ML18241A319

Issuance of Amendment Nos. 306, 329, and 289 to Revise Approved NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants-Revision

ML18241A319
Person / Time
Site:	Browns Ferry
Issue date:	10/09/2018
From:	Farideh Saba Plant Licensing Branch II
To:	James Shea Tennessee Valley Authority
Saba F DORL/LPL2-2 301-415-1447
References
EPID L-2018-LLA-0121
Download: ML18241A319 (33)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Joseph W. Shea Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A Chattanooga, TN 37 402-2801 October 9, 2018

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 - ISSUANCE OF AMENDMENT NOS. 306, 329, AND 289 TO REVISE APPROVED NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR ELECTRIC GENERATING PLANTS-REVISION TO ATTACHMENT A, TABLE B-1 (EPID NO. L-2018-LLA-0121)

Dear Mr. Shea:

The U.S. Nuclear Regulatory Commission (the Commission) has issued Amendment Nos. 306, 329, and 289 to Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant (Browns Ferry), Units 1, 2, and 3, respectively.

These amendments are in response to Tennessee Valley Authority's license amendment request dated May 3, 2018. The amendments revise the Browns Ferry, Units 1, 2, and 3 Renewed Facility Operating Licenses to provide a correction to previously_submitted information in relation to the approved fire protection program under Title 1 O of the Code of Federal Regulations Section 50.48(c), "National Fire Protection Association Standard NFPA 805."

Specifically, the amendments modify the Browns Ferry Renewed Facility Operating Licenses to reflect changes to Item 3.3.4 in Table B-1, "Transition of Fundamental Fire Protection Program

& Design Elements," of Attachment A in the NRG-approved amendments regarding NFPA 805 dated March 27, 2013 (Agencywide Documents Access and Management System Accession No. ML13092A393).

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

Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. Amendment No. 306 to DPR-33

2. Amendment No. 329 to DPR-52

3. Amendment No. 289 to DPR-68

4. Safety Evaluation cc: Listserv Sincerely, Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 306 Renewed License No. DPR-33

1.

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

A.

The application for amendment by Tennessee Valley Authority (the licensee) dated May 3, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the renewed license is amended by changes as indicated in the attachment to this license amendment and to the following paragraphs:

Paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-33 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 306, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

Paragraph 2.C.(13) of Renewed Facility Operating License No. DPR-33 is hereby amended to read as follows:

(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 October 9, 2018. 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.

3.

The license amendment is effective as of its date of issuance and shall be implemented immediately.

Attachment:

Changes to the Renewed Facility Operating License Date of Issuance: October 9, 2018 FOR THE NUCLEAR REGULATORY COMMISSION

~~

Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT NO. 306 BROWNS FERRY NUCLEAR PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-33 DOCKET NO. 50-259 Replace the following pages of Renewed Facility Operating License No. DPR-33 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of changes.

REMOVE 3

5 INSERT 3

5 (3)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5)

Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

BFN-UNIT 1 Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1)

(2)

Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 306, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 234 to Facility Operating License DPR-33, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 234. For SRs that existed prior to Amendment 234, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 234.

Renewed License No. DPR-33 Amendment No. 306 (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 No. 286.

(12)

Deleted.

(13)

TVA Browns Ferry Nuclear Plant shall implement and maintain in effect BFN-UNIT 1 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 October 9, 2018. 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 Renewed License No. DPR-33 Amendment No. 306

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-260 BROWNS FERRY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 329 Renewed License No. DPR-52

1.

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

A.

The application for amendment by Tennessee Valley Authority (the licensee) dated May 3, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

1.

Accordingly, the renewed license is amended by changes as indicated in the attachment to this license amendment and to the following paragraphs:

Paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-52 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 329, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Sl!)ecifications.

Paragraph 2.C.(14) of Renewed Facility Operating License No. DPR-52 is hereby amended to read as follows:

(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 October 9, 2018. 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.

3.

The license amendment is effective as of its date of issuance and shall be implemented immediately.

Attachment:

Changes to the Renewed Facility Operating License Date of Issuance: October 9, 2018 FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT NO. 329 BROWNS FERRY NUCLEAR PLANT, UNIT 2 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-52 DOCKET NO. 50-260 Replace the following pages of Renewed Facility Operating License No. DPR-52 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of changes.

REMOVE 3

5 INSERT 3

5 sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;

( 4)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5)

Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

BFN-UNIT 2 Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2)

Technical Specifications (3)

The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 329, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 253 to Facility Operating License DPR-52, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 253. For SRs that existed prior to Amendment 253, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 253.

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 Renewed License No. DPR-52 Amendment No. 329 (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 312.

