ML18107A499
| ML18107A499 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/25/1999 |
| From: | Bezilla M Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LR-N990091, NUDOCS 9908310325 | |
| Download: ML18107A499 (15) | |
Text
. 1*
I e OPS~G
, Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit AUG 2 5 1999l LR-N990091 LCR S99-07 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR LICENSE AMENDMENT SINGLE CELL CHARGING SAFETY RELATED BATTERIES SALEM GENERATING STATION FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 In accordance with 10CFR50.90, Public Service Electric & Gas Company (PSE&G) hereby requests amendment to the Facility Operating Licenses for Salem Generating I
Station Unit Nos. 1 and 2. In accordance with 10CFR50.91 (b), a copy of this request has been sent to the State of New Jersey.
An evaluation performed in accordance with 10CFR50.59 concluded that the use of a single cell battery charger on a safety related battery while the battery remains OPERABLE involves an Unreviewed Safety Question (USQ) since the possibility for a malfunction of a different type than any previously evaluated in the safety analysis.
report may be created. 10CFR50.59(c) requires that the licensee shall submit an application for amendment of its operating license for any changes to procedures involving a USQ.
The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1),
using the criteria in 10 CFR 50.92(c); and a determination has been made that the USQ involves no significant hazards considerations. The basis for approval of the USQ condition is provided in Attachment 1 to this letter. A 10 CFR 50.92 evaluation for the USQ condition, with a determination of no significant hazards consideration, is provided in Attachment 2. The marked up Facility Operating Licenses pages affected by the proposed change are provided in Attachment 3.
l))"\i,)02 9908310325 990825 PDR ADOCK 05000272 p PDR The power is in your hands.
95-2168 REV. 6/94
'Document Control Desk : LR-N.990091 PSE&G has reviewed the proposed License Change Request (LCR) against the criteria of 10 CFR 51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, PSE&G concludes that the proposed change meets the criteria delineated in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
Upon NRG approval of this proposed change, PSE&G requests that the amendment to Appendix C to the Operating License be made effective upon the date of issuance, but allow an implementation period of sixty days to provide sufficient time for associated administrative activities.
Should you have any questions regarding this request, we will be pleased to discuss them with you.
Sincerely,
/)f116~o-11 Mark s. Bez;117 ....
Vice President - Operations Affidavit Attachments (3)
'AUG 2 51999
'Document Control Desk LR-N990091 C Mr. H. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager- Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 0-8-B-1 Rockville, MD 20852 Mr. S. Morris (X24)
USNRC Senior Resident Inspector - Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway PO Box 415 Trenton, NJ 08625
REF: LR-N990091 LCR S99-07 STATE OF NEW JERSEY)
) SS.
COUNTY OF SALEM )
M. B. Bezilla, being duly sworn according to law deposes and says:
I am Vice President - Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Salem Generating Station Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subscribe~nd Sworn to before me this r25 ...._day of ~..t.t&?t , 1999 JENNIFER M. TURNER NOTARY .P~BLIC OF NEW JERSEY My Commission expires on ----'M=y'-"C"""omWJm,,..1..,..ss-w-'Oi:ru....E~xpmirui;esQ..,J.iuu....
ty.gj:25-....,4'20'*'00'
'Document Control Desk LR-N990091
- Attachment 1 LCR S99-07 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 SINGLE CELL CHARGING SAFETY RELATED BATTERIES BASIS FOR REQUESTED CHANGE:
REQUESTED CHANGE AND PURPOSE:
The proposed change would permit the use of non-Class 1 E single cell battery chargers, with proper electrical isolation, for charging connected cells in OPERABLE class 1E batteries. The single cell charger would be used to restore individual cell float voltage to the normal limit specified in Technical Specifications.
BACKGROUND:
The class 1Ede system is described in Salem Final Safety Analysis Report (UFSAR) section 8.3.2. The system consists of three independent 125 VOC systems and two independent 28 VOC systems. Under normal operating conditions, the installed Class 1E battery charger supplies the operating de loads and a float charge to the battery.
