Text

TVA Request for Revision to Item Related to 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 - Attachment a, Table B-1
	ML18124A053
Person / Time
Site:	Browns Ferry
Issue date:	05/03/2018
From:	Henderson E; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNL-18-001
	Download: ML18124A053 (28)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-18-001 May 3, 2018 10 CFR 50.90 10 CFR 50.4 10 CFR 50.48(c)(3)

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:

TVA Request for Revision to Item Related to 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 - Attachment A, Table B-1

References:

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

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

3. 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)

4. NRC Letter 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, MF 1186, and MF1187), dated October 28, 2015 (ML15212A796)

In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Tennessee Valley Authority (TVA) requests an amendment to the Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant (BFN),

Units 1, 2, and 3, respectively.

U.S. Nuclear Regulatory Commission CNL-18-001 Page 2 May 3, 2018 The proposed amendment modifies the BFN licensing basis regarding the National Fire Protection Association (NFPA) 805 program to provide a correction to previously submitted information.

Reference 1 provided TVAs Fire Protection Report that described BFNs conformance to Appendix R fire protection requirements. Reference 2 provided NRCs approval of TVAs Fire Protection Report. These references included a discussion of the insulating materials that were acceptable for use at BFN.

In Reference 3, TVA submitted a license amendment request (LAR) to adopt NFPA 805 requirements. Reference 4 provided NRCs acceptance of TVAs NFPA 805 fire protection program. In Reference 3, TVA utilized NEI 04-02 guidelines that included Attachment A, Table B-1 Transition of Fundamental Fire Protection Program & Design Elements. In Attachment A, Table B-1, Item 3.3.4, Insulation Materials, was reported as Complies with the NFPA 805 requirements.

TVA requests that the compliance statement be revised to state "Complies with previous approval." This correction is based on the previous NRC approval (Reference 2) for the use of insulating materials that are not currently approved for use with the requirements specified in NFPA 805.

Through information sharing between industry peers, TVA was informed that the definition used in NFPA 805 for Limited Combustibility (Section 3.3.4) was different from that in BTP CMEB 9.5-1. Upon review of the NFPA 805 application, TVA discovered that a discrepancy existed in the NFPA 805 LAR. In Table B-1, Item 3.3.4,"Insulation Materials," TVA reported that BFN "complies" with the NFPA 805 based on the use of noncombustible materials. However, TVA specifications allow the use of materials that are combustible and that may also not meet the NFPA 805 definition of limited combustible. This condition was entered into TVA's Corrective Action Program for tracking and closure purposes. provides the description and evaluation of the requested change. In order to correct the erroneous information in Table B-1, TVA has provided a corrected page with updated information as shown in Enclosure 2. provides a markup of the revised BFN NFPA 805 submittal Appendix A page. provides a clean typed version of the BFN NFPA 805 submittal Appendix A page. provides a markup of the affected pages of the BFN Units 1, 2, and 3 Renewed Operating Licenses. Enclosure 5 provides clean typed pages of the affected pages of the BFN Units 1, 2, and 3 Renewed Operating Licenses.

TVA has determined that there are no significant hazards consideration associated with the proposed change and that the change to the Renewed Operating License qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).

U.S. Nuclear Regulatory Commission CNL-18-001 Page 3 May 3, 2018 The BFN Plant Operations Review Committee has reviewed this amendment request and concluded that operation of BFN in accordance with the proposed change will not endanger the health and safety of the public.

Additionally, in accordance with 10 CFR 50.91 (b)(1 ), TVA is sending a copy of this letter and enclosures, to the Alabama State Department of Public Health.

TVA requests NRC approval of this LAR by May 3, 2019 in order to support the implementation of the NFPA 805 program at BFN.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 3rd day of May 2018.

Respectfully,

~ri/.e0t-E. K. Henderson Director, Nuclear Regulatory Affairs Enclosures Enclosure 1 - Request for Revision to Attachment A, Table B-1 , NFPA 805 Item 3.3.4 "Insulation Materials" Enclosure 2 - Revised Attachment A, Table B Markup Pages Enclosure 3 - Revised Attachment A, Table B Clean Pages Enclosure 4 - Markups of BFN Units 1, 2, and 3 Operating Licenses Enclosure 5 - Clean Typed Pages of BFN Units 1, 2, and 3 Operating Licenses (for Information Only) 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

Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials Table of Contents 1.0 Summary Description 2.0 Detailed Description 2.1 Proposed Changes 2.2 Reason for the Proposed Changes 3.0 Technical Evaluation 3.1 Technical Basis for the Request 3.2 Nuclear Safety and Radiological Release Performance Criteria 3.3 Safety Margin 3.4 Defense-in-Depth 3.5 Future Installations 3.6 Conclusions 4.0 Regulatory Evaluation 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedents 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions 5.0 Environmental Considerations 6.0 References CNL-18-001 E1-1 of 12

Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials 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. The Enclosure to the BFN NFPA License Amendment Request (Reference 1) contained Attachment A, NEI 04-02 Attachment A, Table B-1 Transition of Fundamental Fire Protection Program & Design Elements, Item 3.3.4, Insulation Materials. This item was previously reported as it Complies with the NFPA 805 requirements. These revisions are discussed in Section 2.2 below.

