RC-18-0112, (Vcsns), Unit 1 - Request for License Amendment to Virgil C. Summer Nuclear Station Technical Specification 3.8.2, D.C. Sources - Operating, Surveillance Requirements 4.8.2.1.B.2 and 4.8.2.1.C.3
| ML18270A360 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 09/27/2018 |
| From: | Lippard G South Carolina Electric & Gas Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LAR-10-02395, RC-18-0112 | |
| Download: ML18270A360 (20) | |
Text
George A. Lippard Vice President, Nuclear Operations 803.345.4810 A SCANA COMPANY September 27, 2018 RC-18-0112 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Sir I Madam:
Subject:
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS), UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 LICENSE AMENDMENT REQUEST-LAR-10-02395 REQUEST FOR LICENSE AMENDMENT TO VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATION 3.8.2, "D.C. SOURCES-OPERATING," SURVEILLANCE REQUIREMENTS 4.8.2.1.8.2 AND 4.8.2.1.C.3 Pursuant to 10 CFR 50.90, South Carolina Electric & Gas Company (SCE&G), acting for itself and as agent for South Carolina Public Service Authority, hereby requests a change to the Technical Specifications (TS) of Facility Operating License No. NPF-12 for VCSNS Unit 1. The proposed amendment seeks to correct a non-conservative TS by revising the inter-cell resistance value listed in Surveillance Requirements 4.8.2.1.b.2 and 4.8.2.1.c.3.
The enclosure contains a description and assessment of the proposed change. Attachment 1 contains the marked-up version of the affected TS page. Attachment 2 contains the reprinted version of the affected TS page.
SCE&G has evaluated the proposed changes in accordance with 10 CFR 50.91 (a) using criteria in 10 CFR 50.92(c) and has determined that the proposed changes do not involve a significant hazards consideration. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.
Approval of the proposed amendment is requested by September 30, 2019 to correct the non-conservative TS. Once approved, the amendment shall be implemented within 60 days.
The VCSNS Plant Safety Review Committee and the Nuclear Safety Review Committee have reviewed and approved the proposed change. In accordance with 10 CFR 50.91, SCE&G is notifying the State of South Carolina of this license amendment request by transmitting a copy of this letter and enclosure to the designated State Official.
No new commitments are being made in this submittal.
If there are any questions or if additional information is needed, please contact Michael Moore at (803) 345-4752.
V. C. Summer Nuclear Station* P. 0. Box 88 *Jenkinsville, South Carolina* 29065
- F (803) 941-9776
- www.sceg.com
Document Control Desk LAR-1 0-02395 RC-18-0112 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on TS/GAL/wm Zi ::::Lippard
Enclosure:
Evaluation of Inter-cell Resistance Value Change Proposed Technical Specification Changes - Mark-up Proposed Technical Specification Changes - Retyped c:
J. E. Addison W. K. Kissam J. B. Archie J. H. Hamilton G. J. Lindamood W. M. Cherry C. Haney S. A. Williams (w/Enclosure)
NRC Resident Inspector K. M. Sutton S. E. Jenkins (w/Enclosure)
P. Ledbetter (w/Enclosure)
File (813.20)
PRSF (RC-18-0112) (w/Enclosure)
~
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 1 of 12 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ENCLOSURE EVALUATION OF INTER-CELL RESISTANCE CHANGE
Subject:
Technical Specification Surveillance Requirements 4.8.2.1.b.2 and 4.8.2.1.c.3 Revisions to Correct Non-Conservative Technical Specifications
- 1.
SUMMARY
DESCRIPTION
- 2.
DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Description of the Proposed Change
- 3.
TECHNICAL EVALUATION
- 4.
REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No significant Hazards Consideration Determination 4.4 Conclusions
- 5.
ENVIRONMENTAL CONSIDERATION
- 6.
REFERENCES : :
Proposed Technical Specification Changes-Mark-up Proposed Technical Specification Changes - Retyped
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 2 of 12 1.0
SUMMARY
DESCRIPTION This evaluation supports a request to amend Operating License No. NPF-12 for Virgil C.
Summer Nuclear Station (VCSNS), Unit 1.
