ML20206F432

Forwards Responses to NRC RAI Questions for Chapter 3.8 of Ts.Proposed Revs to TS Previously Submitted with LAR Related to RAI

ML20206F432
Person / Time
Site:	Farley
Issue date:	04/30/1999
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206F438	List: L-99-180, Forwards Responses to NRC RAI Questions for Chapter 3.8 of Ts.Proposed Revs to TS Previously Submitted with LAR Related to RAI ML20206F432 ML20206F442
References
NEL-99-0180, NEL-99-180, NUDOCS 9905060123
Download: ML20206F432 (45)

Text

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D:ve Morey S uthirn huchar -

Vice President Optrati;g Comps;y,lic.

i Farley Project Post Office Box 1295 Birmingham. Alabama 35201 Tei 205.992 5131 SOUTHERN COMPANY Apri1'30, 1999 Energy ro Serve Your%rld

• Docket Nos.:

50-348 NEL-99-0180 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Response to Request for Additional Information Related to Conversion to the Imoroved Technical Soccifications - Chanter 3.8 Ladies and Gentlemen

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By letters dated March 12,1998 and April 24,1998, Southern Nuclear Operating Company (SNC) submitted the Farley Nuclear Plant (FNP) - specific Improved Technical Specifications (ITS) conversion documentation packages in accordance with 10 CFR 50.90. The April 24,1998 letter, which submitted the Clean-Typed copies of the FNP ITS, included an attachment which provided hard copies of changes to the original submittal to correct minor editorial errors and inconsistencies within the package. By letter dated August 20,1998, SNC submitted an electronic copy of the Discussion of Changes (DOCS) and Significant Hazards Evaluations (SHEs) associated with the ITS conversion. Included with that letter were hard copies of changes to the original submittal to correct additional minor editorial errors and inconsistencies within the package. By letter dated November 20,1998, SNC submitted responses to Requests for Additional Information (RAIs) for Chapters 3.6 and 5.0. Included with that letter were hard copies of changes to the original submittal to reflect the SNC responses to the RAIs. By letter dated February 20,1999, SNC submitted responses to a RAI for Chapter 3.4. Included with that letter were hard copies of changes to the original submittal to reflect the SNC responses to the RAI.' NRC E-mail dated February 2, f 999, requested SNC provide additional information for Chapter 3.8.

Attachment I provides the SNC responses to the NRC RAI questions for Chapter 3.8. A conference call was held with the NRC on February 11,1999 to discuss the Chapter 3.8 RAI.

During that call, numerous questions were withdrawn by the NRC. 'Ihose questions are identified in Attachment I with the words " Withdrawn by NRC." Attachment II includes proposed revisions to the previously submitted license amendment request related to this RAI, grouped by RAI number. Meetings were held with the NRC on April 19-20,1999 to discuss the outstanding RAI questions. During those meetings, the Staff stated that it w~as not necessary to provide mark-ups of the Current Technical Specifications (CTS) in responses to RAIs. Therefore, not all of the attached packages will include CTS mark-ups.

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U. S. Nuclear Regulatory Commission

'In response to this RAI,'some changes to the SIEs were required. As denoted in 10 CFR 50.92(cy, SNC has determined the proposed changes to the FNP TS do not involve a significant hazards censideration. De revised SHEs are included in Attachment II. SNC has also determined that the proposed changes will not significantly affect the quality of the human enviromnent. A copy of the proposed changes has been sent to Dr. D. E. Williamson, the

- Alabama State Designee, in accordance with 10 CFR 50.91(b)(i).

Clean-typed copies of the affedoi ITS pages are not included. A complete clean-typed copy of the FNP ITS will be re-subm'aul at the end of the NRC review process.

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Mr. D. N. Morey states that he is a Vice President of Southern Nuclear Operating Company and i

is authorized to execute this oath on behalf of Southern Nuclear Operating Company and that, to the best of his knowledge and belief, the facts set forth in this letter and attachments are true.

f there are any questions, please advise.

Respectfully submitted, SOlJTHERN NUCLEAR OPERATING COMPANY

- Dave Morey Sworn to andsubscribedbefor me this zfay of_

1999

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U Notary Publie MyCommissionExpires: W

$, c200l WAS/maf: itsrai_3. doc Attachments:

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SNC Response to NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.8 II. SNC Response to NRC Request for AdditionalInformation Related to Conversion to the Improved Technical Specifications - Chapter 3.8, Associated Package Changes Grouped by RAI Number 1

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See next page.

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Page 3 U. S. Nuclear Regulatory Commission cc:

Southem Nuclear Ooeratina Comoany Mr. L. M. Stinson, General Manager - Farley U. S. Nuclear Renulatory Commission. Washinnton. D. C.

Mr. J. I. Zimmerman, Licensing Project Manager - Farley U. S. Nuclear Renulatory Commission. Renion II Mr. L. A. Reyes, Regional Administrator Mr. T. P. Johnson, Senior Resident Inspector - Farley Alabama Denartment of Public Health Dr. D. E. Williamson, State Health Officer i

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ATTACHMENTI SNC Response to NRC Request for Additional Information Related1o Conversion to the Improved Technical Specifications - Chapter 3.8

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SNC Raponse t2 NRC RAI Reittzd to Chrpter 3.8 3.8.1, AC Sources - Operating NRC Question:

3.8.1-01 Withdrawn by NRC NRC Question:

3.8.1-02 DOC 12 L CTS 3/4.8.1.1 Action e.

ITS T8.1 Doc 12L associated with proposed Condition E does not appear to be correct.

Comment: With two DG sets inoperable, the requirement to verify OPERABILITY of the offsite circuits is applicable even though it is not stated in the Required Actions of Condition E.

This is because, as discussed in DOC 9A, the requirements of Condition B are also applicable

. when Condition E is entered.. However, all the requirements of Condition B are not repeated in Condition E. DOC 12L should be modified, or deleted.

SNC Response:

DO C 12L discusses the deletion of the requirement to demonstrate the OPERABILITY of the remaining AC sources by performance of Surveillance Requirement 4.8.1.1.1.a on both offsite AC circuits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter when both emergency diesel generator (EDG) sets are inoperable. As stated in DOC 9A, this requirement still exists based the concurrent applicability of Conditions B and E when two EDG sets are inoperable. Therefore, while the requirement is deleted firom CTS 3.8.1.1 Action statement "e,"it is still covered under ITS Condition B and would be applicable for the conditions covered by CTS 3.8.1.1 Action statement "e." As such, this is an administrative change. DOC 12L has been changed to DOC 12A and has been revised to reflect the above reasoning.

NRC Question:

3.8.1-03 Withdrawn by NRC l

Page 1 of 39

L SNC Respmse ta NRC RAl' Relited 13 Ch ptir 3.8

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I NRC Question:

. 3.8.1-04'

' Withdrawn byNRC -

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- NRC Question:-

3.8.1-05 '-

CTS SR4.8.1.1.2.c.1 DOC 25LA'

. CTS SR 4.8.1.1.2.C.1 requires a DG inspection in accordance with vendor recommendations every 18 months.

Comment: This SR is proposed to be relocated. Relocation of the SRis acceptable. However, the staffis of the opinion that the SR should be included as part of the DG maintenance plan in l

compliance with the Maintenance Rule as opposed to being place in the TRM SNC Response 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power l

- Plants" (i.e., the Maintenanca Rule), does not require the development of a specific maintanance plan with specific surveillance or maintenance activities. The Maintenance Rule is not prescriptive as to the type ofpreventative maintenance that must be performed but rather that the performance or condition of structures, systems or components be monitored against licensee-j

- established goals. As such, it is deemed more appropriate to relocate these requirements to the

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TRM where changes to these requirements will be controlled by the 10 CFR 50.59 process.

l NRC Question:

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3.8.1-06 DOC 18 ITS SR 3.8.1.2 Note 3 STS SR 3.8.1.2 Not 3

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Note 3 for STS SR 3.8.1.2 states,"A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer." DOC 18 l

states that during the time the DG is being slowly accelerated to full speed the capability of the DG to automatically respond to an ESF or LOSP signal will be impacted.

j Comment: If the performance of a modified start renders the DG unable to meet its design and licensing basis, the DG should be declared inoperable while in this degraded state. Revise the

- submittal to provide additionaljustification for not declaring the DG inoperable during a j

modified start, or expand the Bases for ITS SR 3.8.1.2 to explain why the DG should be declared i

iaWie'during a modified start.

. SNC Response: -

SNC has elected to adopt the STS option to perform modified DG starts for monthly SRs in the interest of minimizing wear and aging on the machines. During a modified start, a FNP DG is not able to automatically respond to ESF or LOSP signals and is thereforc temporarily inoperable.

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SNC Resp nse to NRC RAI Rellt:d to Ch:pter 3.8

- However, the modified start and the accompanying briefinoperability is considered acceptable based on the following. 'Ibc likelihood of an ESF or LOSP actuation during the short duration of a modified start is very small. Each DG will be started locally by an operator in continuous communication with the Control Room. "Ihe DG controls can be immediately reset to permit normal machine response if necessary. Finally, only one DG is placed in the modified start mode at a time. Therefore, the other DGs remain fully capable ofimmediate response to ESF or LOSP signals.

DOC 18 will be revised to indicate that a DG is acceptably inoperable during the briefperiod of time modified starts are in progress. 'Ihe Bases for SR 3.8.1.2 will also be revised describing the inoperability and why it is considered acceptable.

r NRC Question:

3.8.1-07 Withdrawn byNRC

' NRC Questiont 3.8.1-08 DOC 36 CTS 4.8.1.1.2.c.6 Bases forITS 3.8.1 4

CTS 4.8.1.1.2.c.6 states, " Verifying that the permanently connected and the auto--+ed loads to each emergency diesel generator do not exceed the 2000-hour ratmg of 4353 kw for the 4075 kw generators and 3100 kw for the 2850 kw generator." DOC 36 states that these limits will be raoved to the Bases forITS 3.8.1.

Comment: This material could not be found in the Bases. Identify where this material is located, or revise the Bases to incorporate this material.

SNC Response:

' Ibis information was incorporated into Insert AA to page a 3.8-2 in the Background Section of the STS markup (clean-typed Bases page B 3.8.1-3). It is descriptive of the continuous ratmg of the diesel generators. As discussed in DOC 36-LA, in the STS, the TS Bases contain information regardmg system design and operability. "Iherefore, incorporation into the Bases is acceptable.

In addition, the requirement to verify that the permanently connected and the auto-connected loads to each emergency diesel generator do not exceed the 2000-hour rating has been moved to the TRM. DOC 36-LA has been revised to reflect this additional information.

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SNC Response tn NRC RAI Related ta Ch:pt:r 3.8 NRC Question:

.3.8.1 09-ITS 3.8.1.5 CTS 4.8.1.1.2.a.3 -

In ITS SR 3.8.1.5 (NUREG 3.8.1.6), the requirement to " automatically" transfer fuel is deleted.

However, nojustification is provided.

Comment: He staffinterprets this to mean that the Farley design does not include automatic operation of the fuel oil transfer system. Is this correct?

