Text

Request for Amendment to Technical Specifications Associated with Direct Current Electrical Power
	ML032170789
Person / Time
Site:	Dresden
Issue date:	07/29/2003
From:	Simpson P; Exelon Nuclear
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-03-140
	Download: ML032170789 (96)
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Exelon Generation www.exeloncorp.coM Nuclear 4300 Winfield Road Warrenville, IL 60555 10 CFR 50.90 RS-03-140 July 29, 2003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249

Subject:

Request for Amendment to Technical Specifications Associated With Direct Current Electrical Power

References:

(1) Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications,"

dated January 24, 1995 (2) Technical Specifications Task Force (TSTF) Traveler TSTF-360, Revision 1, "DC Electrical Rewrite" (3) Letter from W. D. Becker (U. S. NRC) to A. R. Pietrangelo (Nuclear Energy Institute), dated December 18, 2000 In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) requests an amendment to Facility Operating License Nos. DPR-1 9 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3. The proposed changes modify Technical Specifications (TS)

Sections 3.8.4, "DC Sources - Operating," 3.8.5, "DC Sources - Shutdown," 3.8.6, "Battery Cell Parameters," and 5.5, "Programs and Manuals." The proposed changes request new actions for an inoperable battery charger and alternate battery charger testing criteria for Limiting Condition for Operation (LCO) 3.8.4 and 3.8.5. The proposed changes also include the relocation of a number of Surveillance Requirements (SRs) in TS Section 3.8.4, that perform preventive maintenance on the safety related batteries, to a licensee controlled program. It is proposed that TS Table 3.8.6-1, "Battery Cell Parameter Requirements," be relocated to a licensee controlled program, and specific actions with associated completion times for out-of-limits conditions for battery cell voltage, electrolyte level, and electrolyte temperature be added to TS Section 3.8.6. In addition, specific SRs are being proposed for verification of these parameters.

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July 29, 2003 U. S. Nuclear Regulatory Commission Page 2 A new program is being proposed for the maintenance and monitoring of station batteries based on the recommendations of Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications" (i.e., Reference 1). The items proposed to be relocated will be contained within this new program.

These proposed changes are consistent with Reference 2, which was approved by the NRC in Reference 3. There are some differences between the proposed changes and Reference 2 due to plant-specific design features (e.g., the need for the direct current sources TS to address both the 250 volts direct current (VDC) and 125 VDC subsystems) and ease of use considerations.

This request is subdivided as follows.

Attachment 1 provides an evaluation supporting the proposed TS changes.

Attachment 2 contains the marked-up TS pages with the proposed changes indicated.

Attachment 3 provides the marked-up TS Bases pages with the proposed changes indicated. The TS Bases pages are provided for information only, and do not require NRC approval.

Attachment 4 provides revised TS pages with the proposed changes incorporated.

The proposed changes have been reviewed by the DNPS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program. EGC requests approval of these changes prior to May 15, 2004. Once approved, the amendments shall be implemented within 60 days. This implementation period will provide adequate time for station documents to be revised using the appropriate change control mechanisms.

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

paragraph (b), EGC is notifying the State of Illinois of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Mr. Kenneth M. Nicely at (630) 657-2803.

July 29, 2003 U. S. Nuclear Regulatory Commission Page 3 I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Pdon e lye~0' Patrick R. Simpson 0 Manager - Licensing Mid-West Regional Operating Group

July 29, 2003 U. S. Nuclear Regulatory Commission Page 4 Attachments:

Attachment 1: Description of Proposed Changes, Technical Analysis, and Regulatory Analysis Attachment 2: Markup of Technical Specification Pages Attachment 3: Markup of Technical Specification Bases Pages Attachment 4: Retyped Technical Specification Pages cc: Regional Administrator - NRC Region IlIl NRC Senior Resident Inspector - Dresden Nuclear Power Station Office of Nuclear Facility Safety - Illinois Department of Nuclear Safety

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

2.1 Need for Revision of the Requirements 2.2 Impact on Previous Submittals

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

Page 1 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis

1.0 DESCRIPTION

In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) requests an amendment to Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3.

The proposed phanges modify Technical Specifications (TS) Sections 3.8.4, "DC Sources - Operating," 3.8.5, "DC Sources - Shutdown," 3.8.6, "Battery Cell Parameters,"

and 5.5, "Programs and Manuals." The proposed changes request new actions for an inoperable battery charger and alternate battery charger testing criteria for Limiting Condition for Operation (LCO) 3.8.4 and 3.8.5. The proposed changes also include the relocation of a number of Surveillance Requirements (SRs) in TS Section 3.8.4, that perform preventive maintenance on the safety related batteries, to a licensee controlled program. It is proposed that TS Table 3.8.6-1, "Battery Cell Parameter Requirements," be relocated to a licensee controlled program, and specific actions with associated completion times for out-of-limits conditions for battery cell voltage, electrolyte level, and electrolyte temperature be added to TS Section 3.8.6. In addition, specific SRs are being proposed for verification of these parameters.

A new program is being proposed for the maintenance and monitoring of station batteries based on the recommendations of Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications" (i.e., Reference 1). The items proposed to be relocated will be contained within this new program.

These proposed changes are consistent with Reference 2, which was approved by the NRC in Reference 3. There are some differences between the proposed changes and Reference 2 due to plant-specific design features (e.g., the need for the direct current (DC) sources TS to address both the 250 volts direct current (VDC) and 125 VDC subsystems) and ease of use considerations.

2.0 PROPOSED CHANGE

The proposed changes revise TS 3.8.4, TS 3.8.5, TS 3.8.6, and TS Section 5.5 to be consistent with Reference 2. Each related change is grouped and discussed in detail below. These groupings follow the general presentation found in Reference 2. Section 4.0, 'Technical Analysis," presents subsections that are numbered following the below numbered summary of proposed changes.

(1) Provide Specific Actions and an Increased Completion Time for an Inoperable Battery Charger TS 3.8.4 is being revised to add new Conditions A and E to address the condition where a required 250 VDC or 125 VDC battery charger, respectively, becomes inoperable.

Required Actions are proposed that provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to operable status in a reasonable time. Required Actions A.1 and E.1 require that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Required Actions A.2 and E.2 require verification that the battery float current be less than or equal to 2 amps once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Required Actions A.3 Page 2 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis and E.3 limit the restoration time for the required inoperable battery charger to 7 days.

Existing TS 3.8.4 Conditions A, B, C, D, E, F, G, and H are re-designated to reflect the addition of new Conditions A and E.

(2) Relocate Preventive Maintenance SRs to Licensee Controlled Programs Existing SR 3.8.4.2, SR 3.8.4.4, SR 3.8.4.5, and SR 3.8.4.6 are being deleted from the DNPS TS and relocated to a licensee controlled program. These SRs are also listed in SR 3.8.5.1 and will be deleted from SR 3.8.5.1. This requires renumbering of SR 3.8.4.3 as SR 3.8.4.2, SR 3.8.4.7 as SR 3.8.4.3, and SR 3.8.4.8 as SR 3.8.4.4.

(3) Provide Alternative Testing Criteria for Battery Charger Testing SR 3.8.4.3 (i.e., revised SR 3.8.4.2) for the 250 VDC battery chargers is being revised to permit alternative battery charger testing criteria. The revised SR 3.8.4.2 states:

'Verify each required 250 VDC battery charger supplies > 200 amps at greater than or equal to the minimum established float voltage for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for the 250 VDC subsystems.

OR Verify each 250 VDC battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-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."

Similar changes are proposed for SR 3.8.4.7 (i.e., revised SR 3.8.4.3) for the 125 VDC battery chargers. The revised SR 3.8.4.3 states:

'Verify each required 125 VDC battery charger supplies > 200 amps at greater than or equal to the minimum established float voltage for > 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for the 125 VDC subsystems.

OR Verify each 125 VDC battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-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."

In addition, SR 3.8.4.1 is being revised to require verification that battery terminal voltage is greater than or equal to the minimum established float voltage for each 250 VDC battery, each 125 VDC battery, and the Unit 2 alternate battery.

Page 3 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis (4) Relocate SR 3.8.4.9 to SR 3.8.6.6 SR 3.8.4.9 is being relocated to TS Section 3.8.6 as SR 3.8.6.6. This SR is also listed in SR 3.8.5.1 and SR 3.8.4.8. No changes are proposed to SR 3.8.4.9 other than relocating the SR.

(5) Replace Battery Specific Gravity Monitoring with Float Current Monitoring The specific gravity limits of Table 3.8.6-1 and associated Footnotes (b) and (c) are being deleted. Currently, verification of battery cell specific gravity is required by existing SR 3.8.6.1 and SR 3.8.6.2. Under the proposed changes, specific gravity monitoring will be replaced with float current monitoring. New SR 3.8.6.1 requires verification that each battery float current is less than or equal to 2 amps when battery terminal voltage is greater than or equal to the minimum established float voltage of SR 3.8.4.1. The Frequency of new SR 3.8.6.1 is 7 days.

(6) Relocate Limiting Values for Battery Cell Float Voltage, Electrolyte Level, and Electrolyte Temperature to a Licensee Controlled Program The proposed changes delete Condition A of TS 3.8.6, SR 3.8.6.1, SR 3.8.6.2, SR 3.8.6.3, and Table 3.8.6-1 from TS Section 3.8.6. These requirements are being relocated to the licensee controlled program described in proposed TS Section 5.5.13, with the exception that battery specific gravity monitoring is being replaced with float current monitoring, as described above.

In addition, the title of TS Section 3.8.6 is being revised to "Battery Parameters" and the LCO is being revised to read: "Battery parameters for the 125 VDC and 250 VDC station batteries shall be within limits." A corresponding change to the TS Table of Contents is being made to be consistent with the revised TS Section 3.8.6 title.

(7) Create an Administrative Program Under TS Section 5.5.13 to Reference Actions for Cell Voltage and Electrolyte Level A new program is being added to TS Section 5.5. Specifically, TS Section 5.5.13, "Battery Monitoring and Maintenance Program," is added to provide for restoration and maintenance actions for station batteries based on the recommendations of Reference 1.

(8) Provide Specific Actions with Increased Completion Times for Out-of-limits Conditions for Cell Voltage, Electrolyte Level, and Electrolyte Temperature Six new conditions are being added to TS 3.8.6. These conditions with their associated required actions provide compensatory actions for a specific abnormal battery condition.

(a) Condition A addresses the condition where one battery has one or more battery cells with a float voltage less than 2.07 V.

(b) Condition B addresses the condition where one battery is found with a float current greater than 2 amps.

Page 4 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis (c) Condition C addresses the condition where one battery has one or more battery cells with a float voltage less than 2.07 V and float current greater than 2 amps.

(d) Condition D addresses the condition where a battery is found with electrolyte level in one or more cells less than the minimum established design limits.

(e) Condition E addresses the condition where a battery is found with pilot cell electrolyte temperature less than minimum established design limits.

(f) Condition F addresses the condition where one or more batteries in redundant divisions are found with battery parameters not within limits.

As a result of the new conditions, Condition B is being re-designated as Condition G, and the condition is being revised to reference the six new conditions. In addition, the following new SRs are being added to TS 3.8.6.

(a) SR 3.8.6.2 requires verification that each battery pilot cell voltage is greater than or equal to 2.07 V every 31 days.

(b) SR 3.8.6.3 requires verification that each battery connected cell electrolyte level is greater than or equal to minimum established design limits every 31 days.

(c) SR 3.8.6.4 requires verification that each battery pilot cell temperature is greater than or equal to minimum established design limits every 31 days.

(d) SR 3.8.6.5 requires verification that each battery connected cell voltage is greater than or equal to 2.07 V every 92 days.

A markup of the affected TS pages is provided in Attachment 2. Attachment 3 provides a markup of the affected TS Bases pages. Information contained in Attachment 3 is provided for information only, and does not require NRC approval.

2.1 Need for Revision of the Requirements The current TS limit restoration time for an inoperable battery charger to the same time as for an inoperable battery or a completely de-energized DC distribution subsystem. The 250 VDC system consists of two Class IE battery chargers. In addition, DNPS has a swing (i.e., spare) 250 VDC full capacity battery charger that is available for use on either unit. The swing battery charger can be connected to supply only one of the 250 VDC batteries at a time. This swing charger can be used as a means of supplying backup DC power during periods when maintenance is being performed on the normal divisional charger or in conditions that cause the normal charger to be inoperable. Additionally, a portable 250 VDC battery charger is available, which is identical in size and operating characteristics to the normal and backup battery chargers. The portable charger can be used as a backup to any one of them using the same AC source and circuit breaker protection. The use of the portable charger as a substitute for one of the permanent chargers is described within plant procedures. Use of this charger does not result in the 250 VDC system being operated in a new or different manner compared with the existing battery chargers.

The 125 VDC system consists of four Class 1E divisional battery chargers. Two chargers supply each unit's DC electrical power system. One is the normal battery charger, while the other is the backup battery charger. Additionally, a portable 125 VDC battery charger is available, which is identical in size and operating characteristics to the normal battery chargers.

The portable charger can be used as a backup to any one of them using the same AC source and circuit breaker protection. The use of the portable 125 VDC battery charger as a substitute Page 5 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis for one of the permanent chargers is described within plant procedures. Use of this charger does not result in the 125 VDC system being operated in a new or different manner compared with the existing battery chargers.

The proposed changes will allow additional time for maintenance and testing of the normal 250 VDC and 125 VDC divisional chargers based on the availability of the swing (i.e., for the 250 VDC system) and portable chargers. In addition, relocation of the preventive maintenance SRs and battery cell parameter requirements to a licensee controlled program will continue to provide an adequate level of control of these requirements, assure the batteries are maintained at current levels of performance, allow flexibility to monitor and control these limits at values directly related to the batteries' ability to perform their assumed function, and allow the TS to focus on parameter value degradations that approach levels that may impact battery operability.

2.2 Impact on Previous Submittals EGC has reviewed the proposed changes for impact on previous submittals awaiting NRC approval for DNPS, and has determined that there is an impact to one of them. In Reference 4, EGC requested a license amendment for DNPS to support application of an alternative source term methodology. Reference 4 proposed a revision to TS page 5.5-12 to increase the maximum allowable primary containment leakage rate. The retyped TS pages provided in of this submittal do not reflect the changes proposed in Reference 4.

3.0 BACKGROUND

Each DNPS unit includes a 125 VDC source consisting of a 125 VDC battery and two 125 VDC full capacity battery chargers (i.e., a total of four 125 VDC full capacity battery chargers), and associated control equipment and interconnecting cabling. Each 125 VDC unit source (i.e.,

125 VDC battery and associated chargers) supplies power to the associated unit Division 1 125 VDC electrical power distribution subsystem and the opposite unit Division 2 125 VDC electrical power distribution subsystem. The Division I and Division 2 125 VDC electrical power distribution subsystems provide power to redundant loads, therefore both unit 125 VDC sources are needed to support the operation of both units.

Each DNPS unit also includes a 250 VDC source consisting of a 250 VDC battery and an associated 250 VDC full capacity battery charger (i.e., a total of two 250 VDC full capacity battery chargers), as well as associated control equipment and interconnecting cabling. An additional 250 VDC full capacity (i.e., swing) charger is available for use between the units. The swing charger can only be aligned to one battery at a time. Each 250 VDC battery and charger supplies power to both Unit 2 and Unit 3 loads. Therefore, each unit has two 250 VDC electrical power subsystems. One 250 VDC electrical power subsystem includes the associated unit 250 VDC battery and full capacity battery charger while the other 250 VDC electrical power subsystem includes the opposite unit 250 VDC battery and the full capacity charger.

