CNL-16-036, Sixth Six-Month Status Report in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Sixth Six-Month Status Report in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML16063A470
Person / Time
Site:	Browns Ferry
Issue date:	02/26/2016
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-16-036, EA-12-049, TAC MF0902, TAC MF0903, TAC MF0904
Download: ML16063A470 (17)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-16-036 February 26, 2016 10 CFR 2.202 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

Sixth Six-Month Status Report in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904)

References:

1. NRC Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A735)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ML12229A174)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ML12242A378)

4. Letter from TVA to NRC, Tennessee Valley Authority - Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 29, 2012 (ML12307A104)

5. Letter from TVA to NRC, Tennessee Valley Authority (TVA) - Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant, dated February 28, 2013 (ML13064A465)

U.S. Nuclear Regulatory Commission CNL-16-036 Page 2 February 26, 2016

6. Letter from TVA to NRC, First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant, dated August 28, 2013 (ML13247A284)

7. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -

Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0902, MF0903, and MF0904), dated December 19, 2013 (ML13225A541)

8. Letter from TVA to NRC, Second Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 28, 2014 (ML14064A240)

9. Letter from TVA to NRC, "Third Six-Month Status Report and Revised Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 28, 2014 (ML14248A496)

10. Letter from TVA to NRC, Fourth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 27, 2015 (ML15064A162)

11. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -

Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0902, MF0903, MF0904, MF0881, MF0882, and MF0883), dated April 6, 2015 (ML15069A358)

12. Letter from TVA to NRC, Fifth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 28, 2015 (ML15240A228)

U .S . Nuclear Regulatory Commissio n CNL-16-03 6 Page 3 February 26 , 2016 On March 12, 2012 , the Nuclear Regulatory Commission (NRC) issued an order (Reference 1} to Tennessee Valley Authority (TVA) Reference 1 was immediatel y effective and directed TVA to develop, implement. and maintain guidance and strategies to maintain or restore core cooling , containmen t, and spent fuel pool cooling capabilities following a beyond-de sign-basis external event. Specific requirements are outlined in Attachmen t 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan (OIP) pursuant to Section IV. Condition C. Reference 2 endorses industry guidance document Nuclear Energy Institute (NEI) 12-06 Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2 Reference 4 provided the TVA initial status report regarding mitigation strategies . Reference 5 provided the TVA Browns Ferry Nuclear Plant (BFN) . Units 1, 2, and 3 OIP. Reference 9 provided Revision 1 of the OIP.

Reference 1 requires submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports . TVA provided the first six-month status report on August 28 , 20 13 (Reference 6). The NRC issued its Interim Staff Evaluation regarding TVA's OIP on December 19. 2013 (Reference 7) . TVA provided the second six-month status report on February 28. 20 14 (Reference 8) , the third six month status report and revised OIP on August 28, 2014 (Reference 9), the fourth six-month status report on February 27. 2015 (Reference 10). and the fifth six-month status report on August 28 , 2015 (Reference 12). The NRC issued its onsite Audit Report on April 6 . 2015 (Reference 11 ).

The purpose of this letter is to provide the sixth six-month status report pursuant to Section IV.

Condition C.2. of Reference 1. The enclosed report provides an update of milestone accomplish ments since submittal of the fifth six-month status report, including any changes to the compliance method or schedule .

There are no new regulatory commitmen ts contained in this letter. If you have any question regarding this submittal . please contact Mike Oliver at (256) 729-7874.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 26th day of February 2016.

Respectful ly, J W Sh ea Dlgltally s19nedbyJ.W Shea DN: cn=J. W. Shea.o=TennesseeValley Authority. ou=Nuclea1 Licensing,

• ema1l=jwshea@tva.gov, c=US Date: 2016.02.26 20:34:38 -05'00 J. W . Shea Vice President, Nuclear Licensing Enclosure cc: See Page 4

U.S. Nuclear Regulatory Commission CNL-16-036 Page 4 February 26, 2016

Enclosure:

Tennessee Valley Authority Browns Ferry Nuclear Plants Sixth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) cc (Enclosure):

