ML20121A217

Proposed Technical Specifications Change Battery Surveillance Requirements

ML20121A217
Person / Time
Site:	Millstone
Issue date:	04/30/2020
From:	Mark D. Sartain Dominion Energy Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
19-369
Download: ML20121A217 (21)

Text

Dominion Energy Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen , VA 23060 Dominion Energy.com April 30 , 2020 U. S. Nuclear Regulatory Commission Serial No.19-369 Attention: Document Control Desk NSS&L/TFO : RO Washington , DC 20555 Docket No . 50-423 License No. NPF-49 DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3 PROPOSED TECHNICAL SPECIFICATIONS CHANGE BATTERY SURVEILLANCE REQUIREMENTS Pursuant to 10 CFR 50.90, Dominion Energy Nuclear Connecticut, Inc. (DENC) requests an amendment to Facility Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3). The inter-cell connection resistance value of 150 x 1o-6 ohm in MPS3 Technical Specification (TS) Surveillance Requirement (SR) 4 .8.2 .1.b.2 and 4 .8.2.1 .c.3 for the station batteries is nonconservative if all, or a considerable number, of the connections are at that value since the acceptable total battery resistance value would be exceeded . Therefore , DENC is revising the SRs to add a new acceptance criterion for total battery connection resistance. The new acceptance criterion w ill confirm that the total battery connector resistance is within preestablished limits , and ensures that the batteries can perform their specified safety function by maintaining required battery terminal voltage under design-basis load conditions . to this letter describes the proposed changes and provides justification for the changes. Attachment 2 provides marked-up MPS3 TS pages showing the proposed change . There is no associated TS Bases change.

The proposed amendment does not involve a Significant Hazards Consideration under the standards set forth in 10 CFR 50 .92 . The basis for this determination is included in . DENC has also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure.

Therefore , the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51 .22(c)(9) . Pursuant to 10 CFR 51.22(b) , no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change .

The Facility Safety Review Committee has reviewed and concurred with the determinations herein.

DENC requests approval of this license amendment request by April 30, 2021 , with implementation within 60 days of issuance .

In accordance with 10 CFR 50 .91 (b) , a copy of this license amendment request is being provided to the State of Connecticut.

Serial No: 19-369 Docket Nos. 50-423 Page 2 of 3 If you have any questions or require additional information, please contact Mr. Shayan Sinha at (804) 273-4687.

Sincerely, Mark D. Sartain Vice President- Nuclear Engineering and Fleet Support COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering and Fleet Support of Dominion Energy Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document on behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this ~~ day of ApY"i I , 2020.

My Commission Expires: 1:f\a;c.h 31, 2021,

~*r:Ai4, Notary Public DIANE E. AITKEN NOTARY PUBLIC REG. #7763114 COMMONWEALTH OF VIRGtNfA MY COMMISSION EXPIRES MARCH 3l, 2022

Serial No: 19-369 Docket Nos. 50-423 Page 3 of 3 Attachments:

1. Evaluation of Proposed License Amendment

2. Marked-Up Technical Specification Pages Commitments made in this letter: None cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Richard V. Guzman Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director, Radiation Division Department of Energy and Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 1 of 13 ATTACHMENT 1 EVALUATION OF PROPOSED LICENSE AMENDMENT DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 2 of 13 EVALUATION OF PROPOSED LICENSE AMENDMENT 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Description of the Proposed Change 2.3 Reason for the Proposed Change 3.0 TECHNICAL EVALATION

3.1 Background

3.2 Technical Analysis

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 3 of 13 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Dominion Energy Nuclear Connecticut, Inc. (DENC) requests an amendment to Facility Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3). The inter-cell connection resistance value of 150 x 1o-6 ohm in MPS3 Technical Specification (TS) Surveillance Requirement (SR) 4.8.2.1.b.2 and 4.8.2.1.c.3 for the MPS3 batteries is nonconservative if all, or a considerable number, of the connections are at that value since the acceptable total battery resistance value would be exceeded. Therefore, DENC is revising the SRs to add a new acceptance criterion for total battery connection resistance. The new acceptance criterion will confirm that the total battery connector resistance is within preestablished limits, and ensures that the batteries can perform their specified safety function by maintaining required battery terminal voltage under design-basis load conditions.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Direct Current (DC) power system has six separate systems, consisting of two normal DC power systems serving non-safety related loads, and four Class 1E DC power systems serving safety related loads.