SNC Response: -

The design of the DG Fuel Oil Transfer System includes one automatically and one manually controlled pump for each Fuel Oil Storage Tank. During normal operation, each day tank is

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supplied from its storage tank by actuation oflevel switches that start and stop the automatic j

pump. For condition other than normal, each day tank can be supplied from its storage tank by j

the manual pump t'arough operation ofits control switch on the respective Diesel Iacal Control Panel.

He deletion of the term." automatically" from proposed ITS 3.8.1.5 ensures that capability of both pumps to transfer fuel is demonstrated on a monthly basis.

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NRC Question:

3.8.1-10 ITS SR 3.8.1.7 CTS 4.8.1.1.1.b In ITS SR 3.8.1.7 (NUREG 3.8.1.8), the requirement for automatic transfer to the alternate source of offsite power is deleted. However, no justification is provided.

Comment: The staffinterprets this to mean that the Farley design does not include automatic transfer to the alternate offsite source. Is this correct?

SNC Response:

The 4.16kV emergency busses required to supply equipment a~di for safe shutdown of the plant are F, G, H, J, K and L for each unit. %ese are supplied by two startup transformers on each unit connected to the offsite source during normal and emergency operating conditions. In the event one startup transformer on a unit fails, three of the emergency busses on that unit will be de-energized with their loss annunciated in the Main Control Room. He respective busses' Diesel Generators will start and LOSP loads will be sequenced on to those busses. In the event Diesels fail, manual action will be required to re-energize the affected busses from the other startup transformer for that unit. The staffinterpretation is correct that the Farley design for the

= 4.16kV emergency busses does not include automatic transfer to the alternate offsite source.

Information similar to that above has been added to the Background section of the Bases for LCO 3.8.1.

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SNC Resp:nse to NRC RAI Relited ta Chapttr 3.8 NRC Question:

3.8.1-11:

ITS SR 3.8.1.10 CTS 4.8.1.1.2.c.3 In subpart c. ofITS SR 3.8.1.10 (NUREG 3.8.1.12) the requirement to auto-connect emergency loads through the load sequencer is deleted.

Comment: M staffdoes not understand this deletion. It is the staffs und=4.ndhg that the Farley design includes sequencing emergency loads onto the offsite source. hrefore, the automatic sequence requirement of this SR should be retained. The licensee is requested to include this requirement, or provide a justification for why it should not be included.

SNC Response:

M Farley design does not provide for sequencing of emergency loads on receipt of an ESF signal when offsite power is available. The Farley design for Safety Injection (ESF per ITS) without LOSP is for the DGs to start in response to the ESF signal and operate in standby. h sequencers are also activated by the ESF signal.' However, due to logic sensing that offsite power is avadable, start signal outputs to the various ESF loads are initiated sirnultaneously. The required loads start at the same time rather than being started in sequence when offsite power remains available in conjunction'with ESF initiation. Therefore, SNC deleted the subject statement in ITS SR 3.8.1.10 because it implies that loads are started in sequence. As this information is bracke9,d in the STS, no JD is associated with this change since it simply makes the ITS consistent with the current FNP licensing and design basis.

NRC Question:

3.8.1-12 ITS SR 3.8.1.15 CTS 4.8.1.1.2.c.8 In ITS SR 3.8.1.15 (NUREG 3.8.1.17) the requirement to automatically energize the emergency loads from offsite power is deleted. Nojustification has been provided for this deletion.

Comment: It is the staffs understanding that the Farley design includes automatically energizing emergency loads from offsite power when it is available. The licensee should retain this requirement in the SR, or provide an adequatejustification for its deletion.

SNC Response:

ITS SR 3.8.1.15 replaces CTS SR 4.8.1.1.2.c.8 which demonstrates that Diesel Generators (DGs)

' operating in test mode cos.nected to a bus (and paralleled with off-site power) are diseuh and placed in standby operation upon receipt of an actual or simulated ESF signal. The current testing methodology initiates this feature by simulating an ESF signal to the DG control logic with start signals to ESF loads blocked. Therefore, ESF loads are not currently started during this surveillance testing. As described in the response to Question 3.8.1-11, starting of required loads supplied by offsite power upon receipt of an ESF signal is simultaneous and will be demonstrated in ITS SR 3.8.1.10.-

Page 5 of 39

p SNC Resp:nse t2 NRC RAI Rel:ted ts Chapttr 3.8 Required load response to ESF signals with DGs in test operation and offsite power available would be identical to that demonstrated under SR 3.8.1.10; e.g., required loads start simultaneously. Veri 6 cation ofload response under SR 3.8.1.15 would subject ESF systems to start /stop cycles beyond what is required by the CTS. Herefore, SNC submits that deletion of the subject STS requirement is appropriate and maintains the current Flip licensing basis and is consistent with the FNP design basis. As this information is bracketed in the STS, no JD is associated with this change. However, while evaluating this RAI question, an error was identified in the ITS. The CTS surveillance 4.8.1.1.2.c.8 which verifies the capability of an ESF actuation to override the DG test mode by returning the DG to ready to load condition does not

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contain the operatmg restriction of the STS precluding performance of this test in Modes 1,2,3, and 4. Based on the way that this test is performed at FNP, this restriction is not necessary.

Therefore, the note precluding test performance in Modes 1,2, 3, and 4 has been deleted maintaining the requirements of the FNP CTS. The appropriate changes to the package are included in M~a+ II.

r NRC Question:

3.8.1-13 ITS SR 3.8.1.18 CTS 4.8.1.1.2.c.11 ITS SR 3.8.1.18 (NUREG 3.8.1.10) is a full load reject test. He specified load value of 1200-

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2400KW is considerably less than the rating of the 4075 KW DGs and, at the lower end, considerably less than the rating of the 2850KW DGs.

Comment: The licensee should consider revising the loads in this SR to reflect the actual DG ratings.

SNC Response:

He values in the ITS for the load rejection tests are re-formatted from those that exist in the CTS.

In the early 1980s, Farley proposed to discontinue full load rejection to only perform testing for rejection of the single largest load. The basis for deleting the full load rejection was that the capability had been successfully demonstrated during previous testing and the need for periodic re-demonstration was not evident. He NRC indicated that the probability of single load rejection (originally performed every 5 years) was not considered infrequent. Farley then agreed to perform single largest load rejections of approximately 1000KW every 18 months.

l In further discussion, the NRC informed Farley of an event at a nuclear station during which a DG experienced load rejection greater than the single largest load that caused damage to safety

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related equipment due to voltage transients. In light of that information, Farley agreed that load j

. rejection tests confirming equipment remaining connected would be not affected was worthwhile.

It was agreed that such tests would be perforraed every five years and the load rejected during the tests would be approximately 50% of rating. As'such, the 1200-2400KW range was approved for the 5-year periodic load rejection testing.

Considering the above, SNC intends to maintain the current methodology for load rejection testag as submitted in the ITS. This will maintain the current licensing basis for Farley. Please refer to the letter from E. A. Reeves, NRC to F. L. Clayton, Alabama Power Co. dated March 1, 1982, transmitting Amendment 26 to Facility Operating License No. NPF-2, Page 12 and 13 for complete details regarding this subject.

Page 6 of 39

SNC Resp:nse to NRC RAI Rel:ted t2 Chapter 3.8 NRC Question:

4 3.8.1-14 Withdrawn by NRC 4

NRC Question:

3.8.1-15 Withdrawn by NRC E

NRC Question:

3.8.1-16' CTS 4.8.1.1.2.c.6

' DOC 36LA CTS SR 4.8.1.1.2.c.6 is proposed to be relocated to the Bases Comment: Relocation of the SR is acceptable, but the bases does not appear to be the appropriate location. De purpose of the Bases is to explain what is in the TS. Since this current requirement will not be in the ITS, what would the Bases be explaining? It is suggested that this CTS requirement be relocated to the TRM, FSAR, or QA plan.

SNC Response:

This information was incorporated into Insert AA to page B 3.8-2 in the Background Section of j

the STS markup (clean-typed Bases page B 3.8.1-3). It is descriptive of the continuous rating of the diesel generators. As discussed in DOC 36-LA, in the STS, the TS Bases contain information I

regarding system design and operability. Herefore, incorporation into the Bases is acceptable.

In addition, the requirement to verify that the permanently connected and the auto-connected -

loads to each emergency diesel generator do not exceed the 2000-hour rating has been moved to the TRM. DOC 36-LA has been revised to reflect this additional information.

NRC Question:

3.8.1-17

. CTS SR 4.8.1.1.2.e :

DOC 43LA De footnote to CTS SR 4.8.1.1.2.c is proposed to be relocated to the Bases.

Comment: he staffis of the opinion that this footnote constitutes a permissive that should remain in TS.' De footnote modifies a TS surveillance requirement and is, therefore, inappropriate for inclusion in the Bases.

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I SNC Response is NRC RAI Reitt:d 12 Ch:pt:r 3.8 SNC Response:

The information from the ** footnote to CTS 4.8.1.1.2.e has been reworded to conform to the standard format of the STS and has been included as a note to SR 3.8.1.18. Bases Insert VV to STS page B 3.8 22 has been reworded to describe the new note.

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NRC Question:

3.8.1-18 JFD 7a ITS 3.8.1, CONDITION G Bases page 3.8-14 for Action G1

. Proposed Condition G has a proposed Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. JD 7a states that this is acceptable because it is the same Condition as in CTS for one offsite and one DG set inoperable l

and which has a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time.

Comment: The staff does not agree that proposed Condition G is the same as CTS for one offsite and one DG set inoperable. In CTS, with one offsite inoperable, there is the alternate offsite to power safety loads. In Condition G, the inoperable sequencer precludes starting any safety loads, regardless of the availability ofpower. This is more closely associated with a dead bus which has an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completion time. De staff does not agree with the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion time for Action G1 discussed on page B3.8-14, thus the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time of the NUREG should be retained.

SNC Response:

SNC concurs with the staff position that an inoperable sequencer is more closely===v i=tM with a dead bus. Herefore, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> completion time of the STS will be adopted and JD7a will be eliminated.

NRC Question:

l 3.8.1-19 ITS SR 3.8.1.12 ITS SR 3.8.1.12 Note h Note for ITS SR 3.8.1.12 states that momentary transients outside the load range does not invalidate this test. ffS SR 3.8.1.12 does not specify load ranges, it specifies minimum allowable values.

' Comment: Here is an apparent discrepancy between ITS SR 3.8.1.12 and its Note. Revise the submittal to correct this discrepancy.

~ SNCResponse:

De note has been revised to state: " Momentary transients below the minimum load specified do notinvalidate this test."

Page 8 of 39

SNC Response is NRC RAI Related ta Chrpt:r 3.8

' NRC Question:

3.8.1-20 ITS SR 3.8.1.13 Note 1 Bases for ITS SR 3.8.1.13, STS Bases markup page B 3.8-28 Note 1 for ITS SR 3.8.1.13 states that momentary transients outside the load range does not

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invalidate this test. De first part of Note 1 does not specify load ranges, it specifies minimum allowable values.

