CNL-17-024, Update to License Amendment Request to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor - Revision to Tables S-2 and S-3

Update to License Amendment Request to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor - Revision to Tables S-2 and S-3

ML17158B285
Person / Time
Site:	Browns Ferry
Issue date:	06/07/2017
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML17158B284	List: CNL-17-024, Update to License Amendment Request to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor - Revision to Tables S-2 and S-3
References
CNL-17-024, TAC MF1185, TAC MF1186, TAC MF1187
Download: ML17158B285 (51)

Text

Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390.

Enclosures 2 and 7 to this letter contains Security-Related Information.

Upon removal of these Enclosures, this letter is uncontrolled.

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-17-024 June 7, 2017 10 CFR 50.90 10 CFR 50.4 10 CFR 2.390 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 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:

Update to License Amendment Request to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187) - Revision to Tables S-2 and S-3

References:

1. Letter from TVA to NRC, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), (Technical Specification Change TS-480)," dated March 27, 2013 (ML13092A393)

2. Letter from TVA to NRC, CNL-15-074, "Update to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187)," dated June 19, 2015 (ML15174A149)

3. Letter from TVA to NRC, CNL-15-191, Update to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187) - Revised Safe Shutdown Analysis Request for Additional Information 15, dated September 8, 2015, (ML15251A598)

U.S. Nuclear Regulatory Commission CNL-17-024 Page 2 June 7, 2017

4. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Issuance of Amendments Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) (CAC Nos. MF1185, MF1186, and MF1187), dated October 28, 2015 (ML15212A796)

5. Letter from TVA to NRC, CNL-16-165, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments -

Extended Power Uprate (EPU) - Supplement 34, Revised Proposed License Conditions and Technical Specification Changes, dated October 31, 2016 (ML16305A370)

By letter dated March 27, 2013 (Reference 1), Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, to transition to National Fire Protection Association Standard (NFPA) 805. By letter dated June 19, 2015 (Reference 2), TVA provided an update to Reference 1. By letter dated September 8, 2015 (Reference 3), TVA provided revised Tables S-2 and S-3 in their entirety.

The NRC issued a Safety Evaluation (SE) on October 28, 2015 (Reference 4) regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c). The SE included a statement that, The licensee shall implement the following modifications to its facility as described in Attachment S, Table S-2, Plant Modifications. Likewise, the SE also included a statement that, The licensee shall complete the implementation items as listed in Table S-3, Implementation Items.

During the implementation of modifications identified in the TVA NFPA 805 program, TVA determined that clarifications and revisions were required to certain NFPA 805 modifications. Enclosure 1 of this letter identifies and evaluates each of these proposed changes.

This letter identifies one request to clarify and two requests to delete identified NFPA 805 changes. Two requested changes revise Table S-2; one requested change revises Table S-3. Enclosure 1 provides the basis for the proposed changes.

Note that the Table S-3 items were completed within the required 240 day completion time contained in the SE License Condition (exceptions were noted for Items 32 and 33). An exception to the 240-day completion time was also noted in the SE for the second part of Item 47, i.e., resolving finding-level Findings and Observations from the Focused-Scope Peer Review that was performed to satisfy the first part of Item 47. Table S-3 item 09 is being deleted because TVA finds its implementation to be too restrictive. The Table S-3 items with the exception of Items 32 and 33, and the second part of Item 47, remain complete.

Enclosures 2 and 3 provide markups of Attachment S, Tables S-2 and S-3 respectively. provides a markup of Attachment A. Enclosure 5 to this letter provides markups of Attachment M that contains the Renewed Facility Operating License (RFOL). These revisions reflect the proposed change as described in Enclosure 1.

U.S. Nuclear Regulatory Commission CNL-17-024 Page 3 June 7, 2017 provides a clean copy of Attachment M that contains the RFOL. Enclosure 7 provides a clean copy of Attachment S, Table S-2. Enclosure 8 provides a clean copy of Attachment S, Table S-3. The BFN Extended Power Uprate (EPU) application (Reference 5) included the removal of Implementation Item 49 from Table S-3, but it is still retained in the table until NRC approval of the BFN EPU. Enclosure 9 provides a clean copy of Attachment A. These revisions reflect the proposed changes as described in. Enclosures 2 and 7 to this letter contain security-related information and should be withheld from public disclosure under 10 CFR 2.390.

TVA has determined that there are no significant hazards consideration associated with the proposed change and that the TS change qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9). Additionally, in accordance with 10 CFR 50.91 (b)(1 ), TVA is sending a copy of this letter and enclosures without proprietary information, to the Alabama State Department of Public Health.

These proposed changes are requested to be approved by six months from the date of this letter.

There are no new regulatory commitments contained in this submittal. Please address any questions regarding this submittal to Mr. Edward D. Schrull at (423) 751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 7th day of June 2017.

Resp* C~

J. W Shea resident, Nuclear Licensing - Proposed Changes to NFPA 805 Submittal LAR - Attachment S, Table S Markups - Attachment S, Table S Markups - Attachment A - Markup - Facility Operating License - Markups - Facility Operating License - Clean Copy - Revised Attachment S, Table S Clean Copy - Revised Attachment S, Table S Clean Copy - Attachment A - Clean Copy cc (Enclosure):

NRC Regional Administrator-Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Health Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 Table of Contents 1.0 Summary Description 2.0 Detailed Description 3.0 Technical Evaluation 4.0 Regulatory Evaluation 4.1 No Significant Hazards Consideration Determination 4.2 Applicable Regulatory Requirements/Criteria 4.3 Conclusions 5.0 Environmental Considerations 6.0 References Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 2 of 17 1.0 Summary Description This evaluation supports a request to revise Renewed Facility Operating Licenses (RFOL) DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant (BFN)

Units 1, 2, and 3, respectively. BFN RFOL, paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, Transition License Conditions, requires the Tennessee Valley Authority (TVA) to implement modifications to its facility as described in Attachment S, Table S-2, Plant Modifications, and Table S-3, Implementation Items, to complete the transition to full compliance with 10 CFR 50.48(c). This proposed License Amendment Request (LAR) changes the above license conditions to include a reference to this letter.

The guidance of the March 2, 2016, letter from the Nuclear Regulatory Commission (NRC) to the Nuclear Energy Institute (NEI) (Reference 2) was used to develop this LAR. TVA utilizes guidance in Option A described in the aforementioned letter because the plant modifications have been evaluated using the accepted fire PRA (FPRA) methods and approaches as summarized in TVAs NFPA 805 safety evaluation dated October 28, 2015 (Reference 3). Accordingly, Attachments A, M, and S of the previously approved NFPA 805 submittal for BFN (Reference 1) were revised. The revisions are based on two changes to Attachment S, Table S-2, and one change to Table S-3.

2.0 Detailed Description The current BFN RFOL, paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, Transition License Conditions, Item 2 for each TVA BFN Unit, states the following:

The licensee shall implement the modifications to its facility, as described in Table S-2, Plant Modifications, of TVA letter CNL-15-191, dated September 8, 2015, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

The proposed LAR revises the BFN RFOL, paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, Transition License Conditions, Item 2, to state the following:

The licensee shall implement the modifications to its facility, as described in Table S-2, Plant Modifications, of TVA letter CNL-17-024, dated

__/__/2017, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 3 of 17 The current RFOL, paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, Transition License Conditions, Item 3, for each TVA BFN Unit states:

The licensee shall complete the implementation items as listed in Table S-3, Implementation Items, of Tennessee Valley Authority letters CNL-15-191, dated September 8, 2015, and CNL-15-224 dated October 20, 2015, within 240 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

The proposed LAR revises the BFN RFOL, paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, Transition License Conditions, Item 3, to the following:

The licensee shall complete the implementation items as listed in Table S-3, Implementation Items, of TVA letter CNL-17-024, dated

__/__/2017, within 240 days after issuance of the NFPA 805 License Amendment dated October 28, 2015 unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage.

Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

2.1 NRC Guidance for Changes to Approved Modifications In the NRC letter to NEI, Recommended Content for License Amendment Requests That Seek Changes to License Conditions That Were Established in Amendments to Adopt National Fire Protection Association Standard 805 But Have Yet to be Fully Implemented, dated March 2, 2016 (Reference 2), NRC provided guidance in developing an LAR for licensees wishing to change or remove a plant modification. The NRC provided three options for licensees to provide the necessary information for NRC to review in a timely manner; the most germane option for the TVA proposed changes to the approved NFPA 805 modifications is Option A. NRC recommended that the following information be provided for an Option A approval:

i.

A summary of all changes to the modifications; ii.

A summary of all changes to the probabilistic risk assessment (PRA) models and explanation for each change; iii.

New, updated versions in their entirety of: the License Condition (Attachment M), list of plant modifications (Attachment S), and the summarizing area wide change-in-risk result tables (Attachment W); and iv.

A statement that the defense-in-depth (DID) and safety margin evaluations associated with the original LAR have been completed Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 4 of 17 on the proposed changes.

Items i., ii., and iv are provided in this enclosure. Enclosure 5 to this letter provides the revision to Attachment M, License Condition Changes to reflect the proposed changes to the BFN Units 1, 2, and 3 RFOL, paragraphs 2.C.(13),

2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively. Enclosure 6 provides clean pages of Attachment M, License Condition Changes to reflect the proposed changes to the BFN Units 1, 2, and 3 RFOL, paragraphs 2.C.(13),

2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively.

provides a markup of the changed pages of Attachment S, Table S-2 Plant Modifications. Enclosure 3 to this letter provides a markup of the specific changes to Attachment S, Table S-3, Implementation Items. Enclosure 7 provides a complete clean copy of the Attachment S, Table S-2. Enclosure 8 provides a complete clean copy of Attachment S, Table S-3. Enclosures 7 and 8 supersede all previous versions of Attachment S.

The proposed changes to Attachment S also affect Attachment A, NEI 04-02 Table B-1, Transition of Fundamental Fire Protection Program and Design Elements. A markup of the affected page of Attachment A is included in Enclosure

4. The clean copy of the affected page of Attachment A is contained in Enclosure 9.

Area-wide change in risk tables from Attachment W are not provided with this request. Modeling changes were made in order to correctly quantify the risk impact of the removal of Modification 84. In addition, PRA updates needed to reflect the final configuration of Modifications 52a, 52b, and 52c are scheduled in the future to support Table S-3, Item 32 to update the FPRA after the modifications are completed. Qualitative and quantitative assessments of risk effects are provided in this letter.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 5 of 17 2.2 Attachment S Changes TVA Change Request 1: Revise Table S-2, Modifications 52a and 52b to clarify modification descriptions Proposed Change:

This proposed request changes Table S-2 Modifications 52a and 52b to clarify the modification descriptions to match the design changes that are being implemented.

The current description under Item 52a, Proposed Modification states:

For Drywell wide range pressure instruments P-64-160A and B, provide isolation of associated circuits and make appropriate power supply available such that both division instruments are not lost in the same fire scenario.

This description is changed to state:

Modify power supplies and associated circuits for drywell pressure indication instruments such that indication is available in the MCR for all fire scenarios except those in FA 16.

The current description under Item 52b, Proposed Modification states:

Provide containment pressure indication on the Backup Control Panel.

This description is changed to state:

Provide isolation from circuits in FA 16 for containment pressure indication on the Backup Control Panel.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 6 of 17 TVA Change Request 2: Delete Table S-2, Modification 84 Table S-2, Modification 84 (PM-84) currently states:

This proposed request deletes PM-84 entirely.

TVA Change Request 3: Delete Table S-3, Item 09 Table S-3, Item 09 currently states:

The proposed change deletes Item 09 entirely.

Additionally, Attachment A, Table B-1, Transition of Fundamental Fire Protection Program & Design Elements, for NFPA 805, Chapter 3, Reference item 3.3.5.2

[Electrical Raceway Construction Limits] is revised to delete the Item for Implementation, because it references Attachment S, Table S-3, Item 09 which is being deleted.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 7 of 17 3.0 Technical Analysis TVA Change Request 1: Revise Table S-2, Modifications 52a and 52b Basis for Proposed Change Request 1 The basis for NFPA 805 modification 52 (subdivided into modifications 52a, 52b, and 52c) is to ensure one drywell pressure indication is available for all fire scenarios in order to support operator actions to vent the containment as one means of decay heat removal.

The revised Modification 52a corrects power supply separation and associated circuit issues, for fire scenarios outside Fire Area (FA) 16. Modification 52b corrects separation issues for FA 16 scenarios. Modification 52c does not change; its purpose is to reroute instrument loop cables to address the non-FA 16 scenarios that Modification 52a does not resolve. The original Modification 52 concept was to separate the P-064-0160A and P-064-0160B instrument loops for these indication requirements. However, by considering the availability of additional instrument loops in various fire scenarios, TVA determined that separation of P-064-0160A and P-064-0160B was not necessary. Two additional instrument loops (P-064-0050 and P-064-0067B), which were also credited in the Fire PRA model, provide the required drywell pressure indication. Thus, the four instrument loops noted above (P-064-0050, P-064-0067B, P-064-0160A, and P-064-0160B), provide the required drywell pressure indication in a fire event. Thus, the original wording in the Modifications 52a and 52b description is being changed to more accurately describe the modification being performed.

Risk Impact Discussion The FPRA model utilized to support the NFPA 805 LAR included the additional two drywell pressure indication instrument loops mentioned above (P-064-0050 and P-064-0067B). No modeling changes were required to include these loops as additional sources of the drywell pressure information needed for Hardened Wetwell Vent (HWWV) initiation.

The final modification is expected to be equal to or better than the modification originally described in Table S-2 of the NFPA 805 LAR with respect to fire risk. Risk will be quantified as part of the FPRA update identified in Table S-3, item 32.

Defense-in-Depth/Safety Margin Discussion Defense-In-Depth (DID) is based on the following three echelons:

1) Prevent fires from starting

2) Rapidly detect, control and extinguish promptly those fires that do occur thereby preventing fire damage

3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed The changes to drywell pressure instrumentation made available through PM-52 (a, b, and c) do not affect any DID or Safety Margin. The additional instrumentation credited for drywell pressure indication meets the functional requirements.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 8 of 17 TVA Change Request 2: Delete Table S-2, Modification 84 Basis for Proposed Change Request 2 The analysis performed for the BFN NFPA 805 transition identified scenarios in which fire induced spurious operation of 4kV circuit breakers could overload the off-site power (OSP) circuits feeding the safety related electrical distribution system (4kV Shutdown Boards (SD)). Such an overload is assumed to result in a failure of OSP supply to inventory makeup and decay heat removal systems. The original goal of PM-84 in the NFPA 805 transition was to allow for manual recovery of the affected OSP success path as a means of risk reduction. PM-84 was to reduce the time overcurrent (TOC) setting for breakers (1126, 1132, 1226, and 1232) in these OSP circuits so that the breakers would trip prior to incurring any thermal damage. In this way, the modification would enable subsequent recovery actions to clear the spurious loads and reclose the OSP breakers. See Figure 1 below.

Competing design elements were identified during the design process that limit the amount that the TOC settings could be reduced, including coordination with other breakers and margin to unwanted trip during LOCA/ECCS initiation. When the effect of these limitations is considered on the risk model, the risk worth of the modification is not as large as anticipated. The relatively small fire-risk improvement together with the negative effects on engineering margins for non-fire events make PM-84 implementation inadvisable.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 9 of 17 Risk Impact Discussion A sensitivity analysis was performed to determine the risk impact of removing PM-84 from the FPRA model. In the process, non-conservative modeling was identified in the FPRA logic related to Modification 84. The FPRA logic did not recognize that overload of a Unit 1/2 4kV shutdown (SD) Board could result in overload of the normally connected 4kV SD Bus. As a result, the FPRA model did not recognize that an overload condition on one shutdown board would also cause the loss of OSP to the other shutdown board supplied from the same shutdown bus. This logic deficiency underestimated the impact of an individual shutdown board overload, and therefore underestimated the worth of PM-84. In order to quantify the risk worth of PM-84, a corrected base model was created such that spurious overloading of a shutdown board would also cause the loss of the other shutdown board supplied from the same shutdown bus. Permanent changes to correct this deficiency will be included in the FPRA update discussed in Table S-3, Item 32.