Portable battery chargers are available for both 125 VDC and 250 VDC systems, which are identical in size and operating characteristics to the normal chargers.

During normal operation, the DC loads are powered from the battery chargers with the batteries floating on the system (i.e., float-charge mode). Float-charge is the condition in which the Page 6 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis charger is supplying the connected loads and the battery cells are receiving adequate current to optimally charge the battery. This assures the internal losses of a battery are overcome and the battery is maintained in a fully charged state. In the case of loss of normal power to the battery charger, the DC loads are automatically powered from the associated batteries.

Each battery has adequate storage capacity to start and carry the normal DC loads plus DC loads required for safe shutdown on one unit and operations required to limit the consequences of a design basis accident on the other unit for a period of four hours following a loss of offsite power plus a single active failure, without taking credit for the battery chargers. The batteries are designed with additional capacity above that required by the design duty cycle to allow for temperature variations and other factors. The batteries for the 125 VDC and 250 VDC electrical power subsystems are sized to produce required capacity at 80% of nameplate rating, corresponding to warranted capacity at end of life cycles and the 100% design demands.

Each DC electrical power subsystem battery charger, including the swing charger for the 250 VDC electrical power subsystem, has ample power output capacity for the steady state operation of connected loads required during normal operation, while at the same time maintaining its battery bank fully charged. Each battery charger has sufficient excess capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads.

Each DC electrical power subsystem is required to be operable to ensure the availability of the required power to shutdown the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated design basis accident. The subsystems are arranged so that more than one failure is required before plant needs are not served. Thus, loss of an electrical power subsystem does not prevent the minimum safety function from being performed.

Each unit also has an alternate 125 VDC battery to allow the unit 125 VDC battery to undergo rated discharge testing with both units online. The alternate battery is available to supply system loads upon failure of a unit 125 VDC battery. The alternate battery is of similar type as the unit battery. Although the alternate battery is of different size than the unit battery, it is sized to support the same loads. The alternate battery is normally disconnected from the system and is maintained on float charge.

4.0 TECHNICAL ANALYSIS

(1) Provide Specific Actions and an Increased Completion Time for an Inoperable Battery Charger Current TS 3.8.4 Condition C requires restoration of battery charger operability within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This is the same Completion Time specified for an inoperable battery or a completely de-energized DC distribution subsystem.

New Conditions, with their associated Required Actions and Completion Times are being added to TS 3.8.4 to separately address battery charger inoperability (i.e., Condition A for the required 250 VDC battery chargers and Condition E for the required 125 VDC battery chargers). Each of these Conditions addresses the condition where one required Page 7 of 18

ATTACHMENT 1 Description of Proposed Changes, Technical Analysis, and Regulatory Analysis battery charger becomes inoperable. A proposed Completion Time of 7 days focuses on a tiered approach to assuring adequate battery capability is maintained.

The first priority with an inoperable battery charger is to minimize the battery discharge.

Required Actions A. 1 and E.1 assure the discharge is terminated by requiring that the batteryterminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time provides for returning the inoperable charger to operable status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. This provides assurance that the battery will be restored to its fully charged condition from any discharge that might have occurred due to the charger inoperability. A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion of its recharging cycle. There is no comparable limitation in the current DNPS TS. As such, including this action provides for continued safe plant operation.

The second tiered action (i.e., Required Actions A.2 and E.2) requires that once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , battery float current be verified to be less than or equal to 2 amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it has now been fully charged. If at the expiration of the 12-hour period the battery float current is not less than or equal to 2 amps, there may be additional battery problems and the battery must be declared inoperable. This verification provides assurance that the battery has sufficient capacity to perform its assumed duty cycle.

Given that the DC bus remains energized, the battery discharge (i.e., if it was occurring) is terminated (i.e., Required Actions A.1 and E.1), and the battery is fully recharged (i.e.,

Required Actions A.2 and E.2), there is reasonable basis for extending the restoration time for an inoperable charger beyond the existing 2-hour limit to 7 days (i.e., Required Actions A.3 and E.3). Required Actions A.3 and E.3 are applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., the portable battery chargers).

The revised actions are acceptable because they focus efforts on retaining battery capabilities, retaining the requirement for charger operability, and applying a reasonable restoration time for an inoperable battery charger to avoid an unnecessary plant shutdown transient.

(2) Relocate Preventive Maintenance SRs to Licensee Controlled Programs In accordance with SR 3.0.1, when any SR is not met, the LCO is not met. This is based on the premise that SRs represent the minimum acceptable requirements for operability of the required equipment. However, for SR 3.8.4.2, SR 3.8.4.4, SR 3.8.4.5, and SR 3.8.4.6, failure to meet the SR does not necessarily mean that the equipment is not capable of performing its safety function, and the corrective action is generally a routine or preventive maintenance-type activity. For example, SR 3.8.4.2 requires visual inspection to detect corrosion of the battery cells and connections to provide an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. This action is not required for the battery to perform its safety function, but reflects ongoing preventive maintenance activities. These activities are Page 8 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis inappropriate for operability SRs and are better controlled under the maintenance programs for batteries.

The proposed changes relocate preventive maintenance SRs to a licensee controlled program being added as TS Section 5.5.13. These activities will be included in the Technical Requirements Manual (TRM) and will continue to be performed consistent with recommendations in Reference 1. Changes to the TRM are evaluated under the provisions of 10 CFR 50.59, "Changes, tests, and experiments," to determine if the proposed changes require prior NRC review and approval. In addition, changes implemented which do not require prior NRC review and approval will be reported to the NRC in accordance with 10 CFR 50.71, "Maintenance of records, making of reports,"

paragraph (e). Based on the above, the proposed changes provide adequate assurance of system operability commensurate with the safety significance since the relocated SRs will continue to be performed, and any changes will be evaluated in accordance with 10 CFR 50.59.

(3) Provide Alternative Testing Criteria for Battery Charger Testing Current SR 3.8.4.3, which is being re-designated as SR 3.8.4.2; and SR 3.8.4.7, which is being re-designated as SR 3.8.4.3; for the 250 VDC and 125 VDC battery chargers, respectively, require specific parameters for battery charger performance testing. This test is intended to confirm the charger design capacity. Alternate acceptance criteria are proposed that would allow an actual in service demonstration that the charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-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. This accomplishes the objective of the existing test and allows for normal in-place demonstration of the charger capability thereby minimizing the time when the charger would be disconnected from the DC bus.

SR 3.8.4.1 requires verification that battery terminal voltage is within limits. This provides assurance that the battery will be restored to its fully charged condition from any discharge that might have occurred due to charger inoperability. The proposed changes relocate the specific terminal voltage values to the licensee controlled program being added as TS Section 5.5.13.

(4) Relocate SR 3.8.4.9 to SR 3.8.6.6 The relocation of SR 3.8.4.9 to SR 3.8.6.6 is editorial. This SR demonstrates the operability of the battery and is therefore proposed to be included in TS Section 3.8.6 related to battery operability. No changes'are proposed to SR 3.8.4.9 other than the relocation.

(5) Replace Battery Specific Gravity Monitoring with Float Current Monitoring Existing SR 3.8.6.1 and SR 3.8.6.2, in conjunction with Table 3.8.6-1, require monitoring of individual cell specific gravity. However, the provision of Table 3.8.6-1, Footnote (c),

allows the use of a battery charging current less than 2 amps when on float charge to be used to satisfy specific gravity requirements.

Page 9 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis New SR 3.8.6.1 requires verification that each battery float current is less than or equal to 2 amps every 7 days. This will replace the existing requirements for specific gravity monitoring. Use of float current to determine the state of charge of the battery is consistent with Section 4.5 of Reference 1. Therefore, deleting the requirement for specific ,gravity measurements will not have a significant impact on safety or the ability to accurately determine the operability of the batteries. Reference 2 provides further detailed generic technical support, which the NRC found acceptable in Reference 3, for this change.

(6) Relocate Limiting Values for Battery Cell Float Voltage, Electrolyte Level, and Electrolyte Temperature to a Licensee Controlled Program The proposed relocate TS 3.8.6 Condition A, SR 3.8.6.1, SR 3.8.6.2, SR 3.8.6.3, and Table 3.8.6-1 to the licensee controlled program described in proposed TS Section 5.5.13, with the exception that battery specific gravity monitoring is being replaced with float current monitoring, as described above.

TS Table 3.8.6-1 contains various levels (i.e., Categories) of limitations on battery cell voltage, electrolyte level, and specific gravity parameters. The Category A and B limits reflect nominal fully charged battery parameter values which provide significant margin above that required for declaration of an operable battery. These Category A and B values represent appropriate monitoring levels and appropriate preventive maintenance levels for long-term battery quality and extended battery life. These limits, however, do not reflect the 10 CFR 50.36, 'Technical specifications," criteria for LCOs of the lowest functional capability or performance levels of equipment required for the safe operation of the facility. It is proposed that these values and the actions associated with restoration be relocated to a licensee controlled program being added as TS Section 5.5.13 that is under the control of 10 CFR 50.59. Required actions associated with Category C limits in TS Table 3.8.6-1 are retained in the TS as discussed in changes numbered (5) and (8).

The proposed changes provide adequate assurance of system operability commensurate with the safety significance since the relocated SRs will continue to be performed, and any changes will be evaluated in accordance with 10 CFR 50.59.

The proposed changes to delete the word "cell" from the title of TS Section 3.8.6 and to revise the wording of the LCO are editorial changes.

(7) Create an Administrative Program Under TS Section 5.5.13 to Reference Actions for Cell Voltage and Electrolyte Level The proposed changes create an administrative program for maintenance, monitoring, and restoration actions for batteries by adding TS Section 5.5.13. This program will be based on the recommendations of Reference 1. This program will contain the elements relocated from the affected TS LCOs. The parameter values will continue to be controlled at their current level, and any corrective actions will be implemented in accordance with the EGC Corrective Action Program. Furthermore, preventive maintenance and monitoring of batteries are in part governed by the regulatory Page 10 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis requirements of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants." The relocation of the elements from TS will not compromise the current levels of battery performance, and allows the TS to focus on parameter value degradations that approach values that may impact battery operability.

The program will require actions to restore battery cells with float voltage less than 2.13 V and actions to equalize and test battery cells that have been discovered with electrolyte level below the minimum established design limits. Testing of these cells will be based on Annex D of Reference 1.

The items proposed to be relocated will be contained in the TRM, which is incorporated by reference in the DNPS Updated Final Safety Analysis Report (UFSAR). Thus, changes to the program will be subject to review under 10 CFR 50.59 to determine if the proposed changes require prior NRC review and approval. In addition, changes will be reported to the NRC in accordance with 10 CFR 50.71(e).

Based on the above, the proposed Battery Monitoring and Maintenance Program will contain the necessary elements to ensure that the batteries continue to be maintained in a highly reliable condition.

(8) Provide Specific Actions with Increased Completion Times for Out-of-limits Conditions for Cell Voltage, Electrolyte Level, and Electrolyte Temperature Specific Required Actions are proposed for parameters that have a unique impact on the battery and its continued operability. The proposed changes to TS Section 3.8.6 provide specific Required Actions and increased Completion Times for out-of-limit conditions for cell voltage, electrolyte level, and electrolyte temperature. These Completion Times recognize the margins available, the minimal impact on battery capacity and the capability to perform its intended function, and the likelihood of effecting restoration in a timely fashion avoiding an unnecessary plant shutdown. In addition, SRs are proposed to verify that the batteries are maintained within the established limitations. The bases for the specific actions and SRs are as follows.

A. Condition A addresses the condition where a battery has one or more cells with a float voltage of less than 2.07 V. With a float voltage of less than 2.07 V, the battery cell must be considered degraded. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , verification of the required battery charger operability is made by monitoring the battery terminal voltage (i.e., performance of SR 3.8.4.1), and determining the overall state of charge by monitoring the battery float current (i.e., performance of SR 3.8.6.1).

These actions assure that there is still sufficient battery capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of one or more cells in one or more batteries being less than 2.07 V, and continued operation is permitted for a limited period up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This is considered a reasonable time to effect restoration of the out-of-limit condition.

B. Condition B represents the condition where a battery is found with float current greater than 2 amps, and indicates that a partial discharge of the battery capacity has occurred. This may be due to a temporary loss of the battery charger, or Page 11 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , verification of the required battery charger operability is made by monitoring the battery terminal voltage (i.e., performance of SR 3.8.4.1). If the terminal voltage is found to be less than the minimum established float voltage, there are two possibilities: the battery charger is inoperable or is operating in the current limit mode. Conditions A and E of LCO 3.8.4 address charger inoperability. If the charger is operating in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , that is an indication that the battery has been substantially discharged and likely cannot perform its required design functions.

The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action B.2). The battery must therefore be declared inoperable.

If the float voltage is found to be satisfactory but there are one or more battery cells with float voltage less than 2.07 V, Condition C is applicable and the battery must be declared inoperable immediately. If float voltage is satisfactory and there are no cells less than 2.07 V, there is assurance that, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the battery will be restored to its fully charged condition (Required Action B.2) from any discharge that might have occurred due to a temporary loss of the battery charger. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus, there is assurance of fully recharging the battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , avoiding a premature unit shutdown with its own attendant risk.

If the condition is due to one or more cells in a low voltage condition but is still greater than 2.07 V, and float voltage is found to be satisfactory, this is not indication of a substantially discharged battery and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is a reasonable time prior to declaring the battery inoperable.

C. Condition C specifies actions to take when a battery with one or more battery cells is found with float voltage less than 2.07 V and float current greater than 2 amps. Discovering a battery with one or more battery cells float voltage less than 2.07 V and float current greater than 2 amps indicates that the battery capacity may not be sufficient to perform the intended functions. The battery must therefore be declared inoperable immediately.

D. Condition D addresses the condition where a battery is found with the electrolyte level in one or more cells less than minimum established design limits. With the electrolyte level in one or more cells above the top of the plates, but below the minimum established design limits, the battery still retains sufficient capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of electrolyte level not met. Within 31 days, the minimum established design limits for electrolyte level must be restored.

Page 12 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis With electrolyte level below the top of the plates, there is a potential for dryout and plate degradation. Required Actions D.1 and D.2 address this potential as well as provisions in TS Section 5.5.13. These actions are only applicable if electrolyte level was below the top of the plates. Within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , level is required to be restored to above the top of the plates. The Required Action D.2 requirement to verify that there is no leakage by visual inspection and the Specification 5.5.13, Item b, to initiate action to equalize and test in accordance with manufacturers recommendation are taken from Annex D of Reference 1.

They are performed following the restoration of the electrolyte level to above the top qf the plates. Based on the results of the manufacturers recommended testing, the battery may have to be declared inoperable and the affected cell(s) replaced.

E. Condition E addresses the condition where a battery is found with a pilot cell temperature less than the minimum established design limits. A low electrolyte temperature limits the current and power available from the battery. Since the battery is sized with margin, while battery capacity is degraded, sufficient capacity exists to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of the pilot cell temperature not met, and the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time provides a reasonable time to restore the temperature within established limits.