The compliance statement for Item 3.3.4, Insulation Materials, is revised to state, Complies with previous approval. This correction is based on previous NRC approval (Reference 3) for the use of plastics, including insulation, shielding and sound proofing materials, that do not meet the NFPA 805 limited combustible definition. The enclosed discussion shows that the basis for the previous approval is maintained and that the modeling and evaluation of the combustible hazards of these materials continues to provide the proper consideration in the Fire Hazard Analysis for the NFPA 805 licensing basis. This proposed revision markup and clean typed copy are shown in Enclosures 2 and 3 respectively.

2.0 Detailed Description 2.1 Proposed Changes TVA requests that the response to the BFN NFPA Attachment A, Table B-1 Item 3.3.4, Insulation Materials, be revised from complies to Complies with previous approval. A markup and clean copy of the proposed change is provided in Enclosures 2 and 3 respectively.

TVA also requests 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 as shown below:

BFN Unit 1 License Condition 2.C.(13):

(13) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50 48{a) and 10 CFR 50.48{c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; and May 3, 2018, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14, 2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; and October 23, 2017, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; and ((INSERT DATE)). Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

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Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials BFN Unit 2 License Condition 2.C.(14):

(14) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; and May 3, 2018, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14, 2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; and October 23, 2017, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; and ((INSERT DATE)). Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

BFN Unit 3 License Condition 2.C.(7):

(7) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; and May 3, 2018, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14,2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; and October 23, 2017, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017;and ((INSERT DATE)).

Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c),

and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

The proposed changes above document the transmittal letter for the correction of the error.

This proposed change is shown in Enclosure 2. Enclosure 3 provides a clean typed version of the markup in Enclosure 2.

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Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials 2.2 Reason for the Proposed Change Through information sharing between industry peers, TVA was informed that the definition used in NFPA 805 for Limited Combustibility (Section 3.3.4) was different from that in CMEB-BTP 9.5.1. Upon review of the NFPA 805 application, TVA discovered that a discrepancy existed in the NFPA 805 LAR. In Table B-1, Item 3.3.4,Insulation Materials, TVA reported that BFN "complies" with the NFPA 805 strategies for use of noncombustible materials. However, NRC had previously approved BFN for the current use of insulating materials in Reference 3 for Appendix R requirements.

In order to make the Section 3.3.4, Table B-1 entry accurate, TVA requests a revision to the entry to state, Complies with previous approval. This condition is considered to be an isolated situation limited to this entry.

3.0 Technical Evaluation 3.1 Technical Basis for the Request The current NFPA 805 requirements (Reference 4) do not allow the use of some of the previously approved elastomeric insulation materials because they would exceed the 3,500 BTU/lb requirement. TVA submitted the BFN Fire Protection Report and a comparison of the BFN Fire Protection Program to NRC Branch Technical Position (BTP) CMEB 9.5-1 in Reference 2 that included a discussion of plastic, insulation, and flame retardant materials. In to Reference 2, TVA provided a comparison of the BFN Fire Protection Program to BTP CMEB 9.5-1 (Reference 5). In response to NRC Guideline C.5.d(3), Control of Combustibles, TVA provided the following response:

(3) The use of plastic materials inside buildings is controlled by the Fire Protection Plan, Section 7.2 (Reference 1). Plastic materials used at BFN include pipe insulation (Foam Plastic), cable insulation (PVC etc.), light covers etc. The combustible hazards of these materials have been considered in the Fire Hazards Analysis.

NRC approval of the BFN Fire Protection Report was provided in NRC Safety Evaluation Report (SER) (Reference 3). Section 2.9, Control of Combustibles, of the SER states; Based on the licensees submittal, the staff concluded that combustibles have been separated from safety-related systems or provided with suppression in accordance with the guidelines of BTP CMEB 9.5-1, Section C.5.d, and such separation, therefore, is acceptable.

Section 2.9 of the SER did not specifically address BFNs control of plastic materials, but the SER concluded in Section 3.0; The licensees Fire Protection Plan and Fire Hazard Analysis described in BFN-FPR was reviewed and found acceptable.

The technical basis of the original approval remains valid in that under 10 CFR 50 Appendix R, BFN controlled the use of plastic materials by the Fire Protection Plan (i.e., Appendix R Fire Protection Report, Section 7.2). BFN maintained consideration for combustible thermal insulation materials in the Appendix R Fire Hazard Analysis per the evaluations in the Combustible Load Table calculation.