The ac power for the battery charger in each independent de system is supplied from switchgear in the same channel as that of the battery the charger is supplying. Each installed battery charger has an input ac and output de circuit breaker. Each charger is designed to prevent the ac supply from becoming a load on the battery due to a power feedback as a result of the loss of ac power to the charger. The battery chargers are capable of supplying the largest combined demand of the various continuous steady-state loads plus charging capacity to restore the associated battery.
An equalizing charge applied to the entire battery bank is the normal corrective action to restore the battery from a condition involving low cell voltage or low specific gravity.
The effectiveness of an equalizing charge decreases when only a single cell or a small number of cells require equalizing. Amore effective method of restoring the battery in that case is to perform single cell battery charging.
An evaluation performed in accordance with 10CFR50.59 concluded that the use of a single cell battery charger on a safety related battery while the battery remains OPERABLE involves an Unreviewed Safety Question (USQ) since the possibility for a malfunction of a different type than any previously evaluated in the safety analysis report may be created.
Page 1of4
- Document Control Desk LR-N990091 Attachment 1 LCR S99-07 JUSTIFICATION OF REQUESTED CHANGES:
The OPERABILITY of the Class 1E batteries during operation ensures that sufficient power will be available to supply the safety related equipment required for (1) the safe shutdown of the facility and (2) the mitigation and control of accident conditions within the facility.
The surveillance requirements for demonstrating the OPERABILITY of the Class 1E 125 VDC batteries are in accordance with the recommendations of IEEE Std 450, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations". Technical Specification Table 4.8.2.1-1 specifies the normal limits for each designated pilot cell and each connected cell for electrolyte level, float voltage and specific gravity. The normal limits ensure the OPERABILITY and capability of the battery of the 125 VDC batteries.
Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8.2.1-1 is permitted for up to 31 days. During this 31 day period, the allowable values ensure the battery's capability to perform its design function. The 31-day ACTION time was derived taking into consideration that while battery capacity is degraded, sufficient capacity exists to perform the intended function while providing a time period adequate to permit full restoration of the battery cell parameters to normal limits.
Although the current surveillance requirements for demonstrating the OPERABILITY of the Class 1E 28 VDC do not address all the recommendations of IEEE-450, the current surveillance requirements provide assurance that the 28 VDC batteries will perform their design basis function. The current action statements associated with the 28 VDC batteries only allow a two hour ACTION time to perform any corrective measures when battery cell parameters are outside their Technical Specification limits before a plant shutdown is initiated.
The requested change implements an industry accepted practice for raising the voltage of an individual cell or of a small number of cells without affecting the remainder of the cells in the battery. IEEE Std 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead Storage Batteries for Stationary Applications," states that single cell charging is an acceptable method of correcting low cell voltage or low specific gravity conditions for a single cell or for a small number of cells. The NRC previously reviewed the use of non-safety grade battery chargers for Class 1E battery banks at the Virgil C. Summer Nuclear Station and found this to be acceptable in a Safety Evaluation Report provided to the licensee in a letter dated December 20, 1989. The NRC has also approved the use of non-Page 2of4
'Document Control Desk LR-N990091 Attachment 1 LCR 599-07 safety grade battery chargers for Class 1E battery banks at Hope Creek Generating Station in an SER dated February 9, 1999.
At least two class 1E fuses in series will be used to connect the positive lead of the charger to the positive terminal of the battery cell and at least two class 1E fuses in series will be used to the connect the negative lead of the charger to the negative terminal of the battery cell to protect the battery if a fault should develop in the charger.
The battery charger will be powered from non-class 1E 120 VAC. The battery charger design includes diodes, a power transformer and control circuitry to prevent draining the connected cells in the event of a short circuit in the 120 Volt ac source or a loss of charger input or output voltage. Charger output is controlled automatically to prevent overcharging the connected cells.
Based upon experience in charging individual cells in non-1 E battery banks and upon a review of industry operational experience reports, PSE&G believes that failure of a single cell charger resulting in a loss of a battery due to an open circuit condition is highly unlikely. However, in the event of a charger controller failure resulting in charger overvoltage, procedural controls governing the use of the charger will ensure the condition is detected and corrected before failure of a connected cell occurs. While the single cell charger is connected, procedures will require periodic checks to verify proper charger operation and to measure electrolyte level, temperature and specific gravity for the cells being charged. Monitoring will be performed at least once every four hours, a frequency sufficient to ensure compliance with the ACTION requirements of Technical Specifications. Operator actions during single cell charging are similar to those currently performed during equalizing charges applied to the entire battery bank.