NRR Director - NRC Headquarters NRO Director - NRC Headquarters NRC JLD Director - NRC Headquarters NRC Regional Administrator - Region II NRC Project Manager - Browns Ferry Nuclear Plant NRC JLD Project Manager - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Browns Ferry Nuclear Plant

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANTS SIXTH SIX-MONTH STATUS REPORT IN RESPONSE TO THE MARCH 12, 2012, COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (ORDER NUMBER EA-12-049) 1 Introduction In response to Order EA-12-049 (Reference 2 in Section 8), Browns Ferry Nuclear Plant (BFN) developed an Overall Integrated Plan (OIP) (Reference 1 in Section 8) documenting the diverse and flexible strategies (FLEX). OIP Revision 1 was submitted with the third six-month status report (Reference 7 in Section 8). This enclosure provides an update of milestone accomplishments since the submittal of the fifth six-month status report (Reference 10 in Section 8) regarding the OIP, including any changes to the compliance method or schedule.

2 Milestone Accomplishments The following milestones have been completed since the submittal of the fifth six-month status report regarding the OIP, and milestone accomplishments are current as of February 19, 2016.

Unit 1 Design Engineering 3 Milestone Schedule The following provides an update to Attachment 2, Milestones, of OIP Revision 1. The update provides the activity status of each item and whether the target date has changed.

The target completion dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

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Revised Target Original Target Activity Activity Completion Date Status Date Submit Overall Integrated Plan February 2013 Complete Submit 6 Month Updates:

Update 1 August 2013 Complete Update 2 February 2014 Complete Update 3 August 2014 Complete Update 4 February 2015 Complete Update 5 August 2015 Complete Update 6 February 2016 Complete Update 7 August 2016 Not Started Update 8 February 2017 Not Started Update 9 August 2017 Not Started Update 10 February 2018 Not Started FLEX Strategy Evaluation March 2014 Complete Unit 1 - Validation of connection points for FLEX Phase 2 & 3 via November 2016 Not Started walkthrough or demonstration.

(Graded approach)

Unit 2 - Validation of connection points for FLEX Phase 2 & 3 via April 2015 Complete walkthrough or demonstration.

(Graded approach)

Unit 3 - Validation of connection points for FLEX Phase 2 & 3 via April 2016 In-Progress walkthrough or demonstration.

(Graded approach)

Perform Staffing Analysis January 2015 Complete Modifications:

Modifications Evaluation March 2014 Complete Unit 1 N-1 Walkdown October 2014 Complete Unit 1 Design Engineering November 2014 Complete Unit 1 Implementation Outage November 2016 Not Started Unit 2 N-1 Walkdown March 2013 Complete Unit 2 Design Engineering December 2014 Complete Unit 2 Implementation Outage April 2015 Complete Unit 3 N-1 Walkdown March 2014 Complete Unit 3 Design Engineering November 2014 Complete Unit 3 Implementation Outage April 2016 In-Progress March 2016 Storage:

Storage Design Engineering August 2014 Complete Storage Implementation April 2015 Complete FLEX Equipment:

Procure On-Site Equipment January 2015 Complete Develop Strategies with RRC February 2015 Complete Identify Off-Site Delivery Station April 2015 Complete Procedures:

BWROG issues FSG guidelines April 2014 Complete Create Browns Ferry FSIs April 2015 In-Progress October 2016 Page 2 of 13

Revised Target Original Target Activity Activity Completion Date Status Date Create Maintenance Procedures April 2015 Complete Training:

Develop Training Plan December 2014 Complete Implement Training February 2015 Complete Unit 1 FLEX Implementation November 2016 In-Progress Unit 2 FLEX Implementation April 2015 In-Progress April 2017 Unit 3 FLEX Implementation April 2016 In-Progress April 2018 Full Site FLEX Implementation November 2016 In-Progress April 2018 Submit Completion Report December 2016 Not Started May 2018 4 Changes to Compliance Method The following is a list of changes made to the information provided in OIP Revision 1 (Reference 7 in Section 8) and not provided in previous 6 month updates. These changes meet the NEI 12-06 compliance method.