Figure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 10 of 17 A sensitivity study was performed to evaluate the risk worth of PM-84 using the corrected base model. The sensitivity study compared the corrected base model results that allow for probabilistic success of operator recovery actions with the results from the "PM-84 removed" model where the operator recovery actions were always unsuccessful. The results tabulated below in Table 1 show the risk worth of PM-84 using the corrected model.

Table 1 U1 CDF U1 LERF U2 CDF U2 LERF U3 CDF U3 LERF Base PRA model for NFPA 805 LAR With PM-84 included**

5.03E-05 5.47E-06 5.64E-05 5.37E-06 5.92E-05 5.02E-06 Corrected Base model with PM-84 included 5.69E-05 5.38E-06 6.48E-05 5.45E-06 6.03E-05 5.04E-06 Corrected Base model with PM-84 removed 6.06E-05 5.81E-06 6.59E-05 5.47E-06 6.09E-05 5.04E-06

-risk

• 3.61E-06 4.29E-07 1.08E-06 2.47E-08 5.91E-07 1.58E-10

% change 5.96%

7.39%

1.64%

0.45%

0.97%

0.00%

• -risk is defined as the change in risk from the corrected model with PM-84 removed to the corrected model with PM-84 included. Note that the positive values indicate that risk increases by the amount shown.

• • CDF and LERF values are taken from the latest risk quantification results submitted in Reference 8. These values differ slightly from NFPA 805 Safety Evaluation (Reference 3) based on results of a sensitivity analysis associated with removal of Modification 93 submitted in Reference 9.

As shown above in Table 1, the impact on CDF and LERF for fire events is small when PM-84 is removed. Final risk values will be included in the FPRA update discussed in Table S-3, Item 32.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 11 of 17 The -risk (from Table 1) and total fire plus internal / external events (from the below Table 2) values are within the guidelines provided in Regulatory Guide (RG) 1.174 for NRC consideration of a requested change.

Table 2 U1 CDF U1 LERF U2 CDF U2 LERF U3 CDF U3 LERF Internal Events /

Internal Flood*

6.93E-6 1.26E-6 6.29E-6 1.21E-6 7.72E-6 1.45E-6 External Floods /

High Winds /

Tornados / Other 1.00E-6 Negligible 1.00E-6 Negligible 1.00E-6 Negligible Seismic 3.70E-6 Negligible 5.40E-6 Negligible 5.40E-6 Negligible Fire from PM-84 Sensitivity 6.06E-5 5.81E-6 6.59E-5 5.47E-6 6.09E-5 5.04E-6 TOTAL 7.22E-5 7.07E-6 7.86E-5 6.68E-6 7.50E-5 6.49E-6

• These LERF and CDF values reflect the March 2016 update and quantification of the internal events PRA.

Defense-in-Depth/Safety Margin Discussion Defense-In-Depth (DID) is based on the following three echelons:

1) Prevent fires from starting

2) Rapidly detect, control and extinguish promptly those fires that do occur thereby preventing fire damage

3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed Deletion of PM-84 has no effect on fire initiation (Echelon 1), because the existing BFN offsite power breaker settings protect against cable self-ignition events. PM-84 was originally conceived as an aid to retain or restore equipment function under some postulated overload conditions.

In addition, non-implementation of PM-84 does not affect DID Echelons 2 or 3. Adequate safety margins are maintained because this change does not affect any codes and standards or their alternatives accepted for use by the NRC, and this change does not affect any safety analysis acceptance criteria used in the licensing basis.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 12 of 17 TVA Change Request 3: Delete Table S-3, Item 09 Basis for Proposed Change 3 Table S-3, Item 09 was implemented as stated. However, TVA has determined that implementation of the item is overly restrictive because of the short conduit lengths.

TVA compared BFN with the guidelines in NRC Branch Technical Position (BTP)

CMEB 9.5.1.e(1), Guidelines for Fire Protection for Nuclear Power Plants, dated July 1981 (Reference 5) which states:

Only metal should be used for cable trays. Only metallic tubing should be used for conduit. Thin-wall metallic tubing should not be used. Flexible metallic tubing should only be used in short lengths to connect components to equipment. Other raceways should be made of noncombustible material.

TVAs implementation of the BTP was provided in the BFN fire protection report (Reference 6) as part of BFNs implementation of Generic Letters 86-10 and 88-12 as follows:

Only metal is used for cable tray and conduit construction. Thin-wall metallic tubing is not used. Flexible metallic tubing is only used in short lengths of six feet or less.

NRC issued a Safety Evaluation (Reference 7), that stated, in part:

Only metal is used for cable tray construction. Flexible metal components are used in lengths of six feet or less. Thin wall metallic tubing is not used. Separation and fire protection features for those cables required to achieve and maintain safe shutdown are in compliance with the requirements of Section III.G of 10 CFR 50 Appendix R.

The NFPA 805 transition process allows for deviations based on prior NRC approval.

BFN was previously granted approval for utilizing flexible metallic conduits in lengths up to six feet (Reference 7).

The NFPA 805 Electrical requirement in Section 3.3.5.2 states, Flexible metallic conduits shall only be used in short lengths to connect components. BFNs previously approved requirement from TVA Specification G-40 to limit flexible conduit lengths to 6 feet maximum, meets the NFPA 805, Section 3.3.5.2 requirement and Item 09 may therefore, be deleted from Table S-3.

Additionally, Attachment A, Table B-1, Transition of Fundamental Fire Protection Program & Design Elements, for NFPA 805, Chapter 3, Reference item 3.3.5.2

[Electrical Raceway Construction Limits] is revised to delete the Item for implementation, because it references Attachment S, Table S-3, Item 09. A markup of the Attachment A page is provided in Enclosure 4 and a clean copy is provided in of this LAR.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 13 of 17 Risk Impact Discussion The flexible conduit protects the cable and allows for proper termination of the cable. The protection provided to the cable from the longer flexible conduit is no different from that of the shorter flexible conduit. The proposed deletion does not affect the fire PRA and the risk insights presented in the LAR.

Defense-in-Depth/Safety Margin Discussion This change provides clarification on the identification of the flexible conduit lengths acceptable for use with NFPA 805 cables. Prior approval has been obtained from NRC to utilize 6 ft. conduit lengths instead of the 3 ft. conduit lengths. Therefore, this does not result in a change in DID nor represent a reduction in safety margin.

4.0 Regulatory Safety Analysis 4.1 Significant Hazards Consideration TVA is requesting an amendment to the BFN RFOL, paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, Transition License Conditions, Items 2 and 3, to revise existing commitments regarding NFPA 805 Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants.

A written evaluation of the significant hazards consideration of a proposed license amendment is required by 10 CFR 50.92. According to 10 CFR 50.92, a proposed amendment to an operating license involves no significant hazards consideration if operation of he facility in accordance with the proposed amendment would not:

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

As required by 10 CFR 50.91(a), the TVA analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

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

Response: No The proposed amendment adds the reference to this letter to the BFN RFOL License Condition paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, Transition License Conditions, Items 2 and 3. The changes encompassed by the proposed amendment are to clarify a modification to match the design changes that are being implemented, delete a modification that is no longer needed from a risk perspective, and delete an already implemented item that has been found to be unnecessarily restrictive.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 14 of 17 The revisions are based on the two changes to Table S-2 and one change to Table S-3 proposed in this LAR. One of the changes is justified based on acceptable risk impact to Core Damage Frequency (CDF) or Large Early Release Frequency (LERF) associated with not performing the committed modification. The other two changes have no impact on accident analysis as they are clarifying or administrative in nature.

The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not affect the ability of structures, systems and components (SSCs) to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits. The risk sensitivity analysis performed shows that no significant increase in accident consequence is involved.