F. Condition F addresses the condition with one or more batteries in redundant divisions with battery parameters not within limits. Given this condition, there is not sufficient assurance that battery capacity has not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved, this potentially could result in a total loss of function on multiple systems that rely upon the batteries.

The longer completion times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one division within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

G. Condition G specifies actions to take when the Required Action and associated Completion Time of Condition A, B. D, E, or F are not met. When any battery parameter is outside the allowances of the Required Actions for Condition A, B, D, E, or F, sufficient capacity to supply the maximum expected load requirement is not ensured and the corresponding battery must be declared inoperable. The battery must therefore be declared inoperable immediately.

H. SR 3.8.6.1 requires verification that each battery float current is less than or equal to 2 amps. Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state. The float current requirements are based on the float current indicative of a charged battery. Use of float current to determine the state of charge of the battery and the 7-day Frequency is consistent with Reference 1.

Page 13 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis I. SR 3.8.6.2 and SR 3.8.6.5 verify that the cell voltage of either pilot cells or each connected cell are equal to or greater than the short-term absolute minimum voltage, representing the point where battery operability is in question. Optimal long-term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to 260.4 V at the 250 VDC battery terminals and 125.9 V at the 125 VDC battery terminals, or 2.17 volts per cell (Vpc). This provides adequate over-potential, which limits the formation of lead sulfate and self-discharge, which could eventually render the battery inoperable. Float voltage in this range or less, but greater than 2.07 Vpc, are addressed in new TS Section 5.5.13. The Frequency for cell voltage verification every 31 days for pilot cells and 92 days for each connected cell is consistent with Reference 1.

J. SR 3.8.6.3 requires verification that each battery connected cell electrolyte level is greater than or equal to minimum established design limits. The limit specified for electrolyte level ensures that the plates suffer no physical damage and that the cell maintains adequate electron transfer capability. The Frequency of 31 days is consistent with Reference 1.

K. SR 3.8.6.4 requires verification that each battery pilot cell temperature is greater than or equal to the minimum established design limit (i.e., 65 0F). Pilot cell electrolyte temperature is maintained above this temperature to assure the battery can provide the required current and voltage to meet design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. The Frequency of 31 days is consistent with Reference 1.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

The proposed changes are to Technical Specifications (TS) Section 3.8.4, "DC Sources -

Operating," Section 3.8.5, "DC Sources - Shutdown," Section 3.8.6, "Battery Cell Parameters,"

and Section 5.5, "Programs and Manuals." The proposed changes request new actions for an inoperable battery charger and alternate battery charger testing criteria for limiting condition for operation (LCO) 3.8.4 and LCO 3.8.5. The proposed changes also include the relocation of a Page 14 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis number of surveillance requirements (SRs) in TS Section 3.8.4, that perform preventive maintenance on the safety related batteries, to a licensee controlled program. It is proposed that TS Table 3.8.6-1, "Battery Cell Parameter Requirements," be relocated to a licensee controlled program, and specific Required Actions with associated Completion Times for out-of-limits conditions for battery cell voltage, electrolyte level, and electrolyte temperature be added to TS Section 3.8.6. In addition, specific SRs are being proposed for verification of these parameters.

A new program is being proposed for the maintenance and monitoring of station batteries based on the recommendations of Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications." This program will be described in new TS Section 5.5.13, "Battery Monitoring and Maintenance Program." The items proposed to be relocated will be contained within this new program.

Exelon Generation Company, LLC (EGC) has evaluated the proposed changes to the TS for DNPS, Units 2 and 3, using the criteria in 10 CFR 50.92, and has determined that the proposed changes do not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

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

Response: No The proposed changes restructure the Technical Specifications (TS) for the direct current (DC) electrical power system. The proposed changes add actions to specifically address battery charger inoperability. This change will rely upon the capability of providing the battery charger function by an alternate means (e.g., a 125 volts direct current (VDC) portable battery charger or a 250 VDC portable battery charger) to justify the proposed Completion Times. The DC electrical power system, including associated battery chargers, is not an initiator to any accident sequence analyzed in the Updated Final Safety Analysis Report (UFSAR). Operation in accordance with the proposed TS ensures that the DC electrical power system is capable of performing its function as described in the UFSAR. Therefore, the mitigative functions supported by the DC electrical power system will continue to provide the protection assumed by the analysis.

The relocation of preventive maintenance surveillances, and certain operating limits and actions, to a newly-created licensee controlled Battery Monitoring and Maintenance Program will not challenge the ability of the DC electrical power system to perform its design function. Appropriate monitoring and maintenance, consistent with industry standards, will continue to be performed. In addition, the DC electrical power system is within the scope of 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," which will ensure the control of maintenance activities associated with the DC electrical power system.

The integrity of fission product barriers, plant configuration, and operating procedures as described in the UFSAR will not be affected by the proposed changes. Therefore, the Page 15 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis consequences of previously analyzed accidents will not increase by implementing these changes.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed changes involve restructuring the TS for the DC electrical power system.

This change will rely upon the capability of providing the battery charger function by an alternate means (e.g., a swing charger or a portable battery charger ) to justify the proposed Completion Times. The DC electrical power system, including associated battery chargers, is not an initiator to any accident sequence analyzed in the UFSAR.

Rather, the DC electrical power system is used to supply equipment used to mitigate an accident.

The 125 VDC portable battery charger will be utilized as a common spare to feed the Division I or Division 2 125 VDC bus of Unit 2 or Unit 3. For the 250 VDC system, a full capacity swing charger is available for use between the units, and can be aligned to any one of the 250 VDC batteries. In addition, the 250 VDC portable battery charger can be utilized as a common spare to feed the 250 VDC safety related batteries of Unit 2 or Unit

3. This portable charger is identical to the existing chargers and is non-safety related.

The output of the portable charger will be capable of being connected to any one of the Class I E DC buses for Division I or Division 2 of Unit 2 or Unit 3. Allowing the use of a portable spare and swing battery chargers will increase the reliability of the DC electrical power system. The mitigative functions supported by the DC electrical power system will continue to provide the protection assumed by the safety analyses described in the UFSAR. Therefore, there are no new types of failures that could be created by a failure of the portable battery charger. As such, no new or different kind of accident or transient is expected by these changes.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change Involve a significant reduction in a margin of safety?

Response: No The margin of safety is established through equipment design, operating parameters, and the setpoints at which automatic actions are initiated. The proposed changes will not adversely affect operation of plant equipment. These changes will not result in a change to the setpoints at which protective actions are initiated. Sufficient DC capacity to support operation of mitigation equipment is ensured. The changes associated with the new Battery Maintenance and Monitoring Program will ensure that the station batteries are maintained in a highly reliable manner. The use of a portable battery charger will increase the reliability of the DC system during periods of normal battery Page 16 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis charger inoperability. The equipment fed by the DC electrical sources will continue to provide adequate power to safety related loads in accordance with analysis assumptions.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.,,,

Based upon the above, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c). Accordingly, a finding of no significant hazards consideration is justified.

5.2 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 provides the regulatory requirements for the content required in a licensee's TS.

Criterion 3 of 10 CFR 50.36(c)(2)(ii) requires a limiting condition for operation to be established for a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The DC sources satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

The proposed changes:

(a) do not alter the design or function of any DC electrical power system; (b) do not result in any change in the qualifications of any component; and (c) do not result in the reclassification of any component's status in the areas of shared, safety related, independent, redundant, or physical or electrical separation.

Portions of the proposed license amendment request result in relocating certain surveillances, surveillance acceptance criteria, and Required Actions that do not meet the criteria of 10 CFR 50.36(c)(2)(ii). Existing TS Table 3.8.6-1 limits reflect nominal fully charged battery parameter values, with margin above that required for declaration of an operable battery. These limits represent appropriate monitoring levels and appropriate preventive maintenance criteria for long-term battery quality and extended battery life. As such, they do not reflect the 10 CFR 50.36 criteria for LCOs of the lowest functional capability or performance levels of equipment required for safe operation of the facility. The proposed changes relocate these values and actions associated with restoration to a licensee controlled program under the control of 10 CFR 50.59.

The proposed items to be relocated to a licensee controlled program will have changes subject to review under 10 CFR 50.59 to determine if the proposed changes will require prior NRC review and approval, and will require reporting of all changes to the NRC in accordance with 10 CFR 50.71(e). This provides sufficient control of the requirements to assure the batteries are maintained in a highly reliable condition.

The increased restoration times and revised criteria for monitoring the capacity of the batteries and battery chargers to perform their intended functions, are reasonable and consistent with approved standards, guidance, and regulations. The revised testing criteria ensure that full functionality is maintained and that Criterion 3 of 10 CFR 50.36(c)(2)(ii) is met.

Page 17 of 18

ATTACHMENT I Description of Proposed Changes, Technical Analysis, and Regulatory Analysis In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that 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.

The NRC has granted similar license amendments for Clinton Power Station, Unit 1, in Reference 5 and Limerick Generating Station, Units 1 and 2, in Reference 6.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment 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, "Standards for Protection Against Radiation," or would change an inspection or surveillance requirement. However, the proposed amendment 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 amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1. Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," dated January 24, 1995

2. Technical Specifications Task Force (TSTF) Traveler TSTF-360, Revision 1, "DC Electrical Rewrite"

3. Letter from W. D. Becker (U. S. NRC) to A. R. Pietrangelo (Nuclear Energy Institute),

dated December 18, 2000

4. Letter from K. R. Jury (Exelon Generation Company, LLC) to U. S. NRC, "Request for License Amendments Related to Application of Alternative Source Term," dated October 10, 2002

5. Letter from J. B. Hopkins (U. S. NRC) to 0. D. Kingsley (Exelon Generation Company, LLC), "Clinton Power Station, Unit I - Issuance of Amendment (TAC No. MB3071),"

dated February 15, 2002

6. Letter from S. P. Wall (U. S. NRC) to J. L. Skolds (Exelon Generation Company, LLC),

"Limerick Generating Station, Units 1 and 2 - Issuance of Amendment Re: DC Electrical Power Sources Based on TSTF-360 (TAC Nos. MB5257 and MB5258)," dated January 29, 2003 Page 18 of 18

ATTACHMENT 2 Markup of Technical Specification Pages DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 Request for Amendment to Technical Specifications Associated With Direct Current Electrical Power REVISED TECHNICAL SPECIFICATIONS PAGES iii 3.8.4-1 3.8.4-2 3.8.4-3 3.8.4-4 3.8.4-5 3.8.4-6 3.8.4-7 3.8.5-2 3.8.6-1 3.8.6-2 3.8.6-3 3.8.6-4 5.5-12

TABLE OF CONTENTS (continued) 3.7 PLANT SYSTEMS 3.7.1 Containment Cooling Service Water (CCSW) System . . . . 3.7.1-1 3.7.2 Diesel Generator Cooling Water (DGCW) System . . . . . 3.7.2-1 3.7.3 Ultimate Heat Sink (UHS) . . . . . . . . . . . . . . . 3.7.3-1 3.7.4 Control Room Emergency Ventilation (CREV) System . . . 3.7.4-1 3.7.5 Control Room Emergency Ventilation Air Conditioning (AC) System . . . . . . . . . . . . . . 3.7.5-1 3.7.6 Main Condenser Offgas . . . . . . . . . . . . . . . . . 3.7.6-1 3.7.7 Main Turbine Bypass System . . . . . . . . . . . . . . 3.7.7-1 3.7.8 Spent Fuel Storage Pool Water Level . . . . . . . . . . 3.7.8-1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources -Operating . . . . . . . . . . . . . . . . . 3.8.1-1 3.8.2 AC Sources -Shutdown . . . . . . . . . . . . . . . . . 3.8.2-1 3.8.3 Diesel Fuel Oil and Starting Air . . . . . . . . . . . 3.8.3-1 3.8.4 DC Sources -Operating .. .3.8.4-1 3.8.5 DC Sources-Shutdown .. .3.8.5-1 3.8.6 BatterycParameters . . . . . . .. . . . . . . . 3.8.6-1 3.8.7 Distribution Systems -Operating . . . . . . . . . . . . 3.8.7-1 3.8.8 Distribution Systems -Shutdown . . . . . . . . . . . . 3.8.8-1 3.9 REFUELING OPERATIONS 3.9.1 Refueling Equipment Interlocks . . . . . . . . . . . . 3.9.1-1 3.9.2 Refuel Position One-Rod-Out Interlock . . . . . . . . . 3.9.2-1 3.9.3 Control Rod Position . . . . . . . . . . . . . . . . . 3.9.3-1 3.9.4 Control Rod Position Indication . . . . . . . . . . . . 3.9.4-1 3.9.5 Control Rod OPERABILITY-Refueling . . . . . . . . . . 3.9.5-1 3.9.6 Reactor Pressure Vessel (RPV) Water Level - Irradiated Fuel . . . . . . . i . . . . . . . 3.9.6-1 3.9.7 Reactor Pressure Vessel (RPV) Water Level -New Fuel or Control Rods . . . . . . . . . . . . . . . . 3.9.7-1 3.9.8 Shutdown Cooling (SDC) -High Water Level . . . . . . . 3.9.8-1 3.9.9 Shutdown Cooling (SDC) -Low Water Level . . . . . . . . 3.9.9-1 3.10 SPECIAL OPERATIONS 3.10.1 Reactor Mode Switch Interlock Testing . . . . . . . . . 3.10.1-1 3.10.2 Single Control Rod Withdrawal-Hot Shutdown . . . . . . 3.10.2-1 3.10.3 Single Control Rod Withdrawal -Cold Shutdown . . . . . 3.10.3-1 3.10.4 Single Control Rod Drive (CRD)

Removal -Refueling .. .3.10.4-1 3.10.5 Multiple Control Rod Withdrawal- Refueling . . . . . . 3.10.5-1 3.10.6 Control Rod Testing -Operating . . . . . . . . . . . . 3.10.6-1 3.10.7 SHUTDOWN MARGIN (SDM) Test -Refueling . . . . . . . . . 3.10.7-1 4.0 DESIGN FEATURES 4.1 Site Location . . . . . . . . . . . . . . . . . . . . . 4.0-1 4.2 Reactor Core. . . ...... 4.0-1 4.3 Fuel Storage . . . . . . . . . . . . . . . . . . . . . 4.0-2 (continued) i . .

Dresden 2 and 3 Amendment No. 185/180

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. Two 250 VDC electrical power subsystems;

b. Division 1 and Division 2 125 VDC electrical power subsystems; and

c. The opposite unit's Division 2 125 VDC electrical power subsystem capable of supporting equipment required to be OPERABLE by LCO 3.6.4.3. "Standby Gas Treatment (SGT)

System." LCO 3.7.4, "Control Room Emergency Ventilation (CREV) System" (Unit 3 only), LCO 3.7.5. 'Control Room Emergency Ventilation Air Conditioning (AC) System" (Unit 3 only), and LCO 3.8.1, "AC Sources-Operating."

APPLICABILITY: MODES 1. 2, and 3.

ACTIONS CONDITIONI REQUIRED ACTION COMPLETION TIME One 250 VDC battery Restore 250 VDC Prior to inoperable as a result battery to OPERABLE exceeding 7 of maintenance or status. cumulative days testing. per operating cycle of battery inoperability.

on a per battery basis, as a result of maintenance or testing I 4.