(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 BFN-UNIT 2 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 October 9, 2018. 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 Renewed License No. DPR-52 Amendment No. 329

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-296 BROWNS FERRY NUCLEAR PLANT, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 289 Renewed License No. DPR-68

1.

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

A.

The application for amendment by Tennessee Valley Authority (the licensee) dated May 3, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

1.

Accordingly, the renewed license is amended by changes as indicated in the attachment to this license amendment and to the following paragraphs:

Paragraph 2.C.(2) of Renewed Facility Operating License (RFOL) No. DPR-68 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 289, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

Paragraph 2.C.(7) of RFOL No. DPR-68 is hereby amended to read as follows:

(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 October 9, 2018. 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.

3.

The license amendment is effective as of its date of issuance and shall be implemented immediately.

Attachment:

Changes to the Renewed Facility Operating License Date of Issuance: October 9, 2018 FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

ATTACHMENT TO LICENSE AMENDMENT NO. 289 BROWNS FERRY NUCLEAR PLANT, UNIT 3 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-68 DOCKET NO. 50-296 Replace the following pages of Renewed Facility Operating License No. DPR-68 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of changes.

REMOVE 3

4 INSERT 3

4 (3)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5)

Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in BFN-UNIT 3 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

( 1)

(2)

Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 289, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 212 to Facility Operating License DPR-68, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 212. For SRs that existed prior to Amendment 212, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 212.

Renewed License No. DPR-68 Amendment No. 289 (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)

TV A 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 October 9, 2018.

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. 289

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 306 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-33 AMENDMENT NO. 329 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-52 AND AMENDMENT NO. 289 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-68 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296

1.0 INTRODUCTION

By letter dated May 3, 2018 (Reference 1 ), Tennessee Valley Authority (TVA or the licensee) submitted a license amendment request (LAR) regarding the Browns Ferry Nuclear Plant (BFN),

Units 1, 2, and 3. The licensee requested a change to its approved fire protection program (FPP). Specifically, the licensee requested to change its compliance statement for National Fire Protection Association Standard (NFPA) 805 Chapter 3, Item 3.3.4, "Insulation Materials," from "Complies" to "Complies with previous approval." To support this change, the licensee submitted revised versions of Table B-1, "Transition of Fundamental Fire Protection Program &

Design Elements," and a revised fire protection license condition.

1.1 Background

On March 27, 2013 (Reference 2) (NFPA 805 LAR), TVA requested to revise the BFN, Units 1, 2, and 3 FPP in accordance with Title 10 of the Code of Federal Regulations ( 10 CFR)

Section 50.48(c). On October 28, 2015 (Reference 3), the U.S. Nuclear Regulatory Commission (NRC or the Commission) issued Amendment No. 290 to Renewed Facility Operating License (RFOL) No. DPR-33 for Unit 1, Amendment No. 315 to RFOL No. DPR-52 for Unit 2, and Amendment No. 273 to RFOL No. DRR-68 for Unit 3. The amendments consisted of changes to the operating licenses to transition the BFN-FPP to a risk-informed, performance-based (RI/PB) program based on NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition (Reference 4),

in accordance with 10 CFR 50.48(c). NFPA 805 allows the use of PB methods such as fire modeling (FM) and RI methods such as fire probabilistic risk assessment (FPRA) to demonstrate compliance with the nuclear safety performance criteria.

On June 7, 2017 (Reference 5), the licensee requested to change certain modifications and implementation items related to implementation of its NFPA 805 FPP. On December 19, 2017 (Reference 6), the NRC issued Amendment No. 302 to RFOL No. DPR-33 for Unit 1, Amendment No. 326 to RFOL No. DPR-52 for Unit 2, and Amendment No. 273 to RFOL No. DRR-68 for Unit 3 approving the proposed changes.

2.0 REGULATORY EVALUATION

The following regulations address fire protection:

Section 50.48(a)(1) of 10 CFR requires that each holder of an operating license have a fire protection plan that satisfies General Design Criterion (GDC) 3, "Fire Protection," of Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear Power Plants."

Section 50.48(c) of 10 CFR incorporates NFPA 805 (2001 Edition) by reference, with certain exceptions, modifications, and supplementation. This regulation establishes the requirements for using an RI/PB FPP in conformance with NFPA 805 as an alternative to the requirements associated with 10 CFR 50.48(b) and Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," to 10 CFR Part 50, or the specific plant fire protection license condition. The regulation also includes specific requirements for requesting approval for an RI/PB FPP based on the provisions of NFPA 805.

Appendix A to 10 CFR Part 50, GDC 3, states that:

Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fi.re detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Firefighting systems are designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.