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

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

Response: No The proposed amendment adds the reference to this letter to the BFN RFOL License Condition paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, Transition License Conditions, Items 2 and 3. The changes encompassed by the proposed amendment are to clarify a modification to match the design changes that are being implemented, delete a modification that is no longer needed from a risk perspective, and delete an already implemented item that has been found to be unnecessarily restrictive.

The revisions are based on the two changes to Table S-2 and one change to Table S-3 proposed in this LAR. One of the changes is justified based on acceptable risk impact to Core Damage Frequency (CDF) or Large Early Release Frequency (LERF) associated with not performing the committed modification. The other two changes have no impact on accident analysis as they are clarifying or administrative in nature.

The proposed changes will not result in any new or different kinds of accident from that previously evaluated because it does not change and precursors or equipment that is previously credited for accident mitigation.

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

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 15 of 17 The proposed amendment adds the reference to this letter to the BFN RFOL License Condition paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, Transition License Conditions, Items 2 and 3. The changes encompassed by the proposed amendment are to clarify a modification to match the design changes that are being implemented, delete a modification that is no longer needed from a risk perspective, and delete an already implemented item that has been found to be unnecessarily restrictive.

The revisions are based on the two changes to Table S-2 and one change to Table S-3 proposed in this LAR. One of the changes is justified based on acceptable risk impact to Core Damage Frequency (CDF) or Large Early Release Frequency (LERF) associated with not performing the committed modification. The other two changes have no impact on accident analysis as they are clarifying or administrative in nature.

The proposed changes do not adversely affect any systems, structures or components credited for accident mitigation. The margins of safety previously evaluated are not significantly affected. The change does not affect the design function or capabilities of any plant systems. Therefore, the proposed changes will not impact or reduce any margins of safety previously evaluated.

Therefore, based on the above discussion, these proposed changes do not involve a significant reduction in the margin of safety.

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 Commissions 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. TVA has evaluated the proposed amendment and determined that it involves no significant hazards consideration.

4.2 Applicable Regulatory Requirements/Criteria On July 16, 2004, the NRC amended 10 CFR 50.48, Fire Protection, to add a new subsection, 10 CFR 50.48(c), which establishes alternative fire protection requirements.

10 CFR 50.48 endorses, with exceptions, NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants - 2001 Edition (NFPA 805), as a voluntary alternative for demonstrating compliance with 10 CFR 50.48 Section (b),

Appendix R, and Section (f), Decommissioning.

The voluntary adoption of 10 CFR 50.48(c) by BFN does not eliminate the need to comply with 10 CFR 50.48(a) and to CFR 50, Appendix A, GDC 3, Fire Protection.

The new rule provides actions that may be taken to establish compliance with 10 CFR 50.48(a), which requires each operating nuclear power plant to have a fire protection program plan that satisfies GDC 3, as well as specific requirements in that section. The transition process described in 10 CFR 50.48(c)(3)(ii) provides, in pertinent parts, that a licensee intending to adopt the new rule must, among other things, "modify the fire protection plan required by paragraph (a) of that section to reflect the licensee's decision to comply with NFPA 805." Therefore, to the extent that the contents of the existing fire protection program plan required by 10 CFR 50.48(a) are inconsistent with NFPA 805, the Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 16 of 17 fire protection program plan must be modified to achieve compliance with the requirements in NFPA 805. All other requirements of 10 CFR 50.48(a) and GDC 3 have corresponding requirements in NFPA 805.

4.3 Conclusions 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 Commissions 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 Considerations TVA has evaluated the proposed amendment and determined that the amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents 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.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Basis for Proposed Changes to NFPA 805 Submittal LAR CNL-17-024 E1 - 17 of 17 6.0 References

1.

Letter from TVA to NRC, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), (Technical Specification Change TS-480)," dated March 27, 2013 (ML13092A393)

2.

Letter from NRC to NEI, Recommended Content for License Amendment Requests That Seek Changes to License Conditions That Were Established in Amendments to Adopt National Fire Protection Association Standard 805 But Have Yet to be Fully Implemented, dated March 2, 2016 (ML16015A416)

3.

Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Issuance of Amendments Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) (CAC Nos. MF1185, MF1186, and MF1187), dated October 28, 2015 (ML15212A796)

4.

Letter from TVA to NRC, "Response to NRC Request to Supplement License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187)," dated May 16, 2013 (ML13141A291)

5.

NRC Branch Technical Position CMEB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants, dated July 1981

6.

Letter from TVA to NRC, Browns Ferry Nuclear Plant (BFN) - Fire Protection Report (FPR), dated January 15, 1992 (ML9202030168)

7.

Letter from NRC to TVA, Fire Protection Program - Browns Ferry Units 1, 2 and 3 (TAC Nos. M82687, M82688, and M82689), dated March 31, 1993 (ML9304070042)

8.

Letter from TVA to NRC, CNL-14-208, Response to NRC Request for Additional Information Regarding the License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos.

MF1185, MF1186, and MF1187) - Probabilistic Risk Assessment Follow Up (162-Day Responses), dated December 17, 2014 (ML14363A057)

9.

Letter from TVA to NRC, CNL-15-166, Update to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187), dated August 18, 2015 (ML15230A418)

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Attachment S, Table S Markups CNL-17-024 Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390. contains Security-Related Information.

Upon removal of Enclosures 2 and 7, this letter is uncontrolled.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Attachment S, Table S Markups CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 04 1,2,3 Revise procedure NPG-SPP-18.4.7 to only allow untreated lumber with a cross section dimension of 6" x 6" or larger to be used.

4.1 and Attachment A, 3.3.1.2(1) 05 1,2,3 Procedure NPG-SPP-18.4.7 allows plastic sheeting materials that meet the requirements of NFPA 701 or UL Standard 214. UL Standard 214 has been withdrawn and will be removed from NPG-SPP-18.4.7.

4.1 and Attachment A, 3.3.1.2(2) 06 1,2,3 Revise procedure NPG-SPP-18.4.8, to include controls on the use of electric heaters, and to prohibit the use of portable fuel-fired heaters in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.

4.1 and Attachment A, 3.3.1.3.4 07 1,2,3 Revise appropriate procedures to inspect and ensure guides and bearings of active NFPA 805 required sliding fire doors are maintained well lubricated.

4.1 and Attachment A, 3.11.3(1) 08 1,2,3 Plant specifications do not include requirements for wiring installed above suspended ceilings. Revise Specification G-38 to specify that future wiring above suspended ceilings shall be listed for plenum use, routed in armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers.

4.1 and Attachment A, 3.3.5.1 09 1,2,3 To ensure future plant design meets the requirements for electrical raceway construction limits, revise Specification G-40 to state that flexible conduit shall only be used in lengths up to three feet.

4.1 and Attachment A, 3.3.5.2 10 1,2,3 Revise current plant transformer fire protection testing procedures (FP 026-INS007A, FP-0-026-INS007B, FP-0-026-INS007D, FP-1-026-INS007, FP-2-026-INS007, and FP-3-026-INS007) to ensure that the gravel drainage areas around the transformers are free of debris and capable of performing their design function.

4.1 and Attachment A, 3.3.9 11 1,2,3 Procedure NPG-SPP-1.3 will be revised to include a requirement for the prompt cleanup of combustible liquids discovered on insulation, including high flashpoint lubricating oils. Procedure NPG-SPP-18.4.7 will be updated to keep such fluids from coming in contact with hot pipes and surfaces, including insulated pipes and surfaces.

4.1 and Attachment A, 3.3.10 Page S-43 CNL-17-024 Page 1 of 1 DELETE Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Attachment A - Markup CNL-17-024

Attachment A NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Reference Requirements / Guidance Compliance Statement Compliance Basis armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers. See Implementation Item 08 in Table S

-3 of Attachment S.

References Document ID 0-FPR-VOLUME 1/PART 2 Rev. 14 [Section 6.0] - The Fire Protection Report, Fire Hazards Analysis G-38 Rev. 21 [All] - Installation, Modification, and Maintenance of Insulated Cables Rated Up To 15,000 Volts Submit for NRC Approval BFN has wiring above suspended ceilings in the Control Building that does not comply with the requirements in this code section.