(continued)

Dresden 2 and 3 3.8 .4-1 Amendment No. 185/180

DRESDEN UNITS 2 AND 3 INSERTS INSERT: 3.8.4 ACTION A ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required 250 VDC A.1 Restore 250 VDC battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months battery charger terminal voltage to greater inoperable. than or equal to the minimum established float voltage.

AND A.2 Verify 250 VDC battery float Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months current is < 2 amps.

AND A.3 Restore the required 7 days 250 VDC battery charger to OPERABLE status.

DC Sources - Operating 3.8.4 ACTIONS CONDITION I REQUIRED ACTION ICOMPLETION TIME One 250 VDC battery 1 Restore 250 VDC 7 days inoperable, due to the battery to OPERABLE need to replace the status.

battery, as determined by maintenance or testing.

4. 1.

One 250 VDC electrical 1 Restore 250 VDC 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power subsystem electrical power inoperable for reasons subsystem to OPERABLE other than Conditions status.

a a ft

NOTE--------- .1 Place ass oci ated 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Only applicable if the OPERABLE alternate opposite unit is in 125 VDC electrical FU;MODE 1. 2, or 3. power sub!system in

-- -- -- - -- -- -- - service.

Division 1 or 2 AND 125 VDC battery inoperable as a result .2 Restore D ivision 1 or Prior to of maintenance or 2 125 VOC battery to exceeding 7 testing. OPERABLE status. cumulative days per operating cycle on a per battery basis (continued)

\~AgP 3A iTA)

Dresden 2 and 3 3.8.4- 2 Amendment No. 185/180

DRESDEN UNITS 2 AND 3 INSERTS INSERT: 3.8.4 ACTION E ACTIONS CONDITION REQUIRED ACTION f COMPLETION TIME E. One required Division 1 E.1 Restore 125 VDC battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or 2 125 VDC battery terminal voltage to greater charger inoperable. than or equal to the minimum established float voltage.

AND E.2 Verify 125 VDC battery float Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months current is

2 amps.

AND E.3 Restore the required 7 days Division I or 2 125 VDC battery charger to OPERABLE status.

I _____________________________________________________________________________________-.L

DC Sources -Operating 3.8.4 ACTIONS CONDITION E REQUIRED ACTION COMPLETION TIME

NOTE--------- t.1 Place associated 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Only applicable if the OPERABLE alternate opposite unit is in 125 VOC electrical MODE 1. 2, or 3. power subsystem in service.

Division I or 2 ANDg 125 VDC battery inoperable, due to the .2 Restore Division 1 or 7 days need to replace the 2 125 VDC battery to battery, as determined OPERABLE status.

by maintenance or testing.

I.

Division 1 or 2 .1 Restore Division 1 or 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 125 VDC electrical 2 125 VDC electrical power subsystem power subsystem to inoperable for resj 1 OPERABLE status.

other than nd ti

.2 -------- NOTE---------

Only applicable if the opposite unit is not in MODE 1, 2. or 3.

Place associated 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OPERABLE alternate 125 VDC electrical power subsystem in service.

(continued)

Dresden 2 and 3 3.8.4-3 Amendment No. 185/180

DC Sources -Operating 3.8.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Opposite unit Division 1 Restore opposite unit 7 days 2 125 VDC electrical Division 2 125 VDC power subsystem electrical power inoperable. subsystem to OPERABLE Required Action and ( 1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AND Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Dresden 2 and 3 3.8.4 -4 Amendment No. 185/180

(7:~~~~~~~~~~~~~~~~1 DC Sources-Operating 3.8.4 Me f e)rd);Yure SURVEILLANCE REQUIREMENTS' - -

SURVEILLANCE FREQUENCY SR 3.8.4.1 V attery terminal voltag( 7 days

a. 6D`Cf or each 250 VDC subsystem;

b. 6 1V9 V for each 125 VDC subsystem; and

c. ----------- NOTE-----------------

Only required to be met when the Unit 2 alternate battery is required to be OPERABLE.

y._VDCfor Unit 2 alternate I Rfcattery.

.8.42 / erify no visible co ion at battery terminals and conne ors.

DR Verify batte connection resistance es Ah~sAed -f/oa l 1.SE-4 o for inter-cell connec on! L.fhlA 1.

S.5E-4/ hm for terminal conne

< ons.

SR 3.8.4 4 Verify each requ ger supplies 2 200 amps at C p or 2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for the 250 V su systems.

e swbattery n cells, eli plates, and C2_4'"'t Fhs s show no viisual ndication of ph ical wage or abnornial eterioration tha could e grade battery p formance.

(continued)

Dresden 2 and 3 3.8.4-S5 Amendment No. 193/180

DRESDEN UNITS 2 AND 3 INSERTS INSERT: SR 3.8.4.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.2 ... ...

OR Verify each 250 VDC battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-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.

DC Sources -Operating 3.8.4 SURVEILLANCE REOUIREMENTS SURVEILLANCE FREQUENCY

( SR 3.8.4.5 Re ye visible corrosion and verif battery c 1 to cell and terminal conne ions are oated with anti-corrosion a rial.

SR 3. .. Verify battery conne on resistance is

< 1.5E-4 ohm for i er-cell connections

< 1.5E-4 ohm f erminal connections.

SR 3.8.4. Verify each required 125 ba ery charger 24 months supplies > 200 amps at > 1 0 or

> 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for the 125 subsystems.

I-SR 3B8.4.v ------------------- NOTE--------------------

The modified performance discharge test in SR 3.8Bg A~may be performed in lieu of2 (0-(loti10 es' ~SR 3.8.4. 5 rovided the modified performance discharge es completely envelopes the service test.

Verify battery capacity is adequate to 24 months supply. and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.

I (continued)

ZAISEI? SR~3. 6.qi.3 Dresden 2 and 3 3.8.4-6 Amendment No. 185/180

DRESDEN UNITS 2 AND 3 INSERTS INSERT: SR 3.8.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.3 ... ...

OR Verify each 125 VDC battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-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.

DC Sources - Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3g.4.9 Verify bat y capacity is > 80% o h manufac er's rating when subj ed to a perfo ance discharge test o a modified AND p ormance discharge tes

/ ~~~~12month<e battry hows OR>< . degr~~~adation or as reached 85%

hof expected life with capacity 0 / < loot of

> ~~~~manufacturer,

\ ~~~~rating /

\ .t54 monthswhen

\ / ~~battery has

\ / ~reached 85X of, t78\ \ / ~~~~~~~~~~~~~the expected/ l

@ Y ~~~~~~~~~~~~~~~~life with/

\ ~~capacity 10%

\ of /of Dresden 2 and 3 3.8.4- 7 Amendment No. 185/180

DC Sources - Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

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

SURVEILLANCE REOUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 ------------------- NOTE--------------------

The following SRs are not required to be performed for the 250 VDC 1.t rical power subsystem SR 3.8.4.g t3.'.4.8 and SR 3.8.4.@f For DC electrical power subsystems required In accordance to be OPERABLE the following SRs are with applicable applicable: SRs SR 3.8.4.1, S3.4.2, SR 3.8.4.3,_ R SR 3.8 4.4 ~3845 ~3846-z Dresden 2 and 3 3.8.5- 2 Amendment No. 185/180

Battery G Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS

n ,I - -- _.o n_ A__

J.0.0Od~~aieryUC rdfMrdme lterf-b LCO 3.8.6 Battery ')parameters for the 125 and 250 station 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

.1 I

_ /-1-1 A. One o mre batteries A.1 / YVerify pilot cell(s) wi one or more electrolyte level an tery cell float voltage mee

/prameters not withi/ Table 3.8.6-1/

/ Table 3.8.6-1 Ca egry Category C its.

Aor 8 limits./

AND/

A.2 rify battery cell parameters meet

/ T~able 3.8.6-1 Category C limits.

I AND A.3 Res e battery cell ameters to Table 3.8.6-1 Category A and B limits.

(continued)

Dresden 2 and 3 3.8.6 -1 Amendment No. 185/180

DRESDEN UNITS 2 AND 3 INSERTS INSERT: 3.8.6 ACTIONS ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One 250 VDC or A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 125 VDC battery with one or more battery AND cells float voltage

< 2.07 V. 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 AND A.3 Restore affected cell voltage to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

Ž2.07 V.

B. One 250 VDC or 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 125 VDC battery with float current AND

> 2 amps.

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

<2 amps.

C. One 250 VDC or C.1 Declare associated battery Immediately 125 VDC battery with inoperable.

one or more battery cells float voltage

< 2.07 V and float current > 2 amps.

DRESDEN UNITS 2 AND 3 INSERTS INSERT: 3.8.6 ACTIONS (cont)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

--- NOTES -A--------NOTE-----

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

D. One 250 VDC or D.I Restore electrolyte level to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 125 VDC battery with above top of plates.

one or more cells electrolyte level less AND than minimum established design D.2 Verify no evidence of leakage. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months limits.

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

E. One 250 VDC or E.1 Restore battery pilot cell 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 125 VDC battery with temperature to greater than or pilot cell electrolyte equal to minimum established temperature less than design limits.

minimum established design limits.

F. One or more batteries F.1 Restore battery parameters for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in redundant divisions batteries in one division to with battery within limits.

parameters not within limits.

Battery Parameters 3.8.6 ACTIONS CONDITION I REOUIRED ACTION COMPLETION TIME 6

Qrs Required Action and 61 Declare associated Immediately associated Completion battery inoperable.

Time of Condition A not met.

One or m7(e batteries with 0 rage eletroyte befipraure of the repesetative cele not within limits/

OR/

One-or m bteries a

with of or more batt Mycell/

pa meters not withn Catle 3.8.6-C i Dresden 2 and 3 3.8.6-2 Amendment No. 185/180

Battery O Parameters 3.8.6 Dresden 2 and 3 3.8.6- 3 Amendment No. 185/180

DRESDEN UNITS 2 AND 3 INSERTS INSERT: 3.8.6 SRs 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. 7 days SR 3.8.6.2 Verify each battery pilot cell voltage is Ž 2.07 V. 31 days SR 3.8.6.3 Verify each battery connected cell electrolyte level is 31 days greater than or equal to minimum established design limits.

SR 3.8.6.4 Verify each battery pilot cell temperature is greater 31 days than or equal to minimum established design limits.

SR 3.8.6.5 Verify each battery connected cell voltage is Ž 2.07 V. 92 days SR 3.8.6.6 Verify battery capacity is > 80% of the manufacturers 60 months rating when subjected to a performance discharge test or a modified performance discharge test. AND 12 months when battery shows degradation or has reached 85% of expected life with capacity < 100% of manufacturers rating AND 24 months when battery has reached 85% of the expected life with capacity

> 100% of manufacturers rating

Battery Cell Parameters 3.8.6 Table 3.8.6-1 (page 1 of 1)

Battery Cell Parameter Requirements /

r ~~~~~~~~~~~~~~~~~~~~~~~I -

CATEGORY A: CATEGORY B: CAT ORY C:

LIMITS FOR EACH LIMITS FOR EACH LIM S FOR EACH DESIGNATED PILOT CONNECTED CELL C NECTED CELL PARAMETER CELL Electrolyte irum level > Minimum level Above top of Level stion mark, and indication mark. plates, and not n s above and < M inch ab ve overflowing ur Revel maximum level indication mk&)

Float Voltac > 2.07 V

_~~~~~~~~~~~~~~4 Specific > 1.200 1.195 Not more than Gravi tycb""c) 0.020 below average of all connected cells of all

{d cells AND Average of all connected cells

> 1.195 S

(a) It is acceptable f the electrolyte level to temporariX increase above the specified maxmum level during and, for a limited time, following equalizing charfs provided it is not overflowing.

(b) Corrected for lectrolyte temperature and level.

(c) A battery arging current of < 2 amps when on float charge is acceptabl for meeting specific gravity limits following a battery recharg for a maximum of 7 days. When charging current is used to satisf specific gravity requirements, specific gravity of each conn cted cell shall be measured prior to expiration of the 7 day al wance.

Dresden 2 and 3 3.8.6 -4 Amendment No. 185/180

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakage Rate Testing Program (continued)

c. The maximum allowable primary containment leakage rate, Lo, at Pa, is 1.6X of primary containment air weight per day.

d. Leakage rate acceptance criteria are:

1. Primary containment overall leakage rate acceptance criterion is < 1.0 Lo. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 L, for the combined Type B and Type C tests, and I 0.75 L. for Type A tests.

2. Air lock testing acceptance criteria is the overall air lock leakage rate is < 0.05 L, when tested at > P,.

e. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

Dresden 2 and 3 5.5-12 Amendment No. 185/180

DRESDEN UNITS 2 AND 3 INSERTS INSERT: 5.5.13 Program 5.5.13 Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance, based on the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," including the following:

a. Actions to restore battery cells with float voltage < 2.13 V, and

b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

ATTACHMENT 3 Markup of Technical Specification Bases Pages DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 Request for Amendment to Technical Specifications Associated With Direct Current Electrical Power REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 3.8.4-3 B 3.8.4-5 B 3.8.4-6 B 3.8.4-7 B 3.8.4-8 B 3.8.4-9 B 3.8.4-10 B 3.8.4-11 B 3.8.4-12 B 3.8.4-13 B 3.8.4-14 B 3.8.4-15 B 3.8.4-16 B 3.8.4-17 B 3.8.5-4 B 3.8.6-1 B 3.8.6-2 B 3.8.6-3 B 3.8.6-4 B 3.8.6-5 B 3.8.6-6 B 3.8.6-7

DC Sources - Operating B 3.8.4 BASES BACKGROUND (Ea( battery has equate storage capa *ty to carry the (continued) Normal loads pI all loads required or safe shutdown o Kone unit and o erational loads req red to limit the consequences f a design basis e nt on the other u for a period of hours (Ref. 4).

Each DC battery is separately housed in a ventilated room apart from its.-c..a-rger and distribution centers. -'ach subsystem is -located in an area separated physically and electrically from the other subsystems to ensure that a

.g 3.8.-1, single failure inone subsystem does not cause a failure in a redundant subsystem. There is no sharing between redundant Class 1E subsystems such as batteries, battery chargers, or distribution panels.

The batteries for DC electrical power subsystems are sized

...L.. v 3S ET to produce required capacity at 80% of nameplate rating.

.S 3.s.6'2} corresponding to warranted capacity at end of life cycles and the 100% design demand. The minimum design voltage

\ limit is 105/210 V. A->->

vexcesse Each DC electrical power subsystem batt y c arger has ample A/S(,E'7~ power output capacity for the steady s ate operation of connected loads required during norm operation, while at

.d 38-s p yethe same time maintaining its batter bank fully charged.

Each battery charger has sufficient capacity to restore the battery from the design minimum charge to its fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months while supplying normal steady state loads (Ref. 4).

APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR. Chapter 6 (Ref. 5) and Chapter 15 (Ref. 6), assume that Engineered Safety Feature (ESF) systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This includes maintaining DC sources OPERABLE during accident conditions in the event of:

(continued)

Dresden 2 and 3 B 3.8.4-3 Revision 0

DRESDEN UNITS 2 AND 3 INSERTS INSERT: B 3.8.4-1 Each battery has adequate storage capacity to meet the duty cycle(s) discussed in UFSAR Chapter 8 (Ref. 4). The battery is designed with additional capacity above that required by the design duty cycle to allow for temperature variations and other factors.

