 TS 3.8.5; SR 3.8.5.1 (Revised)

Current HNP Unit 2 SR 3.8.5.1 states:

SR 3.8.5.1 ----------------------------------------N()TE:----------------------------------------

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

For required Unit 2 DC sources, 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 HNP Unit 2 SR 3.8.5.1 would state:

SR 3.8.5.1 ----------------------------------------N()TE:----------------------------------------

The following SRs are not required to be performed: SR 3.8.4.2 and SR 3.8.4.3.

For required Unit 2 DC sources, the following SRs are applicable:

SR 3.8.4.1 SR 3.8.4.2 SR 3.8.4.3 The frequency for revised HNP Unit 2 SR 3.8.5.1 would remain unchanged and would state "In accordance with applicable SRs."

!::valuation of HNP Unit 1 and Unit 2 TS 3.8.5; SR 3.8.5.1 (Revised); Change (5)

As discussed in Section 3.2.1.10 and Section 3.2.1.13 of this SE:, (1) current SRs 3.8.4.2, 3.8.4.3, 3.8.4.4, 3.8.4.5, and 3.8.4.8 will be deleted or relocated from TS 3.8.4, and (2) current SRs 3.8.4.6 and 3.8.4.7 will be renumbered as SR 3.8.4.2 and SR 3.8.4.3, respectively.

Therefore, the references in revised SR 3.8.5.1 to the revised SRs 3.8.4.1, 3.8.4.2, and 3.8.4.3, are consistent with the proposed changes to TS 3.8.4.

Current HNP TS require the performance of SR 3.8.4.6 (to be revised to SR 3.8.4.2) as invoked by SR 3.8.5.1. The note in revised SR 3.8.5.1 would not require SR 3.8.4.2 and SR 3.8.4.3 to be performed. This note is consistent with TSTF-500. According to TSTF-500, the purpose of the note is to preclude requiring the operable DC sources from being discharged below their capability to provide the required power supply or being rendered inoperable during the performance of SRs 3.8.4.2 and 3.8.4.3. Since SRs 3.8.4.2 and 3.8.4.3 are associated with the battery charger capacity test and the battery capacity test, respectively, the NRC staff finds that the note is acceptable for HNP SR 3.8.5.1 to avoid rendering a battery and/or a charger inoperable during the performance of these SRs at shutdown conditions. Conversely, the alternate criterion added to SR 3.8.4.2 would allow performance of the alternate test when the DC electrical power subsystem is not needed to support the DC electrical power distribution system required by LC() 3.8.8.

In summary, the NRC staff finds the proposed revised SR 3.8.5.1 acceptable since the proposed change is consistent with TSTF-500 and the proposed changes to TS 3.8.4, and also meets the intent of the current SR. Based on the above, the NRC staff concludes that the proposed revised SR 3.8.5.1 meets 10 CFR 50.36(c)(3) 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 HNP Unit 1 and Unit 2 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) of the battery. The licensee also proposed revising the current TS 3.8.6 title, LCO, Conditions, Required Actions and SRs, deleting Table 3.8.6-1, "Battery Cell Parameter Requirements," and relocating some SRs to the proposed new TS 5.5.15, "Battery Monitoring and Maintenance Program." The current TS 3.8.6 and the proposed changes to TS 3.8.6 are similar for both HNP Unit 1 and Unit 2. Therefore, the following NRC staff evaluation for the proposed changes to TS 3.8.6 is applicable to both HNP Unit 1 and Unit 2.

3.2.3.1 HNP Unit 1 and Unit 2 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 HNP Unit 1 and Unit 2 TS 3.8.6; Title (Revised); Change (1)

The NRC staff finds that deleting the term "cell" in the current title of TS 3.8.6 is editorial in nature. Therefore, the NRC staff concludes that the proposed revised title of TS 3.8.6 is acceptable since it does not change the intent of TS 3.8.6.

3.2.3.2 HNP Unit 1 and Unit 2 TS 3.8.6; Table 3.8.6-1, "Battery Cell Parameter Requirements" (Deleted); Change (2)

The current 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 delete TS Table 3.8.6-1 and relocate the table requirements to proposed new LCOs and SRs in TS 3.8.6 and the proposed new Battery Monitoring and Maintenance Program in TS 5.5.15.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; Table 3.8.6-1 (Deleted);

Change (2)

The current TS Table 3.8.6-1 Category A defines the 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.

The licensee proposed relocating the Category A and B values for electrolyte level, float voltage, and specific gravity of TS Table 3.8.6-1 and the required actions associated with restoring inoperable batteries to operable status to the Battery Monitoring and Maintenance Program, required by proposed new TS 5.5.15. In Question 5 of the RAI dated October 17, 2016 (Reference 22), the NRC staff asked the licensee to clarify whether the battery cell

parameters that are proposed to be relocated to the Battery Monitoring and Maintenance Program will be at the current Category A, B, and C limits. By letter dated November 16, 2016 (Reference 8), the licensee confirmed that the current TS Table 3.8.6-1 Category A and B limits will be maintained at their current levels in accordance with new TS 5.5.15, "Battery Monitoring and Maintenance Program." The licensee also clarified that the current Category C limits for specific gravity will also be relocated to the Battery Monitoring and Maintenance Program.

Furthermore, the licensee stated that actions to restore deficient values of the Category A, B, and C limits will be tracked and implemented in accordance with the SNC corrective action program.

On page 1O of the NRC-approved TSTF-500 traveler, Revision 2, it states: "The Category A and B values of TS Table 3.8.6-1 represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. The definition of Limiting Condition for Operation presented in 10 CFR 50.36(c)(2)(i) states that LCOs are 'the lowest functional capabilities or performance levels of equipment required for the safe operation of the facility.' As such, the Category A and B values for cell voltage and electrolyte level do not reflect the 10 CFR 50.36 criteria for LCOs." In addition, as discussed in Section 3.2.3.3 of this SE, specific gravity measurement criteria will no longer be required per the TS SRs and are being replaced with float current monitoring.

The NRC staff finds that relocating the Category A and B values for electrolyte level, float voltage, and specific gravity as well as the Category C values for specific gravity to the Battery Monitoring and Maintenance Program is acceptable, because: (1) the Category A and B values are maintenance levels (and the staff agrees with the reasoning in TSTF-500 that these values do not reflect the criteria of 10 CFR 50.36(c)(2) for LCOs); (2) specific gravity criteria are being replaced with float current monitoring limits; and (3) 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. Furthermore, the preventive maintenance for the batteries and related components are subject to the regulatory requirements of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

The NRC staff finds that these changes will provide adequate assurance that the battery parameters are appropriately maintained at an acceptable level of performance.

By letter dated November 16, 2016, the licensee clarified that current TS Table 3.8.6-1 Category C limits for electrolyte level and float voltage will also be monitored and maintained per the requirements of the TS. The TS 3.8.6 proposed new Conditions D and A will provide the requirements for battery electrolyte level and float voltage, respectively, based on the current limits for these parameters (see Sections 3.2.3.7 and 3.2.3.9 of this SE for the NRC staff evaluation of the proposed new conditions). In addition, the proposed new SRs 3.8.6.3 and 3.8.6.5 will require monitoring of battery connected cell's electrolyte level and float voltage, respectively (see Sections 3.2.3.16, and 3.2.1.18 of this SE for the NRC staff evaluation of the proposed new SRs). These proposed new SRs will satisfy the intent of the Category C limits.

Therefore, the NRC staff concludes that the elimination of TS Table 3.8.6-1 Category C limits is acceptable.

Based on the above, the NRC staff concludes that the proposed elimination of Table 3.8.6-1 ensures the battery parameters (i.e., electrolyte level, float voltage, and specific gravity) will be appropriately monitored and maintained in accordance with the TS Battery Monitoring and Maintenance Program in TS 5.5.15, the requirements of 10 CFR 50.65 (Maintenance Rule), and

the revised requirements in TS 3.8.6. The NRC staff finds that there is adequate assurance that safe plant conditions will continue to be maintained, and as such, the proposed change is, therefore, acceptable. The implications of this change on the LCO are discussed in Section 3.2.3.4 of this SE.