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Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials Under the NFPA 805 licensing basis, combustible materials added by plant modifications are controlled by the NFPA 805 Fire Protection Program Change Impact Screening Process procedure whereby combustible materials including combustible thermal insulation are considered for impact to the NFPA 805 Fire Protection Program. Secondary combustibles such as foam insulation (e.g., cellular elastomeric) are considered in the Fire Hazard Analysis by fire scenario development (i.e., fire modeling) and fire risk evaluations. Secondary combustibles, such as combustible thermal insulation, are considered in the fire scenario development by the use of an increased heat release rate and zone of influence (ZOI) where appropriate for the fire scenarios affected by the secondary combustibles. The increased ZOI and resulting Fire PRA target damage are reflected in the performance-based, risk-informed fire risk evaluations. This modeling and evaluation of the combustible hazards of these materials continues to provide the proper consideration in the Fire Hazard Analysis for the NFPA 805 licensing basis. Therefore, BFN continues to meet the basis for the previous approval.

3.2 Nuclear Safety and Radiological Release Performance Criteria The selection and application of thermal insulation material is controlled per the TVA General Specification G-82, Installation, Modification and Maintenance of Insulation and Site Specification N1M-001 Installation, Modification, and Maintenance of Thermal and Antisweat Insulation. The Fire PRA development requires the inclusion of the effect of intervening or secondary combustibles to be documented and included in the analysis where determined to have fire effects as part of the performancebased approach. TVA Fleet Procedures that govern the Engineering Change Process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required.

Secondary combustibles with the potential to affect the Fire PRA are considered in the fire scenario development performed in fire modeling. The supporting analyses and existing fire scenarios either (1) already consider the thermal insulation as a secondary combustible, (2) use bounding conservative target sets (i.e., expanded ZOIs due to the ignition of secondary combustibles in the area would not fail additional Fire PRA targets), or (3) the thermal insulation is out of the ZOI of any nearby fixed or transient ignition sources.

The use of insulation material other than non-combustible and more than limited combustible has no impact on the radiological release performance criteria. The radiological release review was performed based on the manual fire suppression activities in areas containing or potentially containing radioactive materials and is not dependent on the type of thermal insulation material.

The insulation material, regardless of heat contribution value, does not change the radiological release evaluation performed that concluded that potentially contaminated water is contained and smoke is monitored. The insulation materials do not add radiological materials to the area or challenge system boundaries.

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Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials 3.3 Safety Margin The insulation material, and specifically the increase in heat contribution in conjunction with the limited applications, does not compromise automatic fire suppression functions, manual fire suppression functions, or post-fire safe shutdown capability as previously designed, reviewed, and considered. The insulation materials in the current configuration are considered as non-cable secondary combustibles. The inherent safety margins included in the fire modeling methods are unchanged by this NFPA 805 Chapter 3 deviation. The selection and application of thermal insulation material is controlled per the BFN piping and equipment thermal insulation specification. TVA Fleet Procedures that govern the Plant Modifications and Engineering Change Control process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required. Therefore, the safety margin inherent in the analysis for the fire event has been preserved.

3.4 Defense-in-Depth The three echelons of defense-in-depth are:

Prevent fires from starting (i.e., combustible/hot work controls)

Rapidly detect, control, and extinguish fires that do occur, thereby limiting damage (i.e., fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans)

Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (i.e., fire barriers, fire rated cable, success path remains free of fire damage, recovery actions)

The use of insulation material, which is more than limited combustibles does not affect Echelons 1, 2, or 3. The insulation material, and specifically the increase in heat contribution in conjunction with the limited applications, does not introduce new ignition sources, does not exceed the design bases of installed fire protection systems, does not compromise manual fire suppression functions, and does not adversely impact fire protection systems and features or post-fire safe shutdown capability as previously designed, reviewed, and considered.

Echelon 1: Prevent Fires from Starting The thermal insulation does not introduce new ignition sources and presents a negligible hazard in terms of secondary or intervening combustibles. The selection and application of thermal insulation material is controlled per the TVA insulation specification. TVA Fleet Procedures that govern the Plant Modifications and Engineering Change Control process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required.

Echelon 2: Rapidly Detect, Control, and Extinguish Fires that do Occur, Thereby Limiting Damage The limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not result in increased combustible loading which would challenge the design bases of the installed fire protection systems. The presence of the thermal insulation in limited applications and associated procedural controls do not impact the ability of the automatic suppression and detection systems to perform credited functions. Portable fire extinguishers and CNL-18-001 E1-6 of 12

Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials hose stations are available for manual firefighting activities by the site fire brigade.

Therefore, if a fire were to occur, damage would be limited.

Echelon 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 limited applications of exposed thermal insulation materials installed for industrial personnel safety and on miscellaneous system piping do not adversely impact the installed fire protection systems and features, and essential safety functions are maintained and capable of being performed. The insulation material does not compromise post-fire safe shutdown capability as previously designed, reviewed, and considered. The insulation materials in the current configuration are considered as non-cable secondary combustibles and are bound by the Fire PRA. TVA Fleet Procedures that govern the Plant Modifications and Engineering Change Control process are in place to review future installation impacts to the Fire Protection Program and Fire PRA, resulting in updates to the applicable analyses and calculations as required. The presence of the thermal insulation does not compromise automatic/manual fire protection functions, or post-fire safe shutdown capability and will not prevent essential safety functions from being performed.