The DC power systems are each powered by two types of onsite DC sources; lead-calcium batteries and static battery chargers. The lead-calcium batteries are self-contained stored energy sources, and the battery chargers provide DC by rectifying power from the 480 Volt Alternating Current (VAC) buses.

The Class 1E DC power system has sufficient redundancy, capacity, capability, and reliability to supply power to all safety related loads, even in the event of a single failure, by maintaining electrical independence between redundant trains and channels in accordance with General Design Criteria (GDC) 17, 22, 33, 34, 35, 38, 41 and 44.

Additionally, GDC 18 applies to battery inter-cell connections related to inspection and testing to ensure continuity of systems and the condition of their components.

During normal operation, the 125 Volt Direct Current (VDC) load is supplied from the battery chargers with the batteries floating on the 125 VDC buses. The four Class 1E batteries are lead-calcium type and are designed for continuous duty. Each battery consists of 60 cells connected in series. Inter-cell and terminal connectors consist of lead-plated copper connectors.

The ampere-hour capacity of each 125 VDC battery is suitable for supplying all connected safety related loads for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without use of the battery chargers. The characteristics of each load, the length of time each load is required, and the basis used to establish the power required for each safety related load, are utilized to establish the combined load demand to be connected to each DC supply during the "worst" operating

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 4 of 13 conditions. At the end of the 2-hour period, the final battery voltage is a minimum of 1. 75 voe per cell.

2.2 Description of the Proposed Change The following changes are being proposed to the SRs in TS Section 4.8.2.1, Electrical Power Systems, DC Sources, Operating, which is applicable to the DC electrical sources in modes 1, 2, 3, and 4. These changes also impact TS Section 4.8.2.2, Electrical Power Systems, DC Sources, Shutdown, which is applicable in modes 5 and 6, in that TS SR 4.8.2.2 requires SR 4.8.2.1 be met for the applicable DC battery banks.

Change 1 Current SR 4.8.2.1.b At the frequency specified in the Surveillance Frequency Control Program and within 7 days after a battery discharge with battery terminal voltage below 110 volts, or battery overcharge with battery terminal voltage above 150 volts, by verifying that:

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

2) There is no visible corrosion at either terminals or connectors, or the connection resistance of these items is less than 150 x 1o- 6 ohm, and

3) The average electrolyte temperature of six connected cells is above 60°F.

Proposed SR 4.8.2.1.b At the frequency specified in the Surveillance Frequency Control Program and within 7 days after a battery discharge with battery terminal voltage below 110 volts, or battery overcharge with battery terminal voltage above 150 volts, by verifying that:

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

2) There is no visible corrosion at either terminals or connectors, or the connection resistance of these items each cell-to-cell and terminal connection is less than 150 x 1o- 6 ohm and total battery resistance is less than 3700 x 10- 6 ohm, and

3) The average electrolyte temperature of six connected cells is above 60°F.

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 5 of 13 Change 2 Current SR 4.8.2.1.c At the frequency specified in the Surveillance Frequency Control Program by verifying that:

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

2) The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material,

3) The resistance of each cell-to-cell and terminal connection is less than or equal to 150 x 1o-6 ohm, and

4) Each battery charger will supply at least the amperage indicated in Table 4.8-2b at greater than or equal to 132 volts for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Proposed SR 4.8.2.1.c At the frequency specified in the Surveillance Frequency Control Program by verifying that:

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

2) The cell-to-cell and terminal connections are clean, tight, and coated with anticorrosion material,

3) The resistance of each cell-to-cell and terminal connection is less than or equal to 150 x 1o-6 ohm and total battery resistance is less than 3700 x 10- 6 ohm, and

4) Each battery charger will supply at least the amperage indicated in Table 4.8-2b at greater than or equal to 132 volts for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Effect of Changes on SR 4.8.2.2 SR 4.8.2.2 TS SR 4.8.2.2 requires one train of batteries and its associated charger to be operable in modes 5 and 6. The associated SR 4.8.2.2 states the following:

The above required train shall be demonstrated OPERABLE in accordance with Specification 4.8.2.1.

Therefore, Changes 1 and 2 for SR 4.8.2.1.b and 4.8.2.1.c are also applicable to SR 4.8.2.2 in modes 5 and 6.