3.2.3.3 HNP Unit 1 and Unit 2 TS 3.8.6; Float Current Monitoring (Added to Replace Specific Gravity Measurement); Change (3)

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 proposed new Battery Monitoring and Maintenance Program specified in TS 5.5.15.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; Float Current Monitoring (Added to Replace Specific Gravity Measurement); Change (3)

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 method for determining battery state of charge than specific gravity monitoring. The licensee proposed a float current of 20 amps for the station service battery and 5 amps for the DG battery. In Attachment 3 to the LAR, the licensee stated that the 20-amp and 5-amp values for the station service and DG battery float currents, respectively, are based on returning the battery to 95 percent charge and assumes a 5 percent design margin for the battery.

In Enclosure 1 of the LAR, the licensee provided a letter dated April 25, 2012, from the manufacturer of the HNP Units 1 and 2 Class 1E batteries, verifying the acceptability of using float current monitoring instead of specific gravity monitoring as a reliable and accurate indication of the state of charge of the batteries for the life of the batteries. However, the licensee did not state how the float current values were obtained. Hence, to determine the adequacy of the proposed battery float currents, the NRC staff requested the licensee to explain how the float current values for the station service and DG batteries were derived in Question 2 of the RAI dated July 13, 2016 (Reference 23).

In its response letter dated August 12, 2016 (Reference 6), the licensee provided a summary of the calculations for the float currents (or return to service currents) using the charger rated DC output amps, net charging amps, and the float current limit at three time constants. The licensee considered the maximum current limit of the battery chargers as the net charging amps for the batteries. However, the NRC staff could not determine whether the battery chargers' connected DC loads were taken into account in the float current calculations provided. Thus, in Question 1 of a follow-up RAI dated October 17, 2016 (Reference 22), the NRC staff requested the licensee to provide data to show that the station service and DG batteries are 95 percent charged with their respective float currents at 20 amps and 5 amps while being supplied by their associated battery chargers operating in the float charge mode. In its response letter dated November 16, 2016 (Reference 8), the licensee explained that the methodology used in determining the battery (DG and station service) charge accounts for the connected loads. In addition, the chargers for both DG and station service batteries are sufficiently sized such that, when operating in the float charge mode at their respective float currents, the batteries will maintain a 5 percent design margin (i.e., will be at least 95 percent charged).

The NRC staff finds that the licensee's confirmation from the battery manufacturer regarding the use of float current measurement to determine the batteries' state of charge, in addition to the 5 percent design margin used for the batteries sizing, provide adequate assurance that replacing the specific gravity measurements with the float current monitoring will not impact the ability to accurately determine the operability of the batteries.

In Attachment 2 to the LAR, the licensee stated that the FSAR will be revised to provide a description of how a 5 percent design margin for the batteries corresponds to a 20-amp and 5-amp float current value, for the station service and DG batteries, respectively, indicating that the batteries are 95 percent charged. This provides reasonable assurance that the batteries' float current values will appropriately reflect the design of the plant.

The requirements for monitoring the float currents are provided in the proposed new SR 3.8.6.1 (see Section 3.2.4.14 of this SE for the NRC staff evaluation of the proposed new SR 3.8.6.1 ).

In addition, in Attachment 1, Section 2.2 of the LAR, the licensee stated that the measuring equipment that will be used to monitor float current under proposed new SR 3.8.6.1 will have the necessary accuracy and capability to measure electrical currents in the expected range.

Furthermore, specific gravity monitoring is appropriate for troubleshooting activities and for periodic trending of the batteries' 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 or battery modified performance discharge test in accordance with the proposed new Battery Monitoring and Maintenance Program in TS 5.5.15.

The NRC staff concludes that the proposed float current monitoring is a suitable replacement for the specific gravity monitoring when used to determine the state of charge of the HNP DG and station service safety-related batteries. The staff further concludes that the proposed changes meet 10 CFR 50.36(c)(3) requirements for surveillances by ensuring that the necessary quality of systems and components is maintained and that the LCOs will be met and the changes are, therefore, acceptable.

3.2.3.4 HNP Unit 1 and Unit 2 TS 3.8.6; LCO 3.8.6 (Revised); Change (4)

Current LCO 3.8.6 states:

LCO 3.8.6 Battery cell parameters for the station service and DG 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 station service and DG electrical power subsystem batteries shall be within limits.

Evaluation of TS 3.8.6; LCO 3.8.6 (Revised); Change (4)

The proposed changes would remove the word "cell" and would add the term "electrical power subsystem" to LCO 3.8.6, and delete the reference to Table 3.8.6-1 from the LCO. The NRC staff finds that the wording changes do not change the intent of the LCO. In addition, as discussed in Sections 3.2.3.2 and 3.2.3.3 above, Table 3.8.6-1 will be deleted from the TS with the table's battery parameter limits relocated to proposed new Conditions and SRs in TS 3.8.6 and to the proposed new Battery Monitoring and Maintenance Program in TS 5.5.15.

Therefore, the NRC staff finds that deleting the reference to Table 3.8.6-1 from LCO 3.8.6 is consistent with the proposed changes discussed in other sections of this SE.

The NRC staff concludes that the proposed revised LCO 3.8.6 is acceptable and will continue to meet the requirements of 10 CFR 50.36(c)(2).

3.2.3.5 HNP Unit 1 and Unit 2 TS 3.8.6; Current Condition A (Deleted);

Change (5)

Current HNP Unit 1 and Unit 2 TS 3.8.6, Condition A states:

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

Current HNP Unit 1 and Unit 2 TS 3.8.6, Required Actions A.1, A.2, and A.3 state:

A.1 Verify pilot cell's 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.

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

Evaluation of HNP Unit 1 and Unit 2 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. The NRC staff finds 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 3.2.3.2 of this SE for further discussion on the elimination of TS Table 3.8.6-1 ).

Therefore, the NRC staff concludes that this elimination of TS 3.8.6 current Condition A is acceptable since the change is editorial in nature and does not change the intent of TS 3.8.6.

3.2.3.6 HNP Unit 1 and Unit 2 TS 3.8.6; New Condition A (Added); Change (6)

New HNP Unit 1 and Unit 2 TS 3.8.6, Condition A would state:

A. One DG or station service battery on one subsystem with one or more battery cells float voltage~ 2.07 V.

New HNP Unit 1 and Unit 2 TS 3.8.6 Required Actions A.1, A.2, and A.3 would state:

A.1 Perform SR 3.8.4.1.

AND A.2 Perform SR 3.8.6.1.

AND A.3 Restore affected cell voltage> 2.07 V.

New CTs for HNP Unit 1 and Unit 2 TS 3.8.6 Required Actions A.1, A.2, and A.3 would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />," "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />," and "24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />," respectively.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New Condition A (Added);

Change (6)

New TS 3.8.6 Condition A would apply when one DG or a station service battery on one subsystem is found with one or more battery cells with a float voltage of less than or equal to 2.07 V. According to TSTF-500, entry into TS 3.8.6 Condition A requires a battery cell float voltage of less than 2.07 V. The NRC staff requested the licensee to justify the proposed battery cell float voltage limit in proposed new Condition A. By letter dated August 12, 2016 (Reference 6), the licensee stated that the proposed cell float voltage in new Condition A is consistent with the current TS Table 3.8.6-1 Category C limit for connected cells float voltage, which is "greater than 2.07 V." The HNP current TS Bases for TS Table 3.8.6-1 state that the battery cell float voltage limit of 2.07 Vis based on the recommendations of IEEE Std. 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications" (Reference 17). The IEEE Std. 450states that a battery cell float voltage of 2.07 V or below, not caused by elevated temperature of the cell, indicates internal cell problems (degradation) and may require cell replacement. The NRC staff finds that a battery cell float voltage of 2.07 V or less for the HNP batteries may indicate an internal cell degradation problem if not caused by elevated temperature. Therefore, the NRC staff concludes that the proposed new Condition A is acceptable, since the proposed battery cell float voltage limit is consistent with the HNP current licensing basis and IEEE Std. 450.