Section 50.48, "Fire protection," of 10 CFR, provides the NRC requirements for nuclear power plant fire protection. The NRC regulations include specific requirements for requesting approval for an RI/PB FPP based on the provisions of NFPA 805.

Section 50.48(a)(1) requires each holder of an operating license, and holders of a combined license issued under Part 52, to have a fire protection plan that satisfies GDC 3 of Appendix A to 10 CFR Part 50 and states that the fire protection plan must describe the overall fire protection program; identify the positions responsible for the program and the authority delegated to those positions; and outline the plans for fire protection, fire detection and suppression capability, and limitation of fire damage.

Section 50.48(a)(2) states that the fire protection plan must describe the specific features necessary to implement the program described in paragraph (a)(1) including administrative controls and personnel requirements for fire prevention and manual suppression activities; automatic and manual fire detection and suppression systems; and the means to limit fire damage to structures, systems, and components to ensure the capability to safely shut down the plant. Section 50.48(a)(3) requires that the licensee retain the fire protection plan and each change to the plan as a record until the Commission terminates the license and that the licensee retain each superseded revision of the procedures for 3 years.

Paragraph 50.48(c)(3)(i) of 10 CFR states, in part, that:

A licensee may maintain a fire protection program that complies with NFPA 805 as an alternative to complying with [10 CFR 50.48(b )] for plants licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979.

The licensee shall submit a request to comply with NFPA 805 in the form of an application for license amendment under § 50.90. The application must identify any orders and license conditions that must be revised or superseded, and contain any necessary revisions to the plant's technical specifications and the bases thereof.

10 CFR 50.48(c)(3)(ii) states that:

The licensee shall complete its implementation of the methodology in Chapter 2 of NFPA 805 (including all required evaluations and analyses) and, upon completion, modify the fire protection plan required by paragraph (a) of this section to reflect the licensee's decision to comply with NFPA 805, before changing its fire protection program or nuclear power plant as permitted by NFPA 805.

The purpose of 10 CFR 50.48(c)(3)(ii) is explained in the statement of considerations for the Final Rule, "Voluntary Fire Protection Requirements for Light Water Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative" (69 FR 33536 through 69 FR 33548; June 16, 2004), which states, in part, that:

This paragraph requires licensees to complete all of the Chapter 2 methodology (including evaluations and analyses) and to modify their fire protection plan before making changes to the fire protection program or to the plant configuration. This process ensures that the transition to an NFPA 805 configuration is conducted in a complete, controlled, integrated, and organized manner. This requirement also precludes licensees from implementing NFPA 805 on a partial or selective basis (e.g., in some fire areas and not others, or truncating the methodology within a given fire area).

Pursuant to 10 CFR 50.90, whenever a holder of a license desires to amend the license or permit, an application for an amendment must be filed with the Commission describing the changes desired, and following, as far as applicable, the form prescribed for original applications. Accordingly, a licensee who seeks to amend its NFPA 805 authorizations must file an amendment stating, as applicable, the desired changes to orders, license conditions, and technical specifications.

Pursuant to 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Under 10 CFR 50.40, common standards for issuance of licenses include considerations of safety and satisfaction of the requirements of the National Environmental Policy Act of 1969 as implemented in 10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." Under 10 CFR 50.57(a), to issue an operating license, the Commission must find, among other things, that ( 1) there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public; (2) there is reasonable assurance that such activities will be conducted in compliance with the regulations in this chapter; and (3) the issuance of the license will not be inimical to the common defense and security or to the health and safety of the public. Additional findings required to issue amendments related to fire protection are provided in 1 O CFR 50.48, as discussed below.

The regulations also allow for flexibility that was not included in the NFPA 805 standard.

Licensees who choose to adopt 10 CFR 50.48(c) but wish to use the PB methods permitted elsewhere in the standard to meet the fire protection requirements of NFPA 805, Chapter 3, "Fundamental Fire Protection Program and Design Elements," may do so by submitting an LAR in accordance with 10 CFR 50.48(c)(2)(vii). Alternatively, licensees may choose to use RI or PB alternatives to comply with NFPA 805 by submitting an LAR in accordance with 1 O CFR 50.48( c )( 4 ). Both regulations state that the Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the licensee's approach:

(A)

Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (B)

Maintains safety margins; and (C)

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

In addition to the conditions outlined by the rule that require licensees to submit an LAR for NRC review and approval in order to adopt an RI/PB FPP, a licensee may submit additional elements of its FPP for which it wishes to receive specific NRC review and approval, as set forth in Regulatory Position C.2.2.1 of Regulatory Guide (RG) 1.205, Revision 1, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants" (Reference 7).

