Text

Response to Request for Additional Information Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF)-500, Revision 2, DC Electrical Rewrite Update to ...
	ML18257A017
Person / Time
Site:	Peach Bottom
Issue date:	09/14/2018
From:	Jim Barstow; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	EPID L-2017-LLA-0312
	Download: ML18257A017 (43)
	v • d • e

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp com 10 CFR 50.90 September 14, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRG Docket Nos. 50-277 and 50-278

Subject:

Response to Request for Additional Information Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF)-500, Revision 2, "DC Electrical Rewrite-Update to TSTF-360"

References:

1. Exelon Letter to the NRG, "Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF)-500, Revision 2, "DC Electrical Rewrite-Update to TSTF-360," dated September 29, 2017 (ADAMS Accession No. ML17275A069)

2. Exelon Letter to NRG, "Supplemental Information to Support Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF) -500. Revision 2, DC Electrical Rewrite Update to TSTF-360," dated August 14, 2018 (ADAMS Accession No. No. ML18227A610)

3. NRG Email to Exelon, "Peach Bottom Units 2 and 3 - Request for Additional Information (FINAL) - Adopt TSTF-500 Battery TS Changes LAR (EPID L-2017-LLA-0312)," dated August 28, 2018 (ADAMS Accession No. ML18240A174)

In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposed a change to the Technical Specifications (TSs), Appendix A of Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, on September 29, 2017 to adopt TSTF-500, Revision 2 (Reference 1).

During their technical review of the application, the NRG Staff identified the need for additional information. Reference 2 provided the first response to one of the three questions communicated in a teleconference on August 3, 2018. The Attachment to this letter provides the response to the two remaining questions as documented in the final Request for Additional Information (RAI) received on August 28, 2018 (Reference 3).

U.S. Nuclear Regulatory Commission Application to Revise TS to Adopt TSTF-500 - RAI Response Docket Nos. 50-277 and 50-278 September 14, 2018 Page 2 contains the RAI Response. Attachment 2 contains the revised clean TS pages. Attachment 2 supersedes previously submitted clean TS pages and incorporates Reference 2 TS Markups.

Exelon has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of the Reference 1 letter. Exelon has concluded that the information provided in this response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92. In addition, Exelon has concluded that the information in this response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania of this response by transmitting a copy of this letter to the designated State Official.

There are no regulatory commitments contained in this response.

Should you have any questions concerning this response, please contact Mr. Frank J. Mascitelli at (610) 765-5512.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 141h day of September 2018.

James Barstow Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Response to Request for Additional Information, Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF)-500, Revision 2, "DC Electrical Rewrite-Update to TSTF-360"

2. TS Clean pages cc: Regional Administrator - NRC Region I w/ attachments NRC Senior Resident Inspector - PBAPS NRC Project Manager, NRR - PBAPS R. R. Janati, Pennsylvania Bureau of Radiation Protection "

D. A. Tancabel, State of Maryland

ATTACHMENT 1 License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 Response to Request for Additional Information Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF)-500, Revision 2, "DC Electrical Rewrite-Update to TSTF-360" Page 1 of 3 License Amendment Request Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-500, Revision 2 Response to NRC Staff's Request for Additional Information By application dated September 29, 2017 (Agency wide Documents Access and Management System (ADAMS) Accession No.ML17275A069), Exelon Generation Company, LLC (EGG, the licensee) requested changes to the Technical Specifications (TSs) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, to adopt U.S.

Nuclear Regulatory Commission (NRC)-approved Technical Specification Task Force (TSTF) -500, Revision 2, "DC [direct current] Electrical Rewrite - Update to TSTF-360."

The License Amendment Request (LAA) proposes to revise TS requirements related to DC electrical power 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." A new "Battery Monitoring and Maintenance Program" is being proposed for TS 5.5, "Programs and Manuals."

In an email dated August 28, 2018, from the NRG (Jennifer Tobin) to Exelon (David Helker)

(ADAMS Accession No. ML18240A174), the NRG provided a Final Request for Additional Information (RAI) seeking clarification of certain issues related to the submittal. In a previous clarification teleconference on 8/21/18 to discuss the draft RAI, Mr. Frank Mascitelli stated that Exelon would provide a response to the RAI by September 14, 2018.

EEOB RAl-1 QUESTION Regulatory Requirement

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

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

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

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

2. 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.