The proposed amendment revises VCSNS Technical Specifications (TS) Surveillance Requirements (SRs) for safety-related battery terminal connection resistances in TS SRs 4.8.2.1.b.2 and 4.8.2.1.c.3 for batteries XBA-1A-ED and XBA-1 B-ED. VCSNS is replacing the non-conservative safety related battery inter-cell resistance of 150 micro-ohms (IJO) currently listed in TS SRs 4.8.2.1.b.2 and 4.8.2.1.c.3 with calculated individual connection average resistance values for inter-cell, jumper, and terminal plate connections or a maximum measured resistance as determined by VCSNS Calculation DC08320-020, V. C. Summer Class 1 E 125Vdc System Maximum Allowable Battery Connection Resistance.
Additionally, this change addresses the NRC's concern of the VCSNS non-conservative TS associated with inter-cell resistance.
2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Class 1 E 125-volt direct current (DC) Electrical System is required to provide a source of reliable, uninterruptible DC power for essential control and instrumentation during normal operation and for orderly shutdown of Engineered Safety Features equipment. The Class 1 E ED System consists of two independent, redundant ungrounded 125V DC power distribution load groups/trains. Each Class 1 E battery consists of 60 battery cells, battery racks, and accessories, including spacers and hardware for interconnection of cells. Each redundant sub-system also consists of a normal 125 Volt static battery charger, a main 125 Volt distribution panel bus, and three 125 Volt sub-distribution panel buses. The train 'A' and 'B' battery chargers are supplied from separate, redundant diesel backed 480-volt alternating current (AC) motor control centers.
During normal plant operation, the Class 1 E ED System loads are supplied from the battery chargers with the batteries floating on the system. Upon loss of station AC power, the entire load is powered from the batteries until AC power is restored by the emergency diesel generator or the preferred power source.
Two redundant 125-volt DC nominal station batteries with chargers are required such that each battery and associated charger are used to supply two of the four protection instrument power supply inverters. Both redundant 125-volt DC systems shall be capable of supporting/operating normal and required emergency DC loads in the event of a loss of all offsite power with a coincident loss of coolant accident (LOOP/LOCA) for a minimum duration of 10.25 seconds following loss of AC power until emergency AC power is restored by the associated diesel generator.
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 3 of 12 One of the redundant 125-volt DC systems shall be capable of supporting/operating normal (non-accident) loads necessary to ensure that the reactor core is cooled and containment integrity is maintained in the event of a station blackout (SBO) for a 4-hour duration.
2.2 Description of the Proposed Change This amendment proposes to remove the non-conservative safety related battery inter-cell resistance of 150 !JO currently listed in TS SRs 4.8.2.1.b.2 and 4.8.2.1.c.3.
TS SR 4.8.2.1.b.2 currently states: At least once every 92 days and within 7 days after a battery discharge with battery terminal voltage below 11 0-volts, or battery overcharge with battery terminal voltage above 150-volts, VCSNS must verify that there is no visible corrosion at either terminals or connectors or the connection resistance of these items is less than 150 x 1 o-6 ohms.
TS Surveillance 4.8.2.1.c.3 currently states: At least once every 18 months, VCSNS Unit 1 must verify that the resistance of each cell-to-cell and termination connection is less than or equal to 150 X 10-6 ohms.
TS SRs 4.8.2.1.b.2 and 4.8.2.1.c.3 will be revised with the below proposed changes. The proposed TS changes are noted on the marked-up TS page provided in Attachment 1. The proposed retyped TS pages are provided in Attachment 2.