The purpose of the FPP established by NFPA 805 is to provide assurance through a DID philosophy that the NRC's fire protection objectives are satisfied.

Section 1.2, "Defense-in-Depth," of NFPA 805 states that:

Protecting the safety of the public, the environment, and plant personnel from a plant fire and its potential effect on safe reactor operations is paramount to this standard. The fire protection standard shall be based on the concept of defense-in-depth. Defense-in-depth shall be achieved when an adequate balance of each of the following elements is provided:

(1)

Preventing fires from starting; (2)

Rapidly detecting fires and controlling and extinguishing promptly those fires that do occur, thereby limiting fire damage; and (3)

Providing an adequate level of fire protection for structures, systems and components important to safety, so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed.

In accordance with 10 CFR Part 50, Appendix A, GDC 3, fire detection and fighting systems must be designed such that their rupture or inadvertent operation does not significantly impair the ability of the SSCs important to safety to perform their intended safety functions.

In addition, 10 CFR 50.32, "Elimination of repetition," states, in part, that, "The applicant may incorporate by reference information contained in previous applications, statements or reports filed with the Commission: Provided, That such references are clear and specific."

The NRC staff's review of this LAR also relied on the following additional codes, RGs, and standards:

Revision 1 of RG 1.205 (Reference 7) provides guidance for use in complying with the requirements that the NRC has promulgated for RI/PB FPPs that comply with 1 O CFR 50.48 and the referenced 2001 Edition of the NFPA standard. Revision 1 of RG 1.205 sets forth regulatory positions; emphasizes certain issues; clarifies the requirements of 10 CFR 50.48(c) and NFPA 805; clarifies the guidance in Nuclear Energy Institute (NEI) 04-02, Revision 2, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," dated April 2008 (Reference 8), and provides exceptions to the NEI 04-02 guidance where required.

Should a conflict occur between NEI 04-02 and RG 1.205, the regulatory positions in RG 1.205 govern.

NEI 04-02, Revision 2 (Reference 8), provides guidance for implementing the requirements of 10 CFR 50.48(c) and represents methods for implementing in whole, or in part, an RI/PB FPP. This implementing guidance for NFPA 805 has two primary purposes: (1) provide direction and clarification for adopting NFPA 805 as an acceptable approach to fire protection consistent with 10 CFR 50.48(c), and (2) provide additional supplemental technical guidance and methods for using NFPA 805 and its appendices to demonstrate compliance with fire protection requirements. Although there is a significant amount of detail in NFPA 805 and its appendices, clarification and additional guidance for select issues help ensure consistency and effective utilization of the standard. The NEI 04-02 guidance focuses attention on the RI/ PB FPP fire protection goals, objectives, and performance criteria contained in NFPA 805 and the RI/PB tools considered acceptable for demonstrating compliance. Revision 2 of NEI 04-02 incorporates guidance from RG 1.205 and approved Frequently Asked Questions.

3.0 TECHNICAL EVALUATION

3.1 Background/Discussion In its NFPA 805 LAR (Reference 2), the licensee used the systematic approach described in NEI 04-02, Revision 2 (Reference 8), as endorsed by the NRC in RG 1.205, Revision 1, (Reference 7), to assess the proposed FPP against the NFPA 805, Chapter 3 requirements. As part of this assessment, the licensee reviewed each section and subsection of NFPA 805, Chapter 3, against the existing FPP and provided specific compliance statements for each NFPA 805, Chapter 3 attribute that contained applicable requirements.

The results of the assessment are included in the licensee's NFPA 805 LAR, Attachment A:

NEI 04-02, Table B-1, "Transition of Fundamental Fire Protection Program and Design Elements," and describes how the existing FPP element complies with the requirement as follows:

1.

The existing FPP element directly complies with the requirement: Noted in LAR Attachment A, "NEI 04-02 Table B-1, Transition of Fundamental Fire Protection Program and Design Elements," as "Complies."

2.

The existing FPP element complies through the use of an explanation or clarification: Noted in LAR Attachment A, Table B-1, as "Complies with clarification."

3.

The existing FPP element complies through the use of existing engineering equivalency evaluations (EEEEs) whose bases remain valid and are of sufficient quality: Noted in LAR Attachment A, Table B-1 as "Complies with Use of EEEEs."

4.

The existing FPP element complies with the requirement based on prior NRC approval of an alternative to the fundamental FPP attribute and the bases for the NRC approval remain valid: Noted in LAR Attachment A, Table B-1, as "Complies with previous NRC approval."

5.