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 6 of 13 A markup of the proposed TS changes is provided in Attachment 2. There are no associated TS Bases changes.

2.3 Reason for Proposed Change Operating Experience (OE) item OE 23813 for Quad Cities, dated November 28, 2006, identified an issue concerning potentially non-conservative surveillance values for battery connection resistance in TS. DENC performed a review of MPS3 battery voltage verification calculations and determined that no provisions were included to accommodate the inter-cell resistances involved in the construction of the sixty (60) cell battery bank. Therefore, it is a conservative assumption that the battery intercell connection resistance was not taken into consideration in the battery duty cycle voltage verification. The inter-cell connection resistance value of 150 x 1o- 6 ohm (micro-ohm) in TS SR 4.8.2.1.b.2 and 4.8.2.1.c.3 for the MPS3 batteries is nonconservative if all, or a considerable number, of the connections are at that value since the acceptable total battery resistance value would be exceeded. In accordance with Nuclear Regulatory Commission's Administrative Letter 98-10 (Reference 6.1 ), DENC is revising these SRs to add a new acceptance criterion for total battery connection resistance.

3.0 TECHNICAL EVALUATION

3.1 Background

3.1.1 DC Power System Description.

The DC power system is described in Final Safety Analysis Report (FSAR) section 8.3.2.

The MPS3 DC power system has six separate systems which include two normal DC power systems serving non-safety related loads, and four Class 1E DC power systems serving safety related loads. The DC power systems are each powered by two types of onsite DC sources, consisting of lead-calcium batteries and static battery chargers. The lead-calcium batteries are self-contained stored energy sources, and the battery chargers provide DC power by rectifying power from the 480 VAC buses.

The Class 1E 125 VDC power system is a safety related, two-wire, ungrounded bus system, divided into four separate channels as described in FSAR section 8.3.2.1.2. Two of the DC power system channels (batteries 301A-2 and 301 B-2) exclusively supply the associated regulated 120 VAC vital bus loads, and the other two channels (batteries 301 A-1 and 301 B-1) supply safety related DC loads in addition to the associated regulated 120 VAC load. Each channel consists of one operating battery charger, one 125 VDC battery, and one distribution switchboard. The power source for each channel is supplied from either its associated battery charger or battery. The battery charger is powered from the associated train emergency 480 VAC bus. A spare battery charger is shared by two channels of the same train.

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 7 of 13 During normal operation, the 125 VDC load is supplied from the battery chargers with the batteries floating on the 125 VDC buses. On a loss of AC power to the battery chargers, the DC load is supplied from the batteries. Power is available to these DC loads for a period of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. After 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, it is assumed that AC power is either restored or that the emergency generators are available to energize the battery chargers. The Class 1E battery chargers are described in FSAR Section 8.3.2.1.2.1.

3.1.2 Class 1E Batteries Each of the four 125 VDC Class 1E batteries is a 60-cell lead-calcium battery designed for continuous duty, manufactured by GNB. Batteries 301A-1 and 301 B-1 are model number NCN-27. Batteries 301A-2 and 301 B-2 are model number NCN-11. The ampere-hour capacity of each battery is suitable for supplying all connected safety related loads for a minimum or 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without the use of the battery chargers. At the end of the 2-hour period, the final battery voltage is a minimum of 1.75 VDC per cell.

The selection criteria for battery capacity and reliability meets the requirements of Institute of Electrical and Electronics Engineers (IEEE) standard 308, "Standard Criteria for Class IE Power Systems for Nuclear Power Generating Stations" (Reference 6.2) and GDC 17, "Electric Power Systems". The batteries are sized using the methods from IEEE standard 485 (Reference 6.8). The reliability of the batteries is assured by periodic discharge testing at a frequency specified by the MPS2 Surveillance Frequency Control Program and maintenance in accordance with IEEE standard 450, "Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations" (References 6.3 and 6.4). The performance and service tests comply with Regulatory Guide 1.129 (Reference 6.5). The batteries are seismically qualified and are mounted on Seismic Category I battery racks.

The battery inter-cell and terminal connectors are lead-plated copper. Each battery voltage level is continuously monitored and displayed in the control room. FSAR Table 8.1-2 describes the industry standards related to the DC power system. Additional battery and battery rack details are described in FSAR Sections 8.3.2.1.2.2 and 8.3.2.1.2.3.