3.5 Future Installations Future installations of insulation materials are controlled by the Plant Modifications and Engineering Change Control process, which requires the performance of an NFPA 805 Fire Protection Program Change Impact Screening. This process includes a screening requirement for insulation material to be noncombustible or limited combustible material.

Insulation materials that do not meet this screening criteria require a Fire Protection Program Change Evaluation.

3.6 Conclusion The use of thermal insulation materials that do not meet the limited combustible criteria of NFPA 805 has been previously approved and the basis for the previous approval remains valid. TVA has determined that the approach satisfies the following criteria:

The performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release

Maintains safety margin

Maintains fire protection defense-in-depth (i.e., fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability)

Therefore, TVA requests that the previously approved insulation materials continue to be permitted. The correction of the error in Reference 1, Attachment A, Item 3.3.4, Insulation Materials, does not adversely affect NFPA 805 evaluations.

This requested change corrects the erroneous compliance statement in Reference 1, Transition Report, Attachment A, Table B-1, Item 3.3.4 Insulation Materials, with the correct compliance statement.

The change to the BFN RFOLs are administrative in nature. The proposed change does not result in any physical changes in the plants or in any plant equipment nor in any changes to CNL-18-001 E1-7 of 12

Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials BFN NFPA 805 program procedures. No changes will be made to any of the previously evaluated NFPA 805 program modifications previously approved by NRC.

4.0 Regulatory Evaluation 4.1 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) (Reference 4) 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 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.

4.2 Precedents Similar requests for performance-based methods have been included in other LARs to transition to fire protection licensing basis under NFPA 805. Examples include:

On February 3, 2017, the NRC issued Amendment No. 249 to the H. B.

Robinson Renewed Facility Operating License (Reference 8). The amendment authorized the transition of the fire protection program to a risk-informed, performance-based program based on NFPA 805. Section 3.1.4.5 of the NRC Safety Evaluation discussed H. B. Robinsons use of insulation materials that did not meet NFPA 805 Section 1.6.36 definition of non-combustible materials.

NRC evaluated these existing similar insulation materials and concluded it was an acceptable alternative.

On September 26, 2013, Duke Energy submitted a LAR (Reference 9) for the McGuire Nuclear Station Units 1 and 2, to transition the fire protection program to a riskinformed, performance-based program based on NFPA Standard 805.

By letter dated September 29, 2016 (Reference 10), Duke Energy submitted a response to a request for additional information for similar insulation material concerns and compliance with NFPA 805, Section 3.3.4, Insulation Materials.

On December 6, 2016, the NRC issued Amendment Nos. 291 and 270 to the Renewed Facility Operating License for McGuire Nuclear Station, Units 1 and 2, respectively (Reference 11), authorizing the transition of the fire protection CNL-18-001 E1-8 of 12

Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials program to a risk-informed, performance-based program based on NFPA Standard 805.

4.3 No Significant Hazards Consideration Determination TVA requests an amendment to the Browns Ferry Nuclear (BFN) Plant Renewed Facility Operating License (RFOL), paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for BFN Units 1, 2, and 3, respectively, to update the licenses to document the correction of an error in Reference 1, Transition Report, Attachment A, Table B-1 Item 3.4.4, Insulation Materials.

The proposed change also provides a corrected entry to the Compliance statement from Complies to Complies with previous approval. This proposed revision corrects erroneous information provided in the BFN Transition Report [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)] in support of the BFN implementation of NFPA 805, Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants at BFN.

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 the 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 BFN Units 1, 2, and 3, respectively.

The change encompassed by the proposed amendment is to correct the entry in Attachment A Table B-1 of the BFN Transition Report.

The proposed change does 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 change does 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.

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

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Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials

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 BFN Units 1, 2, and 3, respectively.

The change encompassed by the proposed amendment is to correct the entry in Attachment A Table B-1 of the BFN Transition Report.

There is no risk impact to Core Damage Frequency (CDF) or Large Early Release Frequency (LERF) because this is an administrative change. Plant secondary combustibles, including insulating materials, are considered in the fire modeling input to the Fire PRA.

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

Therefore, the proposed change does 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 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 BFN Units 1, 2, and 3, respectively.

The change encompassed by the proposed amendment are to correct the entry in Attachment A Table B-1 of the BFN Transition Report.

This proposed change corrects erroneous information to previously approved information in the BFN Transition Report. This proposed change will have an insignificant impact on the accident analysis as it is a clarifying or administrative change. Plant secondary combustibles, including insulating materials, are considered in the fire modeling input to the Fire PRA.

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

Therefore, based on the above discussion, these proposed changes do not involve a 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.