EEOB RAl-1 of the LAA discusses TS 3.8.4 new Condition D., current Condition C. (revised and renumbered to Condition E.), associated Required Actions and CTs for Required Actions.

Page 2 of 3 License Amendment Request Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-500, Revision 2 Additionally, in Section 2.2.5 in Attachment 1of the LAA, the licensee states, "PBAPS will not be requesting a Completion Time longer than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for an inoperable battery or greater than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for an inoperable DC subdivision for other reasons than an inoperable battery or inoperable battery charger."

The Reviewer Note for TSTF Section 3.8.4 Required Action B.1 .2 stated that Condition B (D in LAA) is included if Required Action B.1 (D.1 in LAA) (One [or two] batter[y][ies on one subsystem] inoperable) and Required Action C.1 (E.1 in LAA) (One DC electrical power subsystem inoperable for reasons other than Condition A [or B]), (C [or Din LAA]) would have different Completion Times. If the plant design supports different Completion Times when a battery is inoperable but the charger is OPERABLE, then Condition B (D in LAA) is used. If not, Condition B (D in LAA} is deleted and only Condition C (E in LAA} is used."

Since Section 2.2.5 in Attachment 1of LAA stated that PBAPS would like to keep the same (2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months s} Completion Time for both Required Action D.1 for an inoperable battery and Required Action E.1 for an inoperable DC subdivision for other reasons than an inoperable battery or inoperable battery charger, the proposed CONDITION D, Required Action D.1 and CT for Required Action D.1 appears to be duplicative.

Further, the proposed new Condition D (one battery on one subsystem inoperable) in the LAA would be acceptable if the new Condition D and revised Condition E (one unit 2/3 DC electrical power subsystem inoperable) have different CTs. But the proposed Condition D and revised Condition E have the same CTs (2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months s}, which means that the new Condition D should not be adopted.

The NRC staff requests the licensee to provide justification for deviation from the TSTF-500, Revision 2 for adoption of new Condition D with same CTs (2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) for new Required Actions D.1 and E.1.

RESPONSE

After a careful review of the Reviewer Note for TSTF 500, Revision 2, Section 3.8.4 Required Action B.1.2, Exelon agrees that the proposed inoperable battery CONDITION D is duplicative since both the inoperable battery condition completion time and the one DC electrical power subsystem inoperable completion time are the same (i.e., 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ).

Accordingly, the proposed CONDITION D will be deleted, and the subsequent Conditions will be renumbered. See Attachment 2 for the revised clean TS pages.

EEOB RAI -2 QUESTION Regulatory Requirement

1. Title 1O of the Code of Federal Regulations, Part 50 (1 O CFR 50)

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

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

Page 3 of 3 License Amendment Request Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-500, Revision 2 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.

2. 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 ....

TS Section 5.5.15.b.2, Battery Monitoring and Maintenance Program in Attachment 2 of the LAR states, "Actions to determine whether the float voltage of the remaining battery cells is

=: 2.07 V when the float voltage of a battery cell has been found to be< 2.13 V." However, TS 5.5.14.b.2, "Battery Monitoring and Maintenance Program," of TSTF-500, Revision 2 states, "Actions to determine whether the float voltage of the remaining battery cells is ;=:

[2.13] V when the float voltage of a battery cell has been found to be < [2.13] V."

There appears to be a discrepancy between TSTF-500 recommended float voltage ;=: [2.13]

V limit and the LAR recommended <:: 2.07 limit in the proposed TS Section 5.5.15.b.2, Battery Monitoring and Maintenance Program.

Please provide a discussion explaining the discrepancy between <:: 2.07 V in the LAR and TSTF-500 recommended float voltage <:: [2.13] V limit in the proposed TS Section 5.5.15.b.2, Battery Monitoring and Maintenance Program.

