CNL-18-100, TVA Request for Revision of Modifications 85, 102, and 106 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 - Table

TVA Request for Revision of Modifications 85, 102, and 106 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 - Tables

ML18295A109
Person / Time
Site:	Browns Ferry
Issue date:	10/18/2018
From:	Henderson E Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18295A108	List: CNL-18-100, TVA Request for Revision of Modifications 85, 102, and 106 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 - Table
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CNL-18-100
Download: ML18295A109 (42)

Text

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

Attachments 1 and 2 to this letter contains Security-Related Information.

Upon removal of these Attachments, this letter is uncontrolled.

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-18-100 October 18, 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 of Modifications 85, 102, and 106 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 - Tables S-2 and 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)

5. TVA Letter to NRC, CNL-17-024, Update to License Amendment Request to Revise Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. - MF1185, MF1186, and MF1187) Revision to Tables S-2 and S-3, dated June 7, 2017 (ML17158B285)

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.

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

Attachments 1 and 2 to this letter contains Security-Related Information.

Upon removal of these Attachments, this letter is uncontrolled.

U.S. Nuclear Regulatory Commission CNL-18-100 Page 2 October 18, 2018 The proposed amendment modifies the BFN licensing basis regarding the National Fire Protection Association (NFPA) 805 program to delete Modification 85 from Table S-2 Plant Modifications Committed, which was previously submitted. TVA requests that Table S-2, Modification 85 be deleted in its entirety. This modification was determined to be non-essential to meeting NFPA 805 requirements and did not factor into the BFN Fire PRA.

Additionally, TVA requests that Table S-2, Modifications 102 and 106 due dates be extended four months and six months, respectively, due to technical and scheduling difficulties related to implementation of the modifications. TVA is attempting to complete these modifications by the NFPA 805 due date, however, an extension of these due dates will ensure that TVA can complete the modifications and not impact operation and safety of the BFN units.

Modification 102 modifies the actuation for the Main Unit Service Station Transformer (USST) and Common Service Station Transformer (CSST) transformer water spray system, such that the circuits are supervised per NFPA 15-2001, 6.5.3.1.1.

Modification 106 installs additional equipment to provide water to the cooling tower lift pump bearing lubrication water system in order to provide this system with a water supply independent from the Raw Service Water (RSW) and High Pressure Fire Protection (HPFP) pumps to ensure that pressure is maintained in the fire protection system during normal operation without using a fire pump.

None of the above Modifications adversely affect the BFN Fire PRA (FPRA). Therefore, the FPRA will remain unaffected by the approval of the requested proposed changes. provides the description and evaluation of the requested change. In order to delete Modification 85, the information in Table S-2 was corrected with updated information. Enclosure 1, Attachment 1 provides a markup of the revised BFN NFPA 805 Table S-2 page. Enclosure 1, provides a clean typed version of the revised BFN NFPA 805 Table S-2. Note that is an entire Table S-2 including the updated pages and replaces all previous versions. Enclosure 1, Attachment 3 provides a markup of the affected pages of the BFN Units 1, 2, and 3 Renewed Facility Operating Licenses (RFOLs). Enclosure 1, Attachment 4 provides clean typed pages of the affected pages of the BFN Units 1, 2, and 3 Renewed Operating Licenses. Enclosure 1, Attachment 5 provides a markup of Attachment A, Table B-1, NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements. Enclosure 1, contains a clean copy of Attachment A, Table B-1.

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

Attachments 1 and 2 contain security-related information and TVA requests that this document be withheld from public disclosure under 10 CFR 2.390.

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.

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

Attachments 1 and 2 to this letter contains Security-Related Information.

Upon removal of these Attachments, this letter is uncontrolled.

U.S. Nuclear Regulatory Commission CNL-18-100 Page 3 October 18, 2018 TVA requests NRC approval of this LAR by the start of the BFN Unit 2 refueling outage (U2R20),

which is currently scheduled to begin on March 2, 2019.

There are no new regulatory commitments contained in this submittal. Please address any questions regarding this submittal to Michael A. Brown at (423) 751-3275.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this u ~

18th day of October 2018.

