ML18243A298

Issuance of Amendment to Modify DC Sources Technical Specification Surveillance Requirement 3.8.4.5

ML18243A298
Person / Time
Site:	Brunswick
Issue date:	09/27/2018
From:	Dennis Galvin Plant Licensing Branch II
To:	William Gideon Duke Energy Progress
Galvin D NRR/DORL/LPL2-2 301-415-6256
References
EPID L-2017-LLA-0477
Download: ML18243A298 (17)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 27, 2018 Mr. William R. Gideon, Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd., SE (M/C BNP001)

Southport, NC 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS TO MODIFY DC SOURCES TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 3.8.4.5 (EPID L-2017-LLA-0477)

Dear Mr. Gideon:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 286 and 314 to Renewed Facility Operating License Nos. DPR-71 and DPR-62 for Brunswick Steam Electric Plant, Units 1 and 2, respectively. These amendments are in response to your license amendment request dated October 3, 2017.

The amendments revise the required supplied amperage of the battery chargers contained within Technical Specification Surveillance Requirement 3.8.4.5.

A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register Notice.

Sincerely, Dennis J. Galvin, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324

Enclosures:

1. Amendment No. 286 to DPR-71

2. Amendment No. 314 to DPR-62

3. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS. LLC DOCKET NO. 50-325 BRUNSWICK STEAM ELECTRIC PLANT. UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 286 Renewed License No. DPR-71

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by Duke Energy Progress, LLC, dated October 3, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-71 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 286, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION Booma Venkataraman, Acting Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Operating License and Technical Specifications Date of Issuance: September 2 7, 2 O1 8

ATIACHMENT TO LICENSE AMENDMENT NO. 286 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-71 DOCKET NO. 50-325 Replace Page 6 of Renewed Facility Operating License No. DPR-71 with the attached revised Page 6.

Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3.8-25 3.8-25

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 1801h day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 286, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 203 to Renewed Facility Operating License DPR-71, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 203. For SRs that existed prior to Amendment 203, including SRs with modified acceptance criteria and SRs whose frequency of Renewed License No. DPR-71 Amendment No. 286

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 Remove visible corrosion and verify battery cell to cell In accordance with and terminal connections are coated with the Surveillance anti-corrosion material. Frequency Control Program SR 3.8.4.5 Verify each required battery charger supplies In accordance with

~ 300 amps at ~ 135 V for ~ 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. the Surveillance Frequency Control Program SR 3.8.4.6 -------------------------------NOTES-------------------------------

1. The modified performance discharge test in SR 3.8.4.7 may be performed in lieu of the service test in SR 3.8.4.6 once per 60 months.

2. This Surveillance shall not be performed in MODE 1 or 2 for the Unit 1 DC electrical power subsystems. However, credit may be taken for unplanned events that satisfy this SR.

3. A single test at the specified Frequency will satisfy this Surveillance for both units.

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

Brunswick Unit 1 3.8-25 Amendment No. 286 I

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-324 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 314 Renewed License No. DPR-62

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by Duke Energy Progress, LLC, dated October 3, 2017, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-62 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 314, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days.

FOR THE NUCLEAR REGULATORY COMMISSION Booma Venkataraman, Acting Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Operating License and Technical Specifications Date of Issuance: September 2 7, 2 O1 8

ATTACHMENT TO LICENSE AMENDMENT NO. 314 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-62 DOCKET NO. 50-324 Replace Page 6 of Renewed Facility Operating License No. DPR-62 with the attached revised Page 6.

Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 3.8-25 3.8-25

(c) Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by 2. below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in 2. above.