New Condition A would provide remedial measures (Required Actions) for the condition of a degraded battery cell. Required Action A.1 would require the licensee to verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that the affected DG or station service battery terminal voltage is greater than or equal to the minimum established float voltage (revised SR 3.8.4.1 ). As stated in Attachment 2 to the LAR, the minimum established design limits for the DG and station service batteries' terminal float voltages will be incorporated into the HNP FSAR as specified by TSTF-500, Revision 2.

Required Action A.2 would require verification of each DG or station service battery's float current to be less than or equal to 5 amps and 20 amps, respectively (proposed new SR 3.8.6.1 ). The above actions ensure that there is still sufficient battery capacity to perform the intended safety functions. Therefore, continued operation is permitted for a limited period up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to allow restoration of the affected cell(s) voltage to greater than 2.07 V per Required Action A.3. The NRC staff finds that the proposed Required Actions A.1, A.2, and A.3 and the associated CTs are consistent with TSTF-500, and as such, the proposed Required Actions and associated CTs for new Condition A provide reasonable assurance of safety.

Based on the above, the NRC staff concludes that the proposed TS 3.8.6, new Condition A, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.3.7 HNP Unit 1 and Unit 2 TS 3.8.6; New Condition B (Added); Change (7)

New HNP Unit 1 and Unit 2 TS 3.8.6, Condition B would state:

B. One DG battery on one subsystem with float current > 5 amps.

New HNP Unit 1 and Unit 2 TS 3.8.6, Required Actions B.1 and B.2 would state:

B.1 Perform SR 3.8.4.1.

B.2 Restore battery float current to s 5 amps.

New CTs for HNP Unit 1 and Unit 2 TS 3.8.6, Required Actions B.1 and B.2 would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />" and "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," respectively.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New Condition B (Added);

Change (7)

New TS 3.8.6 Condition B would apply when one DG battery on one subsystem is found with a float current greater than 5 amps. A DG battery's float current of greater than 5 amps indicates that a partial discharge of the battery has occurred. The discharge of the battery may be due to a temporary loss of a battery charger or possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity.

The new Required Action B.1 would verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that the DG battery terminal voltage is greater than or equal to the minimum established float voltage (revised SR 3.8.4.1 ), thus confirming battery charger operability. If the DG battery had been discharged due to an inoperable battery charger, the 2-hour CT would provide time to return the inoperable charger to operable status or reestablish an alternate means (e.g., spare battery charger) of restoring the affected DG battery terminal voltage to greater than or equal to the minimum established float voltage. At the end of the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 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. This provides assurance that the battery can be restored to its fully charged condition.

New Required Action B.2 would require the affected DG battery float current to be restored to less than or equal to 5 amps within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (see Section 3.2.3.3 of this SE for a discussion on the 5-amp float current value). This would confirm that the affected DG battery had been fully recharged from any discharge that might have occurred. In Attachment 3 to the LAR, the licensee stated that the discharged battery with terminal voltage of at least the minimum established float voltage can be fully recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a sufficient amount of time to fully charge the battery in this condition, accounting for the previous discharge and the recharge characteristics of the battery. Restoring the affected DG battery to its fully charged state provides the assurance that the battery has sufficient capacity to perform its safety function.

Based on the above, the NRC staff concludes that the proposed TS 3.8.6 Condition B, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.3.8 HNP Unit 1 and Unit 2 TS 3.8.6; New Condition C (Added); Change (8)

New HNP Unit 1 and Unit 2 TS 3.8.6 Condition C would state:

C. One station service battery on one subsystem with float current > 20 amps.

New HNP Unit 1 and Unit 2 TS 3.8.6, Required Actions C.1 and C.2 would state:

C.1 Perform SR 3.8.4.1.

AND C.2 Restore battery float current to ::;; 20 amps.

New CTs for HNP Unit 1 and Unit 2 TS 3.8.6, Required Actions C.1 and C.2 would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />" and "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," respectively.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New Condition C (Added); Change (8)

New Condition C would apply when one station service battery on one subsystem is found with float current greater than 20 amps. A station service battery's float current of greater than 20 amps indicates that a partial discharge of the battery capacity has occurred. This may be due to a temporary loss of a battery charger or possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity.

The new Required Action C.1 would verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that the station service battery terminal voltage is greater than or equal to the minimum established float voltage (revised SR 3.8.4.1 ),

thus confirming battery charger operability. If the station service battery had been discharged due to an inoperable battery charger, the 2-hour CT would provide time to return the inoperable charger to operable status or reestablish an alternate means (e.g., spare battery charger) of restoring the affected station service battery terminal voltage to greater than or equal to the minimum established float voltage. At the end of the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 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. This provides assurance that the battery can be restored to its fully charged condition.

New Required Action C.2 would require the affected station service battery float current to be restored to less than or equal to 20 amps within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (see Section 3.2.3.3 of this SE for a discussion on the 20-amp float current value). This would confirm that the affected station service battery had been fully recharged from any discharge that might have occurred. In to the LAR, the licensee stated that the discharged battery with terminal voltage of at least the minimum established float voltage can be fully recharged within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a sufficient amount of time to fully charge the battery in this condition, accounting for the previous discharge and the recharge characteristics of the battery. Restoring the affected station service battery to its fully charged state provides reasonable assurance that the battery has sufficient capacity to perform its safety function.

Based on the above, the NRC staff concludes that the proposed TS 3.8.6 new Condition C, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.3.9 HNP Unit 1 and Unit 2 TS 3.8.6; New Condition D (Added); Change (9)

New HNP Unit 1 and Unit 2 TS 3.8.6 Condition D would state:


N()TE:-----------------------------------------------

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

D. ()ne DG or station service battery on one subsystem with one or more cells electrolyte level less than minimum established design limits.

New HNP Unit 1 and Unit 2 TS 3.8.6 Required Actions D.1, D.2, and D.3 would state:


N()TE:-----------------------------------------------

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

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

AND D.2 Verify no evidence of leakage.

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

New CTs for HNP Unit 1 and Unit 2 TS 3.8.6 Required D.1, D.2, and D.3 would state "8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />,"

"12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />," and "31 days," respectively.

E:valuation of HNP Unit 1 and Unit 2 TS 3.8.6; New Condition D (Added);

Change (9)

New Condition D would apply when one DG or station service battery on one subsystem is found with one or more cells with an electrolyte level less than the minimum established design limits. If the electrolyte level is below the top of the battery's plates, there is a potential for dryout and plate degradation. New Required Action D.1 would restore the electrolyte level to above top of the plates (the current Category C limit for battery connected cell electrolyte level) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and the new Required Action D.2 would 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. These actions are modified by a note that would indicate that they are only applicable if electrolyte level is below the top of the plates. Additionally, provisions in the proposed new Battery Monitoring and Maintenance Program specified in TS 5.5.15 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 D.1 and D.2 ensure that the batteries will be restored to an operable condition in a timely manner.

If the electrolyte level is above the top of the plates, but below the minimum established design limits, the battery should still have sufficient capacity to perform the intended safety function.

The affected battery is not required to be considered inoperable solely as a result of electrolyte level not being met. New Required Action D.3 would restore the affected battery electrolyte level to greater than or equal to the minimum established design limits within 31 days. In to the LAR, the licensee stated that the minimum established design limits for battery electrolyte level will be incorporated into the HNP FSAR. This provides reasonable assurance that the minimum limits for the batteries' electrolyte levels will appropriately reflect the design of the plant.