TS SR 4.8.2.1.b.2:
There is no visible corrosion at either terminals or connectors, or the battery connection resistance is less than or equal to the individual connection resistance for the connection types listed below or total battery resistance is less than or equal to 2890 !JO:
Maximum Individual Battery Connection Resistances Number of Individual Connection Type Connections Connection Resistance (IJO)
Inter-cell 56 45 Jumper 3
100 Terminal Plate 2
35
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 4 of 12 TS SR 4.8.2.1.c.3:
The battery connection resistance is less than or equal to the individual connection resistance for the connection types listed below or total battery resistance is less than or equal to 2890 J.JO:
Maximum Individual Battery Connection Resistances Number of Individual Connection Type Connections Connection Resistance (JJO)
Inter-cell 56 45 Jumper 3
100 Terminal Plate 2
35
3.0 TECHNICAL EVALUATION
OE23813, "Technical Specification for Safety Related Battery lntercell Resistance Determined to be Non-Conservative (Quad Cities)," (event date November 28, 2006) detailed a condition at Quad Cities Station Units 1 and 2 where TS value for safety related battery inter-cell resistance of 150 J.JO was determined to be non-conservative. Specifically, if all the battery inter-cell connections degraded to the SR of 150 J.JO, the battery would not be able to perform its safety function. When questioned about the basis of the battery inter-cell resistance value of 150 J.JO, Quad Cities could not provide a basis or calculation to demonstrate the batteries could perform their design function. Quad Cities was tasked to demonstrate or document that its 125-volt DC safety-related batteries could perform their design functions if each of the inter-cell resistances were found to be at the TS allowable value of 150 J.JO. The information contained in OE23813 was submitted to alert other nuclear power plants of the potential for having TS requirements with improper or insufficient basis for nuclear safety-related batteries potentially resulting in non-conservative TS.
During VCSNS's review of the operating experience, it was determined that VCSNS fell into the same group of plants having less than conservative TS regarding surveillance requirements for safety-related battery inter-cell resistances. Per Nuclear Regulatory Commission Administrative Letter 98-10, the condition described constituted a degraded or nonconforming condition that required prompt action to correct or resolve the condition, including the evaluation of compensatory measures, such as administrative controls. VCSNS engineering staff had previously established acceptable values for inter-cell connection resistances, jumper resistances, and field plate resistances. These values were documented in the station's surveillance test procedures as administrative controls to ensure conservative values and to ensure the batteries would perform their design basis function when needed. The administrative controls established are as follows: Cable connection at cells 1 and 60 (field plates) are less than or equal to 12 J.JO; Inter-cell straps are less than or equal to 31 J.JO; and Jumpers between cells 15-16, 30-31, and 45-46 are less than or equal to 77 J.JO. The
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 5 of 12 administrative controls remain in effect today per station surveillance test procedures providing assurance that the batteries remain operable.
During the 2017 NRC Design Basis Assurance Inspection (DBAI), the NRC identified that the resolution of the non-conservative TS SRs 4.8.2.1.b.2 and 4.8.2.1.c.3 associated with inter-cell resistance as previously identified in 2010 has not been timely. There was precedence for amendment submittals and approvals for changes made to TS surveillance requirements; however, VCSNS did not have the technical documentation (i.e., a calculation with acceptance criteria considered for inter-cell resistance) to support values needed to revise the current TS surveillance inter-cell resistance value of 150 !JO. Following this finding, VCSNS Nuclear Licensing and Engineering Services worked with a vendor to develop a calculation that provides a design basis for the maximum allowable total connection resistance of the Class 1 E batteries.
Maintaining the total battery connection resistance at or below the maximum allowable resistance calculated in DC08320-020 ensures all DC components necessary to mitigate a 4-hour SBO event and all Class 1 E DC components necessary to mitigate the initial seconds of a LOOP with a coincident LOCA have adequate voltage to perform their design basis functions.
The results of this calculation provide the new inter-cell battery resistance values in the TS changes being proposed per this license amendment request.
VCSNS 125-volt DC Class 1 E system station batteries are C&D LCR-31 batteries with 15 positive plates per cell per DC08320-005, ESF 1 A & 1 B Capacity. The batteries are sized in accordance with IEEE Standard 485 to a minimum terminal voltage of 1 08-volts DC and are sized for 60-cell, 59-cell, and 58-cell operations.
Table 3-1 provides the maximum battery duty cycle load for the Train A Battery XBA-1A-ED and Train B Battery XBA-1 B-ED during the first minute, middle duration, and last minute of the bounding design basis event. The values in Table 3-1 were taken from Section 6.8 (Battery XBA-1A-ED) and Section 6.11 (Battery XBA-1 B-ED) of calculation DC08320-005.