2. The licensee shall implement the modifications to its facility, as described in Table S-1, "Plant Modifications Committed," of Duke letter BSEP 14-0122, dated November 20, 2014, to complete the transition to full compliance with 10 CFR 50.48(c) by the startup of the second refueling outage for each unit after issuance of the safety evaluation. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete all implementation items, except Item 9, listed in LAR Attachment S, Table S-2, "Implementation Items," of Duke letter BSEP 14-0122, dated November 20, 2014, within 180 days after NRC approval unless the 180th day falls within an outage window; then, in that case, completion of the implementation items, except item 9, shall occur no later than 60 days after startup from that particular outage. The licensee shall complete implementation of LAR Attachment S, Table S-2, Item 9, within 180 days after the startup of the second refueling outage for each unit after issuance of the safety evaluation.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2923 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 314, are hereby incorporated in the license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 233 to Renewed Facility Operating License DPR-62, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 233. For SRs that existed prior to Amendment 233, Renewed License No. DPR-62 Amendment No. 314

DC Sources-Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.4.4 Remove visible corrosion and verify battery cell to cell In accordance with and terminal connections are coated with the Surveillance anti-corrosion material. Frequency Control Program SR 3.8.4.5 Verify each required battery charger supplies In accordance with

~ 300 amps at ~ 135 V for ~ 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. the Surveillance Frequency Control Program SR 3.8.4.6 --~-~-~-~-~--~-~-~-~~N()TES~-~--~-~-~---~-~----

1. The modified performance discharge test in SR 3.8.4. 7 may be performed in lieu of the service test in SR 3.8.4.6 once per 60 months.

2. This Surveillance shall not be performed in M()DE 1 or 2 for the Unit 2 DC electrical power subsystems. However, credit may be taken for unplanned events that satisfy this SR.

3. A single test at the specified Frequency will satisfy this Surveillance for both units.

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

Brunswick Unit 2 3.8-25 Amendment No. 314 I

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENTS NOS. 286 AND 314 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-71 AND DPR-62 DUKE ENERGY PROGRESS, LLC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324

1.0 INTRODUCTION

By letter dated October 3, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17277A855), Duke Energy Progress, LLC (Duke Energy, the licensee) submitted a license amendment request (LAR) to revise the Brunswick Steam Electric Plant, Units 1 and 2 (Brunswick), Technical Specifications (TSs). Specifically, the proposed amendments would revise the required supplied amperage (amp) of the battery chargers contained within TS 3.8.4, "DC [Direct Current] Sources - Operating," Surveillance Requirement (SR) 3.8.4.5.

2.0 REGULATORY EVALUATION

The U.S. Nuclear Regulatory Commission (NRC, the Commission) staff applied the following regulatory requirements in its review of the application.

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(3) requires a licensee's TSs to include SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation (LCOs) will be met.

Appendix A to 10 CFR Part 50, 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 that are important safety. The onsite electric power system is required to have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure. The offsite electric power system is required to be supplied by two physically independent circuits that are designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. In addition, this criterion requires provisions to minimize the probability of losing electric power from the remaining electric power supplies as a result of, or coincident with, the loss of power from the unit, the offsite transmission network, or the onsite power supplies.

Enclosure 3

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.

The NRC staff also considered the following regulatory guidance related to this application.

Safety Guide 6, "Independence Between Redundant Standby (Onsite) Power Sources and Between their Distribution Systems" (ADAMS Accession No. ML003739924 ), describes an acceptable degree of independence between redundant standby (onsite) power sources and between their distribution systems. Safety Guide 6, Regulatory Position 3, states that each DC load group should be energized by a battery and battery charger. The battery-charger combination should have no automatic connection to any other redundant DC load group. The Brunswick Updated Final Safety Analysis Report (UFSAR) (ADAMS Accession No. ML18250A015), Section 3.1.2.2.8, "Criterion 17 - Electrical Power Systems," states that the Brunswick electrical power system design is in conformance with the recommendations of Safety Guide 6.

3.0 TECHNICAL EVALUATION

The Brunswick DC electrical power system provides the alternating current (AC) emergency power system with control power. It also provides both motive and control power to selected safety-related equipment and preferred AC vital instrument bus power through the inverters. As required by the Brunswick design criteria, the DC electrical power system is designed to have sufficient independence, redundancy, and testability to perform its safety functions, assuming a single failure.