Based on the above, the NRC staff concludes that the proposed TS 3.8.6 new Condition D, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.3.10 HNP Unit 1 and Unit 2 TS 3.8.6; New Condition E (Added); Change (10)

New HNP Unit 1 and Unit 2 TS 3.8.6, Condition E would state:

E. One DG or station service battery on one subsystem with pilot cell electrolyte temperature less than minimum established design limits.

New HNP Unit 1 and Unit 2 TS 3.8.6, Required Action E.1 would state:

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

New CT for HNP Unit 1 and Unit 2 TS 3.8.6, Required Action E.1 would state "12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New Condition E (Added);

Change (10)

The proposed new TS 3.8.6, Condition E would apply when one DG or station service battery in one subsystem is found with a pilot cell electrolyte temperature less than the minimum established design limit. A low battery electrolyte temperature limits the current and power available from the battery. Batteries are designed with margins to account for factors such as temperature and aging affecting battery performance. In Attachment 1, Section 2.2 of the LAR, the licensee stated that the HNP DG and station service batteries are sized with temperature and aging margins, which will be described in the FSAR, and a 5 percent design margin will be maintained to ensure that the batteries are 95 percent charged once charging currents reach 5 amps for the DG batteries and 20 amps for the station service batteries. Furthermore, the licensee stated that temperature excursions are expected to be detected and corrected prior to the average battery electrolyte temperature dropping below the minimum electrolyte temperature. In Question 5 of the RAI dated July 13, 2016 (Reference 23), the NRC staff requested the licensee to discuss periodic monitoring of the battery room temperature and actions to restore battery room temperature if it was outside the temperature design limits.

In its response letter dated August 12, 2016 (Reference 6), the licensee stated that the temperature of the DG and station service battery rooms are monitored and recorded at a minimum of once per day on the dayshift in accordance with plant daily rounds procedures.

Each room has a high and low administrative temperature limit provided in the procedures. If the temperature in a DG or station service battery room is found below the administrative limit, the procedures require performance of current TS SR 3.8.6.3, which is being replaced with the proposed new TS SR 3.8.6.4 (see Section 3.2.3.17 of this SE for the NRC staff evaluation of the proposed new SR 3.8.6.4). In addition, the temperature monitoring frequency for the affected battery room could be increased to some appropriate value, beyond the routine once per day check, until the room temperature returned to normal, and heaters could be used to mitigate cold temperatures. The NRC staff finds that the response to the above RAI is acceptable because the licensee explained that the battery temperature is monitored daily and that there are procedures in place to restore the pilot cell electrolyte temperature to within design limits.

Based on the above considerations for the batteries (i.e., temperature margins and room temperature monitoring) and the fact that batteries have very large thermal inertia, the NRC staff concludes that the DG or station service battery's room temperature excursion will likely be corrected by the licensee prior to the battery's electrolyte reaching its maximum or minimum design temperature. In addition, 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) the HNP batteries are designed with adequate margins (i.e., temperature, aging, and design); and (3) the licensee monitors and corrects low battery room temperatures. If the DG or station service battery pilot cell electrolyte temperature falls below the minimum design temperature, the new Required Action E.1 would require restoration of the pilot cell temperature to greater than or equal to the minimum established design limit within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Since the temperature of the entire battery is represented by the pilot cell temperature, the 12-hour CT provides adequate time to restore the battery electrolyte temperature within established limits. This ensures that the other cells are above the pilot cell voltage which must remain above the TS limit.

Currently, the licensee monitors battery average cell electrolyte temperature (current SR 3.8.6.3) instead of battery pilot cell temperature (proposed new SR 3.8.6.4). In order to use pilot cell temperature instead of average battery cell temperature, temperature must be used as a criterion when selecting a pilot cell. However, in Attachment 1 to the LAR, the licensee stated that temperature will not be taken into account when selecting a pilot cell. As discussed in TSTF-500, Revision 2, Section 4.0, "Technical Analysis," if it can be shown that the maximum temperature deviation across the battery does not exceed the maximum of 5 °F as recommended by IEEE Std. 450-2002 (Reference 17), then temperature is not a critical parameter and does not have to be taken into account when selecting pilot cells. Therefore, in Question 3 of the RAI dated July 13, 2016 (Reference 23), the NRC staff requested the licensee to provide temperature deviations for the batteries based on operational experience.

In its response letter dated August 12, 2016, the licensee provided randomly selected historical cell temperature data for the various station service and DG batteries. The data indicated that the HNP station service and DG batteries do not exhibit cell electrolyte temperature variations of greater than 5 °F (maximum is 4 °F). The NRC finds that, since the maximum temperature variations across the station service and DG batteries do not exceed 5 °F, temperature is not critical parameter and does not have to be a criterion in the selection of pilot cells according to TSTF-500, Revision 2. Thus, the NRC staff concludes that the licensee practice for selecting battery pilot cells without accounting for temperature is acceptable.

Regarding the method for selecting pilot cells, TSTF-500, Revision 2 states that, due to the change of the minimum voltage limit for battery cells, pilot cells must be selected to represent the lowest voltage cells in the battery. This ensures that the voltages of the other cells in the battery are above the pilot cell voltage, which must remain above the TS cell voltage limit (i.e.,

greater than 2.07 V). In the response letter dated August 12, 2016, the licensee stated that pilot cells will be selected using voltage and specific gravity to determine those cells that best approximate the condition of the entire battery.

In Question 2 of the follow-up RAI dated October 17, 2016 (Reference 22), the NRC staff requested the licensee to explain the proposed method for selecting pilot cells using voltage and specific gravity. In its response letter dated November 16, 2016 (Reference 8), the licensee stated that the pilot cell for each battery will be selected to be the connected cell with the lowest voltage. The licensee further clarified that if a pilot cell for specific gravity is needed, a cell that is representative of the specific gravity of all the batteries' cells will be selected. This will result in two pilot cells, one for voltage and one for specific gravity, unless the cell representative of the specific gravity is also the lowest voltage cell. The NRC staff finds that since the station service and DG batteries' pilot cells will be selected based on the lowest voltage cells, the proposed method of selection for pilot cells is consistent with TSTF-500, Revision 2 and is, therefore, acceptable.

Based on the above, the NRC staff concludes that the proposed TS 3.8.6 new Condition E, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.3.11 HNP Unit 1 and Unit 2 TS 3.8.6; New Condition F (Added); Change (11)

New TS 3.8.6 Condition F would state:

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

New HNP Unit 1 and Unit 2 TS 3.8.6, Required Action F.1 would state:

F.1 Restore battery parameters for batteries in one subsystem to within limits.

New CT for HNP Unit 1 and Unit 2 TS 3.8.6 Required Action F.1 would state "2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New Condition F (Added); Change (11)

The licensee proposed adding new TS 3.8.6 Condition F 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 functions. With redundant batteries involved, loss of function is possible for multiple systems that depend upon the batteries.

Required Action F.1 would restore the battery parameters for the affected battery in one subsystem to within limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Considering the potential for loss of function of components that depend on the batteries (i.e., emergency AC power subsystem(s), electrical breaker control/position indication power), the NRC staff finds the relatively short duration of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to resolve the condition acceptable, and is consistent with TSTF-500.

Based on the above, the NRC staff concludes that the proposed TS 3.8.6 new Condition F, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.3.12 HNP Unit 1 and Unit 2 TS 3.8.6; Current Condition B (Revised and Renumbered as Condition G); Change (12)

Current HNP Unit 1 and Unit 2 TS 3.8.6, Condition B states:

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

OR One or more batteries with average electrolyte temperature of the representative cells not within limits.

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

Revised and renumbered HNP Unit 1 and Unit 2 TS 3.8.6, Condition G would state:

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

One DG battery on one subsystem with one or more battery cells float voltages 2.07 V and float current> 5 amps.

One station service battery on one subsystem with one or more battery cells float voltage s 2.07 V and float current > 20 amps.