. Comment: Here is an apparent discrepancy within Note 1 for ITS SR 3.8.1.13. Revise the j

submittal to correct this discrepancy.

j SNC Response:

He note has been revised to state: " Momentary transients below the minimum load specified do not invalidate this test."

j NRC Question:

3.8.1-21 Withdrawn byNRC

. NRC Question:

3.8.1-22 Bases forITS Action E.1 Page B 3.8-13 The discunion of Action E.1 beginning on Pg. B 3.8-13 is confusing. De discussion does not adequately address the TS completion times for this Condition / Action which are variable

- depending on how many and which DGs are inoperable.

Comment: h Bases should be expanded to more completely address the TS.

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. SNC Response:

He Bases for Action El has been expanded to address the different completion times for different combinations ofinoperable DGs.

NRC Question:

3.8.1-23 Bases forITS Action I.1 Page B 3.815

. h Bases discussion for Action I.1 on Pg. B 3.8-15 needs to be expanded.

Comment: De Bases should clearly address what a loss of 3 AC sources represents; i.e., two f

offsite circuh and one DG (one of a set), or two DGs (one of a set and one set) and one offsite circuits, etc.

Page 9 of 39

SNC Resptase ts NRC RAI Rilited 13 Ch pt:r 3.8 i

SNC Response:

De AC sources required to be OPERABLE are defined in ITS LCO 3.8.1. Specifically, two offsite sources, two DG sets and the load sequencers for Train A and B are required. He Bases for ITS Action I.1 is re-numbered from STS Condition H.1 and uses the same general wording contained in the STS discussing the severity of degradation associated with three or more AC sources inoperable. SNC believes that a detailed listing of all possible combinations of inoperable sources is not necessary. However, a statement has been added to the STS standard i

wording to assist the user in recognizing this level of AC source degradation.

NRC Question:

r 3.8.1-24 Bases discussion forITS SR 3.8.1.3 Page B 3.8-18 The second paragraph in the discussion of SR 3.8.1.3 on Pg. B3.8-18 includes a discussion of load bands. His is inappropriate since load bands are not included in the TS.

Comment: ne material should be deleted.

SNC Response:

SR 3.8.1.3 requires that the DG be synchronized, loaded and operated for 2 60 minutes at a load 2 j

2700 kW and s 2850 kW for the 2850 kW DG and 2 3875 kW and s 4075 kW for the 4075 kW i

DGs. Herefore, the discussion ofload bands is appropriate and should be retained.

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NRC Question:

3.8.1-25 Bases discussion forITS SR 3.8.1.18 Page B 3.8-22 De Bases for ITS SR 3.8.1.18 on Pg. B3.8-22 do not appear to be correct.

Comment: The purpose of the full load rejection test is to ensure the DG does not trip on overspeed following tH rejection. It was never intended that the DG output breaker remain closed during this test. See also comment for ITS SR 3.8.1-13 above.

SNC Response:

As discussed in the response to Question 3.8.1-13, the general issue of DG load rejection was addressed with the NRC in the early 1980s. Durmg the discussions, the NRC informed Farley of an event at a nuclear station during which a DG experienced load rejection greater than the single largest load that caused damage to safety related equipment due to voltage transients. In light of that information, Farley agreed that load rejection tests confirming equipment remaining connected would be not affected was worthwhile. It was agreed that such tests would be performed every five years and the load rejected during the tests would be approximately 50% of rating. He Bases discussion in the submittal for ITS SR 3.8.1.18 provides an explanation of the reasoning for maintaining the requirements of the CTS.

Page 10 of 39

l SNC Resp:nse to NRC RAI Rel ted ta Ch:pter 3.8 Please refer to the letter from E. A. Reeves, NRC to F. L. Clayton, Alabama Power Co. dated March 1,1982, transmitting Amendment 26 to Facility Operating License No. NPF-2, Page 12 and 13 for complete details regarding this subject.

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NRC Question:

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3.8.1-26 Bases discussion forITS SR 3.8.1.13 I

Page B 3.8-28 The Bases discussion for ITS SR 3.8.1.13 on Pg. B3.8-28 includes a reference to a load band.

The FNP TS do not incorporate load bands, and this should be deleted from the Bases.

SNC Response:

The following sentences have been deleted from the Farley ITS Bases for SR 3.8.1.13: "%e load

)

bnd is provided to avoid routine overloading of the DG. Routine overloads may result in more I

frg.nent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY."

3.8.2, AC Sources - Shutdown NRC Question:

3.8.2-01 CTS LCO 3.8.1.2 DOC 1A CTS LCO 3.8.1.2 includes the phrase "as a minimum" prior to listing the required AC sources.

As discussed in DOC 1A, it is proposed to delete this phrase, and the change is classified as Administrative.

Comment: He staffdoes not agree that this is an Administrative change. He wording of the CTS implies that more than one offsite circuit and more than one DG may be required during shutdown. He licensee has not addressed this potential for requiring additional AC sources. He DOC (& CTS markup) should be revised to address this issue.

SNC Response:

Exchding "as a minimum," CTS LCO 3.8.1.2 states "the following A. C. electrical power sources shall be OPERABLE" and requires one circuit from the offsite transmission network through the switchyard to the Class IE distribution system and one DG. He STS LCO 3.8.2 requires one circuit between the offsite transmission network and the Class IE distribution system and one DG. Herefore, the requirements of the CTS modified by the phrase "as a mimmum" (e.g., the least permissible quantity of AC sources) are reflected in the ITS. As noted in DOC 1A the CTS phrase "as a minimum" is deleted to be consistent with the phrasing of the ITS.

Page 11 of 39

SNC Resp:nse ts NRC RAI Rel ted ts Ch:pttr 3.8 he availability of offsite sources and DGs in practice is frequently more than the minimum required by the CTS LCO during shutdown. However, there is no requirement nor implication in the CTS due to the phrase "as a minimum" that more than one offsite circuit and one DG is required during shutdown. Therefore, SNC maintains that the change described by DOC 1A is indeed administrative in nr.tre and there is no need to revise the DOC and/or the CTS markup.

l NRC Question:

3.8.2-02 ~-

ITS LCO 3.8.2.b ITS LCO 3.8.2.b requires one Diesel Generator to be OPERABLE. In ITS LCO 3.8.1, the DG requirements are stated in terms of DG " Sets."

Comment: Should the requirement in ITS LCO 3.8.2.b be for one DG set as opposed to just one DG7 He licensee is requested to revise the ITS, or provide ajustification for why LCOs 3.8.1 and 3.8.2 use different terminology.

SNC Response:

During operation in Modes 1-4, two DG sets (one to supply Train A and one to supply Train B electrical distribution systems) are required operable. The DG sets are comprised ofindividual

)

DGs 1-2A and IC for Train A of both units and DG IB and DG 2B for Train B of Units 1 and 2 j

respectively. He Train A set for both units is comprised of I-2A and IC due to logic that automatically aligns 1-2A to the accident unit and IC to the other unit during a SI/LOSP event.

Both DG sets are required operable during Modes 1 through 4 on either unit to provide read y of onsite AC sources.

During Modes 5 and 6 while moving irradiated fuel, one DG capable of supplying one train of electrical distribution on the shutdown unit is required. CTS 3.8.1.2b for Unit I requires DG l-2A or 1C or IB operable. For Unit 2, DG l-2A or IC or 2B must be operable. Therefore ITS LCO 3.8.2 is correct as submitted in requiring one individual DG operable instead of a DG " set."

NRC Question:

3.8.2-03 Bases discussion for ITS LCO 3.8.2 Page B 3.8-37 On Pg. B3.8-37 in the LCO 3.8.2 discussion, the paragraph which begins " Proper sequencing of loads..."is modified.

Comment: He staff does not understand the proposed modification. Do the proposed Bases mean that the sequencer performs some function associated with a DG start on loss of power or degraded voltage? He licensee is requested to explain in greater detail the meaning of the proposed Bases change. In addition, the licensee is requested to provide a discussion of how the sequencer functions, or does not function, in Modes 5 and 6.

Page 12 of 39

SNC Response ts NRC RAI Rel:ted to Chrpter 3.8 1

L SNC Response:

I Many electrical loads required operable and available for sequencing in Modes 1 through 4 are j

not required to be operable in Modes 5 and 6. In addition, the timing of sequenced loads required

(

(and assumed in accident analysis) during Modes 1 through 4 is not required in Modes 5 and 6 because operating mode accidents are not possible during shutdown. Finally, due to lower decay heat and pressure / temperature conditions in Modes 5 and 6, any required electrical loads can be manually started if necessary. Therefore the ability of the sequencer to properly sequence ESF loads is not a safety requirement in Modes 5 and 6.

In the event of degraded voltage during Modes 5 and 6, the sequencers are required to sense the condition, trip ESF bus offsite supply breakers and initiate DG start and breaker closure. He j

sequencers are also required to initiate DG start and breaker closure for LOSP events during Modes 5 and 6. Any load normally sequenced during Modes 1 through 4 thatis in service during either of the above events while in Modes 5 and 6 will receive a start rignal at the appropriate sequence step following DG breaker closure. However, as stated above, the sequencing of such j

loads is not required from a safety standpoint during Modes 5 and 6.

3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air j

NRC Question:

3.8.3-01 DOC M.1, JD 5 ITS SR 3.8.3.1 CTS 3.8.1.1 item b.3 CTS 4.8.1.1.2 (1) Condition A of LCO 3.8.3 as well as SR 3.8.3.1 address the " useable" volume of fuel oilin the storage tanks. However, the term "useabls"is not defined in the Bases for either TS.

Consequently, the TS have no real meaning.

(2) CTS 3.8.1.1 item b.3 states that each EDG shall be equipped with a fuel storage system containing a minimum of 25,000 gallons of useable fuel for each required EDG. CTS 4.8.1.1.2.a.2 requires verifying the fuel level in the fuel storage tanks. Rese requirements have been retained in corresponding ITS SR 3.8.3.1 in accordance with the STS.

Comment:

(1) he licensee should define what is meant by " useable" volume of fuel oil, or, revise the TS to state a volume that includes the unusable volume of fuel oil in the storage tanks, JD 5 does not provide any clarification on this issue.

(2) Nojustification has been provided to support this proposed admmistrative change. Revise the submittal to provide the appropriatejustification for the proposed change.

SNC Response:

He useable volume of fuel oil available in a storage tank is tid amount above the pump suction piping nozzle available for transfer from the storage tank to the DG day tank. Since the suction nozzle (s) are located some distance above the bottom of the tank (s), the volume between the bottom of the tank (s) and the nozzle (s) is not considered uscable fuel.

Page 13 of 39

i SNC Resp:nse ts NRC RAI Rel.ted ts Chrpt:r 3.8 l

I Comment 1: JD 5 has been revised to address this comment and a definition of" useable" fuel has been incorporated in the Background section of Bases Section 3.8.3.

Comment 2: DOC 3A addresses relocation of CTS 3.8.1.1 LCO requirements for DG auxdiary

)

systems to the appropriate sections of the STS. This DOC combined with the clarifications added as a result of Comment 1 provide the appropriate detail and explanation of the conversion from CTS to ITS.