4.1 Section 1, Determine Applicable Extreme External Hazard, Storms with High Winds and Tornadoes Hazards Assessment, first paragraph, was changed to read as follows:

Browns Ferry Nuclear Plant is susceptible to hurricanes; however, based on the contour lines shown in NEI 12-06, Figure 7-1 (Ref. 3a), BFN is not susceptible to winds exceeding 130 mph from hurricanes.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation TVA requested and received relaxation from full implementation until the completion of the spring 2017 refueling outage for BFN Unit 2 and the spring 2018 refueling outage for BFN Unit 3 to allow sufficient time to implement a severe accident capable hardened containment wetwell vent (References 8 and 9 in Section 8). The Milestone Schedule (Section 3 and Attachment 2) has been revised to reflect this relaxation.

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6 Open Items from Overall Integrated Plan and NRC Evaluation The following tables provide a summary of the open items documented in the OIP or the NRC Evaluation and the status of each item.

Overall Integrated Plan Open Item Status OI-1: Flood and seismic re-evaluations Open pending NRC review. No further TVA action pursuant to the 10 CFR 50.54(f) required.

letter of March 12, 2012 are not completed and therefore not assumed in this submittal. As the re-evaluations are completed, appropriate issues will be entered into the corrective action system and addressed.

OI-2: Liquefaction of haul routes for Closed. Liquefaction study for path from Staging FLEX will be analyzed from Area B to the West Access Portal is performed by Staging Area B to Staging Area A. Amec Environment and Infrastructure Inc and is Also, an evaluation will be documented in their report dated August 19, 2014.

conducted of haul routes from The report concluded that liquefaction induced Staging Area D and Staging Area settlement will not exceed 2.5 and cracking due to C to Staging Area B. lateral spreading will be insignificant. The Staging Areas inside the Protected Area (PA) were evaluated during construction of ISFSI Pad, and it was determined that there would be no significant displacement (< 1.0) due to SSE seismic event (Ref Calc No. CDQ007920030261). Therefore, it can be concluded that paths to the staging areas inside the protected area will not be susceptible to any significant deformations that would impact deployment of FLEX Equipment after any severe seismic event.

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Overall Integrated Plan Open Item Status OI-3: TVA will confirm that they have Closed. The duration of the ELAP is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and enough fuel onsite for the first all permanent plant sources of AC power are 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. A diesel fuel storage considered unavailable. The T/Gs will burn No. 2 and refueling plan also has to be Diesel Fuel at a full load consumption rate of developed. 110 gallons/hour per T/G. The T/Gs are not provided with their own fuel oil storage tanks. Two portable trailer mounted Transcube fuel oil storage tanks with 1200 gallon of No. 2 Diesel Fuel each will be stored in the FESB and available for deployment with the 480V and 4kV generator sets.

Each Transcube will be equipped with adequate hose, valves, manual priming pump, and compatible connections necessary to support initial generator operation. One dedicated Transcube for the 480V generator will provide adequate fuel for the first 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of operation, and one shared Transcube between the two 4kV generators will provide adequate fuel for the first 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Three Gorman-Rupp portable diesel engine driven self-priming centrifugal diesel fuel pumps will be stored in the FESB. These pumps can be staged to transfer fuel oil from any of the eight Diesel 7 Day fuel oil storage tanks with a Technical Specifications minimum capacity of >35,280 gallons each or from one of two fuel oil storage tank located on the east side of the plant. The total combined Technical Specification minimum volume for the 8 installed EDGs is 282,240 gallons.

OI-4: BFN will evaluate SRV Open pending NRC review. No further TVA action qualification against the predicted required containment response with FLEX implementation to ensure there will be sufficient DC bus voltage and pneumatic pressure to operate the SRVs throughout Phase 1 and Phase 2.

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Overall Integrated Plan Open Item Status OI-5: A reference source for the plant Closed. 1,2,3-FSI-6C, Key Instrument Readings operators will be developed that During Loss of DC Power, are new FLEX provides approaches to obtaining procedures that have been developed to provide necessary instrument readings to guidance during a BDBEE with the loss of support the implementation of the instrument power. A 3-Tiered approach to FLEX coping strategy (NE 12-06, measurement strategies as follows (all three tiers Section 3.2.1.1 0). This reference may not be applicable for every measurement to be source should include control obtained):

room and non-control room TIER 1: Provide power to primary instruments (i.e.,

readouts and should also provide transmitter or RTD) and measure at locations guidance on how and where to directly accessible from the Control Bay. These measure key instrument readings locations are the Auxiliary Instrument Rooms or at containment penetrations, Electric Board Rooms. Primary instrument wiring where applicable, using a portable would be lifted and handheld devices connected instrument (e.g., a Fluke meter).