CNL-18-001 E1-10 of 12

Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials 4.4 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.

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

3. 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)

4. National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition" (NFPA 805)

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, CNL-14-020, "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) - Set 4," dated February 13, 2014 (ML14055A305)

CNL-18-001 E1-11 of 12

Enclosure 1 Request for Revision to Attachment A, Table B-1, NFPA 805 Item 3.3.4 Insulation Materials

7. Letter from TVA to NRC, CNL-17-130, Update to Response to NRC Request for Additional Information for License Amendment Request to Revise Modifications and an Implementation Item Related to 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 Table S-3, dated September 18, 2017 (ML17297A039)

8. Letter from NRC to Duke Energy Progress, LLC, H. B. Robinson Steam Electric Plant, Unit No 2 - Issuance of Amendment Regarding National Fire Protection Association Standard 805 (CAC No. MF2746), dated February 3, 2017 (ML16337A264)

9. Letter from Duke Energy Carolinas, LLC to NRC, McGuire Nuclear Station, Transition to 10CFR50.48(c) - NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, dated September 2013 (ML13276A127)

10. McGuire Nuclear Station Units 1 and 2 , Submittal Responding to Request for Additional Information Related to License Amendment Request to Implement a Risk-informed Performance-Based Fire Protection Program (TAC Nos. MF2934 and MF2935), dated September 29, 2016 (ML16278A610)

11. Letter from NRC to Duke Energy Carolinas, LLC, McGuire Nuclear Station, Units 1 and 2 - Issuance of Amendments Regarding National Fire Protection Association Standard (NFPA) 805 (CAC Nos. MF2934 and MF2935), dated December 6, 2016 (ML16077A135)

CNL-18-001 E1-12 of 12

Enclosure 2 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Revised Attachment A - Markup Pages CNL-18-001

Attachment A NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Compliance noncombustible or limited combustible with exceptions having previous approval. BFN historically has allowed the use of some thermal insulation materials (e.g., ASTM C534 cellular elastomeric insulation on cold/chilled NFPA 805 Ch. 3 Reference Requirements / Guidance Statement Compliance Basis water systems) that do not meet the Limited or Noncombustible definitions in NFPA 805, in that these materials would exceed the 3500 BTU/lb requirement [NFPA Fire Protection Handbook, 20th Edition].

Submit for NRC (Interior Floor Finishes)

TVA letter, Browns Ferry Nuclear Plant (BFN)-Fire Protection Report (FPR), to NRC dated January, 1992 provided in Enclosure 2 a comparison of the BFN Fire Protection Program to NRC Branch Technical Position (BTP) CMEB Approval 9.5-1 (TVA RIMS# R08920115806). In response to NRC Guideline C.5.d(3), Control of Combustibles, TVA provided the following response: BFN has epoxy floor coatings that do not comply with the requirements in (3) The use of plastic materials inside buildings is controlled by the Fire Protection Plan, Section 7.2 (Reference 1). this code section. See Attachment L, Request 2 for further details on the Plastic materials used at BFN include pipe insulation (Foam Plastic), cable insulation (PVC etc.), light covers etc. The combustible hazards of these materials request haveapproval for NRC been considered in the for existing Fire Hazards epoxy Analysis. The NRC floor coatings.

accepted the above response in a SER dated March 31, 1993 (TVA RIMS# A02930406002), did not specifically address BFN's control of plastic materials in Section 2.9 but concluded in Section 3.0, The licensee's Fire Protection Plan and Fire Hazard Analysis described in BFN-FPR was reviewed and found acceptable. BFN also has carpet tile floor finishes in the Main Control Room. These floor finishes meet the requirements of NFPA 101 Class I interior finishes.

A review Under 10 CFR 50 Appendix R, BFN controlled the use of plastic materials by the Fire Protection Plan (i.e., Fire Protection Report, Section 7.2). BFN of design maintained changes for consideration verified the requirements combustible have been thermal insulation met and materials in the Appendix R Fire Hazard Analysis per the evaluations in the Combustible Load Table calculation. maintained.

Under the NFPA 805 licensing basis, added combustible materials by plant modifications are controlled by the NFPA 805 Fire Protection Program Change Impact Screening Process procedure whereby combustible Item for Implementation:

materials including combustible thermal insulation are considered for impact to the NFPA 805 Fire Protection Program. Secondary combustibles such as foam insulation are considered in the Fire Hazard Analysis by fire scenario development (i.e., fire modeling) and fire risk evaluations. Where appropriate, secondary combustibles are considered in the fire scenario development by the use of an increased heat release rate and zone of Revise design output to ensure interior epoxy floor finishes meet the Class influence as applicable for the fire scenarios affected by the secondary combustibles. The increased zone of influence and resulting Fire PRA target damage are II requirements reflected and interiorincarpet the performance-based, floor finishes meetrisk-informed the Class I fire risk evaluations. This modeling and evaluation of the combustible hazards of these materials continues to provide the proper consideration in therequirements.