Single cell charging would be limited to one OPERABLE class 1E battery bank at a time for either the 28 VOC or 125 VOC system. Therefore, failure of a class 1E battery as a result of single cell charging would be limited to a single channel and would not reduce the number of OPERABLE de sources below that required to safely shutdown the plant.
Administrative controls would also prohibit the use of single cell charging for an OPERABLE class 1E battery if less than the minimum number of class 1 E batteries required by Technical Specifications are OPERABLE.
The leads connecting the battery charger to the battery cell are non-class 1E. Plant procedures governing use of the single cell charger will require visual inspection of the leads before connection to the battery. The procedure will also require the use of insulating, material with an appropriate rating, near terminals that could be affected by charger leads becoming dislodged to minimize the possibility of shorting leads or clips at the battery. Similar controls on the use of non-safety related battery cables and connecting clips were evaluated by the NRC and found to be acceptable in a SER Page 3of4
'Document Control Desk LR-N990091
- Attachment 1 LCR S99-07 provided to Virgil C. Summer Nuclear Station in a letter dated December 20, 1989, and in Hope Creek SER dated February 9, 1999.
The single cell battery chargers used at Salem are portable units that are transported to the required location and rest on the floor while in use. PSE&G's procedure for the use and storage of transient loads requires that transient loads be controlled when they are used in seismic control areas (such as the Class 1E battery rooms). The controls are provided to prevent damage to OPERABLE safety related equipment during an earthquake. Control of transient loads is established by evaluating the load and, where necessary, securing the load with restraints. These controls governing the use and storage of transient loads are sufficient to ensure the use of single cell battery chargers does not create a potential missile hazard to safety related systems, structures and components.
Cells that have been charged using single cell chargers will be checked weekly for four weeks after single cell charging. This increase in surveillance frequency, together with PSE&G's corrective action program which requires degraded and non-conforming conditions to be documented and evaluated, provides assurance that the use of single cell charging will not cause long-term cell degradation to go undetected.
CONCLUSIONS:
The requested change permits the use of an industry accepted method to restore individual connected cell parameters to the normal values specified in Technical Specifications. The potential to adversely affect the Class 1E batteries is minimized by the use of Class 1E fuses and by appropriate administrative controls.
Page 4of4
- Document Control Desk LR-N990091
- Attachment 2 LCR S99-07 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 SINGLE CELL CHARGING SAFETY RELATED BATTERIES 10 CFR 50.92 EVALUATION Public Service Electric & Gas (PSE&G) has concluded that the Unreviewed Safety Question does not involve a significant hazards consideration. In support of this determination, an evaluation of each of the three standards set forth in 10 CFR 50.92 is provided below.
REQUESTED CHANGE The proposed change permits the use of non-Class 1E single cell battery chargers, with proper electrical isolation, for charging connected cells in OPERABLE class 1E batteries.
BASIS
- 1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change permits the use of an industry accepted method to restore a battery cell to its design basis from an OPERABLE but degraded condition or to prevent a cell from becoming degraded. IEEE Std 450-1995,"IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead Storage Batteries for Stationary Applications," states that single cell charging is an acceptable method of correcting low cell voltage or low specific gravity conditions for a single cell or for a small number of cells.
At least two class 1E fuses in series will be used on both the positive and negative leads between the battery and the charger to protect the battery if a fault should develop in the charger. The battery charger design includes diodes, a power transformer and control circuitry to prevent draining the connected cells in the event of a short circuit in the 120 Volt ac source or a loss of charger input or output voltage. Charger output is controlled automatically to prevent overcharging the connected cells.
Page 1of3
'Document Control Desk LR-N990091 LCR 599-07 In the event of a controller failure resulting in charger overvoltage, procedural controls governing the use of the charger ensure the condition is detected and corrected before failure of a connected cell occurs. While the single cell charger is connected, procedures will require periodic checks to verify proper charger operation and to measure electrolyte level, temperature and specific gravity for the cells being charged. Monitoring will be performed at least once every four hours, a frequency sufficient to ensure compliance with the requirements of the Technical Specifications.