NRC Question:

I 3.8.3-02 DOC M.1 '

-1TS 3.8.3 Condition A, Required Action A.1, and Completion Time CTS 3.8.1.1 item b.3 C TS 4.8.1.1.2.a.2 Condition A for ITS 3.8.3 addresses one or more DGs with fuel level < 25,000 gal and > 21,000 gal in the storage tank. Required Action A.1 requires to restore fuel oil level to within limits with a Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in accordance with the STS. This is a proposed change relative to the Actions associated with corresponding CTS 3.8.1.1 item b.3 and 4.8.1.1.2.a.2.

Comment: This proposed change has been categorized as more restrictive. 'lhe proposed change appears to be less restrictive. Revise the submittal to provide the appropriatejustification for the proposed change.

Additionally, DOC M.1 does not explain why 21,000 gal is acceptable. Revise the submittal to explain why this value is acceptable.

SNC Response:

J The only place that a DOC 1-M (not M.1) was found related to this issue was the DOC associated with the addition of a new TS (ITS 3.8.3). As stated in that DOC, the addition of requirements for DG lube oil, startmg air receiver pressure, and fuel oil properties represent new TS requirements not explicitly addressed by the CTS. Therefore, the addition of a new TS is more restrictive. However, it was noted that there is no DOC addressing the conversion of CTS DG j

fuel oil volume requirements in CTS 3/4.8.1.1 to the STS (including the 6-day supply). As a result, DOC 3a-L for CTS 3/4.8.1.1 and the accompanying SHE have been developed and are included in the revised submittal.

l

, Page 14 of 39

SNC Resporse t3 NRC RAI Rited ts Chrpt:r 3.8 i

NRC Question:

3.8.3-03 ITS LCO 3.8.3 E, ACTION El 1

JD 2 Proposed Condition E of LCO 3.8.3 states "... with the required starting air receiver pressure...".

Proposed Action E.1 states " Restore at least one starting air receiver pressure...". Dese requirements are not fully understood, and the proposed Bases do not provide much clari6 cation.

He licensee should provide a more detailed description of the DG starting air systems in JD 2 to assist in understanding the above requirements. He discussion should address such things as the independence, redundancy, and capacity of the DG startmg air receivers. As appropriate, some or all of this information should also be in included in the Bases.

SNC Response:

)

l Each DG startmg air system consists of dual 100% capacity compressors, dryers, receivers and

)

associated piping and valves. Each receiver is of sufficient volume to supply air to start its l

respective DG five times. Since either redundant system associated with a DG is capable of providing air for five starts, restoration of at least one receiver to above the minimum pressure i

restores the system operability. This is the basis for the proposed Action E.1. Information similar to that above has been added to JD-2.

l l

The Background section for Bases 3.8.3 has a description of the system modified with FNP f

specifics on Page B 3.8-41. SNC believes that this is sufficient information for use by plant

{

personnel who are already familiar with the FNP design.

NRC Question:

3.8.3-04 Bases discussion for ITS LCO 3.8.3, ACTION A.1 Page B 3.8-43 In the Bases discussion for Action A.1 on Pg. B3.8-43, the word "a"is deleted and "the required"

'is substituted. He staffdoes not understand the purpose of this change. LCO 3.8.3 allows separate Condition entry for each DG, so the NUREG Bases discussion addressed a single DG.

In addition, in Modes 1 through 4,2 DG sets (3DGs) are required to be OPERABLE, notjust one.

Comment: The licensee is requested to review this proposed change and provide ajustification forit other than PSE.

i Page 15 of 39

n SNC Resp:nse ts NRC RAI Related ta Ch:pter 3.8 SNC Response:

h DGs at FNP are connected to the fuel oil transfer and storage system. He system consists of j

storage tanks, transfer pumps, piping and valves. He system is arranged to permit transfer of fuel from storage tanks to DG day tanks and between storage tanks as well. He storage tanks have the capacity at the minimum permissible fuel volume of 25,000 gallons to supply the required DGs for 7 days operation supplying post LOCA electricalloads. %e Applicability of the LCO is stated as,"When associated DG is required OPERABLE." As the capability to transfer fuel oil between storage tanks exists, there could be times when not all DGs are required to be OPERABLE and transfer of fuel oil between storage tanks could cause a reduction below the minimum level in a tank neintM with a non-required DG. He wording in the Bases for Action A.1 is revised, consistent with the Applicability, to clarify that the Condition only applies to the tanks supporting " required" DGs. For purposes of additional clarification, the proposed change will be modified from "the required DG" to "the required DG(s)."

l NRC Question:

3.8.3-05 Withdrawn by NRC f

I NRC Question.

3.8.3-06 Bases discussion forITS SR 3.8.3.1 Page B 3.8-45

% staff questions the meaning of" useable" as used in the Bases discussion for SR 3.8.3.1 on Page B 3.8-45. See comment 3.8.3 1. Revise the Bases as necessary. Also, in this Bases discussion, the word "each"is deleted and "the required"is substituted. He staff does not j

I understand this change. The licensee is requested to provide ajustification for this change other than PSC. See comment 3.8.3-3.

SNC Response:

i As stated in the Response to Comment 3.8.3-1, a definition of the term " useable" has been added to the Background section of the Bases Section 3.8.3 on Page B3.8-41. He purpose of the i

proposed change from "each" to "the required" is specific to the FNP design as described in the response to Comment 3.8.3-04. The proposed change will be modified from "the required DG's operation" to "the operation of the required DG(s)" to correct punctuation from singular to plural since more than one DG may be required.

NRC Question.

1 3.8.3-07 Withdrawn by NRC 1

Page 16 of 39 b

I SNC Rcspoose t2 NRC RAI Related to Cbrptir 3.8 NRC Question:-

-3.8.3-08 Withdrawn by NRC '

1 NRC Question:

i

. Withdrawn by NRC.

3.8.3-09

~

3.8.4, DC Sources - Operating

]

NRC Question:

3.8.4-01 CTS LCO 3.8.2.5 ITS LCO 3.8.4 CONDITION D DOCSL The proposed change to the Action in CTS LCO 3.8.2.5 is acceptable except for the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> delay in declaring the Service Water Train inoperable.

Comment: If any other component of the Service Water Train becomes inoperable, the action is that the Train is immediately inoperable. Here is no delay. Derefore, there should be no delay

===~iaud with the battery. De 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is more than adequate to do what is ec~ y to restore the battery to OPERABLE status. (See DOC SL)

SNC Response:

The two-hour delay has been deleted. De package has been revised to require that upon determination that the SWIS DC electrical power subsystem is inoperable, the associated service water system train is declared inoperable immediately.

NRC Question:

3.8.4-02 ITS SR 3.8.4.2 CTS SR 4.8.2.5.2.c.2 and 3 ITS SR 3.8.4.2 addresses connection resistance " post to post." The CTS SR 4.8.2.5.2.c.2 and 3 address cell-to-cell and terminal connections.

' Comment: What is the difference between the proposed ITS and the CTS? Why is it acceptable? JD3 does not provide adequate information in this area. Note that proposed ITS SR 3.8.4.5 addresses cell-to cell and terminal connections.

)

- Page 17 of 39

SNC Response to NRC RAI Relited t2 Ch:pter 3.8 4

i i

SNC Response:

CTS 4.8.2.5.2.c.3 states "'Ihe resistance of each cell-to-cell and terminal connection is less than or equal to 1500 micro-ohms from post to post." Cell-to-cell connectors are bolted to the terminal posts of adjacent battery cell jars. A connection on one battery cell termmal post does not constitute the complete cell-to-cell connection; rather, the connector (s) and both bolted f

connections to the terminal posts of the adjacent celljars do. He resistance is measured from j

" post-to-post" to ensure the total resistance of each bolted connector to terminal post interface j

and the connector itselfis reflected in the measurement. Onussion of the words " post to post" i

from ITS could lead to the interpretation that the resistance of a singular connector to terminal post interface must be less than 1500 micro ohms. This would be non-conservative in that the connecto resistance and that of the other connector / terminal post interface would not be included.

l The phrase " post-to-post" proposed for inclusion in ITS merely reflects wording that exists in the CTS. JD3 has been revised to provide more detail. As noted in the question, cell-to-cell and terminal connections are addressed in SR 3.8.4.5. Herefore, for consistency, the phrase "of each cell-to-cell and terminal connection" will be added following " battery connection resistance" to ITS SR 3.8.4.2.

NRC Question:

3.8.4 03 Bases for ITS SR 3.8.4.8, STS Bases markup page B 3.8-57 Bases for STS SR 3.8.4.8 The Bases for STS SR 3.8.4.8 states the that a battery performance discharge test is "normally done in the as found condition." His statement has not been adopted in the Bases for corresponding ITS SR 3.8.4.8.

Comment: Nojusti6 cation has been provided to support this proposed difference. Revise the submittal to provide the appropriatejustification for the proposed difference, or conform to the STS.

SNC Response:

No specific justifications are provided in the submittal for Bases only changes, only for changes i

to the TS. The following provides information to support this proposed difference. He CTS Bases state that battery surveillances are based on the recommendations ofIEEE 450-1980.

Section 5 of the standard entitled " Capacity Test Schedule" states that tests are used to: 1) determine whether the battery meets its specification or the manufacturer's rating, or both; 2) periodically determine whether the rating of the battery, as found, is holding up; and 3) if required, determine whether the battery meets the design requirements of the system to which it is connected.

Item 1 applies to Acceptance Tests performed on new batteries following initial installation. Item 2 applies to Performance Tests performed within the first two years of service and eve y five years thereafter. Item 3 applies to Service Tests that are performed every 18 months at FNP.

Page 18 of 39.

SNC Response ts NRC RAI Rel ted to Chrptzr 3.8 Section 5.2 (1) ofIEEE 450 regarding performance tests states," Initial conditions shall be as described in 6.1, omitting requirements (1) and (2). Results of this test reflect all factors, including maintenance, that determine the battery capability. It is desirable for comparison purposes that the performance tests be similar in duration to the battery acceptance test (see 5.1).

If on a performance test the battery does not deliver its expected capacity, the test should be repeated after the requirements of 6.1 (1) and (2) have been completed."

Initial Condition 6.1 (1) states, " Verify that the battery has had an equalizing charge completed more than 3 days and less than 7 days prior to the start of the test." Initial Condition 6.1 (2) states, " Check all battery connections and make sure that all connectors are clean, tight, and free ofcorrosion."

As stated in NUREG 1431 at the bottom of Page B 3.8-57, "%e test is intended to determine overall battery degradation due to age and usage.":In order to assess whether a battery has.

undergone degradation, it is necessary to compare the results ofperiodic performance tests with the results of the acceptance test performed upon initial installation. As such, Farley procedures for performance tests require completion of equalizing charges as prerequisites. His is necessary to ensure the batteries are in the equivalent fully charged state as they were when acceptance tests were initially performed. His permits like for like comparison of performance test results with acceptance test results in' determining the amount of degradation batteries have undergone due to age and usage.

Since the testing is performed following completion of equalize charges, the phrase "normally done in the as found condition"is not included in the bases discussion for ITS SR 3.8.4.8.