Current HNP Unit 1 and Unit 2 TS 3.8.6, Required Action 8.1 states:

B.1 Declare associated battery inoperable Revised and renumbered HNP Unit 1 and Unit 2 TS 3.8.6, Required Action G.1 would state:

G.1 Declare associated battery inoperable.

The CT for HNP Unit 1 and Unit 2 TS 3.8.6, Required Action B.1, renumbered as Required Action G.1, would remain unchanged and would state "Immediately."

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; Current Condition B (Revised and Renumbered Current Condition G); Change (12)

Current Condition B describes conditions of battery inoperability. The second entry condition (i.e., one or more batteries with average electrolyte temperature of the representative cells not within limits) is being deleted. The out-of-limit condition for pilot cell electrolyte temperature is covered in the proposed new TS 3.8.6, Condition E. The third entry condition (i.e., one or more batteries with battery cell parameters not within Category C limits) is also being deleted.

Deleting the third entry condition is consistent with the elimination of TS Table 3.8.6-1 from the TS. Therefore, the NRC staff concludes that the elimination of the second and third entry conditions of current Condition Bis acceptable.

Current Condition B is proposed to be revised and renumbered as Condition G. Condition G would apply when battery parameters fall outside the allowance of the Required Actions for Condition A, B, C, D, E, or F. Under this condition, it is assumed that there is insufficient capacity to supply the maximum expected load requirements. Condition G also addresses two new alternate conditions where (1) one DG battery is found with one or more battery cells having a float voltage less than or equal to 2.07 V and a float current greater than 5 amps; or (2) one station service battery is found with one or more battery cells having a float voltage less than or equal to 2.07 V and a float current greater than 20 amps. In these cases, the affected DG or station service battery may not have sufficient capacity to perform its intended design function.

The Required Action for either of the above entry conditions would be to declare the associated battery inoperable with a CT of "immediately." The NRC staff finds the Required Action and associated CT for new Condition G reasonable, since the battery capacity may be insufficient to supply the required loads in the above conditions specified for new Condition G.

Based on the above, the NRC staff concludes that the proposed TS 3.8.6, Condition G, with its associated Required Actions and CTs, provides acceptable remedial actions as allowed by 10 CFR 50.36(c)(2) and is, therefore, acceptable.

3.2.3.13 HNP Unit 1 and Unit 2 TS 3.8.6; Current SRs 3.8.6.1, 3.8.6.2, and 3.8.6.3 (Deleted); Change (13)

Current HNP Unit 1 and Unit 2 TS 3.8.6 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 parameters meet Table 3.8.6-1 Category B limits.

SR 3.8.6.3 Verify average electrolyte temperature of representative cells is

: 65°F for each station service battery, and;::::: 40°F for each DG battery.

The current HNP Unit 1 and Unit 2 TS 3.8.6 SRs 3.8.6.1 and 3.8.6.3 and their associated surveillance frequencies would be deleted.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; Current SRs 3.8.6.1, 3.8.6.2. and 3.8.6.3 (Deleted); Change (13)

Table 3.8.6-1 Category A and B limits, as referenced in current SRs 3.8.6.1 and 3.8.6.2, represent appropriate monitoring and maintenance levels for long-term battery quality and extended battery life, and not a condition in which the batteries cannot perform their safety function. The licensee proposed relocating the Category A and B values of TS Table 3.8.6-1 for electrolyte level, individual battery cell float voltage, and specific gravity and the remedial actions associated with restoring the battery cell parameters to within limits to the proposed new Battery Monitoring and Maintenance Program specified in TS Section 5.5.15. As discussed in Section 3.2.3.3 of this SE, the NRC staff concluded that relocating the TS Table 3.8.6-1 Category A and B limits to the proposed new Battery Monitoring and Maintenance Program is acceptable because (1) the Category A and B values are maintenance levels; (2) specific gravity criteria are being replaced with float current monitoring limits; and (3) the licensee provided assurance that these battery parameter values will continue to be controlled at their current levels, and that actions to restore deficient values will be implemented in accordance with the licensee's corrective action program. Therefore, the NRC staff finds that the elimination of current SRs 3.8.6.1 and 3.8.6.2 is acceptable because this change is consistent with the acceptable elimination of Table 3.8.6-1 from the TS.

Current SR 3.8.6.3, which requires the monitoring of the battery's average cell electrolyte temperature, will be replaced with new SR 3.8.6.4, which also will require the monitoring of the battery's pilot cell electrolyte temperature (see Section 3.2.3.17 of this SE for more details).

Since the battery cell electrolyte temperature will be acceptably monitored per new SR 3.8.6.4, the NRC staff finds the elimination of current SR 3.8.6.3 acceptable.

Based on the above, the NRC staff concludes that the proposed deletion of SRs 3.8.6.1, 3.8.6.2, and 3.8.6.3 discussed above is acceptable since the change is consistent with the proposed changes to TS 3.8.6 and with TSTF-500.

3.2.3.14 HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.1 (Added); Change (14)

New SR 3.8.6.1 would state:

SR 3.8.6.1 ----------------------------------------N()TE----------------------------------------

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 DG battery float current is :s; 5 amps and each station service battery float current is :s; 20 amps.

The surveillance frequency for new SR 3.8.6.1 would state:

In accordance with the Surveillance Frequency Control Program Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.1 (Added); Change (14)

The proposed new SR 3.8.6.1 would require verification that the DG battery float current is less than or equal to 5 amps and each station service battery float current is less than or equal to 20 amps. The purpose of this SR is to determine the state of charge of the battery. Float

- S4 -

charge is the condition in which the battery charger is supplying the continuous small amount of current 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 discussed in Section 3.2.3.3 of this SE, the use of float current to determine the state of charge of the battery is consistent with the battery manufacturer's recommendations.

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.1 in the Surveillance Frequency Control Program (SFCP) required by TS S.S.13, for consistency with the HNP adoption of TSTF-42S, Revision 3, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative Sb" (Reference 21 ). The current HNP TS have incorporated TSTF-42S, which allows the licensee to relocate most periodic frequencies of TS surveillances and their bases to the SFCP required by TS S.S.13. According to TSTF-42S, all frequencies can be relocated to the SFCP except:

  • Frequencies that reference other approved programs for the specific interval (such as the lnservice 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after thermal power reaching <:: 9S 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 3.8.6.1 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. The TS Bases for the new SR 3.8.6.1 are revised to state that the surveillance frequency is controlled under the SFCP. Furthermore, as stated in TS S.S.13, changes to the frequencies listed in the SFCP shall be made in accordance with Nuclear Energy Institute NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies," April 2007 (Reference 24). Based on the above information, the NRC staff finds that controlling the new SR 3.8.6.1 frequency under the SFCP is consistent with TSTF-42S requirements, and the SFCP provides assurance that the frequency will effectively be changed in accordance with NEI 04-10.

New SR 3.8.6.1 would be modified by a Note that would allow SR 3.8.6.1 to not be met when the battery terminal voltage is less than the minimum established float voltage of revised SR 3.8.4.1. When this minimum established float voltage is not maintained at the battery's terminal, it likely indicates issues with the associated battery charger. In this case, the Required Actions for the new TS 3.8.4 Conditions B and D will provide the necessary and appropriate verifications of the battery condition. Furthermore, the float current limits of S amps and 20 amps for the DG and station service batteries, respectively, are established based on the batteries' nominal float voltage values and are not directly applicable when the minimum

established float voltages are not maintained. Based on the above, the NRC staff finds the Note for new SR 3.8.6.1 acceptable.

The NRC staff concludes that the proposed new SR 3.8.6.1 meets 10 CFR 50.36(c)(3) 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 HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.2 (Added); Change (15)

New SR 3.8.6.2 would state:

SR 3.8.6.2 Verify each DG and each station service battery pilot cell float voltage is> 2.07 V.