3.1 Background In the LAR, the licensee stated that prior to 2013, Brunswick relied on its Calculation BNP-E-6.120, Attachmen.t G, "Battery Discharge State and Charger Load for Normal, Post-LOCA/LOOP [Loss of Coolant Accident/Loss of Offsite Power] and Post-SBO [Station Blackout]

Operation (for Battery Charger Size Verification) & Evaluation of Battery Voltages After Restoration of Battery Chargers," that was based on a battery duty cycle of 1 minute for a LOOP/LOCA event. At the end of the 1 minute LOOP/LOCA duty cycle, the battery chargers were credited for supplying the DC system with sufficient margin available for battery recharge and non-safety loads being transferred automatically back to their respective AC buses. Prior to 2013, Brunswick did not actually require the battery chargers to supply greater than 250 amps until after the 2013 NRC Component Design Basis lnspection.(CDBI). The CDBI inspection report, 50-325/2013-007 and 50-324/2013-007, dated December 6, 2013 (ADAMS Accession No. ML13340A629), identified that the Brunswick Calculation No. BNP-E-06.120 incorrectly credited certain non-safety loads, specifically the Uninterruptible Power Supply (UPS) lighting and communications units, as being automatically transferred back to the AC buses (to the safety-related battery chargers) from the safety-related batteries once AC bus power was restored after 1 minute of the event. Due to the specific loads being non-safety related, their transfer cannot be credited. In addition, if the UPS lighting and communications units fail to transfer to the AC supply, they will continue to be powered from the DC supply after the chargers are restored, resulting in exceeding the charger capability and in continual discharge of the batteries. The licensee determined that this condition is primarily due to the UPS lighting and communications units that contribute approximately 185-195 amps that was being loaded on the chargers at 1 minute after the event after AC buses were energized. Based on above, the licensee determined that the testing requirements contained in SR 3.8.4.5 were not aligned with the design criteria contained in the electrical calculations. Therefore, SR 3.8.4.5 was set at

greater than or equal to 250 amps, which is below the battery charger design continuous rating of 300 amp.

3.2 Brunswick 125/250 Volt Direct Current (VDC) Electric Power System Description Each unit contains a 125/250 VDC Power System that consists of two separate divisions. Each division contains two 125 VDC batteries wired in a series/parallel arrangement to its distribution panel to allow for 125 VDC or 250 VDC loading. Each battery contains its own independent charger. The major loads supplied by this system are 250 VDC valve operators and pumps, and 125 VDC control/logic systems, plant annunciation, and emergency lighting. Each of the 125 VDC battery chargers is provided with AC power via their respective division Emergency Bus.

The purpose of the 125/250 VDC Power System is to ensure that sufficient power will be available to supply safety-related equipment required for the safe shutdown of the facility and the mitigation and control of accident conditions within the facility. Each unit contains two separate and redundant divisions for all equipment and wiring associated with Engineering Safety Features (ESF) and their supporting systems. The 125/250 VDC system provides reliable motive and control power to the ESF loads such that no single credible event can disable the containment isolation function or prevent the standby cooling systems from performing their intended functions. In the LAR, the licensee stated that all safety-related battery chargers at Brunswick were purchased with a 300-amp continuous rating and a 375-amp current limit rating.

The Brunswick UFSAR Section 8.3.2.1, "125/250 Volt DC Power Supply and Distribution System," states that each charger is sized utilizing the largest combination of steady state loads with a charging capacity capable of restoring the battery from the design minimum charged state to the fully charged state in approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> under any load condition.

3.3 Proposed Change to SR 3.8.4.5 The licensee proposes to change the battery charger design continuous rating in SR 3.8.4.5 from 250 amps to 300 amps.

The current SR 3.8.4.5 reads:

Verify each required battery charger supplies ~ 250 amps at ~ 135 V for~ 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

The proposed SR 3.8.4.5 would read:

Verify each required battery charger supplies ~ 300 amps at ~ 135 V for ~ 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

3.4 Design-Basis Accident Loads In the LAR, the licensee stated that for a design-basis accident (LOOP/LOCA), the enveloping single failure is assumed to be the complete loss of one DC division. The remaining division must be capable of supplying power to the ESF loads required for accident mitigation and balance of plant loads that are connected to the 125/250 VDC system. For the available DC division, AC power to the battery charger will be available.