Battery location in the plant and ventilation of these areas is also discussed in FSAR Section 8.3.2.

3.2 Technical Analysis 3.2.1 Battery Resistance Evaluation The proposed amendment seeks to correct a non-conservative TS by revising the inter-cell and interconnection resistance value listed in SR 4.8.2.1.b, and 4.8.2.1.c. A high connection resistance value is an indication of an additional battery impedance due to loose connection fittings, improper mating surfaces, connector corrosion, or material degradation. In the worst-case condition, a majority of the inter-cell and inter-connection

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 8 of 13 resistances at the bounding value could result in a total impedance value that would challenge the safety related battery loading profile due to increased voltage drops.

A technical evaluation (Reference 6.6) was completed to identify the maximum allowable connection resistance values that would ensure the duty profiles are maintained as designed. Resistance sources in the battery setup include plate-to-post connections, inter-cell connections, and cabling connections. As noted previously, the model numbers for the MPS3 batteries are NCN-11 for batteries 301 A-2 and 301 B-2 and NCN-27 for batteries 301A-1 and 301 B-1. Two models are needed due to the design loading on each battery bus. The larger battery model, NCN-27, was used to determine the bounding resistance value due to having more posts and connections. Using the typical 60-cell configuration, including inter-tier and inter-rack cables, a combined resistance value was determined. To ensure additional margin, a safety factor of 1.25 was applied to the total 60-cell resistance value to allow for variation of the inter-cell, inter-tier, and inter-rack connections.

The total allowable battery inter-cell impedance was determined to be 4764 micro-ohm.

However, because surveillance procedure C SP 760, "Battery Discharge Test" (Reference 6.7) monitors only the plate-to-post and inter-cell connections and does not include the resistance from the inter-tier and inter-rack cabling (which have a total calculated impedance of 870 micro-ohm), the new calculated bounding acceptance criteria value is 3894 micro-ohm. For additional conservative margin, the new TS SR limit for total inter-cell resistance will be 3700 micro-ohm. By supplementing the surveillance to confirm that individual cell resistances are below 150 micro-ohm with a requirement to verify a conservative bounding total of 3700 micro-ohm, the battery functionality (including voltage) will not be challenged by one or multiple resistances approaching the 150 micro-ohm value. Therefore, a revision to the 150 micro-ohm criteria value in the MPS3 TS SRs is not required.

To ensure full functionality of the battery and associated loads with the new total allowable battery inter-cell impedance of 4 764 micro-ohm, the most conservative battery draw and associated voltage drop was verified against the load profiles to ensure all battery minimum voltage requirements would be met. The primary bounding event for batteries is Loss of Onsite Power (LOP), but the calculations supporting the technical evaluation (Reference 6.6) also reviewed the normal and emergency operation loading as part of the sizing verification. The new voltage profile was evaluated as acceptable using the same initial conditions, limiting operation assumptions, and accounts of additional conservative margins in the current MPS3 battery profile calculations. Furthermore, a work order history review was performed to ensure that the recorded minimum battery voltages were acceptable during plant surveillance battery discharge testing. The final evaluation results for MPS3 battery banks 1 through 4 have ensured that the battery banks remain fully capable of meeting design function requirements with the new conservative bounding total impedance.

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 9 of 13 For the purposes of updating the MPS3 TSs, the new bounding acceptance criteria of 3700 x 10-5 ohm will be used. This ensures alignment of the total value with the measurements performed under procedure C SP 760, including a safety factor margin, and is verified to be acceptable for all battery profile loads.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements are applicable to battery inter-cell connections:

GDC 17 - Electric Power Systems 10 CFR 50, Appendix A, General Design Criterion (GDC) 17 for electric power systems requires that "nuclear power plants have onsite and offsite electric power systems to permit the functioning of structures, systems and components (SSCs) that are important to safety." GDC additionally notes that "the onsite electric power supplies, including the batteries, and the onsite electric distribution system, must have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure."

Revision of the SRs as herein proposed does not affect compliance with GDC 17.

GDC 18 - Inspection and Testing of Electric Power Systems 10 CFR 50, Appendix A, GDC 18 for inspection and testing of electric power systems requires that "electric power systems important to safety be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the conditions of their components."