which provide both power and measuring Such a resource could be provided capabilities.

as an attachment to the plant procedures/guidance. Guidance TIER 2: Provide power to primary instruments and will include critical actions to measure at Reactor Building locations. These perform until alternate indications locations are within Secondary Containment.

can be connected and on how to Primary instrument wiring would be lifted and control critical equipment without handheld devices connected which provide both associated control power. power and measuring capabilities.

TIER 3: Provide alternate instruments to measure the desired parameters as close to the process as is practical.

OI-6: Validate the preliminary Battery Closed. Calculation EDQ0009992013000202 does studies that were performed to the load calculation for the 250 volt unit batteries.

ensure appropriate battery life will This load study strips nonessential loads to allow be available with regards to the BFN Units 1, 2, & 3 to last 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

overall FLEX strategies. Ensure DCN 71470 is the modification that procures fans that buildup of hydrogen is for installation in the battery rooms during a beyond considered and mitigated design basis event to account for the hydrogen appropriately.

production during battery off gassing during battery charging.

Flex procedure 0-FSI-4A installs the fans during a beyond design basis event in the battery rooms on elevation 1C (593) in the control bay.

OI-7: BFN will take actions as necessary Open pending NRC review. No further TVA action to assure RCIC can operate at required elevated temperatures.

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Overall Integrated Plan Open Item Status OI-8: Perform modifications, as Closed. Reactor Core Isolation Cooling (RCIC) necessary, to ensure that RCIC is system has been evaluated using the Expedited seismically robust. Seismic Evaluation Process (ESEP). Calculation CDQ0009992014000268 has determined that the RCIC system is seismically rugged and complies with the requirements of BFN FLEX Strategies.

Based on the conservative evaluation documented in this calculation, BFN Units 1, 2, & 3 meet all seismic capacity requirements for ESEP.

The ESEP review performed for BFN Units 1, 2, &

3 was summarized in AREVA Inc. Document No. 51-9230498 Rev. 1, Expedited Seismic Evaluation Process (ESEP) Summary Report for Browns Ferry Nuclear Plant, dated December 10, 2014.

OI-9: Develop and perform the design Closed. DCN 71329 installed connection points in modifications identified in the the B EECW pump room, D RHRSW pump FLEX Strategy document to permit room, and the B RHRSW pump room for the timely and safe connection of connection of the portable FLEX pump systems.

the FLEX and NSRC equipment This DCN also establishes a connection point and during the adverse conditions isolation for the RCIC oil cooler. The EECW, B encountered during these beyond RHRSW, and D RHRSW system tie-ins and design basis events. manifolds are complete. Connections to the Unit 2 RCIC oil cooler are complete, and the Unit 1 and 3 connections will be complete prior to the FLEX compliance date. FSIs direct the connections and operation of FLEX pump systems.

DCN 71454 installed a pump deployment path from the FLEX Equipment Storage Building (FESB) to the new FLEX Pump Deployment pads at the Intake Pump Station forebay. 0-FSI-6A (Ref. 13n) provides guidance during a BDBEE. Steps are directed to identify issues that will impede deployment of equipment and implementation of FLEX strategies.

OI-10: Design and construct a Flexible Closed. Flex Mitigation System Design Criteria Equipment Storage Building, BFN-50-7360 identifies the design attributes and located above the probable storage requirements for the Flex Equipment maximum flood level, which is Storage Building (FESB).

adequately protected from the DCN 70745 implements the design of the building hazards listed in Section 1 which complies with the Flex Design Criteria.

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Overall Integrated Plan Open Item Status OI-11: Modify currently installed Closed. Proposed modifications to the existing hardened wetwell vent to install Hardened Wet Well Vent (HWWV) to comply with backup pneumatic supply or NRC Order EA-13-109 includes the design for a provided procedural guidance for backup pneumatic supply for operation of the manual operation, to allow use Hardened Containment Vent System (HCVS) within current design limits. valves (FCV-064-0221 & 0222) during an BDBEE.