E. K. Henderson Director, Nuclear Regulatory Affairs Enclosures Enclosure 1 - Request for Revision to NFPA 805, Table S-2 Modifications 85, 102, and 106 Attachment 1 - Revised Table S Markup Pages Attachment 2 - Revised Table S Entire Table Including Proposed Changes Attachment 3 - Markups of BFN Units 1, 2, and 3 Renewed Facility Operating Licenses Attachment 4 - Clean Typed Pages of BFN Units 1, 2, and 3 Renewed Facility Operating Licenses (for Information Only)

Attachment 5 - Attachment A, Table 8-1, Markup Attachment 6 -Attachment A, Table 8-1, Clean Copy cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Health

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 Table of Contents Page 1.0 Summary Description 2 2.0 Detailed Description 3 2.1 Proposed Changes 3 2.2 Reasons for the Proposed Changes 6 3.0 Technical Evaluation 7 3.1 Technical Basis for the Request 7 3.2 Safety Margin 8 3.3 Defense-in-Depth 8 4.0 Regulatory Evaluation 9 4.1 Applicable Regulatory Requirements/Criteria 9 4.2 Precedents 9 4.3 No Significant Hazards Consideration Determination 10 4.4 Conclusions 12 5.0 Environmental Considerations 12 6.0 References 12 Attachments Attachment 1 - Revised Table S Markup Pages Attachment 2 - Revised Table S Entire Table Including Proposed Changes Attachment 3 - Markups of BFN Units 1, 2, and 3 Renewed Facility Operating Licenses Attachment 4 - Clean Typed Pages of BFN Units 1, 2, and 3 Renewed Facility Operating Licenses (for Information Only)

Attachment 5 - Attachment A, Table B-1, Markup Attachment 6 - Attachment A, Table B-1, Clean Copy CNL-18-100 E1-1 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 1.0 Summary Description The current state of the BFN National Fire Protection Association (NFPA) 805 project is as follows:

There are a total of fifty-seven (57) modification items listed in the S-2 Table provided in Reference 1, which defines modification commitments in transition license condition 2.

Forty-two (42) of the items are complete and fifteen (15) remain to be completed. With the exception of the modifications addressed in this request, the remaining modifications are required to be completed by the end of BFN Unit 2 Refueling Outage 20 (U2R20) presently scheduled for the Spring of 2019.

This request revises Renewed Facility Operating Licenses (RFOL) DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3, respectively, to eliminate Modification 85 and to extend the due dates for Modifications 102 and 106. These modifications are discussed in this enclosure (Enclosure 1). BFN NFPA 805 License Amendment Request (LAR) (Reference 3), Attachment S, Modifications and Implementation Items, Table S-2 listed Modifications 85 and 102 in the original submittal of this table.

Modification 106 was later added to Table S-2 per Reference 4. The affected modifications are fire protection system upgrades related to the Reference 3 LAR, Attachment A, NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements. These revisions are discussed in Section 2.0 below.

TVA proposes to eliminate Modification 85 due to technical challenges with the design and the modification having no benefit to plant nuclear safety. Due date extensions for Modifications 102 and 106 are being requested to mitigate schedule risk from unforeseen circumstances. TVA intends to complete these modifications by the original schedule of startup from the second refueling outage for each unit, which occurs with U2R20 on April 14, 2019, however an extension of these due dates avoids the need for an exigent change request should there be an unexpected delay.

The affected modifications are fire protection system upgrades for NFPA code compliance and are not credited in the BFN FPRA. Therefore, they have no direct impact on fire risk.

This change includes revisions to Attachment S, Modifications and Implementation Items, Table S-2 and LAR Attachment A, NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements. The proposed revision markup and clean typed copy for Table S-2 and Table B-1 are shown in Attachments 1, 2, 5, and 6 respectively. Note that contains a complete clean copy of Table S-2 that supersedes all previous versions.

CNL-18-100 E1-2 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 2.0 Detailed Description 2.1 Proposed Changes The following changes are proposed for BFN NFPA 805, Table S-2, Plant Modifications Committed.

MODIFICATION 85 Table S-2 Plant Modifications Committed Item Rank Unit Problem Statement Proposed Modification In Comp Risk Informed FPRA Measure Characterization 85 Low Common NFPA 12. Carbon Dioxide Install pneumalic pre-<lischarge No Yes This is an NFPA 805 Chapter 3 Extinguishing Systems. 2008 alarms a nd pneumatic time delays compliance modification . This requires pneumatic pre- in C02sys1ems 10 meel NFPA 12, level of deiail is not modeled in discharge alarms and 2008. lhe P RA.

pneumatic time delays for CO2 syslems.

Associa1ed N FPA 805 Chapter 3 reference:

3.10.1 TVA requests that the Modification 85 in Table S-2 be deleted and removed from the table. A markup and clean copy of the proposed change is provided in Attachments 1 and 2, respectively. The proposed change also affects the response in the Reference 3 LAR, Attachment A, NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program &

Design Elements. A mark-up and clean copy of this change is provided in Attachments 5 and 6, respectively.