The existing FPP element does not comply with the requirement, but the licensee is requesting specific approval for a PB method in accordance with 10 CFR 50.48(c)(2)(vii): Noted in LAR Attachment A, Table B-1, as "Submit for NRC approval."

In its LAR dated May 3, 2018 (Reference 1 ), the licensee requested a correction of the compliance basis in its NFPA 805 LAR Attachment A, Table B-1, "Transition of Fundamental Fire Protection Program & Design Elements," for Item 3.3.4, "Insulation Materials," from "Complies" to "Complies with previous approval," and also requested to revise its RFOL, paragraphs 2.C.(13), 2.C.(14), and 2.C.(7).

NFPA 805, Section 3.1, "General," states in part, that:

Previously approved alternatives from the fundamental protection program attributes of this chapter by the authority having jurisdiction (AHJ) take precedence over the requirements contained herein.

NFPA 805, Section 3.3.4, "Insulation Material," states that:

Thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials shall be noncombustible or limited combustible.

NFPA 805, Section 1.6.36, "Limited Combustible," states that:

Material that, in the form in which it is used, has a potential heat value not exceeding 3500 Btu/lb (8141 kJ/kg [kilojoule/kilogram]) and either has a structural base of noncombustible material with a surfacing not exceeding a thickness of 1/8 in. [inch] (3.2 mm [millimeter]) that has a flame spread rating not greater than 50, or has another material having neither a flame spread rating greater than 25 nor evidence of continued progressive combustion, even on surfaces exposed by cutting through the material on any plane.

NFPA 805, Section 1.6.41, "Noncombustible Material," states that:

A material that, in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat.

NEI 04-02, Section 2.3, "Demonstration of Compliance with New Requirements," states in part, that:

3.2 Compliance with Chapter 3 may also be demonstrated by showing that the NRC has previously approved an alternative to a fundamental program attribute. A claim of prior NRC approval must be based on plant specific docketed correspondence from the NRG. Note that the plant configuration(s) addressed in this docketed correspondence/approval may have been modified subsequently during the course of plant operation. If those modifications were made in accordance with an approved process (10 CFR 50.59, Fire Protection Program Regulatory Review Processes (NEI 96-07)) they are part of the plant's approved Fire Protection Program, but they are not considered previously approved by the NRC for the purposes of Chapter 3 of NFPA 805 unless they have been explicitly reviewed and approved by the NRC.

Licensee's Technical Basis for Requested Change In its LAR dated May 3, 2018, the licensee discussed its rationale for changing its compliance statement for NFPA 805, Section 3.3.4, from "Complies" to "Complies with previous approval."

The licensee stated that the current NFPA 805 requirements do not allow the use of some elastomeric insulation materials used by the licensee because the materials would exceed the 3,500 British Thermal Units/Pound (BTU/lb) requirement of NFPA 805, Section 1.6.36.

However, use of these insulation materials by the licensee was previously approved by the NRC. The licensee discussed its basis for claiming prior approval and also included discussions concerning the impact the proposed change has on the nuclear safety performance criteria, the radiological release performance criteria, DID, and safety margins.

The licensee also stated that in a letter dated January 15, 1992 (Reference 9), it submitted its BFN Fire Protection Report (FPR) to the NRC staff for review, which included a discussion of plastic, insulation, and flame retardant materials. In Enclosure 2 of the BFN FPR, the licensee provided a comparison of the BFN-FPP to Branch Technical Position (BTP} CMEB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants" (Reference 10).

BTP CMEB 9.5-1, Guideline C.5.d(3), "Control of Combustibles," states, in part, that:

(3) The use of plastic materials should be minimized. In particular, halogenated plastics such as polyvinyl chloride (PVC) and neoprene should be used only when substitute noncombustible materials are not available.

In its response to BTP CMEB 9.5-1, Guideline C.5.d(3), the licensee stated the following in the BFN FPR:

(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.

The licensee also stated that in a letter dated March 31, 1993 (Reference 11 ), the NRC staff found its FPP as described by the BFN FPR acceptable and found that it conformed to BTP CMEB 9.5-1. In Section 2.9, "Control of Combustibles," of the corresponding safety evaluation, the NRC staff stated that:

Based on the licensee's 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.

In its LAR dated May 3, 2018 (Reference 1 ), the licensee stated that while Section 2.9 of the safety evaluation does not specifically address BFN's control of plastic materials, the safety evaluation concluded in Section 3.0 that:

The licensee's Fire Protection Plan and Fire Hazard Analysis described in BFN-FPR was reviewed and found acceptable.