Deletion of the phrase makes the statement correct in that the FNP performance tests provide indication of degradation due to age and usage. He FNP approach is in accordance with IEEE 450 Initial Conditions 6.l(1) and (2) which are permissible prior to performance tests when effects of maintenance are not under consideration.

NRC Question:

3.8.4-04 ITS SR 3.8.4.6 JD 5, JD if The proposed changes to ITS/NURfG SR 3.8.4.6 are confusing. The change to add " required" to the SR is interpreted by the :taff to mean that the battery charger (s) for which credit is taken to satisfy the LCO must be subject to the SR. This is contrary to the SR Note proposed for deletion as discussedin JD 5.

i Comment: De purpose of the Note is to preclude conducting this SR on a battery charger for which credit is taken to satisfy the LCO. Consideration should be given to retaining the Note in a revised form which states that the SR will not be conducted on the required battery charger (s) in Modes 1,2,3, or 4.

SNC Response:

De FNP design for the Auxiliary Building Batterie:: includes battery chargers dedicated to each train and a spare charger that can be aligned to either train. His allows the spare charger to be aligned to either train when a train related charger is taken out of service for maintenance or testing. The SWIS Battery design includes redundant batteries and chargers (two of each) for Page 19 of 39 j

l i

SNC Resp:nse 13 NRC RAI Rel:ted t2 Chrptir 3.8 cach train. Either SWIS battery / charger on a given train may be placed in service to supply its associated SWIS DC train while the other is out of service for maintenance or testing. 'Iberefore, the design of both DC systems provides operational flexibility that eliminates the need to prohibit

. testing of chargrrs dedicated to a given train during Modes 1 through 4.

The staffinterpretation on insertion of the word " required"is correct in that it means chargers

)

used to satisfy the LCO must be subjected to the SR testing. As discussed above, any charger can j

be taken out of service and tested because a spare or redundant battery / charger is available to maintain operability of the DC train. As such, SNC intends to maintain the deletion of the note that prohibits testing of chargers in Modes 1 through 4 consistent with the CTS.

JD 5 has been revised to specify that any of the chargers may be tested without affecting

]

battery / battery charger operability.

NRC Question:

3.8.4-05 ITS SR 3.8.4.7 JD 7 d

1 ITS/ NUREG SR 3.8.4.7 is not correctly worded.

Comment: It is the intent of Note 1 to allow a modified performance discharge test to be pe.ifur.d in lieu of the service test at anytime, notjust once every 60 months. A performance test, however, may only be substituted once every 60 months. In light of this, the licensee may wish to reconsider proposed changes to this SR.

I SNC Response-Based on the Staff suggestion in RAI 3.8.4-07, SNC has elected to adopt the additional option for j

modified performance tests with exceptions discussed in the response to 3.8.4-07. CTS SR 4.8.2.3.2.d allows a performance discharge test in lieu of a service discharge test (CTS SR 4.8.2.3.2.c.5) once per 60 month interval. In order to maintain the current licensing basis and adopt the Staff suggestion in RAI 3.8.4-07, Note 1 affecting SR 3.8.4.7 will be revised to allow j

performance discharge tests in lieu of service tests once per 60 months. Consistent with IEEE-450 and the Staff's interpretation, an additional note will be added which allows modified performance discharge tests in lieu of service tests at any time. 'Ibe appropriate changes to the package are attached.

]

NRC Question:

3.8.446 ITS SR 3.8.4.7, Note 2.

39 g In SR 3.8.4.7, the Note is modified to be applicable to the Auxiliary Building batteries, only.

Comment: In light of the confusion with SR 3.8.4.6 identified above, it is suggested that the Note in this SR be further modified to include the required SWIS battery; i.e., this surveillance shall not be pe,ifvirc.ed on the Auxiliary Building batteries or the required SWIS batteries in Modes 1,2,3, or 4. 'Ihis comment is also applicable to the SR 3.8.4.8 Note.

Page 20 of 39

SNC Response is NRC RAI R:Jated to Chapttr 3.8 SNC Response:

SR 3.8.4.7 and 3.8.4.8 address battery service and performance discharge testing respectively.

'Ihis ter. ting renders batteries inoperable during performance and during subsequent recharging.

The STS note is not part of the CTS. 'Ibe note is modified to restrict performance of such testing during Modes 1 through 4 on the Auxiliary Building Batteries because there is only one battery per train in that DC subsystem. 'Ihe SWIS battery subsystem has two complete and redundant 100% capacity batteries per train. Only one of the two SWIS batteries per train is required to be in service during Modes I through 4. In addition, the out ofservice batteries can be placed in service and the in service batteries removed from service during normal operation. Mrefore, all SWIS battenes can be made available for service or performance discharge testing during any mode ofplant operation.

Considering the above, SNC intends to prohibit testing of the Auxiliary Building batteries during :-

Modes I through 4 and continue to maintain the ability to test the SWIS batteries in any mode of

. operation consistent with the CTS. Therefore, the original submittal will be maintained.

NRC Question:

3.8.4-07 ITS SR 3.8.4.8 JD 11 SR 3.8.4.8 includes an allowance to utilize a performance test or a modified performance test.

The licensee has cnosen to delete the provisions for a modified test.

Comment: 'Ihe licensee might wish to reconsider the proposed deletion. Inclusion of the modified performance test is a permissive, not a requirement. Including it in the SR does not impose any new requirements, but its exclusion means that a license amendment would be required ifit was ever decided to utilize a modified performance test.

SNC Response:

Farley battery performance testing is presently performed every 60 months (per CTS SR 4.8.2.3.2.d) at constant current utilizing the appropriate manufacturer's 2-hour discharge rates.

j

'Ihese constant current rates are significantly higher than the current demand imposed by the i

design load profile. As such the existing 60-month constant rate performance testing of the batteries is substantially more demanding than the 18-month service tests. The CTS also allows for the 60-month performance test in lieu of the 18-menth battery service test required by CTS SR 4.8.2.3.2.c.5.

The STS Bases discussion at the top of Page B 3.8-58 states that either the performance discharge or modified performance discharge test is acceptable to satisfy STS SR 3.8.4.8. It also states that only the modified performance discharge test may be used to satisfy both STS SR 3.8.4.8 and 3.8.4.7 at the same time. The latter statement constitutes an additional requirement not addressed by CTS.

Page 21 of 39

SNC Respo.se ta NRC RAI Rel:ted to Chrpter 3.8 i

ne additional flexibility eTorded by an option for modified performance discharge tests is not currently required at FNP by reasoning discussed in the first paragraph. However, future design changes may present a need to utilize such an option. Herefore, SNC proposes to adopt the staff suggestion that the modified performance test option of the STS be retained with the following exceptions: De modified performance discharge test may be used to satisfy SR 3.8.4.8 and 3.8.4.7 simultaneously at any time, consistent with IEEE-450; and the performance discharge test may be used to satisfy SR 3.8.4.8 and 3.8.4.7 simultaneously once per 60 months consistent with the FNP current licensing basis. De appropriate changes to the package are *M NRC Question:

3.8.4-08 Bases for ITS SR 3.8.4.2, STS Bases markup page B 3.8-54 Bases for STS SR 3.8.4.2 Bases for ITS SR 3.8.4.5, STS Bases markup page B 3.8-55 l

Bases for STS SR 3.8.4.5 He Bases for STS SRs 3.8.4.2 and 3.8.4.5 state that the limits established for this SR must be no l

more tlan 20% above the resistance as measured during installation or not above the ceiling vahe established by the manufacturer. His requirement has not been adopted in the Bases for corresponding ITS SRs 3.8.4.2 and 3.8.4.5.

Comment: Nojustification has been provided to support these proposed differences. Revise the submittal to provide the appropriate justification for the proposed differences.

SNC Response:

No specific justifications are provided in the submittal for Bases only changes, only for changes to the TS. He following provides information to support these proposed differences. Enclosure 5, JD 3 for FNP ITS 3.8.4 on Page E5-2 D addresses revision of connection resistance surveillance requirements in STS 3.8.4 to be consistent with the FNP CTS. The values of 150 micro-ohms for the Auxiliary Building and 1500 micro-ohms for the SWIS batteries have been annotated against SR 3.8.4.2 and 3.8.4.5 on Page 3.8-25 of the STS with reference to JD 3.

%e CTS value of 150 micro-ohms for the Auxiliary Building Batteries is based on STS values '

that were in effect during the mid-1980s. He 1500 micro-ohm value for the SWIS batteries was proposed by FNP during the same time frame based on the following points. He 60 cell SWIS batteries consist of 20 triple cell cases connected by 19 inter-cell connectors. He SWIS batteries have a design load profile of 30 amps for 1 minute followed by 3 amps ibr 119 minute.

Assuming all 19 connections at the maximum value, the total voltage drop at the 30 amp

- discharge rate is 0.855 volts. His value is approximated 0.7% of the nomhnal terminal voltage j

andis considered negligible.

The CTS values were approved in the Safety Evaluation by NRR Related to Amendment 59 for Unit I and Amendment 50 for Unit 2. Please refer to the Safety Evaluation transmitted by letter from Mr. Edward A. Reeves (NRC) to Mr. R. P. Mcdonald (Alabama Power Company) dated May 24,1985 for further clarification if necessary.

Page 22 of 39

g SNC Resp:nse to NRC RAI Relat:d ts Ch:ptir 3.8

. NRC Question:

3.8.4 09 Bases discussion forITS LCO 3.8.4 Page B 3.8-51 Insert IIis added to the Background discussion for LCO 3.8.4 on Pg. B 3.8-51. h insent states that the Auxiliary Building batteries are sized to furnish DBA loads without dropping below Il0V. & insert also states that there is no DBA scenario where the Auxiliary Building batteries will be acquired to supply DBA loads for more than one minute without charger support.

Comment: The staffis confused by these two statements. He licensee is requested to provide details on what the design capability of the batteries is with regard to accident loads and on what the relationship of the above statement is.

SNC Response:

Under accident conditions (LOSP or LOSP plus SI) the Auxiliary Building Batteries are required to provide power to safety-related loads for less than one minute until their respective battery chargers are re-energized by Diesel Generators. After that point in time, safety-related DC loads are supplied by the battery chargers. His design feature is the origin of the statement regarding

. no DBA scenario in which Auxiliary Building batteries are required to supply loads for greater than one minute without charger support.

He batteries are capable of providing the design loads for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> under LOSP or LOSP plus SI conditions assuming loss of a batrery charger with an end of terminal voltage of appraiWy i

110V. De two hour time is considered adequate for Operations to place tne spare charger in i

service in place of the postulated failed charger. Note that any such loss of a charger (or failure to sequence a charger on its DG) is considered a single failure leaving the redundant train to provide for safe shutdown.

The first paragraph ofInsert II for Basee Page B 3.8-51 has been clarified to address the staff concern.

NRC Question:

3.8.4-10 Bases discussion for ITS SR 3.8.4.1 Page B 3.8-54 De revised Bases for SR 3.8.4.1 on Pg. B3.8-54 includes a discussion where the float' voltage is j

stated as 2.2 volts per cell for an overall voltage of 132V.