4 INSERT: B 3.8.4-2 The battery cells are flooded lead acid construction with a nominal specific gravity of 1.215.

This specific gravity corresponds to an open circuit battery voltage of approximately 120 V for a 58 cell battery (i.e., cell voltage of 2.07 volts per cell (Vpc)). The open circuit voltage is the voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage 2 2.07 Vpc, the battery cell will maintain its capacity for 30 days without further charging per manufacturer's instructions. Optimal long term performance however, is obtained by maintaining a float voltage of 2.17 to 2.25 Vpc. This provides adequate over-potential, which limits the formation of lead sulfate and self-discharge. The nominal float voltage of 2.22 Vpc corresponds to a total float voltage output of 128.8 V for a 58 cell battery as discussed in UFSAR Chapter 8 (Ref. 4).

INSERT: B 3.8.4-3 The battery charger is normally in the float-charge mode. Float-charge is the condition in which the charger is supplying the connected loads and the battery cells are receiving adequate current to optimally charge the battery. This assures the internal losses of a battery are overcome and the battery is maintained in a fully charged state.

When desired, the charger can be placed in the equalize mode. The equalize mode is at a higher voltage than the float mode and charging current is correspondingly higher. The battery charger is operated in the equalize mode after a battery discharge or for routine maintenance.

Following a battery discharge, the battery recharge characteristic accepts current at the current limit of the battery charger (if the discharge was significant, e.g., following a battery service test) until the battery terminal voltage approaches the charger voltage setpoint. Charging current then reduces exponentially during the remainder of the recharge cycle. Lead-calcium batteries have recharge efficiencies of greater than 95%, so once at least 105% of the ampere-hours discharged have been returned, the battery capacity would be restored to the same condition as it was prior to the discharge. This can be monitored by direct observation of the exponentially decaying charging current or by evaluating the amp-hours discharged from the battery and amp-hours returned to the battery.

DC Sources - Operating B 3.8.4

-/DsER T

2) ~BASES S3S- ~TOJ APPLICABILITY b. Adequate core cooling is provided, and containment (continued) integrity and other vital functions are maintained in the event of a postulated DBA.

The DC electrical power requirements for MODES 4 and 5 and other conditions in which the DC electrical power sources are required are addressed in LCO 3.8.5, *DC Sources -

Shutdowi.v-ACTIONS

@ Condio s ,250 VDC battery inoperable as a result of maintenance or testing, represents one subsystem with a loss of ability to completely respond to an event. It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of 250 VDC power to the affected subsystem. Operation in this Condition is needed during the operating cycle to r reas, ensure the battery is maintained OPERABLE.

0/her 7'A4r Ifone of the 250 VDC batteries is inoperable, the remaining 250 VDC electrical power subsystem has the capacity to support a safe shutdown of one unit and to mitigate an accident condition in the other unit. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation is limited.

sRequired Actio J1 limits the time the unit can operate in this condition to 7 cumulative days per operating cycle, for any one battery. Therefore, each 250 VDC battery can be removed from service to perform maintenance or testing as long as the cumulative time is not exceeded for that battery.

The 7 day cumulative Completion Time is based on the capacity and capability of the remaining DC sources to supply the required loads.

(continued)

Dresden 2 and 3 B 3.8.4-5 Revision 0

DRESDEN UNITS 2 AND 3 INSERTS INSERT: B 3.8.4 ACTION A ACTIONS A.1, A.2. and A.3 Condition A represents one required 250 VDC battery charger inoperable (e.g.,

the voltage limit of SR 3.8.4.1 is not maintained as both the unit and swing chargers are inoperable). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability. A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharging cycle.

The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus, there is good assurance of fully recharging the battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , avoiding a premature shutdown with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the charger is not operating in the current-limiting mode, a faulty charger is indicated. Current-limiting mode is the condition in which the maximum charger output is limited to ensure that the AC current drawn by the charger is within design limits. The charger output in current-limiting mode is greater than or equal to 220 amps. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action A.2).

DRESDEN UNITS 2 AND 3 INSERTS INSERT: B 3.8.4 ACTION A (cont.)

Required Action A.2 requires that the battery float current be verified as less than or equal to 2 amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it has now been fully recharged. If at the expiration of the initial 12-hour period the battery float current is not less than or equal to 2 amps, this indicates there may be additional battery problems and the battery must be declared inoperable.

Required Action A.3 limits the restoration time for the inoperable battery charger to 7 days. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The 7-day completion time reflects a reasonable time to effect restoration of the qualified battery charger to operable status.

DC Sources-Operating B 3.8.4 BASES ACTIONS (continued)

Condition 250 VDC battery inoperable due to the need to replace the battery as determined by maintenance or testing, represents one subsystem with a loss of ability to completely respond to an event. It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of 250 VOC power to the affected subsystem. Operation in this Condition may be needed during the operating cycle to completely replace a battery to maintain the 250 VDC subsystem OPERABLE for the remainder of the cycle.

If one of the 250 VDC batteries is inoperable, the remaining 250 VDC electrical power subsystem has the capacity to support a safe shutdown of one unit and to mitigate an accident condition in the other unit. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accid nt, continued power operation is limited.

Required Actia 6 .1 limits the time the unit can operate in this condition to 7 days. Therefore, each 250 VDC battery can be removed from service to completely replace a battery.

The 7 day Completion Time to restore the 250 VDC battery is based on the capacity and capability of the remaining DC sources to supply the required loads.

With one 250 VDC electrical owersubsystem 6 no erable for reasons other than Condition Conditi ) r represents I one 250 VDC electrical power subsystem with a Ross of ability to completely respond to an event and a potential loss of ability to remain energized during normal operation It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of 250 VDC power to the affected buses. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is consistent with the allowed time for an inoperable DC Distribution System subsystem.

If one 250 VDC electrical Dower subsystem is ioperable (e.g. inettery, o in erable required ba;Fer harger ), or i operable r uire attery charger and Dresden 2 and 3 B 3.8.4-6 evision 6

DC Sources -Operating B 3.8.4 BASES ACTIONS (continued) k:!:-,/ associated inoperable battery), the remaining DC electrical power subsystems have the capacity to support a safe shutdown of one unit and to mitigate an accident condition.

Since a subsequent worst case single failure could. however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 7)

IC"-

and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem 9COAq and, if the DC electrical power subsystem is not restored to lACE/ONI I OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

1fandA@.2 n Division I or 2 125 VDC battery inoperable as a result of maintenance or testing, represents one division with a loss of ability to completely respond to an event.

It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected division.

Operation in this Condition is needed during the operating cycle to enure the battery is maintained OPERABLE.

nditio is modified by a Note indicating that the Condition is only applicable when the opposite unit is in MODE 1, 2, or 3.

If one of the 125 VDC batteries is inoperable, the remaining 125 VDC electrical power subsystem has the capacity to support a safe shutdown of one unit and to mitigate an accident condition in the other unit. Since a subsequent worst case single failure could, however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accid nt, continued power operation is limited.

Required Action 2 limits the time the unit can operate in this condition to 7 cumulative days per operating cycle, for any one battery. Therefore, each 125 VDC battery can be removed from service to perform maintenance or testing as long as the cumulative time is not exceeded for that battery. In addition. Required Action .1 requires the (continued)

Dresden 2 and 3 B 3.8.4-7 Revision 0

DRESDEN UNITS 2 AND 3 INSERTS INSERT: B 3.8.4 ACTION E ACTIONS E.I. E.2. and E.3 Condition E represents one required Division 1 or 2 125 VDC battery charger inoperable (e.g., the voltage limit of SR 3.8.4.1 is not maintained as both the installed Class 1E battery chargers are inoperable). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring a fully qualified charger to OPERABLE status in a reasonable time period. Required Action E.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to the minimum established float voltage provides good assurance that, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the battery will be restored to its fully charged condition (Required Action E.2) from any discharge that might have occurred due to the charger inoperability. A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharging cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus, there is good assurance of fully recharging the battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , avoiding a premature shutdown with its own attendant risk.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the charger is not operating in the current-limiting mode, a faulty charger is indicated. Current-limiting mode is the condition in which the maximum charger output is limited to ensure that the AC current drawn by the charger is within design limits. The charger output in current-limiting mode is greater than or equal to 220 amps. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

If the charger is operating in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , that is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action E.2).

DRESDEN UNITS 2 AND 3 INSERTS INSERT: B 3.8.4 ACTION E (couiL)

Required Action E.2 requires that the battery float current be verified as less than or equal to 2 amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it has now been fully recharged. If at the expiration of the initial 12-hour period the battery float current is not less than or equal to 2 amps, this indicates there may be additional battery problems and the battery must be declared inoperable.

Required Action E.3 limits the restoration time for the inoperable battery charger to 7 days. This action is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E battery charger). The 7-day completion time reflects a reasonable time to effect restoration of the qualified battery charger to operable status.

OC Sources-Operating DC Sources -Operating B 3.8.4 BASES ACTIONS and .2 (continued) associated OPERABLE alternate 125 VDC electrical power subsystem to be placed in service. An OPERABLE alternate 125 VDC electrical power subsystem consists of the alternate 125 VDC 'battery and one full capacity battery charger. For the alternate 125 VDC battery to be considered OPERABLE, all SR requirements associated with the alternate 125 VDC battery must be met. Therefore, placement of the OPERABLE alternate 125 VDC electrical power subsystem in service will help ensure that the design basis can be met. (The full capacity battery charger is the same battery charger (normal or spare) associated with the normal 125 VDC electrical power subsystem.) However, the design configuration of the alternate battery is susceptible to single failure and hence, is not as reliable as the normal battery. Therefore, only a limited time of operation is allowed in this condition.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time to place the associated OPERABLE alternate 125 VDC electrical power subsystem in service provides sufficient time to safely remove the Division 1 or 2 125 VDC electrical power subsystem from service and place the alternate supply in service. The 7 day cumulative Completion Time is based on the capacity and capability of the remaining DC Sources, including the enhanced capability afforded by the capability of the alternate 125 VDC electrical power subsystem to supply the required loads.

and .2>

Condition Division 1 or 2 125 VDC battery inoperable due to the need to replace the battery as determined by maintenance or testing, represents one division with a loss of ability to completely respond to an event. It is therefore imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for complete loss of DC power to the affected division. Operation in this Condition may be needed during the operating cycle to completely replace a battery to maintain the Division 1 or 2 VDC_ subss em OPERABLE for the remainder of the cycle.

Conditio is modified by a Note indicating that the Condition is only applicable when the opposite unit is in MODE 1. 2. or 3.

(continued)

Dresden 2 and 3 B 3.8.4-8 Revision 0

DC Sources -Operating B 3.8.4 BASES ACTIONS 1 .2 (continued)

If one of the 125 VOC batteries is inoperable, the remaining 125 VDC electrical power subsystem has the capacity to support a safe shutdown of one unit and to mitigate an accident condition in the other unit. Since a subsequent worst case single failure could, however, result in the loss of minimum-necessary DC electrical subsystems to mitigate a worst case accidknt, continued power operation is limited.

Required Actioq 7.2 limits the time the unit can operate in this condition to 7 days. Therefore, each 125 VDC battery can be removed from service to completely replace a battery.

In addition, Required Action 01 requires the associated OPERABLE alternate 1Zb vuG electrical power subsystem to be placed in service. An OPERABLE alternate 125 VDC electrical power subsystem consists of the alternate 125 VDC battery and one full capacity battery charger. For the alternate 125 VDC battery to be considered OPERABLE, all SR requirements associated with the alternate 125 VDC battery must be met. Therefore, placement of the OPERABLE alternate 125 VDC electrical power subsystem in service will help ensure that the design basis can be met. (The full capacity battery charger is the same battery charger (normal or space) associated with the normal 125 VDC electrical power subsystem.) However, the design configuration of the alternate battery is susceptible to single failure and hence, is not as reliable as the normal battery. Therefore, only a limited time of operation is allowed in this condition.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time to place the associated OPERABLE alternate 125 VDC electrical power subsystem in service provides sufficient time to safely remove the Division 1 or 2 125 VDC electrical power subsystem from service and place the alternate supply in service. The 7 day Completion Time to restore the 125 VDC battery is based on the capacity and capability of the remaining DC Sources, including the enhanced capability afforded by the capability of the alternate 125 VDC electrical power subsystem to supply the required loads.

(continued)

Dresden 2 and 3 B 3.8.4-9 Revision 0

- Operating DC Sources DC Sources - Operating B 3.8.4 BASES ACTIONS X1 and i.2 (

(continued)

With one Division or Division 2 125 VDC electrical poiert subsystem ino e for reasons other than Conditions

& Condition represents one division with a loss of ability to completely respond to an event, and a.potential

{for rea~sons) loss of ability to remain energized during normal operation.

It i3- therefore imperative that the operator's attention oAer#an focus on stabilizing the unit, minimizing the potential for

\od F complete loss of DC power to the affected division. The c hour limit is consistent with the allowed time for an inoperable DC Distribution System division.

If one 125 VDC electrical ower subsystem is inoperable

'~-re g. n-operable _r equiradba _ er b~ia@6ror i peable rofuired battq-yft-Fa-rge-r-Tnd associated inoperable battery), the remaining DC electrical power subsystems have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could. however, result in the loss of minimum necessary DC electrical subsystems to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 7) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power subsystem and, if the DC electrical power subsystem is not restored to OPERABLE status. to prepare to effect an orderly and safe unit shutdown.

Required Action .2 is modified by a Note indicating that the action is on y applicable if the opposite unit is not in MODE 1. 2, or 3. In this condition, the shutdown unit is under maintenance and a complete test of at least one 125 VDC subsystem may be necessary. Required Action . 2 requires the OPERABLE alternate 125 VDC electrical power subsystem to be placed in service in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time to place associated OPERABLE alternate 125 VDC electrical power subsystem in service provides sufficient time to safely remove the Division 1 and 2 125 VDC electrical power subsystem from service and place the alternate supply in service. An OPERABLE alternate 125 VDC electrical power subsystem consists of the alternate 125 VDC battery and one full capacity battery charger. For (continuedt)

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DC Sources-Operating DC Sources - Operating B 3.8.4 9-) BASES ACTIONS .1 and i.2 (continued) the alternate 125 VDC battery to be considered OPERABLE all SR requirements associated with the 125 VDC battery must be met. (The full capacity battery charger is the same battery charger (normal or spare) associated with the normal 125 VDC electrical power subsystem.) Upon completing this Required Action continuous operation is-allowed. since if the opposite unit associated OPERABLE alternate 125 VDC electrical power subsystem is placed in service supplying the unit Division 2 loads, the design configuration will not be susceptible to single failure and hence, the reliability is consistent with the normal battery.

With the opposite unit Division 2 125 VDC electrical power system inoperable, certain redundant Division 2 features (e.g., Standby Gas Treatment System) will not function if a design basis event were to occur. With a standby gas treatment subsystem inoperable, LCO 3.6.4.3. Standby Gas v Treatment System requires restoration of the inoperable SGT subsystem to OPERABLE status in 7 days. Therefore, a 7 day Completion Time is provided to restore the opposite unit Division 2 125 VDC electrical power subsystem to OPERABLE status. The 7 day Completion Time is based on consideration of such factors as the availability of the OPERABLE redundant system(s) and the low probability of a OBA occurring during this time period.

If the electrical power subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status. the unit must be brought to at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. The Completion Time to bring the unit to MODE 4 is consistent with the time required in Regulatory Guide 1.93 (Ref. 7).