T bl 3 1 M a e -
ax1mum 8 tt L
d P fl a ery oa ro 1 es Time Battery XBA-1 A-ED Battery XBA-1 B-ED (min)
Max Duty Cycle Load Max Duty Cycle Load (Ad c)
(Ad c) 0-1 410.9 436.9 1-239 200.2 215.8 239-240 246.2 261.8 Table 3-2 provides the lowest battery terminal voltage for the specified times during the bounding design basis event. The voltages in Table 3-2 were taken from Attachment 11 (Study Case 1A TA58 80%) and Attachment 13 (Study Case 1 B TA58 80%) of calculation DC08320-01 0, Class 1 E 125 Volt DC System Voltages and Voltage Drop, for Bus EDEOA (battery XBA-1A-ED) and Bus EDEOB (battery XBA-1 B-ED), respectively. The study cases for the 58-cell discharge analyses are listed because these provide the lowest battery terminal voltages since the batteries can operate with 2 cells removed.
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 6 of 12 Time (min) 0-1 1+
239-239-240 T able 3-2. Mtntmum 8 T
attery ermtna IV It o ages Battery XBA-1 A-ED Battery XBA-1 B-ED Min Terminal Voltage Min Terminal Voltage (Vdc)
(Vdc) 110.81 110.51 112.71 112.53 109.19 108.20 108.58 107.52 The general approach to calculate a maximum allowable battery connection resistance for VCSNS Class 1 E station batteries XBA-1A-ED (Train A) and XBA-1 B-ED (Train B) is to determine the minimum amount of available voltage margin from battery discharge (voltage drop) calculation DC08320-01 0, and then use some of that available voltage margin to accommodate battery connection resistance. A primary goal for this approach was to not impact the minimum allowable battery terminal voltage of 1 08-volt DC used to size the VCS Class 1 E station batteries in calculation DC08320-005 for reasons discussed below.
The sizing methodology provided in IEEE Standard 485 is not directly impacted by the amount of battery connection resistance used. However, the battery sizing results could be indirectly impacted by battery connection resistance if the battery discharge (voltage drop) analysis determined a higher battery terminal voltage was needed to provide adequate voltages to components in the DC system as a result of the increased battery connection resistance. This would then change the minimum battery terminal voltage (and hence the minimum cell voltage) used in the battery sizing analysis.
The approach of DC08320-020 is to ensure that, with up to the maximum allowable battery connection resistance included, the use of 1 08-volts DC (from Table 3-2) as the minimum allowable battery terminal voltage for sizing the VCS Class 1 E station batteries continues to be acceptable. This ensures the results of battery sizing calculation DC08320-005 are not impacted. This also means the correction factors included in calculation DC08320-005 to account for battery aging, temperature, a 10 percent design margin, and battery capacity margin are still available for the VCSNS Class 1 E 125-volt DC System even with the maximum battery connection resistance included.
The steps outlined below implement the above approach:
Identify which loads/circuits are required to mitigate a LOOP/LOCA and/or an SBO.
Determine the minimum required voltage for each required load/circuit.
Determine the existing minimum available voltage for each required load/circuit.
Calculate the voltage margin between the existing minimum available voltage and the minimum required voltage for each required load/circuit.
Determine the overall minimum voltage margin for each train.
Calculate the amount of equivalent battery connection resistance the voltage margin allows given the bounding discharge rate of the battery for that train at the time the circuit/load is required to operate.
The key technical basis behind this approach is based on the knowledge that the majority of
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 7 of 12 loads in the DC system are constant impedance loads, with no known constant current loads and the only notable constant power loads being the station's 120-volt AC Vital Inverters.
Consequently, the system-wide impact to the constant impedance loads has the largest overall effect on the battery performance. Below is a summary of the impact this approach has on individual types of loads:
For constant impedance loads, a reduction in voltage results in less current draw to the load which means there is less voltage drop through the cables (the load terminal voltages improve relative to the linear approximation) and the total battery loading decreases. Therefore, it is conservative for purposes of this calculation to model all constant impedance loads as continuing to draw the same current with the small reduction in system voltages.
For constant current loads, this approach is exact, and no adjustments are required to either voltage drops to the components or total battery loading.
For constant power loads, this approach can introduce a small non-conservative error since a reduction in voltage will create an increase in current to the load. To remain conservative with this approach, this error is accounted for with the voltage drop to the 120-volt AC Vital Inverters. Note that the slight increase in current to the inverters does not need to be accounted for relative to the overall battery loading, because this small battery load increase is more than offset by the decrease in loading to all the constant impedance loads that is not being accounted for.