]

Comment: SR 3.8.4.1 requires verifying a battery terminal voltage of 127.8V (or 2.12 volts per cell). He Bases and the TS do not agree. Which voltage is correct?

I i

SNC Response:

i

' As discussed in the Bases for SR 3.8.4.1, the 2.2V per cell for an overall terminal voltage of 132V is consistent with manufacturer recommendation. He ITS SR requirement to verify j

terminal voltage 2127.8V on a weekly basis is consistent with CTS SR 4.8.2.3.2.a.2. His l

surveillance demonstrates that the average of all cells is 2 2.13V per cell maintaining operability.

)

Float voltage is maintained at the higher value of 2.2V per cell to prolong cell life expectancy.

He Bases for SR 3.8.4.1 has been clari6ed to explain the different values, j

Page 23 of 39 j

SNC Resp:nse is NRC RAI Relited to Chrpter 3.8 NRC Question:

3.8.4 Bases discussion forITS SR 3.8.4.2 Page B 3.8-54 The revised Bases for SR 3.8.4 2 on Page B 3.8-54 includes a discussion of" post-to-post" resistance measurement.

Comment: He staff does not understand what constitutes " post-to-post" resistance measurement. %c licensee is requested to provide a discussion of what this means and how it related to cell-to-cell and terminal connections.

SNC Response:

The term " post-to-post" with respect to resistance measurements is proposed in the ITS consistent with CTS terminolo6y. Adjacent battery cells are electrically connected from the positive

]

terminal post of one cell to the negative terminal post of the next with inter-cell connectors. De connectors are bolted to the terminal posts of the adjacent cells for positive electrical connections.

He technique of measuring resistance " post-to-post" as used in the CTS and proposed in the ITS ensures that the resistance of both bolted connections and that of the inter-cell connector is 1

included in the measured readmg. He " post-to-post" measurement can be considered the same j

.as a " cell-to-cell" measurement. However, SNC considers the phrase " post-to-post" more descriptive because it requires measurements are to be taken from the terminal post of one cell through both bolted connections and the inter-cell connector to the terminal post of the adjacent cell. The phrase " terminal connection"is considered to be a singular bolted connection of an inter-tier /rackjumper lug or positive / negative cable lug connection to a battery terminal post.

l Considering the preceding discusion, SNC intends to continue the CTS terminology of" post-to-post" regarding cell-to-cell resistance measurements in the ITS due to the more descriptive nature and in the interest of maintaining continuity between the two documents.

NRC Question:

3.8.4 12 Withdrawn byNRC 3.8.5 DC Sources - Shutdown I

s Page 24 of 39

' SNC Resp:nse ts NRC RAI Rel:ted in Chrptzr 3.8 -

' NRC Question:

3.8.5-01 ITS LCO 3.8.5 CTS LCO 3.8.2.4 DOC 1M LCO 3.8.4 includes the Auxiliary Building batteries and the SWIS batteries. LCO 3.8.5, however, does not appear to include the SWIS batteries. What is thejustification for this? Is the

. Service Water System not required in Modes 5 and 67 Comment: Some revision to the LCO appears to be required. When making revision, consideration should also be given to the fact that, in some circumstances, more than one Aux.

Bldg., DC power subsystem maybe required in Modes 5 and 6. Also "DC electrical power subsystem" should be corrected to read "DC electrical power subsystem (s)"

SNC Response:

- STS LCO 3.8.4 addresses DC Sources during operation. LCO 3.8.5 generically addresses the

. minimum DC electrical power sources during Modes 5 and 6. De Background Section of Bases for LCO 3.8.5 states that a description of DC sources is provided in the Bases for LCO 3.8.4.

Insert HH written for the Bases of LCO 3.8.4, Page B 3.8-50 states that the 125VDC electrical

. power system consists of two main systems, the Auxiliary Building and SWIS systems.

He proposed Insert SS to LCO 3.8.5 for Page B 3.8-60 begins "The DC electrical power sources j

required to support the necessary portions of AC, DC and AC vital bus electrical power

]

distribation subsystems required by LCO 3.8.10," Distribution Systems - Shutdown" shall be OPERABLE." It further states, "At a minimum, at least one train of DC electrical power source (train A or B) consisting of one battery, one battery charger, and the corresponding control equipment and interconnecting cabling within the train, are requhtd operable." His is considered to require at least one train per subsystem (i.e., Auxiliary Building and SWIS DC electrical power sources.

Neither the Auxiliary Building nor the SWIS batteries are specifically. mentioned in the generic LCO 3.8.5 discussion. LCO 3.8.4 specifies both the Auxiliary Building and SWIS 125VDC systems as DC electrical power sources. Herefore, at least one train from each system is required during Modes 5 and 6 per the second requirement ofInsert SS to LCO 3.8.5 quoted above.

I Insert SS to LCO 3.8.5, aside from requiring at least one train of DC electrical power operable, also addresses cases where LCO 3.8.10 calls for portions of a second train of DC distribution i

systems to be operable. Since LCO 3.8.5 invokes the requirements of LCO 3.8.10 and references DC power sources defined by LCO 3.8.4, SNC submits that the wording of the STS as modified by Insert SS adequately addresses shutdown DC power requirements and that there is no need for revision.

~

De following is provided in response to the question on Service Water system requirements during Modes 5 and 6. Here are no Technical Specification LCO requirements for the Service Water system during Modes 5 and 6. However portions of at least one train of the system are

{

required to be functional to support the operation of other systems.

%c phrase "DC electrical power subsystem" at the beginning of LCO 3.8.5 on Page 3.8-28 will be clarified to "DC electrical power subsystem (s)."

Page 25 of 39

G

\\

1 j:

c.

SNC Response ts NRC RAI Related ts Chapter 3.8

' NRC Question:

- 3.8.5-02 Withdrawn byNRC NRC Question:

3.8.5-03 Withdrawn byNRC NRC Question:

3.8.5-04 Withdrawn by NRC NRC Question:

3.8.5 05 Withdrawn byNRC 3.8.6, Battery Cell Parameters NRC Question:

3.8.6-01 Withdrawn byNRC NRC Question:

3.8,6-02 Witadrawn byNRC NRC Question:

3.8.6-03 Withdrawn by NRC NRC Queuion:

3.8.6-04 Withdrawn by NRC Page 26 of 39

c. -

a SNC Resp:nse 13 NRC RAI Rel:ted 13 Chapt:r 3.8 NRC Question:

)

3.8.6-05 Withdrawn by NRC.

NRC Question:-

3.8.6-06 DOC 23L-CTS 3/4.8.2.3 Table 4.8-2 footnote (b)

ITS Table 3.8.6-1 DOC 23L includes a statement to the effect that "a stabilized charger current is an acceptable alternative to specific gravity measurements." ' Ibis statement is not euctly correct.

Comment:. IEEE-450 (1995) states that a stabilized float current is the most accurate indication of a abun to full charge followine a discharge. It does not say that float current is an acceptable alternative to specific gravity measurements at all times as the DOC would indicate.

Consideration should be given to revising the DOC.

SNC Response:

DOC 23L notes that CTS Table 4.8-2 Footnote (b) is revised to be consistent with Footnote (c) of STS Table 3.8.6-1. Footnote (c) states "A battery charging current of <2 amps when on float charge is acceptable for meeting specific gravity limits following a battery recharge, for a maximum of 7 days. When charging is used to satisfy specific gravity requirements, specific gravity of each 9===41 cell shall be measured prior to expiration of the 7 day allowance "

'Iberefore, the STS time limitation on use of stabilized charging current following a battery recharge is adopted. 'Ibe DOC has been revised to add the qualifying statement that stable charging current is an acceptable alternative to specific gravity readings following battery

~

recharge.

NRC Question:

3.8.6-7 CTS TABLE 4.8-2 Note (4)

TTS LCO 3.8.6, CONDITION A

'Ihc Actions of Condition A allow 31 days to restore Battery Cell Parameters to within Category A and B limits ofTABLE 3.8.6-1.

Comment: 'Ibe Category A and B float voltage per cell is 2.08 Volts. This voltage is

. inconsistent with the last part of Condition B which addresses the average cell float voltage as 2.13 Volts. Even if the Battery Cell Parameters met Category A and B limit, there is a high probability that Condition B'would apply; i.e., less than 2.13 Volts on average. It would appear that the values in ITS Table 3.8.6-1 need to be revised.

i Page 27 of 39

SNC Resp nse ts NRC RAI Rtlited ts Chrpter 3.8 SNC Response:

The battery cell parameters in ITS Table 3.8.6-1 have been revised consistent with FNP CfS values. %e CTS values were approved in the Safety Evaluation by Office of NRR Related to Amendment 59 for Unit I and Amendment 50 for Unit 2. This was transmitted by letter from Mr.

Edward A. Reeves (NRC) to Mr. R. P. Mcdonald (Alabama Power Company) dated May 24, 1985.

In the event the voltage of a cell (or cells) falls below 2.08V requiring entry into Condition A, all battery cell voltages must be verified above the Category C limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and once every seven days thereafter. %e cell voltages below 2.08V must be restored to the Category A and B 3

limits of 2 2.08V before the 31 day completion time of Action A.3. Durmg the 31-day period, the j

7 day frequency of SR 3.8.4.1 to " Verify battery terminal voltage is 2127.8V on float charge" will still be in effect. If terminal voltage measures less than 127.8V on any measurement the battery will have to be declared inoperable.

The minimum terminal voltage of 127.8V equates to an average cell voltage of 2.13V for 60 cell batteries. Therefore, for any cell or number of cells below 2.13V, an equal or greater number must be above 2.13V by an equivalent magnitude to maintain the terminal voltage at 127.8V.

1 Experience has shown that only one cell of a battery at a time is typically found to be below acceptable voltage limits. In an instance involving the very remote possibility of more than one cell falling below the Category A or B limit, the much larger population of cells with voltage

)

above 2.13V will maintain overall terminal voltage above 127.8V.

Derefore, SNC maintains that the additional condition of"One or more required batteries with the average cell float voltage s 2.13V" added to ITS LCO 3.8.6, Condition B and requiring j

declaration ofinoperability if not met, is both appropriate and conservmive.

j NRC Question:

3.8.6-8 ITS TABLE 3.8.6-1 SR 3.8.4 SR Table 3.8.6-1 is applicable to both the Auxiliary Building batteries and the SWIS batteries His means that footnotes b and c are also applicable to both batteries..

Comment: ne staff questions if the value of 2 amps on float charge is correct for the SWIS batteries. His is based primarily on the LCO 3.8.4 SR which requires that the SWIS battery charger be capable of supplying 3 amps for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. If the upper capacity of the battery charger is 3 amps, it would seem that the amperage on float charge would be substantially less than 3 amps.

De licensee is requested to verify whether or not 2 amps on float charge is appropriate for the SWIS batteries.