See Attachment L, Approval Request 3, for further details on the request for NRC approval for existing wiring above suspended ceilings.

References Document ID 0-FPR-VOLUME 1/PART 2 Rev. 14 [Section 6.0] - The Fire Protection Report, Fire Hazards Analysis 1988-04-04 [Supplement Section C.5.a(11)] - BFN-NRC, Browns Ferry Nuclear Plant - Fire Protection Report 3.3.5.2 [Electrical Raceway Construction Limits]

3.3.5.2 Only metal tray and metal conduits shall be used for electrical raceways.

Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. Flexible metallic conduits shall only be used in short lengths to connect components.

Complies with Previous Approval FAQ 06-0021 defines "short lengths" as approximately three feet of flexible metallic conduit.

BFN was previously granted approval for utilizing flexible metallic conduits in lengths up to six feet. Section 2.10 of the NRC Safety Evaluation dated March 31, 1993 states "Only metal is used for cable tray construction.

Flexible metal components are used in lengths of six feet or less. Thin wall metallic tubing is not used.

Separation and fire protection features for those cables required to achieve and maintain safe shutdown are in compliance with the requirements of Section III.G of 10 CFR 50 Appendix R."

Current plant documentation (Fire Protection Report, drawings, calculations, and specifications) was reviewed to determine that plant changes or modifications do not invalidate previous NRC approval.

Item for Implementation:

To ensure future plant design for electrical raceways meets the requirements of this section, revise Specification G-40 to state that flexible conduit shall only be used in lengths up to three feet. See Implementation Item 09 in Table S-3 of Attachment S.

References Document ID 1993-03-31 [Section 2.10] - NRC-BFN, Safety Evaluation for Fire Protection Program - Browns Ferry Nuclear Plant Units 1, 2 and 3 FAQ 06-0021 Rev. 1a [All] - Cable Air Drops G-40 Rev. 17 [All] - Installation, Modification, and Maintenance of Electrical Conduit, Cable Trays, Boxes, Containment Electrical Penetrations, Electric Conductor Seal Assemblies, Lighting and Miscellaneous Systems Fire Safety Analysis Data Manager (4.129)

TVA Browns Ferry Page: 14 of 55 CNL-17-024 Page 1 of 1 DELETE Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Facility Operating License - Markups CNL-17-024

-5b-BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 290 October 28, 2015

2. Fire Protection Program Changes that Have No More than Minimal Risk lmpact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation dated October 28, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions 1.

Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensees 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 following modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-15-191, dated September 8, 2015, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3.

The licensee shall complete the implementation items as listed in Table S-3, Implementation Items, of Tennessee Valley Authority letters CNL-15-191, dated September 8, 2015, and CNL-15-224, dated October 20, 2015, within 240 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

(14)

The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).

(15)

The licensee is required to confirm that the conclusions made in TVAs letter dated September 17, 2004, for the turbine building remain acceptable using seismic demand accelerations based on dynamic seismic analysis prior to the restart of Unit 1.

(16)

Upon implementation of Amendment No. 275, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.

CNL-17-024 Page 1 of 4 CNL-17-024 dated

__/__/2017, CNL-17-024 dated

__/__/2017, NFPA 805 License Amendment dated October 28, 2015 NFPA 805 License Amendment dated October 28, 2015

-5b-Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2.

Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation dated October 28, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

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 following modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-15-191, dated September 8, 2015, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3.

The licensee shall complete the implementation items as listed in Table S-3, Implementation Items, of Tennessee Valley Authority letters CNL-15-191, dated September 8, 2015, and CNL-15-224, dated October 20, 2015, within 240 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

(15)

The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analysis Report (UFSAR).

(16)

Upon complementation of Amendment No. 302, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3. 7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.

BFN-UNIT 2 Renewed License No. DPR-52 Amendment No. 315 Page 2 of 4 CNL-17-024 CNL-17-024 dated

__/__/2017, CNL-17-024 dated

__/__/2017, NFPA 805 License Amendment dated October 28, 2015 NFPA 805 License Amendment dated October 28, 2015

-4b-BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 273 October 28, 2015 The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is adequate for the hazard. Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

Fire Alarm and Detection Systems (Section 3.8);

Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2.

Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation dated October 28, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

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 following modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-15-191, dated September 8, 2015, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

CNL-17-024 Page 3 of 4 CNL-17-024 dated

__/__/2017, NFPA 805 License Amendment dated October 28, 2015 BFN-UNIT 3 Renewed License No. DPR-68 Amendment 273 October 28, 2015 3.

The licensee shall complete the implementation items as listed in Table S-3, Implementation Items, of Tennessee Valley Authority letters CNL-15-191, dated September 8, 2015, and CNL-15-224, dated October 20, 2015, within 240 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

(8)

Deleted.

(9)

The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).

(10) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1.

Pre-defined coordinated fire response strategy and guidance 2.

Assessment of mutual aid fire fighting assets 3.

Designated staging areas for equipment and materials 4.

Command and control 5.

Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets 2.

Communications 3.

Minimizing fire spread 4.

Procedures for implementing integrated fire response strategy 5.

Identification of readily-available pre-staged equipment 6.

Training on integrated fire response strategy 7.

Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1.

Water spray scrubbing 2.

Dose to onsite responders (11) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

(12) Upon completion of Amendment No. 261, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measurement of the CRE pressure as required by TS 5.5.13.d, shall be considered met.

CNL-17-024 Page 4 of 4 CNL-17-024 dated

__/__/2017, NFPA 805 License Amendment dated October 28, 2015 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Facility Operating License - Clean Copy CNL-17-024

-5b-BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 000

2. Fire Protection Program Changes that Have No More than Minimal Risk lmpact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation dated October 28, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions 1.

Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensees 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 following modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-17-024, dated xxxxxxxxxxx xx, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3.

The licensee shall complete the implementation items as listed in Table S-3, Implementation Items, of Tennessee Valley Authority letter CNL-17-024, dated xxxxxxxxxxxx xx, 2017, within 240 days after issuance of the NFPA 805 License Amendment dated October 28, 2015 unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

(14)

The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).

(15)

The licensee is required to confirm that the conclusions made in TVAs letter dated September 17, 2004, for the turbine building remain acceptable using seismic demand accelerations based on dynamic seismic analysis prior to the restart of Unit 1.

(16)

Upon implementation of Amendment No. 275, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.

CNL-17-024 Page 1 of 4

BFN-UNIT 2 Renewed License No. DPR-52 Amendment No. 000

-5b-Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2. Fire Protection Program Changes that Have No More than Minimal Risk lmpact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation dated October 28, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions 1.

Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensees 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 following modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-17-024, dated xxxxxxxxxx xx, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete the implementation items as listed in Table S-3, Implementation Items, of Tennessee Valley Authority letter CNL-17-024, dated xxxxxxxxxx xx, 2017, within 240 days after issuance of the NFPA 805 License Amendment dated October 28, 2015 unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

(15)

The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).

(16)

Upon implementation of Amendment No. 275, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.

CNL-17-024 Page 2 of 4

-4b-BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 000 The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is adequate for the hazard. Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

Fire Alarm and Detection Systems (Section 3.8);

Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);

Gaseous Fire Suppression Systems (Section 3.10); and Passive Fire Protection Features (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

2.

Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation dated October 28, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

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 following modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-17-024, dated xxxxxxxxxx xx, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

CNL-17-024 Page 3 of 4 BFN-UNIT 3 Renewed License No. DPR-68 Amendment No.000 3.

The licensee shall complete the implementation items as listed in Table S-3, Implementation Items, of Tennessee Valley Authority letters CNL-17-024, dated xxxxxxxxxx xx, 2017, within 240 days after issuance of the NFPA 805 License Amendment dated October 28, 2015 unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

(8)

Deleted.

(9)

The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).

(10) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1.

Pre-defined coordinated fire response strategy and guidance 2.

Assessment of mutual aid fire fighting assets 3.

Designated staging areas for equipment and materials 4.

Command and control 5.

Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets 2.