The average intrinsic battery inter-cell connection resistance present when the battery vendor performed battery discharge testing to develop the battery discharge curves for the C&D LCR-31 batteries is assumed to be 10 1-J.O or greater. Typical battery connection resistances are on the order of 30 1-J.O for single connections between cells or 15 1-J.O for parallel connections between cells. Battery vendors perform battery discharge tests and develop the associated battery discharge curves using the same inter-cell connection hardware and torqueing requirements as is used for the installed application so that the battery curves accurately reflect installed equipment performance. The calculation performed in VCSNS Technical Report TR08200-003, Compliance to NRC Rule 10 CFR 50.63 'Station Blackout,'
shows that using battery recommended voltage drops between connections and the rated discharge of a C&D LCR-31 battery, the connection resistance should be around 12 1-J.O. In addition, Section 11.3.2.1 of EPRI TR-1 00248 states, "Normal termination resistance varies with the battery size and termination technique. Normal resistance values can range from less than 10 1-J.O for a large battery to well over 100 1-J.O for a small battery." This statement supports the fact that the range is typically between 10 1-J.O and 100 1-J.O. Therefore, assuming the battery vendor used an average inter-cell connection resistance of 10 1-J.O or greater when developing discharge curves for the C&D LCR-31 batteries is conservative and no further verification is required.
The maximum allowable battery connection resistances above the intrinsic connection resistance for Battery XBA-1A-ED and Battery XBA-1 B-ED are summarized in Table 3-3. The maximum allowable connection resistances shown in Table 3-3 are the maximum amount of resistance in addition to the intrinsic connection resistance that is already present when the
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 8 of 12 battery vendor performed discharge testing of the batteries (to develop the battery curves used in the battery sizing and battery discharge analyses).
The intrinsic connection resistance was assumed to be an average of 10 !JO per connection, which is conservatively low, for a total intrinsic connection resistance of 600 !JO for each 60-cell battery. Using the limiting Battery XBA-1 B-ED connection resistance of 2290 !JOin Table 3-3, in conjunction with an assumed 600 !JO of intrinsic connection resistance during battery vendor discharge testing, results in a maximum allowable measured connection resistance of 2890 !JO to bound batteries XBA-1A-ED and XBA-1 B-ED.
T bl 3 3 M a e -
ax1mum All ow a bl 8 tt e
a ery c f
R
. t onnec1on es1s ance Ab ove I t.
n nns1c Max Max Component Allowable Allowable Train Limiting Time of Limiting Voltage Resistance Measured Duty Cycle Component Margin Above Resistance (Vdc)
Intrinsic (JJO)
(1!0)
A 0-1 minute XIT5901 (inverter) 1.0 2430 3030 B
239-240 minute XIT5904 (inverter]
0.6 2290 2890 The configuration of each VCSNS Class 1 E station battery is 56 inter-cell connections, 3 jumpers, and 2 terminal plate connectors. This includes 59 cell-to-cell connections (for a 60-cell battery) plus the positive and negative connections of the battery terminals (61 total connections). DC08320-020 determined a combination of allowable individual connection type resistances (listed below in Table 3-4) that would not exceed the maximum allowable measured connection resistance of 2890 !JO. The calculation went on to state that other combinations of connection type maximum resistances could be used provided the maximum measured resistance of 2890 !JO is not exceeded.
T bl 3 4 M a e -
ax1mum M easure n 1v1 ua a ery d I d. "d I 8 tt c onnec1on es1s ances f
R
. t Individual Total Connection Connection Maximum Connection Number of Average Maximum Measured Type Connections Measured Measured Resistance Resistance Resistance (JJO)
(JJO)
(JJO)
Inter-cell 56 45 2520 Jumper 3
100 300 2890 Terminal Plate 2
35 70 For both trains, ensuring 1 04-volt DC terminal voltage (from voltage drop adjustment) to the inverters is the limiting constraint on the maximum allowable connection resistance. As shown in Table 3-3, Train A is limited in the first few seconds during a LOOP/LOCA while emergency onsite power sources are starting, while Train B is limited in the last minute of the 4-hour SBO.