MODIFICATION 102 Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 10? I ow 1 ?,:l Trnn~formP.r WAtP.r sprn~* MO<lify lhP er.hiatinn for l hP. Mein, No Thi~ is en NFPA 800 t.hAplP.r 1 actua~on systems are not fail USST and CSST transformer water compliance modification. This safe or fully supervised as spray systems such that the circuits level of detail is not modeled in required by NFPA 15. are supervised per NFPA 15-2001, the PRA.

6.5.3.1.1.

Associated NFPA 805 Chapter 3 reference:

1 9 1(?)

TVA requests a due date extension for Modification 102 of four months after the end of the scheduled U2R20 refueling outage, i.e., an extension to August 14, 2019.

CNL-18-100 E1-3 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 MODIFICATION 106 Table S-2 Plant Modifications Committed In Comp Risk Informed Item Rank Unit Problem Statement Proposed Modification FPRA Measure Characterization 106 Low Commo n Whe n the R SW p um ps a n d In sta ll additio na l eq uipme n t to No Yes Cha pte r 3 complia n ce the wate r tanks are unable to provid e water to the cooling t ower modification. This leve l of det ai l mai ntain t h e p ressure in the lift pump bearing lu b rica tion water is not modeled in the PRA s hared RSW a n d HPFP system in orde r to p rovide th is p iping , a fi re p u mp is system a wa te r s u pply in depen d e nt activated to a id in f rom t h e R SW a n d H P F P system s mai nt a in ing p r essu re in the to e n s u re that pressure is system . m a inta ined in the fi re p rotection system during n o r ma l operatio n w ith out u s in g a fire pump .

Associated N F PA 805 Cha pte r 3 re fe rence:

358 TVA requests a due date extension for Modification 106 of six months after the end of the scheduled U2R20 refueling outage, i.e., an extension to October 14, 2019.

Proposed License Changes The following changes to the BFN Units 1, 2, and 3 Renewed Facility Operating License (RFOL) are proposed to support the requested deletion of Modification 85 and changes to the schedules for Modifications 102 and 106. Note that the bolded and underlined text below indicates the requested changes to the licenses. Because there is another NFPA 805 related LAR under review with the NRC, the following distinction is provided. The term SE1 represents the date of the Safety Evaluation (SE) for the LAR dated May 3, 2018 (Reference 5) and SE2 represents the date of the SE for this LAR.

Transition License Condition 2 With the exception of Modifications 102 and 106, the licensee shall implement modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. Modifications 102 and 106 as described in Table S-2, shall be implemented no later than August 14, 2019 and October 14, 2019, respectively. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

TVA also requests an amendment to the BFN RFOL, paragraphs 2.C.(13) of Unit 1, 2.C.(14) of Unit 2, and 2.C.(7) of Unit 3 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; May 3, 2018; and October 18, 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 CNL-18-100 E1-4 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 dated October 28, 2015; December 19, 2017; October 9, 2018, and ((INSERT DATE SE)). 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.

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; May 3, 2018; and October 18, 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; October 9, 2018; and

((INSERT DATE SE)). 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; May 3, 2018; and October 18, 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; October 9, 2018; and

((INSERT DATE SE)). 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.

CNL-18-100 E1-5 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 2.2 Reasons for the Proposed Changes Modification 85 Modification 85 was to install pneumatic pre-discharge alarms and pneumatic time delays in CO2 systems to meet the retroactive life-safety requirements of NFPA 12 Carbon Dioxide Extinguishing Systems, 2008 Edition (Reference 6), Section 4.5.6.1, Pre-discharge Alarm and Time Delay. The system is currently equipped with electrical pre-discharge time delay and alarm that serve the same function but do not meet NFPA 12, 2008 Edition which requires these functions to be pneumatic. The NFPA 805 (Reference 2) code compliance review performed in support of the Reference 3 LAR, Attachment A, NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements, established that the BFN code of record is NFPA 12, 1966 Edition, which does not require pneumatic pre-discharge time delays and alarms. However, certain life safety provisions of NFPA 12, 2008 Edition are made retroactive by paragraph 1.3.4 including pneumatic pre-discharge time delays and alarms and the retroactive sections were conservatively included in the compliance review.

TVA has encountered design difficulties related to interfacing modern equipment with BFNs older CARDOX system, expanding the scope of the modification beyond what was originally envisioned. TVA has concluded in the course of design development and review that it is not advisable from a safety prospective to proceed with the modification.