Revision of the SRs as herein proposed does not affect compliance with GDC 18.

10 CFR 50.36 - Technical Specifications 10 CFR 50.36(c)(3) requires Technical Specifications to include Surveillance Requirements, which are "requirements relating to test, calibration, or inspection to ensure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions of operation will be met."

Revision of the SRs will ensure that the MPS3 DC Systems are able to perform their safety related functions. Thus, the Limiting Condition for Operation (LCO) will continue to be met.

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 10 of 13 10 CFR 50.63 - Loss of All Alternating Current Power 10 CFR 50.63 "requires that each light-water cooled nuclear power plant licensed to operate must be able to withstand for a specified duration and recover from a station blackout (SBO)."

Revision of the SRs as herein proposed do not affect compliance with 10 CFR 50.63.

10 CFR 50.65 10 CFR 50.65 for requirements for monitoring the effectiveness of maintenance at nuclear power plants requires that preventive maintenance activities must not reduce the overall availability of the SSCs.

Revision of the SRs as herein proposed will not affect compliance with 10 CFR 50.65.

The batteries and other components of the DC electric power system continue to be within the scope of 10 CFR 50.65.

Conclusion The proposed change does not adversely affect MPS3 compliance with the applicable regulatory requirements or criteria.

4.2 Precedent

1. FERMI 2 - Issuance of Amendment Regarding Request to Revise Technical Specification Surveillance Requirements for Direct Current Batteries (TAC No.

MF4002), dated March 16, 2015 [ML15057A297]

2. QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - Issuance of Amendments Regarding (TAC Nos. MF4589 AND MF4590), dated March 30, 2015

[ML15056A772]

4.3 Significant Hazards Consideration Pursuant to 10 CFR 50.90, Dominion Energy Nuclear Connecticut, Inc. (DENC) requests an amendment to Facility Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3). The inter-cell connection resistance value of 150 x 1o-6 ohm in MPS3 Technical Specification (TS) Surveillance Requirement (SR) 4.8.2.1.b.2 and 4.8.2.1.c.3 for the MPS3 batteries is nonconservative if all, or a considerable number, of the connections are at that value since the acceptable total battery resistance value would be exceeded. Therefore, DENC is revising the SRs to add a new acceptance criterion for total battery connection resistance. The new acceptance criterion will confirm that the total battery connector resistance is within preestablished limits, and will ensure that the

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 11 of 13 batteries can perform their specified safety function by maintaining required battery terminal voltage under design-basis load conditions.

DENG has evaluated whether a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change does not modify any plant equipment and does not impact any failure modes that could lead to an accident. The proposed change does not affect the safety function of the batteries. Additionally, the proposed change has no effect on the consequence of any analyzed accident since the change does not affect the accident mitigating functions supported by the Direct Current (DC) electrical power system.

The proposed change to add a total battery resistance constitutes an additional operational limitation or restriction on the acceptable range of values of the battery inter-cell resistance required to ensure that the batteries can perform as designed.

Therefore, the proposed change will not increase the probability or consequences of any accident previously evaluated that involves any of the safety related batteries or associated equipment powered by these batteries.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a modification to the physical configuration of the plant or how the plant is operated. The proposed change to add a total battery resistance constitutes an additional operational limitation or restriction on the acceptable range of values of the battery inter-cell resistance required to ensure that the batteries can perform as designed. No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of this amendment. There will be no adverse effect or challenges imposed on any safety related system as a result of this proposed change. The DC electrical power system supplies power to support systems and components that perform accident mitigation and is not an initiator of any accident.

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 12 of 13 The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change to add a total battery resistance constitutes an additional operational limitation or restriction on the acceptable range of values of the battery inter-cell resistance required to ensure that the batteries can perform as designed.

The safety function of the DC electrical power system to support the plant's accident mitigating systems and components is not affected.

The proposed changes do not physically alter safety related systems. There will be no effect on those plant systems necessary to assure the accomplishment of protection functions. There will be no impact on the overpower limit, departure from nucleate boiling limits, loss of cooling accident peak cladding temperature, or any other margin of safety. The applicable radiological dose consequence acceptance criteria will continue to be met.

The proposed change does not involve a significant reduction in a margin of safety.