Communications 3.

Minimizing fire spread 4.

Procedures for implementing integrated fire response strategy 5.

Identification of readily-available pre-staged equipment 6.

Training on integrated fire response strategy 7.

Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1.

Water spray scrubbing 2.

Dose to onsite responders (11) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

(12) Upon completion of Amendment No. 261, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measurement of the CRE pressure as required by TS 5.5.13.d, shall be considered met.

CNL-17-024 Page 4 of 4

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Revised Attachment S, Table S Clean Copy Updated NFPA 805 License Amendment Request, Attachment S, Table S-2, "Plant Modifications Committed" (29 pages including cover)

CNL-17-024 Security-Related Information - Withhold from Public Disclosure in accordance with 10 CFR 2.390. to this letter contains Security-Related Information.

Upon removal of Enclosures 2 and 7, this letter is uncontrolled.

Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Revised Attachment S. Table S Clean Copy Updated NFPA 805 License Amendment Request, Attachment S, Table S-3 Modifications and Implementation Items (13 pages including cover)

CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S Items provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 fire protection program. This will occur within 240 days after issuance of the license amendment unless that date falls within a scheduled refueling outage. If this is the case, then implementation will occur within 60 days after startup from that scheduled refueling outage. Note that Items 32 and 33 are associated with modifications in Table S-2 and will be completed in accordance with the timetable described in the Implementation Item.

Table S-3 Implementation Items Item Unit Description LAR Section / Source 01 1, 2, 3 Implement the results of the Radioactive Release Review:

a.

Within each pre-fire plan that has an access point to a non-RCA area, enhance the pre-fire plan to better identify concerns for radioactive release by incorporating one of the following options:

a.

Identifying the RCA in the written text or the pre-fire plan drawings is intended to aid the Incident Commander in avoiding radioactive release. For consistency, it is recommended that hardened barriers be identified.

Examples of these would include: the Unit 1 Reactor Building truck bay hatch, water tight doors to the outside as well as passage doors and roll-up door.

b.

Incorporate a descriptive text in the pre-fire plan that highlights escape path concerns specific to that pre-fire plan.

b.

Add generic wording to area fire plans to prompt measures to avoid radioactive release.

c.

Pre-fire plans with doorways to the outside or to non-RCA areas will be revised and will have the plan drawing revised to include the door and an identification method to allow the BFN-FERO to recognize this as an RCA boundary.

d.

Add an appendix to the pre-fire plans for building sump drainage and site storm drains.

e.

Develop a standard operating procedure to support actions to prevent radioactive release. This document will stress actions to prevent the escape of potentially contaminated materials from a building or area boundary. Additional guidance will be provided for fires in yard areas and locations with limited or no engineering controls.

f.

Develop new pre-fire plans for the following areas:

1.

East Access Building 4.4.2 and Attachment E Page S-41 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 2.

Low Level Radwaste Storage Modules 3.

Low Level Radwaste Tool Warehouse 4.

South Access Building 5.

Condensate Storage Tank Area 6.

Auxiliary Decay Heat Removal 7.

Outage Rad Material Storage Warehouse 8.

Off-Gas Stack 9.

Units 1, 2 A and B Chillers (Fire Area 27) g.

Revise the guidance within RWI-001 and/or RWI-111 to address storage of radioactive material for compliance with the radioactive release criteria. The recommended practices would include:

1.

A screening process.

2.

A boundary process.

3.

A source term process.

4.

When radioactive materials are handled outdoors and outside of containers that exceed the source term limits, consideration should be given to reducing the potential for a fire to occur.

h.

Each fire brigade member will be provided training to identify potential points for radioactive release and the actions that can be taken to mitigate a release. To support the training, guidance will be provided in pre-fire plans and standard operating procedures to outline these expectations and actions.

02 1,2,3 The Fire Protection Report will be updated to include the statement that the NRC is the authority having jurisdiction (AHJ) for fire protection changes requiring approval.

4.1 and Attachment A, 3.2.2.4 03 1,2,3 The monitoring program required by NFPA 805 Section 2.6 will be implemented as part of the fire protection program transition to NFPA 805, in accordance with NFPA 805 FAQ 10-0059, and will include a process that reviews fire protection performance and trends in performance. Program specifics are provided in LAR Section 4.6.2.

4.1, 4.6.2 and Attachment A, 3.2.3(3)

Page S-42 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 04 1,2,3 Revise procedure NPG-SPP-18.4.7 to only allow untreated lumber with a cross section dimension of 6" x 6" or larger to be used.

4.1 and Attachment A, 3.3.1.2(1) 05 1,2,3 Procedure NPG-SPP-18.4.7 allows plastic sheeting materials that meet the requirements of NFPA 701 or UL Standard 214. UL Standard 214 has been withdrawn and will be removed from NPG-SPP-18.4.7.

4.1 and Attachment A, 3.3.1.2(2) 06 1,2,3 Revise procedure NPG-SPP-18.4.8, to include controls on the use of electric heaters, and to prohibit the use of portable fuel-fired heaters in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.

4.1 and Attachment A, 3.3.1.3.4 07 1,2,3 Revise appropriate procedures to inspect and ensure guides and bearings of active NFPA 805 required sliding fire doors are maintained well lubricated.

4.1 and Attachment A, 3.11.3(1) 08 1,2,3 Plant specifications do not include requirements for wiring installed above suspended ceilings. Revise Specification G-38 to specify that future wiring above suspended ceilings shall be listed for plenum use, routed in armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers.

4.1 and Attachment A, 3.3.5.1 10 1,2,3 Revise current plant transformer fire protection testing procedures (FP 026-INS007A, FP-0-026-INS007B, FP-0-026-INS007D, FP-1-026-INS007, FP-2-026-INS007, and FP-3-026-INS007) to ensure that the gravel drainage areas around the transformers are free of debris and capable of performing their design function.

4.1 and Attachment A, 3.3.9 11 1,2,3 Procedure NPG-SPP-1.3 will be revised to include a requirement for the prompt cleanup of combustible liquids discovered on insulation, including high flashpoint lubricating oils. Procedure NPG-SPP-18.4.7 will be updated to keep such fluids from coming in contact with hot pipes and surfaces, including insulated pipes and surfaces.

4.1 and Attachment A, 3.3.10 Page S-43 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 12 1,2,3 There are corrective actions identified in MDQ099920100012 that will be completed prior to NFPA 805 implementation, as follows:

Update FPDP-1 to document annual funds for equipment, vehicles, training and education, medical and job-related physical performance evaluations, and other necessary items to accomplish the fire brigade's objectives.

Update FPDP-4 to identify the roles and responsibilities of any responding public fire department and other outside agencies.

Update Fire Brigade procedures to document how the FBL accounts for each member of the FERO present at the scene of emergency.

Update FPDP-4 to document that standard operating procedures shall:

o be maintained in written form and shall address the site-specific functions identified in the industrial fire brigade organizational statement.

o include information regarding site-specific hazards to which industrial fire brigade members can be exposed during a fire or other emergency.

o address the site-specific limitations of emergency response organizations.

o be accessible to all industrial fire brigade members.

Establish a risk management policy for the fire brigade in accordance NFPA 600.

Update training documentation to include training in accordance with NFPA 600 to all personnel who may enter the warm zones.

Update procedures to include standard operating procedures requiring Fire Brigade members to wear SCBA when entering the hot zone.

Update procedures to provide identification that is easily recognizable to indicate FERO members.

Update training documentation to include pre-fire plan awareness as part of the training for support personnel.

4.1 and Attachment A, 3.4.1(a)(1), 3.4.3(a)(1)

Page S-44 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 13 1,2,3 Update Procedure FPDP-2 to require that pre-fire plans are made available in the control room and to the plant industrial fire brigade.

4.1 and Attachment A, 3.4.2, 3.4.2.3 14 1,2,3 Revise TPD-FBT to require fire brigade members to receive training in fire fighting considerations of radioactivity and health physics on a quarterly basis.

4.1 and Attachment A, 3.4.3(a)(2) 15 1,2,3 Revise TPD-FBT to include training for the secondary response group as to their responsibilities, potential hazards to be encountered, and interfacing with the fire brigade.