Fire Hazard Analysis for the NFPA 805 See Implementation licensing Item basis. S-3 37 in Table Therefore, BFN continues of Attachment S.

to meet the basis for the previous approval.

References Document ID G-55 Rev. 18 [All] - Technical and Programmatic Requirements for the Protective Coating Program for TVA Nuclear Plants MAI-5.3 Rev. 49 [All] - Protective Coatings for Service Level I, II, III and Corrosive Environments MAI-5.7 Rev. 28 [All] - Painting and Coating for Balance of Plant (BOP) 3.3.4 Insulation Materials. 3.3.4 Insulation Materials. Complies Thermal insulation materials, radiation shielding materials, ventilation duct Thermal insulation materials, radiation shielding materials, ventilation duct Complies with materials, and sound proofing materials are noncombustible.

materials, and soundproofing materials shall be noncombustible or limited previous combustible. approval.

References Document ID 0-FPR-VOLUME 1/PART 2 Rev. 14 [Section 4.4 and 6.0] - The Fire Protection Report, Fire Hazards Analysis G-95 Rev. 1 [Section 3.1.1] - Installation, Modification, and Maintenance of HVAC Duct G-82 Rev. 4 - Installation, Modification and Maintenance of Insulation 1992-01-15 [Section c.5.d(3)] - BFN - NRC, Browns Ferry Nuclear Plant (BFN)-Fire Protection Report 3.3.5 Electrical. N/A (FPR) N/A Section Heading.

1993-03-31 [Section 2.9] - NRC-BFN, Safety Evaluation for Fire Protection Program - Browns Ferry 3.3.5.1 [Electrical Wiring Above 3.3.5.1 Complies Wiring above suspended ceilings is kept to a minimum by limiting the Nuclear Plant Units 1, 2, and 3 Suspended Ceiling Limitations] Wiring above suspended ceiling shall be kept to a minimum. Where wiring to only that required for the area in which the suspended ceiling is 0-FPR-VOLUME1/PART 1 Rev. 24 - Fire Protection Report (Appendix R) installed, electrical wiring shall be listed for plenum use, routed in armored located. Concealed spaces have limited amounts of combustibles, mainly 0-TPP-FPP-001 Rev. 2 - NFPA 805 Fire Protection Program Change Impact Screening Process cable insulation. These cables have been accounted for in the Fire cable, routed in metallic conduit, or routed in cable trays with solid metal 0-TPP-FPP-007 top and bottomRev. 1 - NFPA 805 Fire Modeling covers. Hazards Analysis (FHA).

The FHA has reviewed the total combustible loading in each fire zone /

area and has found the fire protection and suppression features adequate for the present fire hazards.

Item for Implementation:

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 Fire Safety Analysis Data Manager (4.129) TVA Browns Ferry Run: 03/23/2013 10:31 Page: 13 of 55 BFN Units 1, 2, and 3 NFPA 805 Transition Report, Page 89 of 1661

Enclosure 3 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Revised Attachment A - Clean Pages CNL-18-001

Attachment A NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements Compliance NFPA 805 Ch. 3 Reference Requirements / Guidance Statement Compliance Basis Submit for NRC (Interior Floor Finishes)

Approval BFN has epoxy floor coatings that do not comply with the requirements in this code section. See Attachment L, Request 2 for further details on the request for NRC approval for existing epoxy floor coatings.

BFN also has carpet tile floor finishes in the Main Control Room. These floor finishes meet the requirements of NFPA 101 Class I interior finishes.

A review of design changes verified the requirements have been met and maintained.

Item for Implementation:

Revise design output to ensure interior epoxy floor finishes meet the Class II requirements and interior carpet floor finishes meet the Class I requirements. See Implementation Item 37 in Table S-3 of Attachment S.

References Document ID G-55 Rev. 18 [All] - Technical and Programmatic Requirements for the Protective Coating Program for TVA Nuclear Plants MAI-5.3 Rev. 49 [All] - Protective Coatings for Service Level I, II, III and Corrosive Environments MAI-5.7 Rev. 28 [All] - Painting and Coating for Balance of Plant (BOP)

Thermal insulation materials, radiation shielding materials, ventilation duct materials, 3.3.4 Insulation Materials. 3.3.4 Insulation Materials. and sound proofing materials are noncombustible or limited combustible with Thermal insulation materials, radiation shielding materials, ventilation duct Complies with exceptions having previous approval. BFN historically has allowed the use of some materials, and soundproofing materials shall be noncombustible or limited previous thermal insulation materials (e.g., ASTM C534 cellular elastomeric insulation on cold/

combustible. approval.

chilled water systems) that do not meet the Limited or Noncombustible definitions in References Document ID NFPA 805, in that these materials would exceed the 3500 BTU/lb requirement [NFPA G-95 Rev. 1 [Section 3.1.1] - Installation, Modification, and Maintenance Fire Protection Handbook, 20th Edition].