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

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Serial No.19-369 Docket No. 50-423 Attachment 1, Page 13 of 13

6.0 REFERENCES

6.1 NRC Administrative Letter 98-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety.

6.2 Institute of Electrical and Electronics Engineers, IEEE Standard 308, Standard Criteria for Class IE Power Systems for Nuclear Power Generating Stations, 1975.

6.3 Institute of Electrical and Electronics Engineers, IEEE Standard 450, Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations, 1975.

6.4 Institute of Electrical and Electronics Engineers, IEEE Standard 450, Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations, 1980.

6.5 Regulator Guide 1.129, Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Nuclear Power Plants, Revision 1, February 1978.

6.6 ETE-MP-2019-1083, "MP3 Non-Conservative Battery lntercell Resistance Evaluation."

6.7 C SP 760, "Battery Discharge Test," Millstone Power Station Surveillance Procedure, Rev. 13.

6.8 Institute of Electrical and Electronics Engineers, IEEE Standard 485, IEEE Recommended Practice for Sizing Lead-Acid Batteries for Stationary Applications, 1997.

6.9 Electric Power Research Institute (EPRI) Technical Report TR-1 00248, Stationary Battery Guide: Design, Application, and Maintenance, Revision 2.

Serial No.19-369 Docket No. 50-423 ATTACHMENT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES DOMINION ENERGY NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No.19-369 Docket No. 50-423 Attachment 2, Page 1 of 4

!For lnformatmn Onl',- February 25, 2014 ELECTFJCA.L POWER SYSTEMS

.N.8 ~ D.C. SOl.'RCES OPER:,IING UMITING CONDffiON FOR OPER.A.TlON 3.8.2.l. As a minimum. the following D.C. electrical sources ~Jial! be OPER./1.BLE:.

a. 125-volt Battery Bank 301A-1, and an a;sociated full c.apacity charger.

b. 125-volt Batte.ry B:mk 301A-2, ami an associated full capacity charger,

c. 125-vo!t Battery Bank 301B-I a11d an a,rndated full capacity charger. and

d. 125-volt Battery Bank 301B-2 a11d Ml as,oc:i.ated full capacity charger.

APPLICABil.ITY: MODES 1. 2, 3. and 4.

ACTION:

a. With eitlm Battery Bank 301A-l or 301B-1, and/cir one of the required full capacity charger, inoperable. re~tore fue inoperable battery ballk and/or full capadty charger to OPERABLE status withiu 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT SIA1'mBY within the next 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and in COLD SHUTDOWN within ilie following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With either Battery Bank 30 I A-2 or 30!B-1 .inoperable, and1or one of!he reqmred full capacity chargers inopernble. restore rhe inoperable, barte1y ballk ru1d,'or full capadty charger to OPERABLE status within 24 boms or bl:' in at lea;t HOT STA.t\'DBY within the next 5 hams and in COLD SHUTDO\'VN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Sl}RVEILLANCE REQUIREMENTS 4.8.2.1 Each 125-vo.h battery bank md charger shall b,e demonstrated OPER.il.BLE:

a. At the frequency specified in the Surveillance Frequency Control Progrrun by verifying th.at:

1) The pnrameter; in Table 4.8-2a meet the Category A limits. and

2) TI1e toiai battery term.in.'!.! voltage i; greater than or equal to 119 volt& on float charge.

MIU.STOI\1E - UNIT 3 3/48-11 AmendmentNo.44. 258

Serial No.19-369 Docket No. 50-423 Battery Surveillance Requirements Attachment 2, Page 2 of 4 011m and total ELECTRICAL POWER SYSTE.'vl5 l;attery resisiam:e is less ihan 3700 x SURVEILLANCE REQUIREMENTS (Contim1ed) JO-o ohm. and

\

b. At the frequency specified in the Surveillance Freqti~cy Contrni Program and within 7 days after a banery discharge with battery te~nal voltage below ! 10 eacl1 cell-to-cell volts. or batte1y overcharge wilh battery terminal volrag~bove 150 1.'olts. by and term;nal ---..,,eriJving that: \

connection

1) -----~;-~ters in Table ~.8-2a meet the Category B limits.

---......~.........,~-. - . \\

2) There is no visible C~J!.!f either terminals or connec'!qrs, or the connection resistance oft!ie.ie item; is less than 150;;: rn--0~

3) The average electrol}te temperature of si'!: connected ce.!ls is above 60°F.