4.1 and Attachment A, 3.4.3(b) 16 1,2,3 Revise FPDP-4 to detail specific plans for plant security and radiation protection responsibilities regarding off-site fire authority response.

4.1 and Attachment A, 3.4.5.3 17 1,2,3 There are corrective actions identified in MDQ099920100008 that will be completed prior to NFPA 805 implementation as follows:

Revise pre-fire plans to indicate that for hose stations on elevations 617' and below that are not already provided with the fire pump start buttons, a fire pump shall be started prior to operating the hose station if a fire pump is not already operating.

Verify the pump motor can meet the requirements of Section 6-3.1.3 of NFPA 20

Verify the pump motor and controller can meet the requirements of Section 6-3.1.4 of NFPA 20

Verify the power supply protective devices can meet the requirements of Section 6-3.4.1 of NFPA 20

Verify the power supply protective devices can meet the requirements of Section 6-3.4.2 of NFPA 20.

Revise inspection procedures to perform inspections of the battery chargers at the same time as the batteries are inspected in 0-SI-4.11.B.3.c.

Revise current testing procedures to operate the electric fire pumps weekly, with at least one operation accomplished by utilizing the automatic fire pump start functions.

4.1 and Attachment A, 3.5.3 18 1,2,3 Equip all fire apparatus with 12 spanner wrenches and 6 hose connection gaskets for each size hose. Update procedure FP-0-000-INS005 to include this information.

4.1 and Attachment A, 3.5.15 Page S-45 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 19 1,2,3 There are corrective actions identified in MDQ099920110005 and MDQ099920100017 that will be completed prior to NFPA 805 implementation as follows:

Revise the applicable procedure to include retention of fire alarm signals received for at least one year.

Update Control of Fire Protection Impairment documentation to indicate a retention period of 1 year from the impairment correction date for impairments related to the fire alarm and detection systems in the Impairment Tracking Log.

Update applicable testing procedures to exclude test magnets from being used during smoke detector testing and to ensure smoke detectors are tested and activated using chemical smoke designed solely for smoke detector testing.

4.1 and Attachment A, 3.8.1 20 1,2,3 There are corrective actions identified in MDQ099920100005, MDQ099920110001, MDQ099920110002, and MDQ099920110003 that will be completed prior to NFPA 805 implementation as follows:

Update hydraulic calculations for sprinkler systems to clearly indicate the allowance for hose streams.

4.1 and Attachment A, 3.9.1(1)

Page S-46 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 21 1,2,3 There are corrective actions identified in MDQ099920100007 and MDQ099920110004 that will be completed prior to NFPA 805 implementation as follows:

Revise current plant inspections/walkthroughs to include a visual check for obvious defects, such as broken or missing parts, nozzle loading, or other evidence of impaired protection for the water spray systems protecting cable trays in the Unit 3 Diesel Generator Building cable and pipe tunnel, and Turbine Building El 586 south wall, for selected cable trays.

Revise BFN Procedure 3-SI-4.11.C.1.c to include operation of the manual tripping device for the Diesel Generator Building cable tray water spray system.

Revise Surveillance Procedures (1-and 3-SI.4.11.C.1.c) to include an inspection of the spray nozzles for proper positioning, external loading, and corrosion, and cleaning when necessary.

Revise Surveillance Procedures (1-and 3-SI.4.11.C.1.c) to include verification that the means of system actuation (heat detector, smoke detector, or test valve) cause the deluge valve to operate within 40 seconds.

Revise the transformer water spray system inspection procedures to (1) verify that the water supply at the riser has not deteriorated and (2) if the reading taken at the riser indicates that the water supply has deteriorated, a gauge shall be placed on the hydraulically most remote nozzle and the results compared with the required design pressure.

4.1 and Attachment A, 3.9.1(2) 22 1,2,3 There are corrective actions identified in MDQ099920100004 that will be completed prior to NFPA 805 implementation as follows:

Install warning signs in conspicuous locations in and around the Lube Oil Purification Room.

Replace the existing CO2 system safety signs with signs that comply with the three-panel format retroactively required by NFPA 12 - 2008.

4.1 and Attachment A, 3.10.1(1)

Page S-47 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 23 1,2,3 Post-transition, for personnel performing fire modeling or Fire PRA development and evaluation, TVA will develop and maintain qualification requirements for individuals assigned various tasks. Position Specific Guides will be developed to identify and document required training and mentoring to ensure individuals are appropriately qualified per the requirements of NFPA 805 Section 2.7.3.4 to perform assigned work.

4.7.3 24 1,2,3 For program documentation and configuration control, implement the following:

The Fire Protection Design Basis Document described in Section 2.7.1.2 of NFPA 805 and necessary supporting documentation described in Section 2.7.1.3 of NFPA 805 will be created as part of transition to 10 CFR 50.48(c) to ensure program implementation following receipt of the safety evaluation.

The configuration control procedures which govern fire protection-related documents and databases will be revised to reflect the new NFPA 805 licensing bases requirements.

Several NFPA 805 document types, such as NSCA Supporting Information and Non-Power Mode NSCA Treatment, will generally require new control procedures and processes to be developed since they are new documents and databases created as a result of the transition to NFPA 805. The new procedures will be modeled after the existing processes for similar types of documents and databases.

System level design basis documents will be revised to reflect the NFPA 805 role that the system components now play.

Configuration control of the Fire PRA model will be maintained by integrating the Fire PRA model into the existing processes used to ensure configuration control of the Internal Events PRA model.

4.7.1, 4.7.2, and 4.7.3 25 1,2,3 The additional considerations of NEI 00-01, Revision 2, Chapter 3 will be addressed by linking the EOIs to fire safe shutdown procedures consistent with the recommendations of BWROG document, BWROG-TP-11-011, entitled, BWROG Assessments of Generic Multiple Spurious Operations (MSOs) in Post-Fire Safe Shutdown Circuit Analysis for the Operating BWR Plants, dated June, 2011. with the exception of the MCR abandonment Fire Safe Shutdown procedures. The MCR abandonment Fire Safe Shutdown procedures will include procedure steps for fires impacting the ability to scram from the MCR.

4.2.1.1 Page S-48 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 26 1,2,3 Revise Shutdown Risk Management procedures to reflect the following recommendations during higher risk evolutions (e.g., OPDRV and moving irradiated fuel assemblies) from the calculation entitled, NFPA 805 Transition - Non-Power Operation Modes Analysis:

Restriction of hot work in areas during periods of increased vulnerability.

Restriction of combustible loading.

Restriction of transient combustible materials in areas during periods of increased vulnerability.

Consider plant equipment configuration changes (e.g., removing power from equipment once it is placed in its desired position).

Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability.

Reschedule the work to a period with lower risk or higher defense-in-depth.

Housekeeping.

Presence of functional fire detection and suppression equipment.

4.3.2 and Attachment D 27 1,2,3 The following implementation item is required based on the results of the Operator Action Feasibility Analysis:

Develop / revise post-fire response procedures to reflect the NSCA.

Attachment G 28 1,2,3 The following implementation item is required based on the results of the Operator Action Feasibility Analysis:

Identify required tools during the procedure validation and verification.

Attachment G 29 1,2,3 The following implementation item is required based on the results of the Operation Action Feasibility Analysis:

Document staffing requirements for revised post-fire response procedures.

Attachment G Page S-49 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 30 1,2,3 The following implementation item is required based on the results of the Operation Action Feasibility Analysis:

Train operators on revised post-fire response procedures.

Attachment G 31 1,2,3 The following implementation item is required based on the results of the Operation Action Feasibility Analysis:

Revise training requirements for post-fire response procedures to include periodic drills.

Attachment G 32 1, 2, 3 Update the Fire PRA model, as necessary, after all modifications are complete (returned to operation) and in their as-built configuration. The update will include a verification of the validity of the reported change in risk on as-built conditions after the modifications are completed. If this verification determines that the risk metrics have changed such that the RG 1.174 acceptance guidelines are not met, the Nuclear Regulatory Commission (NRC) will be notified and additional analytical efforts, and/or procedure changes, and/or plant modifications will be made to assure the RG 1.174 risk acceptance criteria are met.