RESPONSE

Exelon has reviewed the proposed TSTF-500, Revision 2 proposed Battery Maintenance Program requirements for extent of condition actions when one battery cell is found to be in a degraded condition due to low float voltage. The original intent of establishing 2.07 volts as the limit was to verify operability of the remaining cells using the inoperable cell float voltage limit. However, Exelon agrees that the intent of the TSTF-500, Revision 2 is to perform an extent of condition of remaining battery cells using the degraded cell float voltage limit, indicated by the 2.13 volts value. Therefore, the TS 5.5.15.b.2 Action will be revised to be consistent with the TSTF 500, Revision 2. TS 5.5.15.b.2 Action is revised to state:

"Actions to determine whether the float voltage of the remaining battery cells is <::

2.13 V when the float voltage of a battery cell has been found to be s 2.13 V."

ATTACHMENT 2 License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 Clean TS Pages Unit 2 TS Pages 3.8-28 3.8-32 3.8-38a 3.8-29 3.8-34 3.8-39 3.8-29a 3.8-35 3.8-39a 3.8-30 3.8-36 3.8-40 3.8-31 3.8-37 5.0-18b 3.8-31a 3.8-38 5.0-18c Unit 3 TS Pages 3.8-28 3.8-32 3.8-38a 3.8-29 3.8-34 3.8-39 3.8-29a 3.8-35 3.8-39a 3.8-30 3.8-36 3.8-40 3.8-31 3.8-37 5.0-18b 3.8-31a 3.8-38 5.0-18c

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. Unit 2 Division I and Division II DC electrical power subsystems; and

b. Unit 3 Division I and Division II DC electrical power subsystems.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Unit 3 DC -------------NOTE------------

el ectri cal power Enter applicable Conditions subsystem inoperable and Required Actions of LCD due to performance of 3.8.7, "Distribution SR 3.8.4.7 or Systems-Operating," when SR 3.8.6.6. Condition A results in de-energization of a Unit 2 4 kV emergency bus or de-energization of a Unit 3 DC bus.

A.l Restore Unit 3 DC 7 days el ectri cal power subsystem to OPERABLE status.

(continued)

PBAPS UN IT 2 3.8-28 Amendment No.

OC Sources-Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One Unit 3 DC -------------NOTE------------

electrical power Enter applicable Conditions subsystem inoperable and Required Actions of LCO for reasons other than 3.8.7, "Distribution Condition A. Systems-Operating," when Condition B results in de-energization of a Unit 2 4 kV emergency bus.

B.l Restore Unit 3 DC 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months electrical power subsystem to OPERABLE status.

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

C.2 Verify battery float Once per 12 current~ 2 amps. hours C.3 Restore battery 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months charger to OPERABLE status.

(continued)

PBAPS UN IT 2 3.8 -29 Amendment No .

DC Sources-Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One Unit 2 DC 0.1 Restore Unit 2 DC 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power electrical power subsystem inoperable subsystem to OPERABLE for reasons other than status.

Condition C.

E. Required Action and E.l Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Associated Completion Time of Condition A, .81iD.

B, C, or D not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two or more inoperable F.l Enter LCO 3.0.3. Immediately DC electrical power subsystems.

PBAPS UN IT 2 3.8-29a Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS

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

SR 3.8.4.l through SR 3.8.4.8 are applicable only to the Unit 2 DC electrical power subsystems. SR 3.8.4.9 is applicable only to the Unit 3 DC electrical power subsystems.

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

SR 3.8.4.2 DELETED SR 3.8.4.3 DELETED (continued)

PBAPS UN IT 2 3.8-30 Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 DELETED SR 3.8.4.5 DELETED SR 3.8.4.6 Verify each required battery charger In accordance supplies~ 200 amps at greater than or with the equal to the minimum established float Surveillance voltage for ~ 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Frequency Control Program.

Verify each battery charger can recharge the battery to the fully charged state within 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

(continued)

PBAPS UNIT 2 3.8-31 Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

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

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.7.

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

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

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

(continued)

PBAPS UN IT 2 3.8-31a Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.8 DELETED (continued)

PBAPS UN IT 2 3.8-32 Amendment No.

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. 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. Unit 3 DC electrical power subsystems needed to support the DC electrical power distribution subsystem(s) required by LCO 3.8.8, "Distribution Systems-Shutdown."

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

ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One battery charger on A.1 Restore battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months one subsystem terminal voltage to inoperable. greater than or equal to the minimum M.12 established float voltage.

The redundant subsystem battery and Afill chargers OPERABLE.

A.2 Verify battery float Once per 12 current~ 2 amps. hours A.3 Restore battery 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months charger to OPERABLE status.

(continued)

PBAPS UN IT 2 3.8-34 Amendment No.

DC Sources-Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Declare affected Immediately DC electrical power required feature(s) subsystems inoperable inoperable.

for reasons other than Condition A. .QR

.QR B.2.1 Suspend CORE Immediately ALTERATIONS.