Page 28 of 39

SNC Response ts NRC RAI Reitted ts Ch:pter 3.8 SNC Response:

He SWIS battery chargers are rated at 12 emperes continuous. He requircment that the charger be capable of supplying at least 3 amperes for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is related to the capability of the charger to

)

recharge a battery while supplying duty cycle load of the batteries. The SWIS batteries have substantial capccity margin (better than double) beyond that required by the design duty cycle. In practice, determination that the current has stabilized is confirmed by consecutive measurements at one hour intervals with digital clamp-on ammeters. Actual stabilized values may be substantially less than 2 amperes for both large and small capacity batteries. However, the final values may vary over the life of a battery. Therefore, the standard stabilized charging current value of < 2 amperes from the STS following a recharge is appropriate for the SWIS batteries.

NRC Question:

3.8.6-9 Bases discussion for ITS LCO 3.8.6 Page B 3.8-64 In the Applicable Safety analysis for LCO 3.8.6 on Pg. B3.8-64, there is no mention of the SWIS batteries or their function.

Comment: Is this an oversight? Should these batteries not be discussed along with the Auxiliary Building batteries: Also, in the discussion for Action B.1 on Pg. B3.8-66, there is no mention of the SWIS batteries or the minimum temperature for these batteries.

SNC Response:

He Bases for 3.8.6 on Page B 3.8-64 deals with battery cell parameters for DC power sources in general terms. The Background section states that a discussion of these batteries and operability requirements is provided in the Bases for LCOs 3.8.4 and 3.8.5 (DC Sources Operating and Shutdown). The Applicable Safety Analysis for ITS 3.8.6 Bases does not specifically mention the Auxiliary Building or the SWIS Batteries. Detailed discussions of the Auxiliary Building and SWIS Batteries exist in the Background Discussion for LCO 3.8.4. Since the Auxiliary Building batteries are not specifically mentioned in the Safety Analysis, not mentioning the SWIS batteries, is not considered an oversight. Similar reasoning applies to the discussion for Action B.1 (see the answer to Question 3.8.6-10). %erefore, SNC does not mention either Auxiliary Building or j

SWIS batteries in the Bases for 3.8.6; but rather, adopts the existing generic terminology of the STS for battery cell parameters as submitted.

NRC Question:

3.8.6-10 ITS 3.8.6 Condition B Bases for ITS 3.8.6 Required Action B.1, STS Bases markup page B 3.8-66 Condition B for ITS 3.8.6 refers to "... < 60 'F for the Auxiliary Building batteries or < 35 'F for the SWIS batteries." He Bases for Required Action B.1 for ITS 3.8.6 refers to "... falling below 60 *F the minimum temperature limit." He Bases does not refer to the 35 *F temperature limit.

Comment: There is an apparent discrepancy between Condition B for ITS 3.8.6 and the Bases for Required Action B.1 for ITS 3.8.6. Revise the Bases to resolve the discrepancy.

Page 29 of 39

SNC Response to NRC RAI Rel:ted in Ch pt:r 3.8 i

SNC Response:

Page B 3.8-66 of the submittal is marked with changes addressing the subject of the question.

Specifically, under the bases for Condition B.1, "60 'F"is circled for deletion with the phrase

• %e minimum temperature limit" bubbled and marked for insertion in its place. The phrase "or the average cell float voltage s 2.13V"is also marked for insertion in the same sentence Herefore, as shown in the clean-typed version included in Volume 12 of the submittal, the entire sentence reads as follows, " Additionally, other potentially extreme conditions, such as not completing the Required Actions of Condition A within the required Completion Time or average electrolyte temperature of representative cells falling below the minimum temperature limit, or the average cell float voltage s 2.13 volts, are also cause for immediately declaring the associated DC electrical power subsystem inoperable."

The Background section for LCO 3.8.6 refers to discussion on operability requirements of the batteries in the Bases for LCO 3.8.4 and 3.8.5. Insert II to the Bases for LCO 3.8.4 speci6cally i

addresses individual minimum temperature limits for the Auxiliary Building and SWIS Batteries.

]

The statement in the Bases for Action B.1 for LCO 3.8.6 now mentions " minimum temperature limit" which encompasses the differing values of 60'F and 35'F for Auxiliary Building and SWIS batteries,respectively, in Condition B ofITS 3.8.6. Therefore, there is no discrepancy between the proposed Bases and the ITS.

NRC Question:

3.8.6-11 Bases for ITS Table 3.8.6-1, STS Bases narkup page B 3.8 48, second paragraph Bases for STS Table 3.8.6-1 He Bases for STS Table 3.8.6-1 states that the Category A float voltage limit is based on "... the recommendations ofIEEE-450, which states that prolonged operation of cells < [2.13] V can reduce the life expectancy of cells." This statement has not been adopted in the Bases for corresponding ITS Table 3.8.6-1, which refers instead to " operating experience."

Comment: Nojustification has been provided to support this proposed difference. Revise the submittal to provide the appropriatejustification for the proposed difference. Also, expand the Bases to explain how operating experience has shown the specified voltage limit value to be acceptable.

j SNC Response:

JD 7 briefly addresses Float Voltage and Specific Gravity sections of Table 3.8.6-1 noting that the revisions incorporate FNP CTS requirements. De CTS values were approved in the Safety Evaluation by Office ofNRR Related to Ameadment 59 for Unit I and Amendment 50 for Unit

2. His was transmitted by letter from Mr. Edward A. Reeves (NRC) to Mr. R. P. Mcdonald (Alabama Power Company) dated May 24,1985.

Page 30 of 39

SNC Respmse ts NRC RAI Reitt:d to Chrpter 3.8

%e Category A and B float voltage limit of 2.08V versus 2.13V per cell was approved based on the following: 1) cell float voltage by itselfis not a comprehensive indicator of the state of charge of a battery; 2) a single pilot cell can exhibit s2.13V while the battery itselfcan still perform its design function; 3) IEEE 450-1980 Appendix Cl does not consider a cell potentially degraded unless its voltage on float charge is 52.07V; and 4) in twenty different instances at FNP with at least one cell s2.13V, the minimum average specific gravity was 1.197 equating to approximately 90% capacity which is well above that required by the design load profile. Additionally, FNP adopted the requirement that the average float voltage be greater than 2.13V per cell (127.8V overall) in order for a battery to be considered operable.

JD7 and the Bases for Table 3.8.6.1 have been expanded to address the differences from the STS and origin of the numerical values in more detail.

NRC Question:

3.8.6-12 Bases for ITS Table 3.8.6-1, STS Bases markup page B 3.8-68,last paragraph Bases for STS Table 3.8.6-1 The Bases for STS Table 3.8.6-1 states that the Category B specific gravity limits are "... based on manufacturer's recommendations." His statement has not been adopted in the Bases for corresponding ITS Table 3.8.6-1, which does not provide a basis for the specified limits.

Comment: Nojustification has been provided to support this proposed difference. Revise the submittal to provide the appropriatejustification for the proposed difference. Also, expand the Bases to provide the basis for the specific gravity limits.

SNC Response:

JD 7 briefly addresses Specific Gravity sections ofTable 3.8.6-1 noting that the revisions incorporate FNP CTS requirements. He CTS values were approved in the Safety Evaluation by Office ofNRR Related to Amendment 59 for Unit I and Amendment 50 for Unit 2. His was transmitted by letter from Mr. Edward A. Reeves (NRC) to Mr. R. P. Mcdonald (Alabama Power Company) dated May 24,1985.

De STS limits at the time of the aforementioned Safety Evaluation for specific gravity were based on manufacturers recommended full charge value of 1.215. He STS Category A and B test criteria based on that value was 1.200 and 1.195 respectively. FNP batteries have manufacturers recommended specific gravity of 1.210 for the SWIS and 1.215 for the Auxiliary l

Building batteries. The Category A and B values are 0.015 and 0.020 lower than recommended full charge values. Derefore, the criteria of 1.195 and 1.190 for Category A and B were established based on the SWIS battery fully charged value of 1.210 and approved for both batteries.

j JD7 and the Bases for Table 3.8.6.1 have been expanded to address the differences from the STS and origin of the numerical values in more detail.

)

Page 31 of 39 j

SNC Response ts NRC RAI Retrted to Chrpter 3.8 3.8.7, Inverters - Operating

' NRC Question:

3.8.7 Withdrawn by NRC NRC Question:

3.8.7 02.

Withdrawn byNRC 3.8.8, Inverters - Shutdown NRC Question:

3.8.8-01 Withdrawn by NRC NRC Question:

3.8.8-02' CTS LCO 3.8.2.2 ITS LCO 3.8.8 DOCS 4M and SL De Action associated with CTS LCO 3.8.2.2 requires establishing containment integrity within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if the LCO is not met. The proposed ITS would replace this requirement with requirements to declare associated equipment inoperable Dr suspend core alterations and movement of irradiated fuel, etc. %ese changes are dirnM in DOCS 4M and SL. -

Comment: In order to assist the staffin determining the acceptability of the proposed changes, the licensee is requested to provide a discussion on how the CTS came into existence. Is there

. anything unique about Farley that would lead to a TS requiring containment integrity? Why is the Farley TS different from so many other plants?

SNC Response:

his requirement was included in the original Technical Specifications for both units. It is consistent with the revision ofNUREG-0452 in effect at the time. No additional information has been found as to the basis for this requirement.

NRC Question:

3.8.8-03

. Withf.rawn by NRC Page 32 of 39

SNC Response is NRC RAI RelatEd ts Chrpter 3.8 NRC Question:

3.8.8-04 Withdrawn by NRC '

NRC Question:

3.8.8 05 Withdrawn by NRC

- 3.8.9, Distribution Systems - Operating -

NRC Question:

3.8.9-01 Withdrawn by NRC NRC Question:

3.8.9-02 CTS LCO 3/4 8.2, Action b ITS LCO 3.8.9, CONDITIONS A and B DOC 9A CTS LCO 3/4 8.2, Action b is revised to read "one or more" AC vital busses inoperable. DOC 9A indicates that this is consistent with the CTS.

Comment: 'Ibe staffdoes not agree with DOC 9A. CTS Action b addresses one inverter inoperable with associated actions regarding the AC Vital bus. CTS does not address n.ultiple inoperabilities of AC Vital busses, and the proposed use of"one or more"is not acceptable.

t SNC Response:

In order to convert CTS LCO 3/4.8.2 into conformance with the format of the STS, the CTS section must be divided into two STS LCO sections, namely 3.8.7 and 3.8.9. LCO 3.8.7 addresses Inverters - Operating while LCO 3.8.9 addresses Distribution Systems - Operating.

CTS LCO 3.8.2.1 states,"The following A.C. electrical busses and inverters shall be OPERABLE and energized." It then lists the required 4160V busses and 600V load centers along

)

with 120V Vital AC busses A through D. 'Ibe Vital AC busses are required to be energized from Inverters A through D connected to their normal supply sources.

i Page 33 of 39

SNC Resp:nse ta NRC RAI Reitted to Chapt:r 3.8 The CTS LCO is goserned two actions (a and b). Action a. states "With less than the above complement of A.C. busses OPERABLE and energized restore the inoperable busses to OPERABLE and energized status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUrDOWN with the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />." He CTS statement of "less than the above compliment of A.C. busses OPERABLE" infers that action is required for any one or more of the required busses inoperable or not energized. Since all listed busses are affected by Action a, one or more AC Vital Bus (es) and inverter (s) could be inoperable under CTS with action pres cribed to restore operability or commence shutdown.