The licensee performed an Engineering Change that updated the battery load study calculations (BNP-E-6.079 and BNP-E-6.120) for post-LOOP/LOCA battery duty cycle based on the non-safety loads being transferred to their respective AC source (battery charger) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> instead of 1 minute. Calculation No. BNP-E-6.120, Revision 10, shows that the voltage remained greater than 107 VDC for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with the UPS loads remaining on the batteries without transferring to the AC sources. Therefore, the battery chargers will have adequate capacity to recharge the batteries within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

The NRC staff's review of the licensee's summary evaluation and the calculations in Enclosures 6 and 7 of the LAR finds that voltage will remain above 107 VDC for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with the UPS loads remaining on the batteries without transferring to the AC sources, and that the battery chargers will have adequate capacity to recharge the batteries within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and is, therefore, acceptable.

3.5 Station Blackout Loads In the LAR, the licensee stated that Brunswick is required to maintain a 4-hour coping duration during an SBO event. The licensee's analysis in Enclosure 6 of the LAR (Calculation BNP-E-6.079, Revision 6) shows that the allowable continuous load current on the DC system while recharging battery in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> would be approximately 245.2 amps based on a 1-hour cross-tie capability, considering aging and temperature derating factors. Brunswick Procedure "AOP-36.2" defines a means to cross tie AC power from the non-blackout unit to the blackout unit battery charger within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. However, there is insufficient margin between the analyzed maximum load current (245.2 amps) and the current SR 3.8.4.5 limit of greater than or equal to 250 amps. By revising this limit to the 300 amps continuous current rating of the battery charger, sufficient margin will be available. The analyzed maximum continuous load current on the DC system (245.2 amps) is well within the continuous current rating (300 amps) of the battery charger.

The licensee's analysis in Enclosure 6 of the LAR (Calculation BNP-E.079, Revision No. 6) demonstrates that each safety-related battery charger has sufficient capacity margin for the safety-related battery to be recharged in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> if the UPS loads are transferred to their AC source within the 4-hour timeframe of the event, consistent with the Brunswick UFSAR Section 8.3.2.1.2, "Description."

3.6 Technical Evaluation Conclusion Based on the above, the NRC staff finds: (1) the safety-related battery chargers at Brunswick were purchased with a 300 amp continuous rating and a 375 amp current limit rating, (2) the proposed 300 amps minimum feed at greater than or equal to 135 VDC for greater than or equal to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from each safety-related battery charger will provide sufficient margin to support the required load current and, thereby, provide assurance that the battery chargers will continue to be capable of supplying the required loads under design-basis events and recharge the batteries in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from minimum design charge state to the full charge after the event, and (3) the minimum load ampere requirement is within the battery charger design capacity that provides assurance that each safety-related battery charger will be capable of supplying the largest combined demands of the various continuous steady-state loads and recharge the battery from design minimum charge state to a fully charged state, while staying within the capacity of the supply breakers. Increasing the current limit verified in SR 3.8.4.5 from 250 amps to 300 amps, which is within the battery charger design rating, confirms that the SR will be a test that ensures that the necessary quality of the battery chargers is maintained and

that the LCO will continue to be met. The NRC staff concludes that with the proposed change, SR 3.8.4.5 will meet the requirements of 10 CFR 50.36(c)(3) and 10 CFR Part 50, Appendix A, GDC 17 and 18, and will continue to conform to the guidelines of Safety Guide 6. Therefore, the NRC staff finds the change proposed in the LAR to be acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendments on August 28, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change SRs.

The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on March 13, 2018 (83 FR 10915). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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

Principal Contributor: Prem Sahay Date: September 27, 2018

ML18243A298 *by email OFFICE NRR/DORULPL2-2/PM NRR/DORULPL2-2/LA NRR/DE/EEOB/BC* NRR/DSS/STSB/BC*

NAME DGalvin BClayton JQuichocho VCusumano DATE 09/07/18 09/20/18 07/30/18 09/05/18 OFFICE OGC-NLO* NRR/DORULPL2-2/BC(A) NRR/DORULPL2-2/PM NAME JWachutka BVenkataraman DGalvin DATE 09/14/18 09/27/18 09/27/18