C. At the frequency specified in the Surveillance Frequency Control Pro gram by verifying that:

I) The cells, cell plates, and batrery racks show no visual indication of physical da.'llage or abnormal deterioration.

2) The cell-to-cell and terminal connections are clean, *tight. and coated with cllm and total anticorrosion materia~

batter/ reslstance --------

is less man 3700 x 3) The-resisllme-e..Qf each cell-to-cell ai1d terminal connection is less than 0.:

10**onm, aM --:;s--->.

~l50x10 ~ m i

4) Each battery charger will supply at least the amperage indicated in Table 4.S-2b at greater than or equal to 132 volts for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

d. At the frequency specified in the Surveillance Freq_uency Conrrol Program. during 'l, shutdown., by verifying that the batte1y capacity is adequate to supply a11dmaintain in OPEK~BLE status all of the actual or simulated ememencY loads for the desi!!ll duty eye le when the battery is mbjected to a battery sen.ice test: **

e. At the freq11ency >}lecified in the St1ffeillance Frequem:y Control Program, during ~, ....

shutdown. by verifying that the battery capadty is at leasi SO% of the manufacturer's rating when subjected. to a perfunnauce discharge test. This -f-,..._

performance discliarge test may be performed in heu of the battery service test required by Specification 4.S.2.ld.; and

f. At least once per 18 months, during shutdown, by gi -1ng performance discharge iests ofbartery capacity 10 any battery that shows ;igns of degradation or has reached 85% of the senice life e>.-pected for the application. Degradation i~

indicated when the battery capacity drops more than 10% of rated capacity from its as:erage on previom performance tests, or is below 90% of the 111anufacmrer's rating.

MillSTONE - UNIT 3 3/4 8-12 Amendmelll No.#, .:W.. ~- +4f), 158

Serial No.19-369 Docket No. 50-423 Battery Surveillance Requirements Attachment 2, Page 3 of 4

!For Information Only 3/09/92 TABLE -l.8-1B B;TIERY CH;;\RGER CAP;.cm*

CHARGER AMPERAGE 301A-1 100 301.A.-2 50 301.A.-3 200 301B-1 200 301B-2 50 301B-3 200 MlliSTONt: - UNIT 3 3/4 8-14 Amendment No. 64 I

Serial No.19-369 Docket No. 50-423 Battery Surveillance Requirements Attachment 2, Page 4 of 4

!For Jnfommtibn onry 3/09/92 TABLE 4.S-2.A BUIERY SFRU:IT,LA~CI REQlTRB(E:NJS CATEGORY AC1l CATEGORY B<2l P.11.RAMETER LIMITS FOR EACH LTh1ITS FOR EACH ALLOWABLE(>)

DESIGNATED COl\:"NECTED CELL VALUE FOR EACH PILOT CONNECTED CELL CELL Elec!rolyte >Minimum level >Minimwn le,el Above top of Level indication mru:k_ indication mark, plates, and and,:;-~** above and 0 * ;'/' above not overflowing maximwu level ma.umum le,*el indication mru:k imlication marl:

Hoat Voltage :e: 2.13 volts > 2.07 volts Specific Not more th.an Grav:ity< 4) O.OJ.O below the avernge of all 2: L:!.OO{S) '.::.U95 connected ceIIs Average of all A\*erage of all co1mected cells connected ce.lJ.s

• , L205  ?: 1.195(:5}

TABLE NOTATIONS

(!) For any Category A parameter(,) ouuide the limit(s) sho,nL the battery may be considered OPERABLE provided that within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> al! the Category B mearnrements are Ui.ken and found to be wiiliin their allowable values, and proi:ided all Category A and B parameter(s) are restored to within. limits within the ne.>1t 6 day,.

(:!) For any Catego.ry B pammerer(s) outside the limii(s) shown, the battery may be considered OPERABLE pro\ided that the Category B parameters are within their allowable values and pro\ided the Category B pammeter(s) are restored to within limits within 7 days.

(3) .'\..1.J.y Category B parameter not within its allowable value indicates an inoperable battery.

(4) Corrected for electrolyte temperntme and. level.

(5) Or battery chru:gir.g current is less than 2 amps when on charge.

(6) Corrected for average electrolyte temperature.

MiliSTONt . UNIT 3 3/4 S-13 Amendment No. 64