An insulating material will be used to minimize the possibility of shorting leads or clips at the battery. Administrative controls governing the use and storage of transient loads are sufficient to ensure the use of single cell battery chargers does not create a potential missile hazard to safety related systems, structures and components.
The Class 1E DC system is not an accident initiator. The Class 1E DC system supports the operation of safety related equipment required for the safe shutdown of the plant and for the mitigation of accident conditions. Therefore, the proposed change does not increase the probability of an accident previously evaluated.
The station's de systems will be operable to mitigate the consequences of an accident previously evaluated. Single cell charging would be limited to one OPERABLE class 1E battery bank at a time for either the 28 VDC or 125 VDC systems. Therefore, failure of a class 1E battery as a result of single cell charging would be limited to a single channel and would not reduce the number of OPERABLE de sources below that required to safely shutdown the plant.
Administrative controls would also prohibit the use of single cell charging for an OPERABLE class 1E battery if less than the minimum number of class 1E batteries required by Technical Specifications are OPERABLE.
The proposed change does not cause the capability of the class 1E DC system to be degraded below the level assumed for any accident described in the SAR. This change would enhance the availability of safety related equipment required for the safe shutdown of the plant and for the mitigation of accident conditions. Therefore the radiological consequences of an accident will remain inside the design basis while single cell charging is performed on an OPERABLE battery.
- 2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The potential to adversely affect the Class 1E batteries is minimized by the use of Class 1E fuses and by appropriate administrative controls. Failure modes Page 2of3
, Document Control Desk LR-N990091 Attachment 2 LCR 899-07 associated with the proposed change are bounded by the loss of a Class 1E battery bank which was previously evaluated. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. The proposed change does not involve a significant reduction in a margin of safety.
The proposed change permits the use of non-Class 1 E single cell battery chargers, with proper electrical isolation, for charging connected cells in OPERABLE class 1E batteries. This would allow parameters for an individual cell or for a small number of cells to be restored to the normal values specified in Technical Specifications without affecting the remainder of the cells in the battery. Increased cell monitoring after single cell charging, together with PSE&G's corrective action program which requires degraded and non-conforming conditions to be documented and evaluated, provides assurance that the use of single cell charging will not cause long-term cell degradation to go undetected. Since all battery cells are required to be maintained within the allowable values specified in Technical Specifications, and since the use of the single cell charger will not adversely affect battery capacity or capability, the proposed change does not involve a significant reduction in the margin of safety.
CONCLUSION Based on the above, PSE&G has determined that the proposed change does not involve a significant hazards consideration.
Page 3of3
'Document Control Desk LR-N990091
- Attachment 3 LCR S99-07 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 SINGLE CELL CHARGING SAFETY RELATED BATTERIES FACILITY OPERA TING LICENSE PAGE WITH PROPOSED CHANGE The following page of Facility Operating License DPR-70 is affected by this change request:
Section Appendix C 1 The following page of Facility Operating License DPR-75 is affected by this change request:
Section Appendix C 1
- Document Control Desk LR-N990091 Atta.chment 3 LCR 599-07 INSERT:
Additional condition Implementation Date The licensee is authorized to perform single cell The amendment shall be charging of connected cells in OPERABLE class 1E implemented within 60 days batteries as described in the licensee's submittal dated of August##, 1999, and evaluated in the staff's safety evaluation attached to this amendment.
APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE NO. DPR-70 Public Service Electric and Gas Company, Philadelphia Electric Company, Delmarva Power and Light Company, and Atlantic City Electric Company shall comply with the following conditions on the schedules noted below:
Amendment Additional Condition Implementation Number Date 192 The licensee is authorized to relocate certain Technical The amendment shall be Specification requirements to licensee-controlled documents. implemented within 60 Implementation of this amendment shall include the days from March 21, relocation of these technical specification requirements to 1997.
the appropriate documents, as described in the licensee's application dated January 11, 1996, as supplemented by letters dated February 26, May 22, June 27, July 12, December 23, 1996, and March 17, 1997, and evaluated in the staff's safety evaluation attached to this amendment.