of HVAC Duct TVA letter, Browns Ferry Nuclear Plant (BFN)-Fire Protection Report (FPR), to NRC dated January, 1992 provided in Enclosure 2 a comparison of the BFN Fire Protection G-82 Rev. 4 - Installation, Modification and Maintenance of Insulation Program to NRC Branch Technical Position (BTP) CMEB 9.5-1 (TVA RIMS#

1992-01-15 [Section c.5.d(3)] - BFN - NRC, Browns Ferry Nuclear Plant R08920115806). In response to NRC Guideline C.5.d(3), Control of Combustibles, (BFN)-Fire Protection Report (FPR) TVA provided the following response:

(3) The use of plastic materials inside buildings is controlled by the Fire Protection 1993-03-31 [Section 2.9] - NRC-BFN, Safety Evaluation for Fire Plan, Section 7.2 (Reference 1).

Protection Program - Browns Ferry Nuclear Plant Units 1, 2, and 3 Plastic materials used at BFN include pipe insulation (Foam Plastic), cable insulation (PVC etc.), light covers etc. The combustible hazards of these materials have been 0-FPR-VOLUME1/PART 1 Rev. 24 - Fire Protection Report (Appendix R) considered in the Fire Hazards Analysis. The NRC accepted the above response in a SER dated March 31, 1993 (TVA RIMS# A02930406002), did not specifically address 0-TPP-FPP-001 Rev. 2 - NFPA 805 Fire Protection Program Change BFN's control of plastic materials in Section 2.9 but concluded in Section 3.0, The Impact Screening Process licensee's Fire Protection Plan and Fire Hazard Analysis described in BFN-FPR was reviewed and found acceptable.

0-TPP-FPP-007 Rev. 1 - NFPA 805 Fire Modeling Under 10 CFR 50 Appendix R, BFN controlled the use of plastic materials by the Fire Protection Plan (i.e., Fire Protection Report, Section 7.2). BFN maintained consideration for combustible thermal insulation materials in the Appendix R Fire Hazard Analysis per the evaluations in the Combustible Load Table calculation.

Fire Safety Analysis Data Manager (4.129) TVA Browns Ferry Run: 03/23/2013 10:31 Page: 13 of 55 BFN Units 1, 2, and 3 NFPA 805 Transition Report, Page 89 of 1661

Attachment A NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements NFPA 805 Ch. 3 Reference Compliance Requirements / Guidance Statement Compliance Basis 3.3.5 Electrical.

3.3.4 Insulation Materials Under the NFPA 805 licensing basis, added combustible materials by (Continued) plant modifications are controlled by the NFPA 805 Fire Protection Program Change Impact Screening Process procedure whereby combustible materials including combustible thermal insulation are considered for impact to the NFPA 805 Fire Protection Program.

Secondary combustibles such as foam insulation are considered in the Fire Hazard Analysis by fire scenario development (i.e., fire modeling) and fire risk evaluations. Where appropriate, secondary combustibles are considered in the fire scenario development by the use of an increased heat release rate and zone of influence as applicable for the fire scenarios affected by the secondary combustibles. The increased zone of influence and resulting Fire PRA target damage are reflected in the performance-based, risk-informed fire risk evaluations. This modeling and evaluation of the combustible hazards of these materials continues to provide the proper consideration in the Fire Hazard Analysis for the NFPA 805 licensing basis. Therefore, BFN continues to meet the basis for the previous approval.

3.3.5.1 [Electrical Wiring Above 3.3.5.1 Complies Wiring above suspended ceilings is kept to a minimum by limiting the Suspended Ceiling Limitations] Wiring above suspended ceiling shall be kept to a minimum. Where wiring to only that required for the area in which the suspended ceiling is installed, electrical wiring shall be listed for plenum use, routed in armored located. Concealed spaces have limited amounts of combustibles, mainly cable, routed in metallic conduit, or routed in cable trays with solid metal cable insulation. These cables have been accounted for in the Fire top and bottom covers. Hazards Analysis (FHA).

The FHA has reviewed the total combustible loading in each fire zone /

area and has found the fire protection and suppression features adequate for the present fire hazards.

Item for Implementation:

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 Fire Safety Analysis Data Manager (4.129) TVA Browns Ferry Page: 13.a of 55 BFN Units 1, 2, and 3 NFPA 805 Transition Report, Page 89 of 1661

Enclosure 4 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Markups of BFN Units 1, 2, and 3 Renewed Operating Licenses CNL-18-001

(8) Deleted.

(9) Deleted.

(10) Deleted.

(11)(a) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.

(b) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan {CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 279, as amended by changes approved by License Amendment Nos. 286 and 297.

and May 3, 2018 (12) Deleted.

(13) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50 48{a) and 10 CFR 50.48{c), as specified in the license amendment requests dated March 27, 2013 and June 7, 2017, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14, 2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, ;

2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; and October 23, 2017, as approved in the Safety Evaluations dated October 28, 2015, and ;

December 19, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50 48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification

and ((INSERT or a license condition, and the criteria listed below are satisfied.