By (continued)

Dresden 2 and 3 B 3.8.4-11 Revision 0

- Operating DC Sources B 3.8.4

) BASES C(continued)

SURVEILLANCE SR 3.8.4.1 REQUIREMENTS Verifying battery terminal voltage while on float charge for tatpr P,, h Dsto ensure the effectiveness of the I~a(I'fye f~' c gin ste andthe ability of the batteries to perform WA/eA S.~eOO~' thir nteded function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome'tfte internal losses of a battery a~nd btrinoteull modified byaNoethe requrgeds taehe Unto lterat batry tod mee the especifie i talvoltagelmtonywe it is

~~re reuired to be OPERABLE. This battery is required to be

~~1~ PE RABLE when it is being used to meet Required Actos 1 p ,otetalydg4d ateyprfra e Theacon ectionrsitno c lirits toblshe fotryti Rcare withinat vlue esbatalsedy by ndsrypacie h connecti rsistance limits o his SR are relate to the resis nc individual bol d onnections, and not inc de the resistance of ndcive components eg.,

caes or conductorslcae between cells. r ks. or The Frequency for t se inspections, whic cndetect conditions that c cause power losses to re SiSt c heating, is 92 d s. This Frequency i cnsidered acceptable bas on operating experie c related dtcing cor son trends.

~~(continued)

Dresden 2 and 3B38412Rvso 8 3.8.4 -12 Revision 0

DRESDEN UNITS 2 AND 3 INSERTS INSERT: B SR 3.8.4.1

... , while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float established by the battery manufacturer (2.17 Vpc or 260.4 V at the 250 VDC battery terminals and 125.9 V at the 125 VDC battery terminals). This voltage maintains the battery plates in a condition that supports maintaining the grid life (expected to be approximately 20 years).

DC Sources - Operating B 3.8.4 BASES aSg SURVEILLANCE SR 3.8.4biand SR 3.8.4.6 REQUIREMENTS the (continued) (tliL2Ug capabillff reguiremen s are bafd ol h si n capacity of t chargers According to

ho ry Regulatory Guide =. (Ref. 9). the attery charger supply i'~< re e to be based on the largest combined demands of varteus steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these demand occurrences. The minimum required amperes and duration ensures that these requirements can be

,,--- -e _ sfied.atisfaeosati The 18 month Frequency for SR 3.8.4 is acceptable 4based on E; St? 3.0i.2J engineering judgement. Operating experience has shown that the 250 V battery chargers usually pass the SR when performed at the 18 month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint..

The 24 Frequency for SR 3.8.4 0 is acceptable given the administrative controls existing to ensure adequate charger performance during these 24 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

fSR 3.8.4.4 Visual in ection of the battery ells. cell plates, an batter acks provides an indi tion of physical dama or abno al deterioration that uld potentially degra ba ery performance. The esence of physical d age or eterioration does not cessarily represent a ailure of this SR, provided an aluation determines t the physical damage or deteriora on does not affect t OPERABILITY of the battery (its ility to perform its esign function).

The 24 month requency for the Surv lance is based on engineerin judgement. Operating -xperience has shown hat these c X onents usually pass t f SR when performed ( thed l 24 mg Frequency. Therefor the Frequency wa ,fnluded (conti nued)

Dresden 2 and 3 B 3.8.4-13 Revision 0

DRESDEN UNITS 2 AND 3 INSERTS INSERT: B SR 3.8.4.2 This SR provides two options. One option requires that each battery charger be capable of supplying 200 amps at the minimum established float voltage for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The ampere requirements are based on the output rating of the chargers. The voltage requirements are based on the charger voltage level after a response to a loss of AC power. The time period is sufficient for the charger temperature to have stabilized and to have been maintained for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

The other option requires each battery charger be capable of recharging the battery after a service test coincident with supplying the largest coincident demands of the various continuous steady state loads (irrespective of the status of the plant during which these demands occur).

This level of loading may not normally be available following the battery service test and will need to be supplemented with additional loads. The duration for this test may be longer than the charger sizing criteria since the battery recharge is affected by float voltage, temperature, and the exponential decay in charging current. The battery is recharged when the measured charging current is < 2 amps.

DC Sources -Operating B 3.8.4 BASES SURVEILLANCE SR 3.8.4.5 and SR 3. .4.6 REQUIREMENTS (continued) Visual inspectio nd resistance measurements f intercell and terminal c nections provides an indican on of physical damage or ormal deterioration that cop.Kd indicate degrade attery condition. The anti- rrosion material is used help ensure good electrical onnections and to re ce termnnal deterioration. T visual inspection for orrosion is not intended to r uire removal of and inspection under each termi connection.

The removal of visible orrosion is a preventive maintena e SR. The presence of isible corrosion does not necess ly represent a failu of this SR, provided visible cor sion is removed du r performance of this Surveillanc The conne ion resistance limits are within values establ' ed by industry practice. The con ction resistance limj of this SR are related to the reitance of i ividual bolted connections, and do ot include the esistance of conductive component e.g., cables or conductors located between cells racks, or tiers).

The 24 month Frequency for e Surveillance is based on engineering judgement. erating experience has show that these components usua y pass the SR when performe at the 24 month Frequency./ Therefore, the Frequency wa concluded t cceptable om a reliability standpoin SR3 A battery service test is a special test of the battery's capability, as found, to satisfy the design requirements (battery duty cycle) of the DC electrical power system. The test can be performed using simulated or actual loads. The discharge rate and test length corresponds to the design duty cycle requirements as specified in Reference 4.

The Frequency of 24 months is acceptable, given unit conditions required to perform the test and the other requirements existing to ensure adequate battery performance during these 24 month intervals. In addition, this Frequency is intended to be consistent with expected fuel cycle lengths.

(conti nued)

Dresden 2 and 3 B 3.8.4-14 Revision 0

DC Sources -Operating B 3.8.4 BASES SURVEILLANE SR 3.8.4. (continued)

REOUIREMEN'

This SR is modified by a Note. The Note allows the performance of a modified performance discharge test in lieu of a service test provided the modified performance discharge test completely envelopes the service test. This substitution is acceptable because a modified performance discharge test represen s a mortksevere test of battery capacity than SR 3.8.

A batte performance d discharge t s a test of constanted culo capacity of a battfry, w bally done in the as fen co dutyon, after having bevni tervice, to detect an c f ange in the capacity de mied by the acceptance Te test is intended to xeermine overall batter degradation due to a and usage./

A battery m performance edischarge test a imulated duty cycle y consisting of just t es; the one mincte ampere-hed for the battery ne argest current lodischge duty cycle, followed by thi of ate employed foa ity eformance dischargn e c dh of which envelope tbtdut cyle of the service tes! The test can consist /

pfoa single rate if tho tet romisngltyed for the o performance discharge test eds the 1 minute rate andge continues to envelope th~rt ycle of the service tenh Since the ampere-hour manedicy a rated one minutema discharge represent Ieysml portion of the b s ery capacity, the te;' e can be changed to that fasthel performance t without compromising the res s of the performance ~shrge test. The battery te ,~nal voltagel for the m dfied performance discharge te Xshould remain l above t minimum battery terminal volt e specified in the battey service test for the duratio of time equal to that of he service test.

A modified performance discha e test is a test of the battery capacity and its abJ'ity to provide a high rae, short duration load (usua y the highest rate of e duty cycle). This will ofte confirm the battery's ility to meet the critical pe r d of the load duty cy e, in addition (continued)

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DC Sources -Operating B 3.8.4 BASES SURVEILLANCE S3..4.9 (contin d REQUIREMENTS to determining s percentage of rated capacity.I a .

conditions fo the modified performance dischar est should be entical to those specified for a rvice test when th odified performance discharge te is performed in lieu a service test. Either the battry performance di harge test or the modified perfo ance discharge tesit $iZ cceptable for satisfying SR 3.8.4 ; however, only the modified performance discharge st may be used to satisfy SR 3.8.4.9 while satisfying requirements of SR 3.8.4.8 at the same time.

The acceptance crite a or this Surveillance is consistent with IEEE-450 (Re 8) and IEEE-485 (Ref. 10). These references rec end that the battery be replaced if it capacity is ow 80% of the manufacturer's rating, ce IEEE-485 ef. 10) recommends using an aging facto of 125%

in the attery size calculation. A capacity of % shows tha he battery rate of deterioration is in asing. even i there is ample capacity to meet the la requirements.

The Frequency for this test is normal 60 months. If the battery shows degradation, or if t battery has reached 85%

of its expected life and capaci is < 100% of the manufacturer's rating, the Su eillance Frequency is reduced to 12 months. However, if e battery shows no degradation but has reached 85% of ' expected life, the Surveillance Frequency is only re ed to 24 months for batteries th retain capacity > 0% of the manufacturer's rating.

Degradation is icated. consistent with IEEE-450 ef. 8).

when the batt y capacity drops by more than 10% elative to its capaci on the previous performance test r when it is

> 10% besw the manufacturer's rating. Th 2 month and 60 mo Frequencies are consistent wit he recommendations in JnEE-450 (Ref. 8). The 24 month F quency is derived om the recommendations of IEEE-4 (Ref. 8).

(continued)

Dresden 2 and 3 B 3.8.4-16 Revision 0

DC Sources - Operating B 3.8.4 BASES (continued)

REFERENCES 1. UFSAR. Section 3.1.2.2.8.

2. Safety Guide 6, March 10, 1971.

3. IEEE Standard 308, 1974.

4. UFSAR. Section 8.3.2.

5. UFSAR, Chapter 6.

6. UFSAR. Chapter 15.

7. Regulatory Guide 1.93. Revision 0. December 1974.

8. IEEE Standard 450. 1995.

9. Regulatory Guide 1.32. Revision 2, February 1977.

( 10. X4E tni 85)18 Dresden 2 and 3 B 3.8.4-17 Revision 0

DC Sources - Shutdown B 3.8.5 BASES ACTIONS would require the unit to be shutdown, but would not require (continued) immediate suspension of movement of irradiated fuel assemblies. The Note to the ACTIONS, 'LCO 3.0.3 is not applicable," ensures that the actions for immediate suspension of irradiated fuel assembly movement are not postponed due to entry into LCO 3.0.3.

A.1. A.2.1. A.2.2. A.2..3,,. and A.2.4 By allowance of the option to declare required features inoperable with associated DC electrical power subsystem(s) inoperable, appropriate restrictions are implemented in accordance with the affected system LCOs' ACTIONS. However, in many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment, and any activities that could result in inadvertent draining of the reactor vessel).

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystems and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the plant safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the plant safety systems may be without sufficient power.

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 requir all Surveillances required by SR 3.8.4.1 through SR 3.8.4. to be applicable. Therefore, see the corresponding Base for LCO 3.8.4 for a discussion of each SR.

(continued)

Dresden 2 and 3 B 3.8.5-4 Revision 0

Battery ( Parameters B 3.8.6 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.6 Battery X Parameters Aa9-r P/'s c arr~a BASES

.s we/i~a aS BACKGROUND This LCO delineates the limits onielectrolyte temperature, lev~el float voltag an speci c gra t for the DC

-electrica1-pcwer su ems batteries. A discussion of these batteries and their OPERABILITY requirements is g 86 provided in the Bases for LCO 3.8.4, 'DC Sources -

oil 3 AOperating," and LCO 3.8.5. 'DC Sources- Shutdown.;

APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in UFSAR. Chapter 6 (Ref. an Chapter 15 (Ref.. , assume Engineered Safety Fetur - J systems are OPERABLE. The DC electrical power subsystems provide normal and emergency DC electrical power for the diesel generators (DGs), emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit as discussed in the Bases for LCO 3.8.4 and LCO 3.8.5.

Since battery ( parameters support the operation of the DC electrical power subsystems, they satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

Battery parameters must remain within acceptable limits to ensure availability of the required DC power to shut down the reactor and maintain it in a safe condition after an anticiag d operational occurrence or a postulated DBA.

El trol e limits are conservatively established, allowing continued DC electrical system function even with Qaijgo7A) A nP6)limits not met._'.,.

APPLICABILITY The battery G parameters are required solely for the support of the associated DC electrical power subsystem.

Therefore, he ce Her) aram are only required when the perarr)efer associate 0 electrical power subsystem is required to be

//a./-Ys

.OPERABLE. Refer to the Applicability discussions in Bases for LCO 3.8.4 and LCO 3.8.5.

(continued)

Dresden 2 and 3 B 3.8.6-1 Revision 0

DRESDEN UNITS 2 AND 3 INSERTS INSERT: B 3.

8.6 BACKGROUND

In addition to the limitations of this Specification, the "Battery Monitoring and Maintenance Program," specified in Specification 5.5.13, is a program that monitors various battery parameters based on the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications" (Ref. 1).

The battery cells are of flooded lead acid construction with a nominal specific gravity of 1.215.

This specific gravity corresponds to an open circuit battery voltage of approximately 120 V for a 58 cell battery (i.e., cell voltage of 2.07 volts per cell (Vpc)). The open circuit voltage is the voltage maintained when there is no charging or discharging. Once fully charged with its open circuit voltage Ž 2.07 Vpc, the battery cell will maintain its capacity for 30 days without further charging per manufacturer's instructions. Optimal long-term performance however, is obtained by maintaining a float voltage of 2.17 to 2.25 Vpc. This provides adequate over-potential which limits the formation of lead sulfate and self-discharge. The nominal float voltage of 2.22 Vpc corresponds to a total float voltage output of 128.8 V for a 58 cell battery as discussed in UFSAR Chapter 8 (Ref. 2).

INSERT: B 3.8.6 LCO Additional preventive maintenance, testing, and monitoring is performed in accordance with the "Battery Monitoring and Maintenance Program" as specified in Specification 5.5.13.

Battery @ Parameters B 3.8.6 BASES (continued)

ACTIONS The ACTIONS Table is modified by a Note which indicates that separate Condition entry is allowed for each battery. This is acceptable, since the Required Actions for each Condition provide appropriate compensatory actions for each inoperable DC electrical power subsystem. Complying with the Required Actions for one inoperable DC electrical power subsystem may allow for continued operation, and subsequent inoperable DC electrical power subsystem(s) are-gogverned by separate Condition entry and application of associated Required Actions.

Wi th g ameters of one or X re cells in one!o or baM eies not withi Tae 3.8.6-1 limits (i.e..JP egory A S6A W Lmits not met or Cat goy B limits not met. or#ategory A and B limits not me but within the Category limits

3. g. 4 specified in Tabl 3.8.6-1. the battery is egraded but there is still fficient capacity to per orm the intended function. Th efore, the affected bat ry is not required to be consi red inoperable solely as/a result of Category A or B limi not met, and continued eration is permitted for a 1 ited period.

The ilot cell(s) electrolyt evel and float voltage ar r uired to be verified to eet the Category C limits thin hour (Required Action .1). This check provides a uick indication of the stat of the remainder of the ba ery cells. One hour pro des time to inspect the ele rolyte level and to confi the float voltage of the piot cell(s).

One hour is cons ered a reasonable amount of me to perform the r ired verification.