Required actions and associated completion time of Condition A B.2.2 Suspend movement of Immediately not met. irradiated fuel assemblies in the secondary containment.

B.2.3 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status.

PBAPS UNIT 2 3.8-35 Amendment No.

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

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

For required Unit 2 DC electrical power In accordance subsystems, the following SRs are with applicable applicable: SRs SR 3.8.4.1 SR 3.8.4.6 SR 3.8.4.7 SR 3.8.5.2 -------------------NOTE--------------------

When Unit 3 is in MODE 4 or 5, or moving irradiated fuel assemblies in the secondary containment, the Note to Unit 3 SR 3.8.5.1 is applicable.

For required Unit 3 DC electrical power In accordance subsystems, the SRs of Unit 3 Specification with applicable 3.8.4 are applicable. SRs PBAPS UN IT 2 3.8-36 Amendment No.

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

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

ACTIONS

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - * - - -

Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME A. One battery on one A. l Perform SR 3.8.4.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months subsystem with one or more battery cells float voltage< 2.07.

A.2 Perform SR 3.8.6.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months A. 3 Restore affected eel l 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months float voltage~ 2.07 V.

(continued)

PBAPS UN IT 2 3.8-37 Amendment No .

Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One battery on one B.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months subsystem with float current > 2 amps.

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

- - - - - - - - NDTE - - - - - - - - - - ------------NOTE-------------

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

plates.

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

1 evel 1 ess than minimum established .Afl..Q.

design limits.

C.2 Verify no evidence of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months leakage.

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

(continued)

PBAPS UN IT 2 3.8-38 Amendment No.

Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One battery with D.1 Restore battery pilot 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months pilot cell electrolyte cell temperature to temperature less than greater than or equal minimum established to minimum design limits. established design limits.

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

F. Required Action and F.l Declare associated Immediately associated Completion battery inoperable.

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

One battery on one subsystem with one or more battery cells with float voltage

< 2.07 V and float current> 2 amps.

PBAPS UN IT 2 3.8-38a Amendment No.

Battery Parameters 3.8.6 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 battery float current is::=: 2 arrps. In accordance with the Surveillance Frequency Control Program.

SR 3.8.6.2 Verify each battery pilot cell float In accordance voltage is~ 2.07. with the Surveillance Frequency Control Program.

SR 3.8.6.3 Verify each battery connected cell In accordance electrolyte level is greater than or equal with the to minimum established design limits. Surveillance Frequency Control Program.

(continued)

PBAPS UN IT 2 3.8-39 Amendment No.

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.4 Verify each battery pilot cell temperature In accordance is is greater than or equal to minimum with the established design limits. Surveillance Frequency Control Program.

SR 3.8.6.5 Verify each battery cell float voltage is In accordance

~ 2.07 v. with the Surveillance Frequency Control Program.

SR 3.8.6.6 - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - -

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

Verify battery capacity is~ 80% of the In accordance manufacturer's rating when subjected to a with the performance discharge test or a modified Surveillance performance discharge test. Frequency Control Program.

12 months when battery shows degradation or has reached 85%

of the expected life with capacity < 100%

of manufacturer's rating 24 months when battery has reached 85% of the expected life with capacity ~ 100%

of manufacturer's rating PBAPS UN IT 2 3.8-39a Amendment No.

Battery Parameters 3.8.6 The information on this page has been deleted.

Intentionally left blank.

PBAPS UN IT 2 3.8-40 Amendment No.

Programs and Manuals 5.5 5.5 Programs and Manuals 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 CRG), with RG exceptions and program provisions as identified below:

a. The program allows the following RG 1.129, Revision 2 exceptions:

1. Battery temperature correction may be performed before or after conducting discharge tests.

2. RG 1.129, Regulatory Position 1, Subsection 2, "References," is not applicable to this program.

3. In lieu of RG 1.129, Regulatory Position 2, Subsection 5.2,"Inspections," the following shall be used: "Where reference is made to the pilot eel l , pilot eel l 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:

PBAPS UN IT 2 5.0-18b Amendment No.

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

1. Actions to restore battery cells with float voltage

< 2.13 V;

2. Actions to determine whether the float voltage of the remaining battery cells is~ 2.13 V when the float voltage of a battery cell has been found to be

< 2.13 V;

3. Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates;

4. Limits on average electrolyte temperature, battery connection resistance, and battery terminal voltage; and

5. A requirement to obtain specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations.

PBAPS UNIT 2 5.0-18c Amendment No.