The surveillance frequency for new SR 3.8.6.2 would state:

In accordance with the Surveillance Frequency Control Program Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.2 (Added);

Change (15)

The proposed new SR 3.8.6.2 would require verification that the float voltage of pilot cells is greater than 2.07 V. In Question 8 of the RAI dated July 13, 2016 (Reference 23), the NRC staff requested that the licensee explain the difference in the battery cell float voltage limit of "greater than 2.07 Volt" compared to the TSTF-500 TS 3.8.6 battery cell float voltage limit, which is "greater than or equal to 2.07 Volt." In its letter dated August 12, 2016 (Reference 6),

the licensee stated that the cell float voltage of "greater than 2.07 V" is consistent with the current TS Table 3.8.6-1 Category C limit for connected cells float voltage. In the current HNP TS Bases for Table 3.8.6-1, the licensee stated that the battery cell float voltage limit of 2.07 V is based on the recommendations of IEEE Std. 450(Reference 17). The IEEE Std. 450stated that a battery cell float voltage of 2.07 V or below, not caused by elevated temperature of the cell, indicates internal cell problems (degraded) and may require cell replacement. Hence, the cell voltage level of 2.07 V represents the point at which battery operability cannot be assured.

The pilot cell float voltage limit must be greater than 2.07 V to reflect the operability limit for the batteries. As discussed in Section 3.2.3.10 of this SE, the pilot cells will be selected based on the lowest cell voltages in the batteries. This ensures that the voltages of the other cells in the batteries are above the pilot cell voltage.

Furthermore, 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 132 Vat the battery terminals, or 2.20 Vpc for the DG and station service 60-cell batteries. This provides adequate over-potential, which limits the formation of lead sulfate and self-discharge, which could eventually render the battery inoperable. In Attachment 3 to the LAR, the licensee stated that the float voltage at the batteries' terminals is maintained between 2.20 Vpc and 2.25 Vpc. Float voltages in this range or less, but greater than 2.07 Vpc, are addressed in the proposed new Battery Monitoring and Maintenance Program in TS 5.5.15. The program includes actions to: (1) restore battery cells with float voltage less than 2.13 V, and (2) 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. Based on the above information, the NRC staff finds that when all battery cells are above 2.07 V, there is adequate assurance that that the battery's terminal voltage is at an acceptable threshold for

establishing battery operability. Therefore, the NRC staff concludes that the proposed new SR is acceptable.

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.2 in the SFCP required by TS 5.5.13 for consistency with the HNP adoption of TSTF-425, Revision 3 (Reference 21 ). The surveillance frequency for new SR 3.8.6.2 applies to the verification of pilot cell float voltage. In accordance with TSTF-425, this frequency does not reference other approved programs, is not event-driven, and is not related to a specific condition of the battery.

Also, the TS Bases for new SR 3.8.6.2 state that the surveillance frequency is controlled under the SFCP. Additional details of the NRC staff evaluation of a similar change can be found in the above Section 3.2.3.14 of this SE. The NRC staff finds that controlling the new SR 3.8.6.2 frequency under the SFCP is acceptable since this change is consistent with TSTF-425, Revision 3.

Based on the above, the NRC staff concludes that the proposed new SR 3.8.6.2 meets 10 CFR 50.36(c)(3) 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 HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.3 (Added); Change (16)

New SR 3.8.6.3 would state:

SR 3.8.6.3 Verify each DG and each station service battery connected cell electrolyte level is greater than or equal to minimum established design limits.

The surveillance frequency for new SR 3.8.6.3 would state:

In accordance with the Surveillance Frequency Control Program Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.3 (Added);

Change (16)

New SR 3.8.6.3 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 limits ensures that the battery plates do not suffer physical damage and continue to maintain adequate electron transfer capability.

The minimum established design limits for battery connected cell electrolyte level would be relocated to the proposed new Battery Monitoring and Maintenance Program in TS 5.5.15. This relocation will allow flexibility to monitor and control this limit at values directly related to the battery's ability to perform its required safety function. In Attachment 2 to the LAR, the licensee stated that the minimum established design level limit for electrolyte level will be included in the HNP FSAR. 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. Based on the above information, the NRC staff finds the proposed new SR 3.8.6.3 acceptable.

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.3 in the SFCP required by TS 5.5.13 for consistency with the HNP adoption of TSTF-425, Revision 3 (Reference 21 ). The surveillance frequency for new SR 3.8.6.3 applies to the verification of

each battery connected cell electrolyte level. In accordance with TSTF-425, this frequency does not reference other approved programs, is not event-driven, and is not related to a specific condition of the battery. Also, the TS Bases for new SR 3.8.6.3 state that the surveillance frequency is controlled under the SFCP. Additional details of the staff evaluation of a similar change can be found in Section 3.2.3.14 of this SE. The NRC staff finds that controlling the new SR 3.8.6.3 frequency under the SFCP is acceptable since this change is consistent with TSTF-425, Revision 3.

Based on the above, the NRC staff concludes that the proposed new SR 3.8.6.3 meets 10 CFR 50.36(c)(3) 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 HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.4 (Added); Change (17)

New SR 3.8.6.4 would state:

SR 3.8.6.4 Verify each DG and each station service battery pilot cell temperature is greater than or equal to minimum established design limits.

The surveillance frequency for new SR 3.8.6.4 would state:

In accordance with the Surveillance Frequency Control Program Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.4 (Added); Change (17)

New SR 3.8.6.4 would require verifying the pilot cell (versus the average) electrolyte temperature to be greater than or equal to minimum established design limits. As discussed in Section 3.2.3.10 of this SE, HNP batteries are designed with margins to account for factors affecting performance (e.g., temperature, aging), and there is monitoring to maintain optimum battery room temperatures. In addition, batteries have very large thermal inertia. As a result, the pilot cell temperature is an accurate representation of the temperature of the battery bank.

When the pilot cell temperature is greater than or equal to the minimum established design limits, there is reasonable assurance that the battery's 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. The relocation of the minimum established design limit for the battery electrolyte temperature will allow flexibility to monitor and control this limit at values directly related to the battery's ability to perform its intended function. In Attachment 2 to the LAR, the licensee stated that the minimum established design limit for electrolyte temperature will be included in the FSAR. 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. Based on the above information, the NRC staff finds the proposed new SR 3.8.6.4 acceptable.

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.4 in the SFCP required by TS 5.5.13 for consistency with the HNP adoption of TSTF-425, Revision 3 (Reference 21 ). The surveillance frequency for new SR 3.8.6.4 applies to the verification of each battery pilot cell temperature. In accordance with TSTF-425, the frequency does not

reference other approved programs, is not event-driven, and is not related to a specific condition of the battery. Also, the TS Bases for new SR 3.8.6.4 are revised to state that the surveillance frequency is controlled under the SFCP. Additional details of the NRC staff evaluation of a similar change can be found in Section 3.2.3.14 of this SE. The NRC staff finds that controlling the new SR 3.8.6.4 frequency under the SFCP is acceptable since this change is consistent with TSTF-425, Revision 3.

Based on the above, the NRC staff concludes that the proposed new SR 3.8.6.4 meets 10 CFR 50.36(c)(3) 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 HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.5 (Added); Change (18)

New SR 3.8.6.5 would state:

SR 3.8.6.5 Verify each DG and each station service battery connected cell float voltage is > 2.07 V.

The surveillance frequency of new SR 3.8.6.5 would state:

In accordance with the Surveillance Frequency Control Program Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.5 (Added); Change (18)

New SR 3.8.6.5 would require verification that the float voltage of all connected cells are greater than 2.07 V. As discussed in Section 3.2.3.15 of this SE, the cell voltage level of 2.07 V represents the point below which battery operability cannot be assured. Furthermore, 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 132 V at the battery terminals, or 2.20 Vpc for the DG and station service 60-cell batteries.