The licensee also stated that the original approval remains valid in that under 10 CFR Part 50, Appendix R, BFN controlled the use of plastic materials by the Fire Protection Plan (i.e.,

Appendix R FPR, Section 7.2). The licensee further stated that it maintained consideration for combustible thermal insulation materials in the Appendix R Fire Hazard Analysis (FHA) per the evaluations in the "Combustible Load Table" calculation.

The licensee further stated that 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 FPP.

The licensee stated that secondary combustibles such as foam insulation (e.g., cellular elastomeric) are considered in its FHA by fire scenario development (i.e., FM) and fire risk evaluations. The licensee further stated that 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 licensee also stated that the increased ZOI and resulting FPRA target damage are reflected in the RI/PB fire risk evaluations. The licensee further stated that this modeling and evaluation of the combustible hazards of these materials continues to provide the proper consideration in the FHA for the NFPA 805 licensing basis.

The licensee stated that the selection and application of thermal insulation material is controlled through the use of general and site specifications. The licensee also stated that the FPRA development requires the inclusion of the effect of intervening or secondary combustibles to be documented and included in the analysis where it is determined to have fire effects as part of the PB approach. The licensee further stated that its fleet procedures that govern the engineering change process are in place to review future installation impacts to the FPP and FPRA, resulting in updates to the applicable analyses and calculations as required.

The licensee stated that the secondary combustibles with the potential to affect the FPRA are considered in the fire scenario development performed in FM. The licensee further stated that 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 ZOls due to the ignition of secondary combustibles in the area would not fail additional FPRA targets), or (3) the thermal insulation is out of the ZOI of any nearby fixed or transient ignition sources.

The licensee stated that the use of insulation material other than noncombustible and more than limited combustible has no impact on the radiological release performance criteria. The licensee stated that 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 licensee further stated that 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, and that the insulation materials do not add radiological materials to the area or challenge system boundaries.

The licensee stated that future installations of insulation materials are controlled by the plant modifications and engineering change control process, which requires the performance of an NFPA 805 FPP change impact screening. The licensee further stated that this process includes a screening requirement for insulation material to be noncombustible or limited combustible material. The licensee also stated that insulation materials that do not meet this screening criteria require a FPP change evaluation.

The licensee also stated that 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 licensee further stated that the proposed change does not affect the ability of SSCs to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits.

The licensee stated that the proposed change does not involve a significant increase in the probability of consequences of an accident previously identified.

3.2.1 Safety Margins The licensee stated that 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 licensee also stated that the insulation materials in the current configuration are considered as non-cable secondary combustibles, and that the inherent safety margins included in the FM methods are unchanged.

The licensee concluded that, because the selection and application of thermal insulation material is controlled per its piping and equipment thermal insulation specification, and because fleet procedures and the engineering change control process are in place to review future installation impacts to the FPP and FPRA, the safety margin inherent in the analysis for the fire event has been preserved.

3.2.2 Defense-in-Depth The licensee stated that the three echelons of DID for fire protection are: (1) prevent fires from starting (i.e., combustible/hot work controls); (2) rapidly detect fires, and control and extinguish fires that do occur, thereby limiting fire damage (i.e., fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans); (3) 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 licensee stated that the use of insulation material, which is more than limited combustibles, does not affect Echelons 1, 2, or 3. The licensee stated that 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.

In regard to Echelon 1, the licensee stated that the thermal insulation does not introduce new ignition sources and presents a negligible hazard in terms of secondary or intervening combustibles. The licensee also stated that the selection and application of thermal insulation material is controlled per its insulation specification. The licensee further stated that its fleet procedures that govern the plant modifications and engineering change control process are in place to review future installation impacts to the FPP and FPRA, resulting in updates to the applicable analyses and calculations as required.

In regard to Echelon 2, the licensee stated that 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. The licensee further stated that the presence of the thermal insulation in limited applications and associated procedural controls does not impact the ability of the automatic suppression and detection systems to perform credited functions, and that portable fire extinguishers and hose stations are available for manual firefighting activities by the site fire brigade, and therefore, that if a fire were to occur, damage would be limited.

In regard to Echelon 3, the licensee stated that 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 that essential safety functions are maintained and capable of being performed. The licensee further stated that the insulation material does not compromise post-fire shutdown capability as previously designed, reviewed, and considered, and that the insulation materials in the current configuration are considered as non-cable secondary combustibles and are bound by the FPRA. The licensee further stated that its fleet procedures that govern the plant modifications and engineering change control process are in place to review future installation impacts to the FPP and FPRA, resulting in updates to the applicable analyses and calculations as required.

The licensee further stated that 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.