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. Unit 3 Division I and Division II DC electrical power subsystems; and

b. Unit 2 Division I and Division II DC electrical power subsystems.

APPLICABILITY: MODES l, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Unit 2 DC - - - - - - - - - - - - -NOTE - - - - - - - - - - - -

electrical power Enter applicable Conditions subsystem inoperable and Required Actions of LCO due to performance of 3.8.7, "Distribution SR 3.8.4.7 or Systems-Operating," when SR 3.8.6.6. Condition A results in de-energization of a Unit 3 4 kV emergency bus or de-energization of a Unit 2 DC bus.

A.l Restore Unit 2 DC 7 days el ectri cal power subsystem to OPERABLE status.

(continued)

PBAPS UNIT 3 3.8-28 Amendment No.

DC Sources-Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One Unit 2 DC - - - - - - - - - - - - - NOTE - - - - - - - - - - - -

electrical power Enter applicable Conditions subsystem inoperable and Required Actions of LCO for reasons other than 3.8.7, "Distribution Condition A. Systems-Operating," when Condition B results in de-energization of a Unit 3 4 kV emergency bus.

B.l Restore Unit 2 DC 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months electrical power subsystem to OPERABLE status.

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

AND C.2 Verify battery float Once per 12 current~ 2 amps. hours AND C.3 Restore battery 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months charger to OPERABLE status.

(continued)

PBAPS UN IT 3 3.8-29 Amendment No.

DC Sources-Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One Unit 3 DC D.l Restore Unit 3 DC 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power electrical power subsystem inoperable subsystem to OPERABLE for reasons other than status.

Condition C.

E. Required Action and E.l Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Associated Completion Time of Condition A, AflQ B, C, or D not met.

E.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months F. Two or more inoperable F.l Enter LCO 3.0.3. Immediately DC electrical power subsystems.

PBAPS UNIT 3 3.8-29a Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS

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

SR 3.8.4.1 through SR 3.8.4.8 are applicable only to the Unit 3 DC electrical power subsystems. SR 3.8.4.9 is applicable only to the Unit 2 DC electrical power subsystems.

SURVEILLANCE FREQUENCY SR 3.8.4.1 Verify battery terminal voltage is greater In accordance than or equal to the minimum established with the fl oat voltage. Surveillance Frequency Control Program.

SR 3.8.4.2 DELETED SR 3.8.4.3 DELETED (continued)

PBAPS UNIT 3 3.8-30 Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 DELETED SR 3.8.4.5 DELETED SR 3.8.4.6 Verify each required battery charger In accordance supplies~ 200 amps at greater than or with the equal to the minimum established float Surveillance voltage for~ 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Frequency Control Program.

Verify each battery charger can recharge the battery to the fully charged state within 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

(continued)

PBAPS UN IT 3 3.8 -31 Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

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

1. The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of SR 3.8.4.7.

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

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

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

(continued)

PBAPS UN IT 3 3.8-3la Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.8 DELETED (continued)

PBAPS UN IT 3 3.8-32 Amendment No.

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. Unit 3 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. 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."

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

ACTIONS

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

LCO 3.0.3 is not applicable.

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

The redundant subsystem battery and AND chargers OPERABLE.

A.2 Verify battery float Once per 12 currents 2 amps. hours A.3 Restore battery 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months charger to OPERABLE status.

(continued)

PBAPS UN IT 3 3.8-34 Amendment No.

DC Sources- Shutdown 3.8.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.l Declare affected Immediately DC electrical power required feature(s) subsystems inoperable inoperable.

for reasons other than Condition A.

B.2.1 Suspend CORE Immediately ALTERATIONS.

Required actions and associated completion time of Condition A B.2.2 Suspend movement of Immediately not met. irradiated fuel assemblies in the secondary containment.

B.2.3 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status.

PBAPS UNIT 3 3.8-35 Amendment No.

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

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

For required Unit 3 DC electrical power In accordance subsystems, the following SRs are with applicable applicable: SRs SR 3.8.4.1 SR 3.8.4.6 SR 3.8.4.7 SR 3.8.5.2 -------------------NOTE--------------------

When Unit 2 is in MODE 4 or 5, or moving irradiated fuel assemblies in the secondary containment, the Note to Unit 2 SR 3.8.5.1 is applicable.