The overall limiting connection resistance shown in Table 3-4 comes from the Train B battery. If the limiting values in Table 3-4 are used, then: (1) the Train A battery will have additional connection resistance margin; and (2) for both trains there is additional connection resistance margin in the first few seconds of a LOOP/LOCA which is when the batteries have to support their Class 1 E functions.
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 9 of 12 These results are applicable to 60-cell, 59-cell, and 58-cell battery operations. Minimum voltage margins (and therefore maximum allowable connection resistances) were calculated assuming 58-cell operations and therefore additional margin is present when operating in either a 59-cell or 60-cell configuration.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations, requirements, and guidance continue to be met.
Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50 Appendix A, General Design Criterion (GDC) 17, "Electric power systems," requires, in part, that nuclear power plants have onsite and offsite electric power systems to permit the functioning of Structures, Systems, and Components (SSCs) that are important to safety. The onsite system is required to have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure.
GDC 18, "Inspection and testing of electric power systems," requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.
10 CFR 50.36, "Technical specifications," identifies Surveillance Requirements as requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within the safety limits, and that the limiting conditions of operation (LCO) will be met.
10 CFR 50.63, "Loss of all alternating current power," requires that each light-water cooled nuclear power plant licensed to operate must be able to withstand a specified duration and recover from a station blackout (SBO).
The requirements of GDC 17 and 18, along with the regulatory requirements listed, continue to be met because the proposed changes will not affect the design capability, function, operation, maintenance or method of testing of the safety-related batteries.
4.2 Precedent Previous NRC approvals of similar license amendment requests to correct technical specification surveillances non-conservative battery connection resistance value of 150 ~0 include the following:
- 1. Callaway Plant, Unit 1 a-Issuance of Amendment (TAC No. ME0292), dated December 9, 2009 [ML093220075]
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 10 of 12
- 2. Cooper Nuclear Station -Issuance of Amendment (TAC No. ME0848), dated March 18, 2010 [ML100610233]
- 3. Wolf Creek Generating Station - Issuance of Amendment (TAC No. ME2965), dated December 20, 2010 [ML103190469]
- 4. Catawba Nuclear Station, Units 1 and 2-Issuance of Amendment (TAC Nos.
ME2934 and ME2935), dated December 20, 2010 [ML103270011]
- 5. McGuire Nuclear Station, Units 1 and 2 -Issuance of Amendment (TAC Nos.
ME2936 and ME2937), dated December 20, 2010 [ML103270096]
- 6. Turkey Point, Units 3 and 4-Issuance of Amendment (TAC Nos. ME6859 and ME6860), dated August 8, 2012 [ML12208A298]
- 7. St. Lucie Plant, Units 1 and 2 -Issuance of Amendment (TAC Nos. ME9297 and ME9298), dated June 18, 2013 [ML13150A337]
- 8. Fermi 2 -Issuance of Amendment (TAC No. MF4002), dated March 16, 2015
[ML15057A297]
4.3 No Significant Hazards Consideration Determination A change is proposed to the VCSNS Unit 1 Technical Specifications to replace the non-conservative safety related battery inter-cell resistance of 150 !J.O currently listed in TS SRs 4.8.2.1.b.2 and 4.8.2.1.c.3 with calculated resistance values for inter-cell, jumper, and terminal plate connections and maximum measured resistance as determined by VCSNS Calculation DC08320-020. SCE&G has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as described below:
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
Performing the proposed changes in battery parameter surveillance testing and verification is not a precursor of any accident previously evaluated. Furthermore, these changes will help to ensure that the voltage and capacity of the batteries is such that they will provide the power assumed in calculations of design basis accident mitigation. Therefore, SCE&G concludes that the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes to the VCSNS TS SR do not involve any physical modification of the plant or how the plant is operated. No new or different type of
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 11 of 12 equipment will be installed. The proposed changes involve surveillance testing and verification activities. No new failure modes/effects which could lead to an accident whose consequences exceed the consequences of accidents previously analyzed will be introduced by the changes to the TS SR.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Do the proposed changes involve a significant reduction in a margin of safety?
Response: No.
Margin of safety is related to the confidence in the ability of the fission product barriers to perform their design functions during and following an accident situation.
These barriers include the fuel cladding, the reactor coolant system, and the containment system. The performance of the fuel cladding, reactor coolant, and containment systems will not be impacted by the proposed changes.