However, compliance with Order EA-13-109 does not support implementation schedule of the FLEX Order EA-12-049. Based on the difference in implementation schedules between Orders EA-13-109 and EA-12-049, BFN has requested and received a relaxation for full compliance with Order EA-12-049.

Valves FCV-064-0221 and 0222 have the ability to be manually operated based on the design implemented under GL 89-16. The event in which operation of the HCVS valves would be needed is a beyond Design Basis External Event (BDBEE).

Operations would be performing actions as needed to maintain the plant in a safe condition, and operation of components to vent containment would be performed in accordance with procedure 2-EOI Appendix 13. Since the plant is performing mitigation strategies and fuel damage has not occurred, environmental conditions in the area would allow access to the valves for operation.

OI-12: Design and install the Closed. The design and implementation of the modifications required by Order Spent Fuel Pool Level Instrumentation will be EA-12-051 for enhancing the SFP. completed in accordance with Engineering Change Packages DCN 71159, DCN 71160, and DCN 71161 for BFN Units 1, 2, & 3, respectively. The applicable codes, standards, regulatory requirements, and procedures are spelled out within the stated DCNs.

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Overall Integrated Plan Open Item Status OI-13: Determine the design Closed. BFN has ordered two Ford F550 trucks specifications for FLEX equipment equipped with scraper blades and winch for debris yet to be ordered, such as the six removal and one compact track loader CAT 299D Portable Ventilation Fans, the for debris removal. DCN 71470 will provide a 480v Mobil Water Purification Unit, supply and connection strategy to portable lighting debris removal equipment for the and ventilation during a BDBEE.

FLEX Equipment Haul path and 20 Smithlight Battery operated LED work lights are piping for the FLEX low pressure identified in the DCN.

pumps.

A total of 12 fans are identified in the DCN and will be deployed and operated using 0-FSI-4A in the Control Bay.

Fan Quantity TA16-5000 3 Coppus Vano 3 175CV Coppus Vano 2 250CV Pedestal Fan 3 30 inch Barrel Fan 1 OI-14: Deployment strategies and Closed. DCN 70745 (Site Bunker Building), DCN deployment routes will be 71454 (Install Deployment Roads and Pump assessed for impact due to Landings) DCN 71405 (Stage 4kv Diesels for identified hazards and guidance Fukushima Event and Provide Connection Points),

developed/provided to ensure that and DCN 71470 (Stage 480v power supply and

1) sufficient area is available for support equipment to charge the Unit Battery deployment, 2) haul paths remain Chargers) have ensured sufficient area is available accessible without interference for deployment. Additionally, all deployment from outage equipment during accessories such as pumps, ramps, winches, and refueling outages and 3) other transfer assemblies such as equipment deployment locations for the trailers, as appropriate, have been assessed and pumps including ramps, winches are included to ensure OIP timeframes are met.

or other transfer assemblies as Haul paths and deployment pads will be observed appropriate to deploy all pumps daily during Nuclear Security rounds to ensure both and hoses within the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Phase paths and pads are accessible without interference.

1 coping interval.

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OI-15: Detailed staffing studies based on Closed. Browns Ferry Nuclear Plant has completed the procedures/guidance a Phase 2 ELAP ERO Staffing Analysis Report in developed. accordance with NEI 12-01. The analysis concluded the on-shift ERO staffing present for the no-site access 6-hour time period is sufficient to perform the FSI, EOI, and emergency response tasks.

OI-16. Validation of the time lines for the Closed. Validation of the time lines for the various various strategies. strategies was performed in accordance with 0-FSI-8B (Ref. 13s). This FSI utilized NEI 14-01 FLEX Validation Process as a reference.

OI-17: Browns Ferry Nuclear Plant (BFN) Closed. BFN has utilized the industry-developed will utilize the industry developed guidance from the BWROG, EPRI, and NEI Task guidance from the Owners team to develop site specific procedures that Groups, EPRI and NEI Task team addressed the criteria in NEI 12-06 (Ref. 6).

to develop site specific procedures 0-AOI-57-1A, EOI appendices, and FSIs support or guidelines to address the the existing symptom-based command and control criteria in NEI 12-06. These strategies in the current EOIs.

procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOIs.