For required Unit 2 DC electrical power In accordance subsystems, the SRs for Unit 2 with appl i cable Specification 3.8.4 are applicable. SRs PBAPS UN IT 3 3.8-36 Amendment No.

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

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

ACTIONS

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

Separate Condition entry is allowed for each battery.

CONDITION REQUIRED ACTION COMPLETION TIME A. One battery on one A.l Perform SR 3.8.4.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months subsystem with one or more battery cells float voltage< 2.07.

A.2 Perform SR 3.8.6.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months A. 3 Restore affected eel l 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months float voltage~ 2.07 V.

(continued)

PBAPS UN IT 3 3.8-37 Amendment No.

Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One battery on one B.l Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months subsystem with float current > 2 amps.

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

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

Requi red Action C.2 Required Actions C.l and C.2 shall be completed if are only applicable if electrolyte level was electrolyte level was below below the top of the top of plates.

plates.

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

level less than minimum established design limits.

C.2 Verify no evidence of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months leakage.

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

(continued)

PBAPS UN IT 3 3.8 -38 Amendment No.

Battery Parameters 3.8.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. One battery with D. 1 Restore battery pilot 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months pilot cell cell temperature to electrolyte greater than or equal temperature less than to minimum minimum established established design design limits. limits.

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

F. Required Action and F.l Declare associated Immediately associated Completion battery inoperable.

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

One battery on one subsystem with one or more battery cells with float voltage

< 2.07 V and float current > 2 amps.

PBAPS UN IT 3 3.8-38a Amendment No.

Battery Parameters 3.8.6 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 battery float current is ::: 2 amps. In accordance with the Surveillance Frequency Control Program.

SR 3.8.6.2 Verify each battery pilot cell float In accordance voltage is~ 2.07. with the Surveillance Frequency Control Program.

SR 3.8.6.3 Verify each battery connected cell In accordance electrolyte level is greater than or equal with the to minimum established design limits. Surveillance Frequency Control Program.

(continued)

PBAPS UNIT 3 3.8-39 Amendment No.

Battery Parameters 3.8.6 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.6.4 Verify each battery pilot cell temperature In accordance is greater than or equal to minimum with the established design limits. Surveillance Frequency Control Program.

SR 3.8.6.5 Verify each battery cell float voltage is In accordance 2: 2.07 v. with the Surveillance Frequency Control Program.

SR 3.8.6.6 - - - - - - - - - - - - - - - - - - NOTE - - - - - - - - - - - - - - - - - - - -

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

Verify battery capacity is 2: 80% of the In accordance manufacturer's rating when subjected to a with the performance discharge test or a modified Surveillance performance discharge test. Frequency Control Program .

.8.N.D.

12 months when battery shows degradation or has reached 85%

of the expected 1 ife 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 PBAPS UN IT 3 3 . 8-39a Amendment No.

Battery Parameters 3.8.6 The information on this page has been deleted.

Intentionally left blank.

PBAPS UN IT 3 3.8-40 Amendment No.

Programs and Manuals 5.5 Programs and Manuals 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 CRG), with RG exceptions and program provisions as identified below:

a. The program allows the following RG 1.129, Revision 2 exceptions:

1. Battery temperature correction may be performed before or after conducting discharge tests.

2. RG 1.129, Regulatory Position l, 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 eel l 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 Cd) 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:

PBAPS UN IT 3 5.0-18b Amendment No.

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

1. Actions to restore battery cells with float voltage

< 2.13 V;

2. Actions to determine whether the float voltage of the remaining battery cells is~ 2.13 V when the float voltage of a battery cell has been found to be

< 2.13 V;

3. Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates;

4. Limits on average electrolyte temperature, battery connection resistance, and battery terminal voltage; and

5. A requirement to obtain specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations.

PBAPS UNIT 3 5.0-18c Amendment No.

v t e Letter Sequence Response to RAI
EPID:L-2017-LLA-0312, TSTF-500, TSTF-425, TSTF-360 (Approved, Closed)
Initiation Request Acceptance Supplement, Supplement Administration Questions 14 August 2018 28 August 2018 Answers 14 September 2018 Results Approval Other:
MONTHYEAR2018-08-14 [Table View]

ML18257A017

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Subject:

References:

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