Section 4.8.2 33 1,2,3 Update the fire HRA (Human Reliability Analysis) upon completion of all procedure updates, all modifications and all training. The update will include a verification of the validity of the reported change in risk on as-built conditions after the procedure updates, modifications, and training are completed. If this verification determines that the risk metrics have changed such that the RG 1.174 acceptance guidelines are not met, the Nuclear Regulatory Commission (NRC) will be notified and additional analytical efforts, and/or procedure changes, and/or plant modifications will be made to assure the RG 1.174 risk acceptance criteria are met.

Attachments G and V Page S-50 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 34 1,2,3 Revise the following EEEEs to meet the administrative requirements for engineering evaluations in accordance with the applicable criteria provided in RG 1.205 and NEI 04-02, as supplemented by FAQ 06-0008 and FAQ 07-0054.

The following EEEEs documented in the Fire Hazard Analysis:

o FHA Section 3.3.4.e SBGT Duct Penetrations o

FHA Section 4.1 Flood Control Doors o

FHA Section 4.2 Personnel and Equipment Access Locks o

FHA Section 4.3 Main Steam and Feedwater Piping Tunnel Barriers

MDQ0100890035 - Fire Boundary Seal Design for Gypsum Walls

RIMS B22 911004 003 Engineering Evaluation of the Bus Duct Penetrations

RIMS B22 911004 201 Engineering Evaluation for the Unprotected Openings in 1-Hour Floor Ceiling Assemblies on Elevation 621.25 and 639 Reactor Buildings 4.2.2 35 1,2,3 Revise NPG-SPP-18.4.7 to establish limits on the types and quantities of materials in designated storage areas.

4.1 and Attachment A, 3.3.1.2(4) 37 1,2,3 Revise design output to ensure interior epoxy floor finishes meet the Class I requirements and interior carpet floor finishes meet the Class I requirements.

4.1 and Attachment A, 3.3.3 38 1,2,3 Develop specific guidance and restrictions on bulk flammable gas storage onsite.

4.1 and Attachment A, 3.3.7, 3.3.7.1, 3.3.7.2 39 1,2,3 Revise FPDP-4 to require that off-site fire authorities be offered a plan for their interface during fire emergencies onsite.

4.1 and Attachment A, 3.4.5.1 40 1,2,3 Establish a contract for maintenance and hydrostatic testing of fire extinguishers in accordance with NFPA 10.

4.1 and Attachment A, 3.7 41 1,2,3 Revise flow drawings for the CO2 systems to note the CO2 shutoff valves are locked in the open position.

4.1 and Attachment A, 3.10.5 42 1,2,3 Revise design output procedure to ensure interior wall and ceiling finishes meet the NFPA 101 material requirements.

4.1 and Attachment A, 3.3.3 Page S-51 CNL-17-024

TVA BFN Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item Unit Description LAR Section / Source 43 1,2,3 Revise the procedure NPG-SPP-18.4.8, Control of Ignition Sources (Hot Work), to incorporate corrective actions identified in MDQ0009992013000160.

4.1 and Attachment A, 3.3.1.3.1 45 1,2,3 Revise procedures NPG-SPP-18.4.7, Control of Transient Combustibles, and NPG-SPP-18.4.8, Control of Ignition Sources (Hot Work), to strengthen risk and defense in-depth administrative controls (e.g., no storage and no hot work designated areas).

Attachment C and V 46 1,2,3 Verification of the condition of electrical cabinet doors to meet Fire Modeling Assumptions will be included in the monitoring Program.

Response to RAI PRA 01.d.i 47 1,2,3 Perform a focused-scope peer review of the Fire PRA. The peer review will include, as a minimum, the following elements: Fire PRA Cable Selection and Location (CS), Human Reliability Analysis (HRA), Fire Risk Quantification (FQ), Uncertainty and Sensitivity Analysis (UNC), Accident Sequence Analysis (AS), and LERF Analysis (element LE-C6). Any focused scope peer review Finding level Facts and Observations (F&Os) will be resolved prior to self-approval of post-transition changes.

Response to RAI PRA 11.a, b and c, PRA RAI 23.d and PRA RAI 24 Part b 48 1,2,3 Develop and deliver training to Fire Operations on incipient detection systems alarm response procedures.

Response to FPE RAI 10, Revision 1 CNL-17-024 Page S-52 49 1,2,3 Revise the program that monitors BFN Residual Heat Removal (RHR) heat exchanger performance for consistency with the assumptions of the NFPA 805 Net Positive Suction Head (NPSH) analysis. The monitoring program shall include verification that the tested worst fouling resistance, with measurement uncertainty added, of all BFN Units 1, 2, and 3 RHR heat exchangers is less than the design value of 0.001517 hr-ft2-°F/BTU and the worst tube plugging is less than 4.57 percent.

Attachment X /

NRC electronic mail from F. Saba (NRC) to G Williams (TVA) and C. Szabo (TVA),

"Browns Ferry NFPA 805 LAR," dated June 10, 2015 / NRC electronic mail from F. Saba (NRC) to G. Williams (TVA), C. Szabo (TVA),

and E. Schrull (TVA), "NFPA 805 Draft SE Issues regarding to implementation 49," dated October 14, 2015 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Attachment A - Clean Copy CNL-17-024

Attachment A NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Reference Requirements / Guidance Compliance Statement Compliance Basis armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers. See Implementation Item 08 in Table S

-3 of Attachment S.

References Document ID 0-FPR-VOLUME 1/PART 2 Rev. 14 [Section 6.0] - The Fire Protection Report, Fire Hazards Analysis G-38 Rev. 21 [All] - Installation, Modification, and Maintenance of Insulated Cables Rated Up To 15,000 Volts Submit for NRC Approval BFN has wiring above suspended ceilings in the Control Building that does not comply with the requirements in this code section.

See Attachment L, Approval Request 3, for further details on the request for NRC approval for existing wiring above suspended ceilings.

References Document ID 0-FPR-VOLUME 1/PART 2 Rev. 14 [Section 6.0] - The Fire Protection Report, Fire Hazards Analysis 1988-04-04 [Supplement Section C.5.a(11)] - BFN-NRC, Browns Ferry Nuclear Plant - Fire Protection Report 3.3.5.2 [Electrical Raceway Construction Limits]

3.3.5.2 Only metal tray and metal conduits shall be used for electrical raceways.

Thin wall metallic tubing shall not be used for power, instrumentation, or control cables. Flexible metallic conduits shall only be used in short lengths to connect components.

Complies with Previous Approval FAQ 06-0021 defines "short lengths" as approximately three feet of flexible metallic conduit.

BFN was previously granted approval for utilizing flexible metallic conduits in lengths up to six feet. Section 2.10 of the NRC Safety Evaluation dated March 31, 1993 states "Only metal is used for cable tray construction.

Flexible metal components are used in lengths of six feet or less. Thin wall metallic tubing is not used.

Separation and fire protection features for those cables required to achieve and maintain safe shutdown are in compliance with the requirements of Section III.G of 10 CFR 50 Appendix R."

Current plant documentation (Fire Protection Report, drawings, calculations, and specifications) was reviewed to determine that plant changes or modifications do not invalidate previous NRC approval.

References Document ID 1993-03-31 [Section 2.10] - NRC-BFN, Safety Evaluation for Fire Protection Program - Browns Ferry Nuclear Plant Units 1, 2 and 3 FAQ 06-0021 Rev. 1a [All] - Cable Air Drops G-40 Rev. 17 [All] - Installation, Modification, and Maintenance of Electrical Conduit, Cable Trays, Boxes, Containment Electrical Penetrations, Electric Conductor Seal Assemblies, Lighting and Miscellaneous Systems Fire Safety Analysis Data Manager (4.129)

TVA Browns Ferry Page: 14 of 55 CNL-17-024 Page 1 of 1 BFN Units 1,2, and 3 NFPA 805 Transition Report, Page 90 of 1661