This provides adequate over-potential, which limits the formation of lead sulfate and self-discharge, which could eventually render the battery inoperable. In Attachment 3 to the LAR, the licensee stated that the float voltage at the batteries' terminals is maintained between 2.20 Vpc and 2.25 Vpc. Float voltages in this range or less, but greater than 2.07 Vpc, are addressed in the proposed new Battery Monitoring and Maintenance Program in TS 5.5.15.

The program includes: (1) actions to restore battery cells with float voltage less than 2.13 V, and (2) 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. Based on the above information, the NRC staff finds that when all battery connected cells float voltages are above 2.07 V, there is adequate assurance that the battery's terminal voltage is at an acceptable threshold for establishing battery operability. Therefore, the NRC staff concludes that the proposed new SR 3.8.6.5 is acceptable.

The licensee proposed to specify the surveillance frequency for new SR 3.8.6.5 in the SFCP required by TS 5.5.13 for consistency with the HNP adoption of TSTF-425, Revision 3 (Reference 21 ). The surveillance frequency for new SR 3.8.6.5 applies to the verification of pilot cell float voltage. In accordance with TSTF-425, the frequency does not reference other approved programs, is not event-driven, and is not related to a specific condition of the battery.

Also, the 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 of a similar change

can be found in Section 3.2.4.14 of this SE. The NRC staff finds that controlling the new SR 3.8.6.3 frequency under the SFCP is acceptable since this change is consistent with TSTF-425, Revision 3.

Based on the above, the NRC staff concludes that the proposed new SR 3.8.6.5 meets 10 CFR 50.36(c)(3) 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.

3.2.3.19 HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.6 (Relocated - Current SR 3.8.4.8); Change (19)

New SR 3.8.6.6 would state:

SR 3.8.6.6 ----------------------------------------N 0 TE----------------------------------------

T his Surveillance shall not normally be performed in MODE 1, 2, or 3, except for the swing DG battery. However, portions of the surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

Verify DG and station service battery capacity is ;:: 80% of the manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test.

The surveillance frequency for new SR 3.8.6.6 would state:

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

of manufacturer's rating The licensee initially proposed to replace current SR 3.8.4.8 with new SR 3.8.6.6, but to relocate all three current surveillance frequencies into the SFCP. The NRC staff noted that the initial proposed change for new SR 3.8.6.6 would be a deviation from TSTF-500, Revision 2, and does not meet the criteria for relocation of SRs to the SFCP as specified in TSTF-425 (Reference 21 ), which the licensee has adopted as approved by the NRC staff in a previous LAR. Specifically, the 12-month and 24-month frequencies of HNP current SR 3.8.4.8 and TSTF-500, SR 3.8.6.6 are related to battery degradation and age and, therefore, should not be relocated to the SFCP. In its letter dated August 12, 2016 (Reference 6), in response to the NRC staff request for justification of the proposed frequency for new SR 3.8.6.6, the licensee stated that the frequencies of the proposed new SR 3.8.6.6 will be revised to remain consistent

with the frequencies of current SR 3.8.4.8. By letter dated September 20, 2016 (Reference 7),

the licensee submitted the revised proposed SR 3.8.6.6.

Evaluation of HNP Unit 1 and Unit 2 TS 3.8.6; New SR 3.8.6.6 (Relocated - Current SR 3.8.4.8); Change (19)

The current SR 3.8.4.8 is a battery capacity test with three surveillance frequencies, which are based on the battery's expected life, degradation, and capacity. These frequencies are based on the qualified life (typically 20 years) and known historical performance characteristics for vented lead-acid batteries, as discussed in the IEEE Std. 450-2002 (Reference 17). The purpose of current SR 3.8.4.8 (battery capacity test) is to demonstrate the operability of the battery; therefore, this SR is being relocated to TS 3.8.6 for battery parameters, as new SR 3.8.6.6.

The new SR 3.8.6.6 would verify battery capacity similarly to current SR 3.8.4.8. The surveillance frequencies for the new SR 3.8.6.6 would remain the same as for current SR 3.8.4.8 and provide adequate data points for trending in order to determine the state-of-health of the safety-related batteries given their expected service life. The surveillance frequencies: ( 1) are appropriately based on the condition of the battery; (2) allow sufficient time for corrective actions to be taken; and (3) are consistent with the safety significance of safety-related batteries.

Based on the above, the NRC staff concludes that the proposed new SR 3.8.6.6 meets 10 CFR 50.36(c)(3) 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 (Programs and Manuals) Change The proposed change would add a new Battery Monitoring and Maintenance Program to TS 5.5.15, and is similar for both HNP Unit 1 and Unit 2. Therefore, the NRC staff evaluation below for the proposed change to add TS 5.5.15 is applicable to both HNP Unit 1 and Unit 2.

3.2.4.1 HNP Unit 1 and Unit 2 TS 5.5.15, New Battery Monitoring and Maintenance Program (Added)

New TS 5.5.15 would state:

5.5.15 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:: 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 HNP Unit 1 and Unit 2 TS 5.5.15; New Battery Monitoring and Maintenance Program (Added)

The proposed new TS Battery Maintenance and Monitoring Program will be in accordance with IEEE Std. 450-2002 (Reference 17), as endorsed by RG 1.129, Revision 2 (Reference 16).

Revision 2 of RG 1.129 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 5.5.15) represent reasonable technical approaches and are appropriate for applying the RG provisions to the proposed TS requirements for 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 Battery Monitoring and Maintenance 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.

The HNP TS 5.4, "Procedures," requires written procedures be established, implemented, and maintained covering the proposed new Battery Monitoring and Maintenance Program. The TS 5.5.15, "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. Furthermore, the batteries and their preventive maintenance and monitoring program continue to be subject to the regulatory requirements of 10 CFR 50.65.

The NRC staff finds that this change is consistent with TSTF-500 and provides assurance that the batteries will be maintained at required levels of performance and that pertinent battery parameters will be monitored. Based on the above, the NRC staff concludes that the proposed change meets 10 CFR 50.36( c)(3) 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 FSAR Descriptions Required for Adoption of TSTF-500, Revision 2 In Attachment 2 to the LAR dated August 11, 2015 (Reference 1), the licensee provided a list of proposed revisions to the FSAR descriptions for HNP, Units 1 and 2, required as part of the adoption of TSTF-500, Revision 2, and stated, in part, that:

SNC will change or verify that the FSAR:

1. Describes how a 5 percent design margin for the batteries corresponds to a 20 amp and 5 amp float current value, for the station service and diesel

generator batteries, respectively, indicating the batteries are 95 percent charged.

2. States that long term battery performance is supported by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to 2.20 V per connected cell and that there are 60 connected cells in the battery, which corresponds to 132 V at the battery terminals.
3. Describes how the batteries are sized with correction margins that include temperature and aging and how these margins are maintained.
4. States the minimum established design limit for battery terminal float voltage.
5. States the minimum established design limit for electrolyte level.
6. States the minimum established design limit for electrolyte temperature.
7. Describes how each battery is designed with additional capacity above that required by the design duty cycles to allow for temperature variations and other factors.
8. Describes normal DC system operation (i.e., powered from the battery chargers) with the batteries floating on the system, and a loss of normal power to the battery charger describing how the DC load is automatically powered from the station batteries.

The NRC staff considers this statement to be a regulatory commitment on the part of SNC to change or verify the FSAR descriptions, as listed in Attachment 2 to the letter dated August 11, 2015, consistent with the model application referenced in the TSTF-500 notice of availability in the September 1, 2011, Federal Register (76 FR 54510).

As discussed in Section 4.4.1 of the NRC's Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-101, Revision 5, "License Amendment Review Procedures" (Reference 25),

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., FSAR). As discussed in this SE, the NRC staff has relied, in part, on the above commitment as part of the NRC staff's approval of the proposed amendment. Consistent with the guidance in NRR Office Instruction LIC-101, the NRC staff has determined that the commitment should be incorporated into the FSAR. As such, the NRC staff has added the following words as a condition of the amendment to ensure that the FSAR is revised as part of the amendment implementation:

Implementation of the amendment shall include revision of the Final Safety Analysis Report as described in Attachment 2 to the licensee's letter dated August 11, 2015.