194 The licensee is authorized to upgrade the initiation The amendment shall be circuitry for the power operated relief valves, as described implemented prior to in the licensee's application dated January 31, 1997, as entry into Mode 3 from supplemented by letters dated March 14, April 8, and April the current outage for 28, 1997, and evaluated in the staff's safety evaluation Salem Unit 1.
attached to this amendment.
196 The licensee shall complete all modifications associated with The amendment shall be the amendment request concerning Containment Fan Cooler Units implemented prior to (CFCU) response time dated October 25, 1996, as described in entry into Mode 3 from the letters supplementing the amendment request dated the clirrent outage for December 11, 1996, January 28, March 27, April 24, June 3, Salem Unit 1.
and June 12, 1997, prior to entry into Mode 3 following refueling outage 12. All modifications made in support of this amendment request and described in the referenced submittals shall be in conformance with the existing design basis for Salem Uriit 1, and programmatic controls for tank monitoring instrumentation shall be as described in the letter dated April 24, 1997. Post modification testing and confirmatory analyses shall be as described in the letter dated March 27, 1997. Future changes to the design described in these l!ubmittals may be made in accordance with the provisions of 10 CFR 50.59. Further, the administrative controls associated with CFCU operability and containment integrity described in the letters dated March 27, and April 24, 1997 shall not be relaxed or changed wi:thout prior staff review until such time as the license has been amended to include the administrative controls as technical specification requirements.
198 The licensee shall perform an evaluation of the containment The amendment shall be liner anchorage by November 30, 1997, for the loading induced implemented within 30 on the contianment liner during a Main Steam Line Break event days from July 17, to confirm the assumptions provided in the Preliminary Safety 1997.
Analysis Report and Updated Final Safety Analysis Report.
1 Amendment No. 198
APPENDIX C ADDITIONAL CONDITIONS OPERATING LICENSE NO. DPR-75 Public Service Electric and Gas Company, Philadelphia Electric Company, Delmarva Power and Light Company, and Atlantic City Electric Company shall comply with the following conditions on the schedules noted below:
Amendment Additional Condition Implementation Number Date 175 The licensee is authorized to relocate certain Technical The amendment shall be Specification requirements to licensee-controlled documents. implemented within 60 Implementation of this amendment shall include the days from March 21, relocati.on of these technical specificatio~ requirements to 1997.
the appropriate documents, as described in the licensee's application dated January 11, 1996, as supplemented by letters dated February 26, May 22, June 27, July 12, December 23, 1996 and March 17, 1997, and evaluated in the staff's safety evaluation attached to this amendment.
177 The licensee is authorized to upgrade the initiation The amendment shall be circuitry for the power operated relief valves, as described implemented prior to in the licensee's application dated January 31, 1997, as entry into Mode 3 from supplemented by letters dated March 14, April 8, and April the current outage for 28, 1997, and evaluated in the staff's safety evaluation Salem, Unit 2.
attached to this amendment.
179 All modifications made in support of the amendment request The amendment shall be concerning Containment Fan Cooler Units (CFCU) response time implemented prior to dated October 25, 1996, as described in the letters entry into Mode 3 from supplementing the amendment request dated December 11, 1996, the current outage for January 28, March 27, April 24, June 3, and June 12, 1997, Salem, Unit 2.
shall be in conformance with the existing design basis for Salem Unit 2, and programmatic controls for.tank monitoring instrumentation shall be as described in the letter dated April 24, 1997. Post modification testing and confirmatory analyses shall be as described in the letter dated March 27, 1997. Future changes to the design described in these submittals may be made in accordance with the provisions of 10 CFR 50.59. Further, the administrative controls associated with CFCU operability and containment integrity described in the letters dated March 27 and April 24, 1997, shall not be relaxed or changed without prior staff review until such time as the license has been amended to include the administrative controls as technical specification requirements.
181 The licensee shall perform an evaluation of the containment The amendment shall be liner anchorage by November 30, 1997, for the loading induced implemented within 30.
on the containment liner during a Main Steam Line Break event days from July 17, to confirm the assumptions provided in the Preliminary S<!-fety 1997.
Analysis Report and Updated Final.Safety Analysis Report.
1 Amendment No. ie1