OI-18: New training of general station Closed. TRN-30, Radiological Emergency staff and EP will be performed Preparedness Training, requires the Emergency prior to the first BFN unit design Preparedness responders to complete INPO implementation outage. These Generic Basic Flex Training (NANTEL 00002382),

programs and controls will be and, for persons assigned key positions, the INPO implemented in accordance with Generic Advanced Flex Training (NANTEL the Systematic Approach to 00002385). Training requirements by position are Training. listed in TRN-30, Attachment 3. This TRN was developed in accordance with the Systematic Approach to Training (SAT).

Additional overview training was developed for Maintenance personnel that may be asked to deploy and connect equipment in various scenarios. This training was developed using the SAT process and approved by the respective Maintenance training oversight committees. The Technical training organizations also documented Training Needs Analysis for their groups with conclusions being that Nantel Basic FLEX overview is sufficient at this time.

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OI-19: TVA will establish a contract with Closed. A contract has been established between the Strategic Alliance for FLEX TVA and the SAFER team, AREVA Inc. Document Emergency Response (SAFER) No. 51-9233061 Rev. 0, Browns Ferry Nuclear team. A local assembly area must Plant SAFER Response Plan. Two off-site local also be established by SAFER staging areas have been identified, and one onsite and TVA for equipment moved staging area has been identified. The onsite from the National SAFER staging area (Staging Area B) is located in the Response Center (NSRC) to BFN. Northeast corner of the Owner Controlled Area at the Facility and Vehicles Maintenance Shop. The two off-site staging areas are TVA Helicopter Operations at the Northwest Alabama Regional Airport (Staging Area C) in Muscle Shoals, Alabama, and at the Pryor Field Regional Airport (Staging Area D) in Decatur, Alabama.

OI-20: Evaluate different strategies to Closed. 2-EOI Appendix 20K is a new procedure allow removal of water from the written to utilize RCIC in test mode to pump the Suppression Pool. Determine if torus to the CST(s). The required valves are any modifications are required and dc-powered and will be available to be operated what strategies are deemed from the Main Control Room.

feasible.

OI-21: Abnormal operating procedure, Closed. 0-FSI-6A, Damage Assessment, is a new AOI-100-9, Turbine Building FLEX procedure that has been developed to Internal Flooding, provides the provide guidance during a BDBEE. Steps are symptoms and operator actions to directed to identify issues that will impede be taken for this condition. During deployment of equipment and implementation of development of procedures to FLEX strategies. Building assessments are support FLEX strategies, performed and information provided to the FLEX adequate guidance will be given to Response SRO, Shift Manager, or Site Emergency operators to ensure their travel Director to make decisions based on results.

paths avoid these areas. Internal plant flooding will be identified, and alternate routes are available for performance of these strategies. Doors are verified unlocked and available to allow access to the Control Bay and Reactor Buildings via Electric Board Rooms on elevations 621 and 593.

7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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8 References The following references support the updates to the OIP described in this attachment.

1. Letter from TVA to NRC, Tennessee Valley Authority (TVA) - Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant, dated February 28, 2013 (ML13064A465)

2. NRC Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A735)

3. NEI 12-06 Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 21, 2012 (ML12242A378)

4. Letter from TVA to NRC, First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant, dated August 28, 2013 (ML13247A284)

5. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0902, MF0903, and MF0904), dated December 19, 2013 (ML13225A541)

6. Letter from TVA to NRC, Second Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 28, 2014 (ML14064A240)

7. Letter from TVA to NRC, "Third Six-Month Status Report and Revised Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 28, 2014 (ML14248A496)

8. Letter from TVA to NRC, Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated August 28, 2014 (ML14247A447)

9. Letter from NRC to TVA, "Browns Ferry Nuclear Plant, Units 2 and 3 - Relaxation of the Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0903 and MF0904), dated December 23, 2014 (ML14281A198).

10. Letter from TVA to NRC, "Fourth Six-Month Status Report and Revised Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 27, 2015 (ML15064A162).

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11. Letter from TVA to NRC, Fifth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 28, 2015 (ML15240A228)

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