The NRC staff notes that following incorporation of the descriptions and statements listed in to the licensee's letter dated August 11, 2015, into the FSAR, future changes to the program as described in the FSAR will be under the provisions of 10 CFR 50.59.

Based on the above, the NRC staff concludes that the licensee's planned revisions and verifications of the HNP Unit 1 and Unit 2 FSAR language as listed above satisfy TSTF-500, Revision 2 guidance and are consistent with the Model Application for Plant-Specific Adoption of Traveler TSTF-500, Revision 2, "DC Electric Rewrite - Update to TSTF-360."

3.4 Summary and Conclusion Based on the above evaluation, the NRC staff finds that the proposed changes to the HNP Unit 1 and Unit 2 TS to adopt TSTF-500, Revision 2, provide assurance of the continued availability of the required DC power systems 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 finds that the proposed TS changes continue to meet the requirements of 10 CFR 50.36 and the intent of GDCs 1, 17, and 18, and the associated Plant Design Criteria.

Therefore, the staff concludes that the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendments on July 27, 2017. The NRC staff verified that the State official had no comments on July 31, 2017.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on June 7, 2016 (81 FR 36623).

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.

6.0 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.

7.0 REFERENCES

1. Pierce, C. R., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant - Units 1 and 2, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF)

Traveler TSTF-500, Revision 2, 'DC Electrical Rewrite - Update To TSTF-360,"' dated August 11, 2015 (ADAMS Accession No. ML15226A276).

2. Pierce, C. R., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant, Request for Additional Information on TSTF-500, 'DC Electrical Rewrite,"' dated October 27, 2015 (ADAMS Accession No. ML15300A442).
3. Pierce, C. R., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant Units 1 and 2, Response to License Amendment Request Unacceptable with Opportunity to Supplement," dated March 16, 2016 (ADAMS Accession No. ML16076A453).
4. Meier, M. D., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant Unit 1 and 2, Response to License Amendment Request Unacceptable with Opportunity to Supplement," dated April 4, 2016 (ADAMS Accession No. ML16095A373).
5. Pierce, C. R., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "E. I. Hatch Nuclear Plant Units 1 and 2, Withdrawal of TSTF-500 Request to Increase the Completion Time for the Station Service Batteries from 2 to 12 Hours," dated June 17, 2016 (ADAMS Accession No. ML16169A239).
6. Wheat, J. T., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant Units 1 and 2, Response to Request for Additional Information on Technical Specifications Revision Request to Implement TSTF-500, 'DC Electrical Re-Write,"' dated August 12, 2016 (ADAMS Accession No. ML16225A687).
7. Wheat, Justin T., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant Units 1 and 2, Revised Technical Specification Pages for Technical Specification Revision Request to Implement TSTF-500, 'DC Electrical Re-Write,"' dated September 20, 2016 (ADAMS Accession No. ML16264A488).
8. Pierce, C. R., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant Units 1 and 2, Response to Request for Additional Information on Technical Specifications Revision Request to Implement TSTF-500, 'DC Electrical Re-write,'" dated November 16, 2016 (ADAMS Accession No. ML16321A497).
9. Pierce, C. R., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant Units 1 and 2, Response to Verbal Request for Additional Information on Technical Specifications Revision Request to Implement TSTF-500, 'DC Electrical Re-write,"' dated February 6, 2017 (ADAMS Accession No. ML17037D334).
10. Hutto, J. J., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant Units 1 and 2, Transmission of Latest Marked-Up and Clean Technical Specification Pages for HNP Implementation of TSTF-500, 'DC Electrical Rewrite,"' dated April 4, 2017 (ADAMS Accession No. ML17100A167).
11. Hutto, J. J., Southern Nuclear Operating Company, Inc., letter to U.S. Nuclear Regulatory Commission, "Edwin I. Hatch Nuclear Plant, Transmission of Marked-Up and Clean Technical Specification Pages for Section 5.5.15 for HNP Implementation of TSTF-500, 'DC Electrical Rewrite,"' dated May 11, 2017 (ADAMS Accession No. ML17131A043).
12. U.S. Nuclear Regulatory Commission, "Model Application for Plant-Specific Adoption of Traveler TSTF-500, Revision 2, 'DC Electrical Rewrite - Update to TSTF-360, '" dated August 22, 2011 (ADAMS Accession No. ML111751792).
13. Technical Specifications Task Force, letter to U.S. Nuclear Regulatory Commission, "Transmittal of TSTF-500, Revision 2, 'DC Electrical Rewrite - Update to TSTF-360,"'

dated September 22, 2009 (ADAMS Accession No. ML092670242).

14. U.S. Nuclear Regulatory Commission, NUREG-1433, Volume 1, Revision 4.0, "Standard Technical Specifications - General Electric BWR/4 Plants," April 2012 (ADAMS Accession No. ML12104A192).
15. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.75, Revision 3, "Criteria for Independence of Electrical Safety Systems," February 2005 (ADAMS Accession No. ML043630448).
16. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.129, Revision 2, "Maintenance, Testing, and Replacement of Vented Lead-Acid Storage Batteries for Nuclear Power Plants," February 2007 (ADAMS Accession No. ML063490110).
17. Institute of Electrical and Electronics Engineers, IEEE Standard 450-2002, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batters for Stationary Applications," Piscataway, NJ.
18. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.6 (Safety Guide 6),

"Independence Between Redundant Standby (Onsite) Power Sources and Between their Distribution Systems," March 10, 1971 (ADAMS Accession No. ML003739924).

19. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.32, Revision 3, "Criteria for Power Systems for Nuclear Power Plants," March 2004 (ADAMS Accession No. ML040680488).
20. Institute of Electrical and Electronics Engineers, IEEE Standard 308-2001, "IEEE Standard Criteria for Class 1E Power Systems for Nuclear Power Generating Stations,"

Piscataway, NJ.

21. Technical Specifications Task Force, letter to U.S. Nuclear Regulatory Commission, "Transmittal of TSTF-42S, Revision 3, 'Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative Sb,'" dated March 18, 2009 (ADAMS Accession No. ML0908S0642).
22. Orenak, M. D., U.S. Nuclear Regulatory Commission, letter to Charles R. Pierce, Southern Nuclear Operating Company, Inc., "Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2 - Request for Additional Information (CAC Nos. MF6611 and MF6612)," dated October 17, 2016 (ADAMS Accession No. ML16271A169).
23. Sreenivas, V., U.S. Nuclear Regulatory Commission, e-mail to Charles R. Pierce, Southern Nuclear Operating Company, Inc., "Edwin I. Hatch Nuclear Plant, Units 1 and 2

- Request for Additional Information (CAC Nos. MF6611 and MF6612)," dated July 13, 2016 (ADAMS Accession No. ML 1619SA400).

24. Nuclear Energy Institute, NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative Sb, Risk-Informed Method for Control of Surveillance Frequencies," April 2007 (ADAMS Accession No. ML0713604S6).

2S. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Office Instruction LIC-101, Revision S, "License Amendment Review Procedures," January 9, 2017 (ADAMS Accession No. ML 16061A4S1).

Principal Contributor: N. Otto, NRR Date: August 29, 201 7

ML17208A231 *via memo OFFICE NRR/DORL/LPL2-1 /PM NRR/DORL/LPL2-1 /LA NRR/DE/EEEB/BC NRR/DSS/STSB/BC (A)

NAME JHall KGoldstein (JBurkhardt for) JZimmerman* JWhitman DATE 08/03/17 08/02/17 03/02/17 08/22/17 OFFICE OGC (NLO w/comments) NRR/DORL/LPL2-1 /BC NRR/DORL/LPL2-1 /PM NAME JWatchutka MMarkley JHall DATE 08/08/17 08/29/17 08/29/17