The proposed VCSNS revisions of the SRs ensure the continued availability and operability of the batteries. As such, sufficient DC capacity to support operation of mitigation equipment remains within the design basis. Therefore, SCE&G concludes that the proposed changes do not involve a significant reduction in the margin of safety.
4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
Document Control Desk Enclosure LAR-1 0-02395 RC-18-0112 Page 12 of 12
6.0 REFERENCES
- 1. V.C. Summer Unit 1 Technical Specifications through Amendment No. 210
- 2. V.C. Summer Calculation DC08320-020, V.C. Summer Class 1E 125Vdc System Maximum Allowable Battery Connection Resistance
- 4. OE23813, Technical Specification for Safety Related Battery lnterce/1 Resistance Determined to be Non-Conservative (Quad Cities)
- 5. NRC Administrative Letter 98-10, Dispositioning of Technical Specifications That are Insufficient to Assure Plant Safety
- 6. V.C. Summer Engineer Technical Work Record, A & B Train Micro-Ohm Acceptance Criteria, dated March 10, 1993
- 7. V. C. Summer Unit 1, Final Safety Analysis Report through May 31, 2018
- 8. V. C. Summer Calculation DC08320-005, ESF 1 A & 1 B Capacity
- 9. V.C. Summer Calculation DC08320-010, Class 1E 125 Volt DC System Voltages and Voltage Drop
- 10. Institute of Electrical and Electronics Engineers, IEEE Standard 485, IEEE Recommended Practice for Sizing Lead-Acid Batteries for Stationary Applications, 1997
- 11. V.C. Summer Nuclear Station Engineering Services Technical Report TR08200-003 (Cross
Reference:
GAl Report #2782), Compliance to NRC Rule 1 OCFR50. 63 'Station Blackout', Revision 8
- 12. Electric Power Research Institute (EPRI) Technical Report TR-1 00248, Stationary Battery Guide: Design, Application, and Maintenance, Revision 2.
Document Control Desk LAR-1 0-02395 RC-18-0112 Page 1 of 4 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION CHANGES-MARK-UP
ELECTRICAL POWER SYSTEMS 3/4.8.2 D.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.2.1 As a minimum the following D.C. electrical sources shall be OPERABL£:
- a.
lZS:..volt* *Battery bank:* No. -lA and its assoG*i-a~ full capacity charger...
- b.
1Z5*vo1t Battery bank No. 18 and its associated full capacity charger.
APPLICABILITY:
MODES 1, 2, 3 and 4.
ACTION:
- a.
With one of the requir-ed battery banks inoperable, restore the fnoperable batte~ bank to OPE~LE status within 2 ~ours or be in at least HOT STANDBY withfn the next 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />'s and in COLO SHU'TDOWN-with1n the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- b.
With one of the required full capacity chargers inoperable. demonstrate the OPERABILITY of its associated battery bank by perfon~fng Surve111a~e Requ1 rement 4. 8. 2.1. a.l w1 th1 n one hour. and at 1 east once per 8 houn thereafter. If any Category A 11*ft fn Table 4.8-2 is not met, declare the batter,y inoperable.
SURVEILLANCE REquiREMENTS 4.8.2.1 Each 125-volt battery bank and charger shall be de.onstrated OPERABLE:
- a.
At least once per 7 days by verifying that:
- 1.
The paruetei'S in Table 4.8*2 meat the Category A 11a1ts, and
- 2.
The total battery terainal voltage is greate~ than Or" equal to 129 volts on float charge
- SI.M4ER - UNIT 1 3/4 8*9
ELECTRICAL POWER SYS'l'EMS SURVEILLANCE REOUIREMEN~S (Continued!
- b.
At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110-volts, or battery overcharge 11ith battery terminal voltage above 150-volts, by Verifying-that:
- 2.
There is no 9isible corrosion at either terminals or connectors, or the eeaaeetien ~esistaaee of these items i& less tbaa 150 X l0 - 6 obms, and Replace with Insert 1
- 3.
Th~ average electrolyte temperature of 10 of the connectew-----------------~
cells is !:. so*:r.
- c.
At least once per 18 months by verifyift9 ~t:
- 1.