3.3

NRC Staff Evaluation

In accordance with 10 CFR 50.48(c)(3)(i), the licensee submitted an LAR to change its compliance statement in its BFN NFPA 805 LAR Attachment A, Table B-1, "Transition of Fundamental Fire Protection Program & Design Elements," Item 3.3.4, "Insulation Materials,"

from "complies" to "complies with previous approval," and to revise its BFN NFPA 805 License Conditions 2.C.(13), 2.C.(14), and 2.C.(7). NFPA 805, Section 3.1 states that previously approved alternatives from the fundamental protection program attributes of Chapter 3 by the authority having jurisdiction take precedence over the requirements of Chapter 3.

The NRC staff reviewed the information provided by the licensee in the LAR, including discussions of previous approval and why the previous approval remains valid. The NRC staff determined that on January 15, 1992, the licensee submitted its revised BFN-FPR for NRC staff review. In that submittal, the licensee included a comparison of the BFN-FPP to NRC BTP CMEB 9.5-1. The guidance in BTP CMEB 9.5-1 Position 5.a.(9) indicates that interior wall and structural components, thermal insulation materials, radiation shielding materials, and soundproofing should be noncombustible. The guidance in BTP CMEB 9.5-1 Position 5.d.(3) indicates that the use of plastic materials should be minimized, and in particular, halogenated plastics such as polyvinyl chloride (PVC) and neoprene should be used only when substitute noncombustible materials are not available.

In its response to BTP CMEB 9.5-1 Position 5.a.(9}, the licensee stated that interior wall and structural components, radiation shielding materials, and soundproofing materials are noncombustible. The licensee further stated that other thermal insulation materials used in the plant are noncombustible and that interior finishes are noncombustible (flame spread rating of less than 50) except for plastic light covers in suspended ceilings in the Control Rooms and Shift Operations Supervisor's office.

In its response to BTP CMEB 9.5-1 Position 5.d.(3), the licensee stated that the use of plastic materials inside buildings is controlled by the Fire Protection Plan, Section 7.2, and that plastic materials used at BFN include pipe insulation (foam plastic), cable insulation (PVC, etc.), and light covers, etc., and that the combustible hazards of these materials have been considered in the FHA.

The NRC staff determined that in its letter dated March 31, 1993, the NRC staff had previously found that the licensee's FPP as described by the BFN-FPR dated January 15, 1992, conformed with BTP CMEB 9.5-1 and that the FPP was acceptable. The NRC staff determined that the previous NRC staff's finding did have one exception, but that the exception was unrelated to the applicable BTP CMEB 9.5-1 Positions 5.a.(9) and 5.d.(3) discussed above.

In its LAR, the licensee stated that the technical basis of the original approval remains valid in that under 10 CFR Part 50, Appendix R, it controlled the use of plastic materials by the Fire Protection Plan (i.e., Appendix R FPR, Section 7.2) and that it also maintained consideration for combustible thermal insulation materials in the Appendix R Fire Hazard Analysis per the evaluations in the "Combustible Load Table" calculation.

The NRC staff concludes that the licensee's proposal to change its compliance statement in its NFPA 805 LAR Attachment A, Table B-1, "Transition of Fundamental Fire Protection Program &

Design Elements," Item 3.3.4, "Insulation Materials," from "Complies" to "Complies with previous approval" is acceptable because the licensee demonstrated previous approval through docketed correspondence dated January 15, 1992, and March 31, 1993, and also demonstrated that the previous approval remains valid, both of which are in accordance with the requirements of NFPA 805, Section 3.1, and the guidance provided in RG 1.205 and NEI 04-02. The licensee also demonstrated that the supporting analyses and existing fire scenarios either ( 1) already consider the thermal insulation as a secondary combustible, (2) use bounding conservative target sets, or (3) the thermal insulation is out of the ZOI of any nearby fixed or transient ignition sources. The NRC staff concludes that further evaluation of the proposed change's impact on the nuclear safety performance criteria, the radiological release performance criteria, safety margins, and DID is not required based on 10 CFR 50.48 and on the requirements of NFPA 805, Section 3.1, which states that previously approved alternatives from the fundamental protection program attributes of Chapter 3 take precedence over the requirements of Chapter 3.

3.4 Conclusion Based on its review of the information submitted by the licensee, and in accordance with 10 CFR 50.48(c)(3)(i), the NRC staff concludes that the proposed change in compliance basis from "Complies" to "Complies with previous approval" for NFPA 805, Section 3.3.4, is acceptable because the NRC staff determined that the licensee had previous NRC approval for the use of the specified insulation materials and that the previous approval remains valid. In accordance with NFPA 805, Section 3.1, previous approval takes precedence over the requirements of NFPA 805, Chapter 3.