Verificat n that the Category C limits e met (Required Action .2) provides assurance that durng the time needed to re ore the parameters to the Cate ry A and B limits, the attery is still capable of perf rming its intended f ction. A period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to complete t Xnitial verification because spe fic gravity measureme s must be obtained for each conn ted cell. Taking int consideration both the time rquired to perform the equired verification and the assura ce that the battery ce parameters are not severe degraded, this time (continued)

Dresden 2 and 3 B 3.8.6-2 Revision 0

DRESDEN UNITS 2 AND 3 INSERTS INSERT B 3.8.6 ACTIONS ACTIONS A.1. A.2. and A.3 With one or more cells in one 250 VDC or 125 VDC battery < 2.07 V, the battery cell is degraded. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage (SR 3.8.4.1) and of the overall battery state of charge by monitoring the battery float charge current (SR 3.8.6.1). This assures that there is still sufficient battery capacity to perform the intended function. Therefore, the affected battery is not required to be considered inoperable solely as a result of one or more battery cells < 2.07 V, and continued operation is permitted for a limited period up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Since the Required Actions only specify "perform," a failure of SR 3.8.4.1 or SR 3.8.6.1 acceptance criteria does not result in this Required Action not met.

However, if one of the SRs is failed, the appropriate Condition(s), depending on the cause of the failures, is entered. If SR 3.8.6.1 is failed, then there is not assurance that there is still sufficient battery capacity to perform the intended function and the battery must be declared inoperable immediately.

B.1 and B.2 One 250 VDC or 125 VDC battery with float current > 2 amps indicates that a partial discharge of the battery capacity has occurred. This may be due to a temporary loss of a battery charger, or possibly due to one or more battery cells in a low voltage condition reflecting some loss of capacity. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , verification of the required battery charger OPERABILITY is made by monitoring the battery terminal voltage. If the terminal voltage is found to be less than the minimum established float voltage, there are two possibilities; the battery charger is inoperable or is operating in the current limit mode. Conditions A and E of LCO 3.8.4 address charger inoperability. If the charger is operating in the current limit mode after 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , that is an indication that the battery has been substantially discharged and likely cannot perform its required design functions.

The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be recharged within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action B.2). The battery must therefore be declared inoperable.

If the float voltage is found to be satisfactory but there are one or more battery cells with float voltage < 2.07 V, Condition C is applicable and the battery must be declared inoperable immediately. If float voltage is satisfactory and there are no cells < 2.07 V, there is good assurance that, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the battery will be restored to its fully charged condition (Required Action B.2) from any discharge that might have occurred due to a temporary loss of the battery

DRESDEN UNITS 2 AND 3 INSERTS INSERT B 3.8.6 ACTIONS (cont.)

charger. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus, there is good assurance of fully recharging the battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , avoiding a premature shutdown with its "own attendant risk.

If the condition is due to one or more cells in a low voltage condition but is still

> 2.07 V, and float voltage is found to be satisfactory, this is not indication of a substantially discharged battery and 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is a reasonable time prior to declaring the battery inoperable.

Since Required Action B.l only specifies "perform," a failure of SR 3.8.4.1 acceptance criteria does not result in the Required Action not met. However, if SR 3.8.4.1 is failed, the appropriate Condition(s), depending on the cause of the failure, is entered.

C.1 Discovering one 250 VDC or 125 VDC battery with one or more battery cells float voltage < 2.07 V and float current > 2 amps indicates that the battery capacity may not be sufficient to perform the intended functions. The battery must therefore be declared inoperable immediately.

D.1. D.2. and D.3 With one 250 VDC or 125 VDC battery with one or more cells electrolyte level above the top of the plates, but below the minimum established design limits, the battery still retains sufficient capacity to perform the intended function.

Therefore, the affected battery is not required to be considered inoperable solely as a result of electrolyte level not met. Within 31 days, the minimum established design limits for electrolyte level must be re-established.

With electrolyte level below the top of the plates, there is a potential for dryout and plate degradation. Required Actions D.1 and D.2 address this potential (as well as provisions in Specification 5.5.13, Battery Monitoring and Maintenance Program). They are modified by a Note that indicates they are only applicable if electrolyte level is below the top of the plates. Within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , level is required to be restored to above the top of the plates. The Required Action D.2 requirement to verify that there is no leakage by visual inspection and the Specification 5.5.13, Item b, to initiate action to equalize and test in accordance with manufacturer's recommendation are taken from Annex D of IEEE-450 (Ref. 1).

They are performed following the restoration of the electrolyte level to above the top of the plates. Based on the results of the manufacturer's recommended testing, the battery may have to be declared inoperable and the affected cell(s) replaced.

DRESDEN UNITS 2 AND 3 INSERTS INSERT B 3.8.6 ACTIONS fcont)

E.1 With one 250 VDC or 125 VDC battery with pilot cell temperature less than the minimum established design limits, 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed to restore the temperature to within limits. A low electrolyte temperature limits the current and power available. Since the battery is sized with margin, while battery capacity is degraded, sufficient capacity exists to perform the intended function and the affected battery is not required to be considered inoperable solely as a result of the pilot cell temperature not met.

F.1 With one or more batteries in redundant divisions with battery parameters not within limits, there is not sufficient assurance that battery capacity has not been affected to the degree that the batteries can still perform their required function, given that redundant batteries are involved. With redundant batteries involved, this potential could result in a total loss of function on multiple systems that rely upon the batteries. The longer completion times specified for battery parameters on non-redundant batteries not within limits are therefore not appropriate, and the parameters must be restored to within limits on at least one division within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

G.1 When any battery parameter is outside the allowances of the Required Actions for Condition A, B, D, E, or F, sufficient capacity to supply the maximum expected load requirement is not ensured and the corresponding battery must be declared inoperable. The battery must therefore be declared inoperable immediately.

Battery ( Parameters B 3.8.6 BASES ACTIONS A.1. A.2" and A.3 continued) considered r sonable. The verification is epated at 7 day int als until the parameters are estored to Categor A and B limits. This periodi verification is consi tent with the normal Frequenc of pilot cell Su <eillances.

Continued operation is only rmitted for 31 days before battery cell parameters m t be restored to within Category A and 8 limits Taking into consideration that while battery capaci is degraded, sufficient capacit exists to perform - e intended function and to allo ime to fully restore t battery cell parameters to norm limits, this time is cceptable for operation prior to daring the associated C batteries inoperable.

hen any battery parameter is out e the Table 3.8.6-1 Category C limit for any connec d cell, sufficient capa ty to supply the maximum expecte load requirement is not ensured and the correspond g DC electrical power su ystem must be declared inopera e. Additionally, other potentially extreme co itions. such as any Requ ed Actions of Condition A and a ociated Completion Time ot met or average electroly temperature of represent ive cells

< 65-F, also ar gcause for immediately dec ring the associated DC lectrical power subsyste noperable.

SURVEILLANCE REQUIREMENTS This SR rifies that Table 3.8.6-1 Cat ory A battery cell para ers are consistent with IEEE-4 (Ref. 3). which re mmends regular battery inspecti s (at least one per nth) including voltage. specif gravity, and electrolyte

~~ level of pilot cells.

3.s SR 3.8.6.2 The quarterly insp tion of specific gravity. v age, and electrolyte lev for each connected cell is nsistent wit QIEEE-450 (Ref 3). In addition, within 7 < s of a battery (continued)

Dresden 2 and 3 B 3.8.6-3 Revision 0

DRESDEN UNITS 2 AND 3 INSERTS INSERT B 3.8.6 SRs SURVEILLANCE SR 3.8.6.1 REQUIREMENTS Verifying battery float current while on float charge is used to determine the state of charge of the battery. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a charged state.

The float current requirements are based on the float current indicative of a charged battery. Use of float current to determine the state of charge of the battery is consistent with IEEE-450 (Ref. 1). The 7-day Frequency is consistent with IEEE-450.

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

SR 3.8.6.2 and SR 3.8.6.5 Optimal long-term battery performance is obtained by maintaining a float voltage greater than or equal to the minimum established design limits provided by the battery manufacturer, which corresponds to 260.4 V at the 250 VDC battery terminal and 125.9 V at the 125 VDC battery terminals, or 2.17 Vpc. This provides adequate over-potential, which limits the formation of lead sulfate and self-discharge, which could eventually render the battery inoperable. Float voltage in this range or less, but > 2.07 Vpc, are addressed in Specification 5.5.13. Failure of SR 3.8.6.2 does not constitute inoperability. SRs 3.8.6.2 and 3.8.6.5 require verification that the cell float voltages are equal to or greater than the short-term absolute minimum voltage. The Frequency for cell voltage verification every 31 days for pilot cell and 92 days for each connected cell is consistent with IEEE-450 (Ref. 1).

SR 3.8.6.3 The limit specified for electrolyte level ensures that the plates suffer no physical damage and maintains adequate electron transfer capability.

The Frequency is consistent with IEEE-450 (Ref. 1).

DRESDEN UNITS 2 AND 3 INSERTS INSERT B 3.8.6 SRs (cont.)

SR 3.8.6.4 This SR verifies that the pilot cell temperature is greater than or equal to the minimum established design limit (i.e., 650F). Pilot cell electrolyte temperature is maintained above this temperature to assure the battery can provide the required current and voltage to meet the design requirements. Temperatures lower than assumed in battery sizing calculations act to inhibit or reduce battery capacity. The Frequency is consistent with IEEE-450 (Ref. 1).

SR 3.8.6.6 A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to determine overall battery degradation due to age and usage.

Either the battery performance discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.6.6; however, only the modified performance discharge test may be used to satisfy the battery service test requirements of SR 3.8.4.4.

A battery modified performance discharge test is a test of the battery capacity and its ability to provide a high rate, short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test when the modified performance discharge test is performed in lieu of a service test.

The modified performance discharge test normally consists of just two rates; for instance, the one minute rate for the battery or the largest current load of the duty cycle, followed by the test rate employed for the performance discharge test, both of which envelope the duty cycle of the service test. (The test can consist of a single rate if the test rate employed for the performance discharge test exceeds the 1 minute rate and continues to envelope the duty cycle of the service test.) Since the ampere-hours removed by a one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test must remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test.

DRESDEN UNITS 2 AND 3 INSERTS INSERT B 3.8.6 SRs (cont.)

The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 1) and IEEE-485 (Ref. 5). These references recommend that the battery be replaced if its capacity is below 80% of the manufacturers rating, since IEEE-485 (Ref. 5) recommends using an aging factor of 125% in the battery size calculation. A capacity of 80% shows that the battery rate of deterioration is increasing, even if there is ample capacity to meet the load requirements. Furthermore, the battery is sized to meet the assumed duty cycle loads when the battery design capacity reaches this 80% limit.

The Frequency for this test is normally 60 months. If the battery shows degradation, or if the battery has reached 85% of its expected life and capacity is < 100% of the manufacturers rating, the Surveillance Frequency is reduced to 12 months. However, if the battery shows no degradation but has reached 85% of its expected life, the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity

> 100% of the manufacturers rating. Degradation is indicated, consistent with IEEE-450 (Ref. 1), when the battery capacity drops by more than 10% relative to its capacity on the previous performance test or when it is

> 10% below the manufacturer's rating. The 12 month and 60 month Frequencies are consistent with the recommendations in IEEE-450 (Ref. 1). The 24 month Frequency is derived from the recommendations of IEEE-450 (Ref. 1).

Battery ( Parameters B 3.8.6 BASES SURVEILLANCE ntned) /

REOUIREMENTS discharg 0 V for a 125 V battery a < 20 Y for a 250 V fttery. or a battery overcharg' 150 V for a 125 V bt y and > 300 V for a 2,50 V ba 0 rthe battery must be ci onstrated to meet Table 3.8. Category B limits.

ransients, such as motor sta ing transients, which may momentarily cause batter yRvtage to drop to < 105 V or

< 210 V. as applicable, not constitute a battery discharge provided th attery terminal voltage and flo current return to p -transient values. This inspect~ n is also consistent wth IEEE-450 (Ref. 3), which reco ends special inspec *ons following a severe discharge r overcharge, ensure that no significant degr ation of the battery o rs as a consequence of such disc rge or overcha e. The 7 day requirement is base on engineering jud et./

S 3.8.6.3/

This Surveillance verificati that the average temperature of representative cells i ithin limits is consistent wit a recommendation of IEE 450 (Ref. 3) that states that t temperature of elect ytes in representative cells s Id be determined on uarterly basis. For this SR. a eck of 10% of the con ted cells is considered represen tive.

Lower than ormal temperatures act to inhibit r reduce battery pacity. This SR ensures that the perating tempe tures remain within an acceptable erating range.

Thi limit is based on manufacturer's r ommendations and t e battery sizing calculation.

Table 3.8.6-1/

This Table delineates the I its on electrolyte level, oat voltage, and specific gra ty for three different categories. The meanin of each category is discu ed below.

Category A defines he normal parameter limit or each designed pilot cX 1 in each battery. The c ls selected as pilot cells ar those whose temperature. ltage. and (conti nued)l Dresden 2 and 3 B 3.8.6-4 Revision 0

Battery 0 Parameters B 3.8.6 BASES SURVEILLANCE REQUIREMENTS elec yte specific gravity app mate the state of chag of e entire battery./

The Category A limits sp fied for electrolyte level are based on manufacturer recommendations and are consis t with the guidance i EEE-450 (Ref. 3). with.,the- ext M inch allowance ave the high water level indica on for operating margi to account for temperature and arge effects. In drddition to this allowance, footne (a) to Table 3.8. -1 permits the electrolyte level- be tempora y above the specified maximum 1 el during and.

for imited time, following an equal _ing charge (normally u a 3 days following the completia of an equalize charge o allow electrolyte stabilizatio provided it is not overflowing. These limits ens that the plates suffer no physical damage, and that adrsuate electron transfer capability is maintained 4 the event of transient conditions. IEEE-450 Xef. 3) *recommends that electrolyt level readings shoul be made only after the battery ha been at float char e for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The Category limit specified for float voltage s > 2.13 V per cell. his value is based on the recommen tion of IEEE-45 (Ref. 3), which states that prolong operation of cell elow 2.13 V can reduce the life e ctancy of cells.

e Category A limit specified for sp ific gravity for each pilot cell is > 1.200 (0.015 below e manufacturer's fully charged nominal specific gravity r a battery charging current that had stabilized at low value). This value is characteristic of a charged 11 with adequate capacity.

According to IEEE-450 (Ref 3). the specific gravity readings are based on a emperature of 770 F (250C).

The specific gravity eadings are corrected for a ual electrolyte temper ure and level. For each 30 F 1.670C) above 770 F (25*C 1 point (0.001) is added to he reading; 1 point is sub acted for each 30F below 77*F The specific gravity of t electrolyte in a cell incre es with a loss of water d to electrolysis or evaporati n. Level correcti will be in accordance with nufacturer's recom dations. o -

(continued)

Dresden 2 and 3 B 3.8.6-5 Revision 0

Battery &)Parameters B 3.8.6 BASES SURVEILLANCE able 3.8.6-1 continued)

REQUIREMENTS Categor defines the normal paramet limits for each conn ed cell. The term 'connect cell" excludes any b ery cell that may be jumpe out.

The Category B limits spe ied for electrolyte level and float voltage are the e as those specified for Category and have been discu d above. The Category B limit specified for sp fic gravity for each connected cell

> 1.195 (0.02 elow the manufacturer's fully charge nominal sp fic gravity) with the average of all nnected cells 1 5 (0.010 below the manufacturer's ful charged, nomi specific gravity). These values are sed on m facturer's recommendations. The minim specific ravity value required for each cell ens es that a cell with a marginal or unacceptable specific gravity is not masked by averaging with cells havi higher specific gravities./

Category C defines the limit or each connected cell.