The celts; cell plates and batterJ racks sbov no visgal indicatioD of physical damage or abnormal deterioration,
- 2.
- 3.
The cell-to-cell and terminal connections are cleaR, tight, and coated vith anti-corrosion material, Replace with Insert 2
- 4.
~be battery charger vill supplJ at least 300 amperes at 132 v~~--------------~
for at least 8 bours.
- d.
At least once per 18 months, daring shutdown, by 9erifying that the battery capacity is adequate to suppl~ and maintain in OPERABLE status all of the actual or simulated e~rgency loads for the design duty cycle wheD the battery is subjected to a battery service test.
- e.
At least onee per 60 moDths, during shutdovD, by verif~iftg that the battery capacity is at least so* of the manufacturer's rating vhen subjected to a performance discharge test.
~his performance discharge test may be perforaed in lieu of the battery service test required by Surveillance RequiremeDt ~.8.2.l.d.
- f.
Annual performance discharge tests of battery capacity shall be given to any battery that shows signs of 4egradation or has reached 85\\ of the service life expected for the application.
Deqradation is indicated when the battery capacity drops more than 10' of rated capaci-ty from its averaqe on previous perfor~~~&nce tests, or is below 90' of the man~facturer*s ratinq.
SUMMER -
UNIT 1 3/4 8-lD AMEHDMEH'l' HO. SG
- 1 0 7
- Insert 1 or the battery connection resistance is less than or equal to the individual connection resistance for the conn f
t I' t d b I t t I b tt
. t
. I th I to 2890 1-10:
ec ron types rs e e ow or o a a ery resrs ance rs ess an or equa Maximum Individual Battery Connection Resistances Individual Connection Type Number of Connection Connections Resistance (IJn)
Inter-cell 56 45 Jumper 3
100 Terminal Plate 2
35 Insert 2 The battery connection resistance is less than or equal to the individual connection resistance for the connection types listed below or total battery resistance is less than or equal to 2890 1-JO:
Maximum Individual Battery Connection Resistances Individual Connection Type Number of Connection Connections Resistance (IJQ)
Inter-cell 56 45 Jumper 3
100 Terminal Plate 2
35
Document Control Desk LAR-1 0-02395 RC-18-0112 Page 1 of 2 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES-RETYPED
ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIRMENTS (Continued)
- b.
At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110-volts, or battery overcharge with battery terminal voltage above 150-volts, by verifying that:
1:
The parameters in Table 4.8-2 meet the category B limits,
- 2.
There is no visible corrosion at either terminals or connectors, or the battery connection resistance is less than or equal to the individual connection resistance for the connection types listed below or total battery resistance is less than or equal to 2890 110:
Maximum Individual Battery Connection Resistances Connection Number of Individual Connection Type Connections Resistance {1.10)
Inter-cell 56 45 Jumper 3
100 Terminal Plate 2
35 I and
- 3.
The average electrolyte temperature of 10 of the connected cells is~ 60°F.
- c.
At least once per 18 months by verifying that:
- 1. The cells; cell plates and battery racks show no visual indication of physical damage or abnormal deterioration,
- 2.
The cell-to-cell and terminal connections are clean, tight, and coated with anti-corrosion
- material,
- 3.
The battery connection resistance is less than or equal to the individual connection resistance for the connection types listed below or total battery resistance is less than or equal to 2890 IJO:
Maximum Individual Battery Connection Resistances Connection Number of Individual Connection Type Connections Resistance (IJ.O)
Inter-cell 56 45 Jumper 3
100 Terminal Plate 2
35 I and
- 4.
The battery charger will supply at least 300 amperes at 132 volts for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
- d. At least once per 18 months, during shutdown, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.
- e.
At least once per 60 months, during shutdown, by verifying that the battery capacity is at least 80%
of the manufacturer's rating when subjected to a performance discharge test. This performance discharge test may be performed in lieu of the battery service test required by Surveillance Requirement 4.8.2.1.d.
- f.
Annual performance discharge tests of battery capacity shall be given to any battery that shows signs of degradation or has reached 85% of the service life expected for the application.
Degradation is indicated when the battery capacity drops more than 10% of rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.
SUMMER-UNIT 1 3/4 8-10 AMENDMENT NO. 80,107