DATE))

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the BFN-UNIT 1 Enclosure 4 Page 1 of 3 Renewed License No. DPR-33 Amendment No. XXX CNL-18-001

(8) Deleted.

(9) Deleted.

(10) Deleted.

(11)(a) The licensee shall fully implement and maintain in effect all provisions of the commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.

(b) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 306, as amended by changes approved by License Amendment Nos. 312 and 321.

(12) Deleted.

and May 3, 2018 (13) Deleted. ;

(14) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013, and June 7, 2017, as supplemented by letters dated May ; 16, 2013; December 20, 2013; January 10, 2014; January 14, 2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; and October 23, 2017, as approved in the Safety Evaluations dated October 28, 2015, and December 19, 2017.

Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, ; and license condition or requirement would require prior NRC approval, the ((INSERT licensee may make changes to the fire protection program without prior DATE))

approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be BFN UNIT 2 Enclosure 4 Page 2 of 3 Renewed License No. DPR-52 Amendment No. xxx CNL-18-001

(3) The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix B to licensee-controlled documents.

Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's application dated September 6, 1996; as supplemented May 1, August 14, November 5 and 14, December 3, 4, 11, 22, 23, 29, and 30, 1997; January 23, March 12, April 16, 20, and 28, May 7, 14, 19, and 27, and June 2, 5, 10 and 19, 1998; evaluated in the NRC staff's Safety Evaluation enclosed with this amendment. This amendment is effective immediately and shall be implemented within 90 days of the date of this amendment.

(4) Deleted.

(5) Classroom and simulator training on all power uprate related changes that affect operator performance will be conducted prior to operating at uprated conditions. Simulator changes that are consistent with power uprate conditions will be made and simulator fidelity will be validated in accordance with ANSI/ANS 3.5-1985. Training and the plant simulator will be modified, as necessary, to incorporate changes identified during startup testing. This amendment is effective immediately.

(6)(a) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," Revision 4, submitted by letter dated April 28, 2006.

(b) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 265, as amended by changes approved by License Amendment Nos. 271 and 281.

; and May 3, 2018 (7) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013 and June 7, 2017, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14,2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; and October 23, 2017, as approved in the Safety Evaluations dated October 28, 2015 and December 19, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee

and ((INSERT BFN-UNIT 3 Renewed License No. DPR-68 DATE))

Amendment No. XXX CNL-18-001 Enclosure 4 Page 3 of 3

Enclosure 5 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Clean Typed Pages of BFN Units 1, 2, and 3 Renewed Operating Licenses CNL-18-001

(8) Deleted.

(9) Deleted.

(10) Deleted.

(11)(a) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.

(b) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan {CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 279, as amended by changes approved by License Amendment Nos. 286 and 297.

(12) Deleted.

(13) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50 48{a) and 10 CFR 50.48{c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; and May 3, 2018, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14, 2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; and October 23, 2017, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; and ((INSERT DATE)). Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the BFN-UNIT 1 Enclosure 5 Page 1 of 3 Renewed License No. DPR-33 Amendment No. XXX CNL-18-001

(8) Deleted.

(9) Deleted.

(10) Deleted.

(11)(a) The licensee shall fully implement and maintain in effect all provisions of the commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.

(b) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 306, as amended by changes approved by License Amendment Nos. 312 and 321.

(12) Deleted.

(13) Deleted.

(14) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; and May 3, 2018, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14, 2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; and October 23, 2017, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; and

((INSERT DATE)). Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be BFN UNIT 2 Enclosure 5 Page 2 of 3 Renewed License No. DPR-52 Amendment No. xxx CNL-18-001

(3) The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix B to licensee-controlled documents.

Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's application dated September 6, 1996; as supplemented May 1, August 14, November 5 and 14, December 3, 4, 11, 22, 23, 29, and 30, 1997; January 23, March 12, April 16, 20, and 28, May 7, 14, 19, and 27, and June 2, 5, 10 and 19, 1998; evaluated in the NRC staff's Safety Evaluation enclosed with this amendment. This amendment is effective immediately and shall be implemented within 90 days of the date of this amendment.

(4) Deleted.

(5) Classroom and simulator training on all power uprate related changes that affect operator performance will be conducted prior to operating at uprated conditions. Simulator changes that are consistent with power uprate conditions will be made and simulator fidelity will be validated in accordance with ANSI/ANS 3.5-1985. Training and the plant simulator will be modified, as necessary, to incorporate changes identified during startup testing. This amendment is effective immediately.

(6)(a) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," Revision 4, submitted by letter dated April 28, 2006.

(b) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 265, as amended by changes approved by License Amendment Nos. 271 and 281.

(7) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; and May 3, 2018, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14,2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; and October 23, 2017, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; and

((INSERT DATE)). Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. XXX CNL-18-001 Enclosure 5 Page 3 of 3