These values, although red ed, provide assurance that sufficient capacity exis to perform the intended functi and maintain a margin f safety. When any battery para ter is outside the Cate ry C limits, the assurance of sufficient capaci described above no longer exist . and the battery mu be declared inoperable.

The Catego C limit specified for electroly level (above the top f the plates and not overflowing) nsures that the plat suffer no physical damage and mai gain adequate el tron transfer capability. The Cat ory C limit for oltage is based on IEEE-450 (Ref. 3) which states that a

/ cell voltage of 2.07 V or below, un en float conditions and not caused by elevated temperatur of the cell. indicates internal cell problems and may quire cell replacement.

The Category C limit on ave ge specific gravity 2 1.1 is based on manufacturer's r ommendations (0.020 below he manufacturer's recommen d fully charged, nominal ecific gravity). In additio to that limit, it is requ ed that the specific gravit for each connected cell st be no more than 0.020 below e average of all connect cells. This limit ensures t t a cell with a marginal r unacceptable specific gravj y is not masked by avera Wng with cells i t(specific ng hag gravities.cnne (continued)

Dresden 2 and 3 B 3.8.6-6 Revision 0

Battery ( Parameters B 3.8.6 BASES SURVEILLANCE Table 3. v6-1 (continued)

REQUIREMENTS The ootnotes to Table 3.8 -1 that apply to specific vity are applicable t Category A. B. and C specific gravity. Footnote (b equires the above mentioned correction for elec olyte level and temperature.

Becrause of spe fic gravity gradients that ar produced during the r arging process, delays of se ral days may occur whi waiting for the specific gravi y to stabilize.

A stabi zed charging current is an acc table alternative to s cific gravity measurement for d ermining the state of chrge of the designated pilot cell This phenomenon is iscussed in IEEE-450 (Ref. 3). ootnote (c) allows the float charge current to be use as an alternate to specifi gravity for up to 7 days fol wing a battery recharge.

Within 7 days, each conne ed cell's specific gravity ust be measured to confirm e state of charge. Follow g a minor battery recharg (such as equalizing charg that does not follow a deep d icharge) specific gravity adients are not significant. d confirming measurements ay be made in ess than 7 da REFERENCES UFSAR., Chapter 6.

/ UFSAR, Chapter 15.

IEEE Standard 450. 1995.

2, Y e-sAe, ehawve Ml g I

5. S_EEjfandger, L/ / 963.

Dresden 2 and 3 B 3.8.6-7 Revision 0

ATTACHMENT 4 Retyped Technical Specification Pages DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 Request for Amendment to Technical Specifications Associated With Direct Current Electrical Power REVISED TECHNICAL SPECIFICATIONS PAGES iii 3.8.4-1 3.8.4-2 3.8.4-3 3.8.4-4 3.8.4-5 3.8.4-6 3.8.5-2 3.8.6-1 3.8.6-2 3.8.6-3 3.8.6-4 5.5-12

TABLE OF CONTENTS (continued) 3.7 PLANT SYSTEMS 3.7.1 Containment Cooling Service Water (CCSW) System... .3.7.1-1 3.7.2 Diesel Generator Cooling Water (DGCW) System...... .3.7.2-1 3.7.3 Ultimate Heat Sink (UHS).......................... .3.7.3-1 3.7.4 Control Room Emergency Ventilation (CREV) System.. .3.7.4-1 3.7.5 Control Room Emergency Ventilation Air Conditioning (AC) System........................ .3.7.5-1 3.7.6 Main Condenser Offgas............................. .3.7.6-1 3.7.7 Main Turbine Bypass System........................ .3.7.7-1 3.7.8 Spent Fuel Storage Pool Water Level............... .3.7.8-1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources-Operating.................. .................. .3.8.1-1 3.8.2 AC. Sources-Shutdown................... .................. .3.8.2-1 3.8.3 Diesel Fuel Oil and Starting Air...... .................. .3.8.3-1 3.8.4 DC Sources-Operating.................. .................. .3.8.4-1 3.8.5 DC Sources-Shutdown................... .................. .3.8.5-1 3.8.6 Battery Parameters................... .................. .3.8.6-1 I 3.8.7 Distribution Systems-Operating........ .................. .3.8.7-1 3.8.8 Distribution Systems-Shutdown......... .................. .3.8.8-1 3.9 REFUELING OPERATIONS 3.9.1 Refueling Equipment Interlocks........ .................. .3.9.1-1 3.9.2 Refuel Position One-Rod-Out Interlock. .................. .3.9.2-1 3.9.3 Control Rod Position.................. .................. .3.9.3-1 3.9.4 Control Rod Position Indication.............. ........... .3.9.4-1 3.9.5 Control Rod OPERABILITY-Refueling............ ........... .3.9.5-1 3.9.6 Reactor Pressure Vessel (RPV) Water Level-Irradiated Fuel...................... 3.9.6-1 .

3.9.7 Reactor Pressure Vessel (RPV) Water Level-New Fuel or Control Rods....................... ........... .3.9.7-1 3.9.8 Shutdown Cooling (SDC)-High Water Level...... ........... .3.9.8-1 3.9.9 Shutdown Cooling (SDC)-Low Water Level....... ........... .3.9.9-1 3.10 SPECIAL OPERATIONS 3.10.1 Reactor Mode Switch Interlock Testing........ ...... .

3.10.2 Single Control Rod Withdrawal-Hot Shutdown... ...... .

3.10.3 Single Control Rod Withdrawal-Cold Shutdown.. 3.10.3-1 .

3.10.4 Single Control Rod Drive (CRD)

Removal-Refueling.......................... ...... .

3.10.5 Multiple Control Rod Withdrawal-Refueling.... ...... .

3.10.6 Control Rod Testing-Operating................ ...... .

3.10.7 SHUTDOWN MARGIN (SDM) Test-Refueling......... ...... .

4.0 DESIGN FEATURES 4.1 Site Location................................ 4.0-1 .

4.2 Reactor Core................................. 4.0-1 .

4.3 Fuel Storage................................. 4.0-2 .

(continued)

Dresden 2 and 3 i ii 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. Two 250 VDC electrical power subsystems;

b. Division 1 and Division 2 125 VDC electrical power subsystems; and

c. The opposite unit's Division 2 125 VDC electrical power subsystem capable of supporting equipment required to be OPERABLE by LCO 3.6.4.3, "Standby Gas Treatment (SGT)

System," LCO 3.7.4, "Control Room Emergency Ventilation (CREV) System" (Unit 3 only), LCO 3.7.5, "Control Room Emergency Ventilation Air Conditioning (AC) System" (Unit 3 only), and LCO 3.8.1, "AC Sources-Operating."

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required 250 VOC A.1 Restore 250 VDC 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months battery charger battery terminal inoperable. voltage to greater than or equal to the minimum established float voltage.

A.2 Verify 250 VDC Once per battery float current 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is < 2 amps.

(continued)

Dresden 2 and 3 3.8.4-1 Amendment No.

DC Sources-Operating 3.8.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.3 Restore the required 7 days 250 VDC battery charger to OPERABLE status.

B. One 250 VDC battery B.1 Restore 250 VDC Prior to inoperable as a result battery to OPERABLE exceeding 7 of maintenance or status. cumulative days testing. per operating cycle of battery inoperability, on a per battery basis, as a result of maintenance or testing C. One 250 VDC battery C.1 Restore 250 VDC 7 days inoperable, due to the battery to OPERABLE need to replace the status.

battery, as determined by maintenance or testing.

D. One 250 VDC electrical D.1 Restore 250 VDC 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power subsystem electrical power inoperable for reasons subsystem to OPERABLE other than Conditions status.

A, B, or C.

E. One required E.1 Restore 125 VDC 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Division 1 or 2 battery terminal 125 VDC battery voltage to greater charger inoperable. than or equal to the minimum established float voltage.

(continued)

Dresden 2 and 3 3.8.4- 2 Amendment No.

DC Sources-Operating 3.8.4 ACTIONS -

CONDITION REQUIRED ACTION COMPLETION TIME E. (continued) E.2 Verify 125 VDC Once per battery float current 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is < 2 amps.

AND E.3 Restore required the 7 days Division 1 or 2 125 VDC battery charger to OPERABLE status.

F. --------- NOTE--------- F.1 Place associated 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Only applicable if the OPERABLE alternate opposite unit is in 125 VDC electrical MODE 1, 2, or 3. power subsystem in service.

Division 1 or 2 AKD 125 VDC battery inoperable as a result F.2 Restore Division 1 Prior to of maintenance or or 2 125 VDC battery exceeding 7 testing. to OPERABLE status. cumulative days per operating cycle on a per battery basis G. --------- NOTE--------- G.1 Place associated 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Only applicable if the OPERABLE alternate opposite unit is in 125 VDC electrical MODE 1, 2, or 3. power subsystem in service.

Division 1 or 2 AND 125 VDC battery inoperable, due to the G.2 Restore Division 1 7 days need to replace the or 2 125 VDC battery battery, as determined to OPERABLE status.

by maintenance or testing.

(continued)

Dresden 2 and 3 3.8.4-3 Amendment No.

DC Sources-Operating 3.8.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME H. Division 1 or 2 H.1 Restore Division 1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 125 VDC electrical or 2 125 VDC power subsystem electrical power inoperable for reasons subsystem to OPERABLE other than status.

Conditions E, F, or G.

OR H.2 -------- NOTE---------

Only applicable if the opposite unit is not in MODE 1, 2, or 3.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Place associated OPERABLE alternate 125 VDC electrical power subsystem in service.

I. Opposite unit 1.1 Restore opposite unit 7 days Division 2 125 VDC Division 2 125 VDC electrical power electrical power subsystem inoperable. subsystem to OPERABLE status.

J. Required Action and J.1 Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met. AUil J.2 Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Dresden 2 and 3 3.8.4 -4 Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY t

SR 3.8.4.1 Verify battery terminal voltage is greater 7 days than or equal to the minimum established float voltage:

a. for each 250 VDC subsystem; I

b. for each 125 VDC subsystem; and I

c. ----------------- NOTE-----------------

Only required to be met when the Unit 2 alternate battery is required to be OPERABLE.

for Unit 2 alternate battery. I t

SR 3.8.4.2 Verify each required 250 VDC battery 18 months charger supplies 2 200 amps at greater than or equal to the minimum established float voltage for 2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for the 250 VDC subsystems.

OR Verify each 250 VDC battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-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)

Dresden 2 and 3 3.8.4-5 Amendment No.

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.4.3 Verify each required 125 VDC battery 24 months charger supplies 2 200 amps at greater than or equal to the minimum established float voltage for 2 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for the 125 VDC subsystems.

Verify each 125 VDC battery charger can recharge the battery to the fully charged state within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-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.

SR 3.8.4.4 ------------------- NOTE--------------------

The modified performance discharge test in SR 3.8.6.6 may be performed in lieu of l SR 3.8.4.4 provided the modified performance discharge test completely envelopes the service test.

Verify battery capacity is adequate to 24 months supply, and maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.

I Dresden 2 and 3 3.8.4-6 Amendment No.

DC Sources-Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately suspend operations with a potential for draining the reactor vessel.

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 ------------------- NOTE--------------------

The following SRs are not required to be performed for the 250 VDC electrical power subsystem: SR 3.8.4.2 and SR 3.8.4.4. I For DC electrical power subsystems required In accordance to be OPERABLE the following SRs are with applicable applicable: SRs SR 3.8.4.1, SR 3.8.4.2, SR 3.8.4.3, and SR 3.8.4.4. I Dresden 2 and 3 3.8.5- 2 Amendment No.

Battery Parameters l 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Parameters I LCO 3.8.6 Battery parameters for the 125 VDC and 250 VDC station I 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 250 VDC or 125 VOC A.1 Perform SR 3.8.4.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months battery with one or more battery cells AK float voltage

< 2.07 V. 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 AND A.3 Restore affected cell 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months voltage to > 2.07 V.

B. One 250 VDC or 125 VDC 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 battery with float current > 2 amps. AKD B.2 Restore battery float 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months current to < 2 amps.

(continued)

Dresden 2 and 3 3.8.6 -1 Amendment No.

Battery Parameters 3.8.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. One 250 VDC or 125 VDC C.1 Declare associated Immediately battery with one or battery inoperable.

more battery cells float voltage < 2.07 V and float current

> 2 amps.

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

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

D. One 250 VDC or 125 VDC D.1 Restore electrolyte 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months battery with one or level to above top of more cells electrolyte plates.

level less than minimum established AND design limits.

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

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

E. One 250 VDC or 125 VDC E.1 Restore battery pilot 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months battery with pilot cell temperature to cell electrolyte greater than or equal temperature less than to minimum minimum established established design design limits. limits.

(continued)

Dresden 2 and 3 3.8.6- 2 Amendment No.

Battery Parameters l 3.8.6 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME F. One or more batteries F.1 Restore battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in redundant divisions parameters for with battery batteries in one parameters not within division to within limits. limits.

G. Required Action and G.1 Declare associated Immediately associated Completion battery inoperable.

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

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 7 days

< 2 amps.

SR 3.8.6.2 Verify each battery pilot cell voltage is 31 days

> 2.07 V.

SR 3.8.6.3 Verify each battery connected cell 31 days electrolyte level is greater than or equal to minimum established design limits.

(continued)

Dresden 2 and 3 3.8.6- 3 Amendment No.

Battery Parameters l 3.8.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.6.4 Verify each battery pilot cell temperature 31 days is greater than or equal to minimum established design limits.

SR 3.8.6.5 Verify each battery connected cell voltage 92 days is > 2.07 V.

SR 3.8.6.6 Verify battery capacity is > 80% of the 60 months manufacturer's rating when subjected to a performance discharge test or a modified AND performance discharge test.

12 months when battery shows degradation or has reached 85%

of expected life with capacity < 100%

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

of manufacturer's rating Dresden 2 and 3 3.8.6-4 Amendment No.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.12 Primary Containment Leakaae Rate Testing Program (continued)

c. The maximum allowable primary containment leakage rate, La, at Pa, is 1.6% of primary containment air weight per day.

d. Leakage rate acceptance criteria are:

1. Primary containment overall leakage rate acceptance criterion is s 1.0 L,. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are

0.60 La for the combined Type B and Type C tests, and s 0.75 La for Type A tests.

2. Air lock testing acceptance criteria is the overall air lock leakage rate is

0.05 La when tested at 2 Pa.

e. The provisions of SR 3.0.3 are applicable to the Primary Containment Leakage Rate Testing Program.

5.5.13 Battery Monitoring and Maintenance Program This Program provides for restoration and maintenance, based on the recommendations of IEEE Standard 450-1995, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications," including the following:

a. Actions to restore battery cells with float voltage

< 2.13 V, and

b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the minimum established design limit.

Dresden 2 and 3 5.5-12 Amendment No.

RS-03-140, Request for Amendment to Technical Specifications Associated with Direct Current Electrical Power

Contents

Text

Subject:

References:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

8.6 BACKGROUND

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RS-03-140, Request for Amendment to Technical Specifications Associated with Direct Current Electrical Power

Text

Subject:

References:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

8.6 BACKGROUND

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