4.0 FIRE PROTECTION LICENSE CONDITION On October 28, 2015 (Reference 3), the NRC issued Amendment No. 290 to RFOL No. DPR-33 for Unit 1, Amendment No. 315 to RFOL No. DPR-52 for Unit 2, and Amendment No. 273 to RFOL No. DRR-68 for Unit 3. The amendments consisted of changes to the operating licenses to transition the BFN-FPP to an RI/PB program based on NFPA 805, in accordance with 10 CFR 50.48(c). The new license conditions adopted the guidelines of the standard fire protection license condition promulgated in RG 1.205, Revision 1, Regulatory Position C.3.1, as issued on December 18, 2009 (74 FR 67253). Plant-specific changes were made to the sample license condition; however, the plant-specific FPP license conditions are consistent with the standard fire protection license condition and incorporated all of the relevant features of the transition to NFPA 805 at BFN.

On June 7, 2017 (Reference 5), the licensee requested to change certain modifications and implementation items related to implementation of its NFPA 805 FPP. On December 19, 2017 (Reference 6), the NRC issued Amendment No. 302 to RFOL No. DPR-33 for Unit 1, Amendment No. 326 to RFOL No. DPR-52 for Unit 2, and Amendment No. 273 to RFOL No. DRR-68 for Unit 3 approving the proposed changes.

In its letter dated May 3, 2018 (Reference 1 ), the licensee submitted a LAR to modify fire protection License Condition 2.C.(13) for Unit 1, 2.C.(14) for Unit 2, and 2.C.(7) for Unit 3. The changes made to the license conditions include adding the licensee's LAR and the issuance date of this safety evaluation. No other changes to the license condition were requested by the licensee or identified by the NRC staff. As described in Section 3.0 of this safety evaluation, the NRC staff reviewed the information provided by the licensee and concludes that the proposed changes are acceptable; therefore, the NRC staff concludes that the revision of the license conditions identifying the LAR and safety evaluation date are appropriate and acceptable.

As revised, the first paragraph of BFN, Units 1, 2, and 3, License Condition 2.C.(13), 2.C.(14),

and 2.C.(7) will read as follows:

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 October 9, 2018. 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.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendments on September 19, 2018. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on July 17, 2018 (83 FR 33270). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

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

8.

REFERENCES

1. TVA letter to U.S. NRC, "TVA Request for Revision to Item Related to NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Attachment A, Table B-1," dated May 3, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18124A053).

2. Shea, J. W., Tennesee Valley Authority, letter to the U.S. 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 (ADAMS Accession No. ML13092A393).

3. U.S. NRC letter to TVA, "Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Issuance of Amendments Regarding Transition to Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c)," dated October 28, 2015 (ADAMS Accession No. ML15212A796}.

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

2001 Edition.

5. TVA letter to U.S. NRC, "Browns Ferry Nuclear Plant, Units 1, 2, & 3, RFOL Nos. DPR-33, DPR-52, and DPR-68, Docket Nos. 50-259, 50-260, and 50-296, Update to LAR to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," dated June 7, 2017 (ADAMS Accession No. ML171588285).

6. U.S. NRC letter to TVA, "Browns Ferry Nuclear Plant, Units 1, 2, & 3 - Issuance of Amendments to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants - Revision to Table S-2 & Table S-3 (CAC Nos. MF9814, MF9815, & MF9816," dated December 19, 2017 (ADAMS Accession No. ML17317A422).

7. U.S. NRC, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," RG 1.205, Revision 1, dated December 2009 (ADAMS Accession No. ML092730314).

8. NEI, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Washington, DC, NEI 04-02, Revision 2, dated April 2008 (ADAMS Accession No. ML081130188).

9. NEI, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Washington, DC, NEI 04-02, Revision 2, dated April 2008 (ADAMS Accession No. ML081130188).

10. U.S. NRC, Branch Technical Position CMEB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," NUREG-0800, dated July 1981 (ADAMS Accession No. ML070660454 ).

11. U.S. NRC letter to TVA, "Fire Protection Program - Browns Ferry Nuclear Plant Units 1, 2, and 3 (TAC Nos. M82687, M&2688, and M82689)," dated March 31, 1993 (ADAMS Accession No. ML18193B017).

Principal Contributor: Jay Robinson Date: October 9, 2018

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 - ISSUANCE OF AMENDMENT NOS. 306, 329, AND 289 TO REVISE APPROVED NFPA 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR ELECTRIC GENERATING PLANTS-REVISION TO ATTACHMENT A, TABLE B-1 (EPID NO. L-2018-LLA-0121) DATED OCTOBER 9, 2018 DISTRIBUTION:

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