Action b. of the CTS LCO states " With one inverter inoperable, energize the associated A.C.

)

Vital Bus within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, restore the inverter to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDB Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUrDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. His is moved to ITS LCO 3.8.7 Condition A with the same actions as the CTS except of restoration of the associated vital bus to operable status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> which is required under r

ITS LCO 3.8.9 Action B.

As discussed above, conversion to the STS requires division of CTS LCO 3.8.2.1 into two parts, distribution (including vital busses) and inverters. CTS Action a. currently has provisions for corrective actions to be taken with less than the required complement of AC busses (including vital) operable. His is equivalent to having one or more bus (es) inoperable. nerefore the CTS addresses situations where multiple busses are inoperable. De wording of STS LCO 3.8.9 however, does not address such a situation. %crefore, the ITS LCO 3.8.9 Action A and B wording is revised to address "one or more" busses and maintain the CTS requirements. STS LCO 3.8.9 Action E imposes the additional requirement to immediately enter LCO 3.0.3 in the event two trains are inoperable resulting in loss of safety function. He CTS requirement for inverters is relocated to ITS LCO 3.8.7 addressing the action required tbr one inoperable inverter.

Aside from DOC 9A discussing this change, JD 1 for FNP TFS 3.8.9 on Page E5-1 G of the submittal provid:s detailed information regarding the rationale for changes to the STS.

Considering the above, SNC maintains that the changes as submitted are apprcpriate and maintain the requirements of the CTS in the format of the STS.

NRC Questica:

3.8.9-03 CTS 3/4.8.2.5 Action ITS LCO CONDfrIONs E and F DOC 5L He proposed change to the Action in CTS LCO 3.8.2.5 and proposed insert O are acceptable except for t'se 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> delay in declaring the Service Water Tmin inoperable.

Comment: If any other component of the Service Water Tmin becomes inoperable, the Action is that the Train is immediately inoperable. There is no delay. Derefore, there should be no de!ay

, associated with the DC distribution subsystem. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is more than adequate f.o do what is necessary to restore the distribution subsystem to OPERABLE status.

(See DOC SL).

Page 34 of 39

SNC Resp:nse t2 NRC RAI Rellt:d to Chrptir 3.8 l

l SNC Response:

He two-hour delay has been deleted. He package has been revised to require that upon determination that the SWIS DC electrical power distribution subsystem is inoperable, the associated service water system train is declared inoperable immediately. In addition, as this is an immediate action upon entry into this condition, the second completion time of"16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to meet LCO" has been deleted from the Condition for the inoperability of the SWIS DC electncal power distribution subsystem.

NRC Question:

3.8.9-04 ITS LCO 3.8.9 CONDITION B' CTS LCO 3.8.2.1 Action b JD 1 Proposed Condition B for LCO 3.8.9 allows "one or more" AC Vital busses to be inoperable.

His is a change from the NUREG that is covered by JD 1. JD 1 states that the change is consistent with the CTS.

Comment: De staff does not agree with the justification stated in LD 1. CTS LCO 3.8.2.1, Action b addresses one (not one or more) inverters inoperable, and, in CTS, the inverters and AC Vital busses are linked together. The proposed change to the NUREG is not acceptable, and the submittal should be revised.

SNC Response:

CTS LCO 3.8.2.1 lists AC electrical busses and inverters that are required operable and energized. He four 120V Vital AC busses are included and are specified as energized from i

inverters connected to their respective power sources. The LCO and therefore the list of busses is governed by two action statements. Action a. applies when "less than the required complement" (e.g., all of the listed busses) are operable and energized. It requires restoration of the inoperable busses to operable and energized within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or to commence plant shutdown. De phrase "less than the required complement" applies if one or more busses are inoperable. Action b.

addresses one inverter inoperable and requires energizing the associated AC Vital bus within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, restoring the inverter to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or commencing plant shutdown if restoration of the inverter is unsuccessful.

%e conversion of the CTS LCO to the STS format requires separation into LCO 3.8.9 requiring

' busses (including vital) to be operable and LCO 3.8.7 requiring inverters operable. The bus operability requirements of CTS LCO 3.8.2.1 are transferred to STS LCO 3.8.9 while inverter i

operability is moved to LCO 3.8.7.

De format of LCO 3.8.9 includes Actions A and B addressing an inoperable AC electrical power

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distribution subsystem and an inoperable AC Vital bus respectively. He CTS Action A phrase "With less than the above complement of A. C. busses OPERABLE and energized"is changed to "One or more AC electrical power distribution subsystems inoperable" for LCO 3.8.9 Action A and "One or more AC vital busses inoperable" for LCO 3.8.9 Action B.

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SNC Resprnse ts NRC RAI Related ts Chapter 3.8 De CTS Action b. phrase of"With one inverter inoperable..."is converted to LCO 3.8.7 Action A phrase of"One required inverter inoperable." Dese changes maintain the requirements of the CTS in the STS format and converts "less than the above complement of A.C. busses OPERABLE..." to the equivalent "one or more" inoperable.

SNC maintains the changes discussed above, in response to Question 3.8.9-02, DOC 9A and in JD1 to STS LCO 3.8.9 are appropriate and maintain the FNP specific requirements of the CfS in the format of the STS.

1 NRC Question:

3.8.9-05 Bases Background discussion for ITS LCO 3.8.9 Page B 3.8-79 The Background discussion for LCO 3.8.9 on Pg. B 3.8-79 appears to need some correction.

i Comment: %e Bases discussion indicates that each 4.16KW ESF bus has a dedicated onsite DG associated with it. At FNP, this is not entirely true. Busses 10 and 2G have dedicated DGs, but busses IF,2F, IK, and 2K share DGs 1-2A and IC. He Bases should be revised accordingly.

SNC Response:

i ne Background discussion for LCO 3.8.9 has been revised to elimmate the word " dedicated" j

before "onsite diesel generator (DG) source." He Background discussion for LCO 3.8.9 refers to more detailed information regarding the DGs in the Bases for LCO 3.8.1.

t NRC Question:

. 3.8.9-06 Bases discussion for ITS 3.8.9 ACTION B.1 Page B 3.8-83 l

In the discussion for Action B.1 on Pg. B3.8-83, the term "or more"is added between "one" and' "AC Vital bus".

Comment: He staff does not agree with this change. %e Bases should be revised (See above comment for LCO 3.8.9 Condition B, RAI item 3.8.9-04.)

SNC Response:

SNC maintains that the change to address "one or more" vital busses for Action B.1 of LCO 3.8.9 is appropriate and merely converts a portion of the requirements of CTS LCO 3.8.2.1 to the format of the STS. Please refer to the responses to RAI 3.8.9-02 and 3.8.9-04.

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SNC Response t NRC RAI Rel:ted ta Chrpter 3.8 NRC Question:

3.8.9-07' Bases discussion for ITS LCO 3.8.9 CONDITIONS E and F Page B 3.9-86 Insert 00 on Pg. B3.8-86 adds the Bases for Condition E and Condition F to this LCO. Condition E add esses "one or more" SWIS DC electrical power subsystems inoperable.

Comment:

(a) %e staff does not understand the use of"one or more". Although there are 4 SWIS DC electrical power subsystems, only two are required. Assuming that only the required subsystems are covered by TS, more than one subsystern results in a loss of function. Herefore, use of"one or more"is inappropriate and is not acceptable. In addition, the Bases for the SWIS DC electrical power subsystems includes wording that allows the subsystems to be considered OPERABLE when powered by the battery charger, only. De licensee has not provided an adequate justification for this Bases. De licensee should provi:le a detailedjusti6 cation for this change which address the fact that CTS does not include this allowance.

(b) Condition F allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore the inoperable DC subsystem before declaring the

- service water system inoperable. The staffdoes not agree with this allowance. See comment 3.8.9-2. Bases changes are necessary.

SNC Response:

(a)

Insent HH to Bases for DC Sources - Operating on Page B3.8-50 provides a detailed description of the SWIS 125 VDC system. As noted, the system consists of four battery / charger subsystems (two for Train A and two for Train B) that are shared between units. Each subsystem is capable

. of supplying 100% of the DC power requirements on both units for its respective train. These are normally aligned with one battery / charger in service and the other in standby on each train. It is i

permissible to have a battery / charger set out of service on each train and still meet Service Water safety function requirements. Herefore, one battery / charger subsystem is required operable on each train as a DC source.

l LCO 3.8.9 addresses distribution systems during operation. He listing of all distribution busses,

required operable is presented in Table B 3.8.9-1 on Page B 3.8-88 as modified by Insert QQ with j

FNP specific detail The SWIS 125 VDC Distribution Panels required include 1 and 2M for Train A and I and 2N for Train B. While only two DC sources are required by LCO 3.8.4, all i

four 125 VDC Distribution Panels are required by LCO 3.8.9. Since both units' panels on either train are normally supplied by one of the two DC sources for that train as described in LCO 3.8.4 it is possible to have more than one panel inoperable (i.e., both units' panels from one train) without loss of function. Herefore, the phrase "one or more"is utilized in Bases E.1 description.

De original submittal OO to Bases Page 3.8-86 contains a statement in the Bases for Action E.1 that a SWIS DC subsystem must be restored to operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by powering from an associated SWIS battery or charger. This condition has been deleted (see item (b) below).

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SNC Resp:nse ts NRC RAI Reitted to Chapt:r 3.8 (b)

The two-hour delay has been deleted. 'Ibe package has been invised to require that upon determination that the SWIS DC electrical power subsystem is inoperable, the associated se vice water system train is declared inoperable immediately. See markups for responses to RAI questions 3.8.4 01 and 3.8.9-03.

' NRC Question

• i 3.8.9-09 Withdrawn by NRC r

NRC Question:

3.8.9-10 Withdrawn byNRC NRC Question:

3.8.9-11 Bases discussion for ITS Table 3.8.9-1 Page B 3.8-88 Bases Table 3.8.9-1 is deleted and Insert QQ is substituted (see Pg. B3.8-88). Insert QQ is the plant specific replacement for Table 3.8.9-1.

j Comment: This change is acceptable to a point. The Table proposed for inclusion in these Bases does not include the SWIS DC electrical distribution subsystems. The Bases should be revised to include a reference to the SWIS DC subsystems.

SNC Response:

A The listing of all distribution busses required operable is presented in Table B 3.8.9-1 on Page B 3.8-88 as modified by Insert QQ with FNP specific detail. The required SWIS 125 VDC Distribution Panels include 1M and 2M for Train A and IN and 2N for Train B.

3.8.10, Distribution Systems - Shutdown NRC Question:

3.8.10-01 Withdrawn by NRC Page 38 of 39

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SNC Response to NRC RAI Rel:ted to Chapter 3.8 NRC Question:

3.8.10-02 Withdrawn byNRC NRC Question:

3.8.10-03 Withdrawn byNRC i

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ATTACILMENTII SNC Response to NRC Request for Additional Information Related to Conversion to the Improved Technical Specifications - Chapter 3.8 Associated Package Changes Grouped by RAI Number I

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Associated Package Changes for RAI-3.8.1-02 1