Modification 102 Modification 102 modifies the actuation for the Main, Unit Station Service Transformer (USST) and Common Station Service Transformer (CSST) water spray systems such that the circuits are supervised per NFPA 15, 2001 Edition, 6.5.3.1.1 (Reference 7). Modification 102 is divided into 10 separate modification stages in order to cover five sets of transformers and the plant conditions required to implement the modifications. Three of the modification stages require a unit outage. One of the stages is complete and the remaining two are scheduled for the upcoming outages in Fall 2018 (BFN Unit 1) and Spring 2019 (BFN Unit 2). The remaining stages do not require a unit outage but are subject to work restrictions during plant conditions requiring protection of offsite power, such as Emergency Diesel Generator allowable outage times (AOTs).

This modification is currently in progress and is scheduled to be complete by the original milestone in Spring 2019 corresponding to the end of the second refueling outage for each unit following issuance of the NFPA 805 License Amendment dated October 28, 2015 (Reference 9). However, TVA requests an extension of four months to August 14, 2019, in case there are unforeseen work delays.

Modification 106 Modification 106 installs a new water intake pumping station to supply bearing lubrication water to the cooling tower lift pumps. Raw Service Water (RSW) and High Pressure Fire protection (HPFP) share piping and features and currently operation of a Fire Pump is required in order to maintain an adequate supply of bearing lubrication water to the cooling tower lift pumps.

Contractors have been selected to design and construct the new station and contracts are being finalized.

CNL-18-100 E1-6 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 TVA intends to complete the modification before the original milestone at the end of the second refueling outage for each unit following issuance of the NFPA 805 License Amendment dated October 28, 2015 (Reference 9). However, TVA requests an extension of six months to October 14, 2019, to accommodate unforeseen delays such as delivery of equipment.

3.0 Technical Evaluation 3.1 Technical Basis for the Request MODIFICATION 85 The CO2 fire suppression system at BFN is currently designed with an electrical pre-discharge time delay and alarm. This system design is in compliance with NFPA 12 1966, which is the code of record for BFN. NFPA 12, 2008 (Reference 6) introduced a new requirement in paragraph 4.5.6.1 for the pre-discharge time delay and alarm to be pneumatic. This paragraph was made retroactive by paragraph 1.3.4 and was therefore considered in the code compliance review performed in support of the Reference 3 LAR, Attachment A, NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements. The review against the retroactive requirements resulted in the implementation items in the B-1 Table.

The CO2 control stations operate with electrical components and timer that govern the pre-discharge time delay and alarm, actuation of the hazard valves that discharge CO2 to the area and determine the duration of the discharge. NFPA 12, 2008 Edition and Modification 85 proposed to convert the discharge time delay and alarm from electric to pneumatic. However, actuation of the system would continue to depend on electrical power.

The purpose of the pre-discharge time delay and alarm is to allow time for personnel occupying the hazard area to safely evacuate. 10 CFR 50.48(c)(2)(i) and NEI 04-02 Revision 2 (Reference 8) do not include life safety provisions as part of an NPFA 805 transition. The addition of a pneumatic timer versus an electric timer has no bearing on the capability of the CO2 system to suppress a fire, because the system is dependent on electric power for actuation. The existing electrical components perform the same function and meet applicable NFPA code requirements with respect to system reliability.

The pre-discharge time delay and alarm only delays introduction of CO2 to the affected areas for a short time (~ 1 minute) to allow personnel already in the area to evacuate. Recovery actions are not performed in locations protected by CO2 when that location is the fire location.

Therefore, it is not a factor in determining accessibility to areas of the plant to perform recovery actions. The Main Control Room (MCR) is not equipped with CO2 suppression and therefore, control room habitability and control room abandonment are not affected. Finally, Modification 85 is not credited in the FPRA.

A markup revision to the Attachment A, NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements is provided in Attachment 5 and a clean copy is provided in Attachment 6.

MODIFICATION 102 Modification 102 upgrades the fire detection and suppression features for the Main, USST, and CSST transformers to be supervised. The transformers are protected by a water deluge system that is initiated by heat detectors and transformer protective relays. The current design is not supervised such that certain types for failures are not immediately detected and alarmed and would only be discovered during periodic testing. The affected detection and suppression CNL-18-100 E1-7 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 systems are not credited in the FPRA. Therefore, delaying completion of the modification until August 14, 2019, would have a small impact on the reliability of transformer fire suppression but would have no impact on fire risk in the FPRA.

MODIFICATION 106 Modification 106 installs a new water intake pumping station to supply bearing lubrication water to the cooling tower lift pumps when they are in operation during the warm season. Due to limited capability of the existing Raw Service Water (RSW) pumps, operation of Fire Pumps, which share the same piping system, is currently required to provide adequate flow to the Cooling Tower Lift Pumps. The goal of Modification 106 is to eliminate reliance on fire pumps for this routine operational purpose.

The fire pumps are not modeled in the FPRA but their availability and reliability is considered to support fire suppression. They are not credited in the deterministic Nuclear Safety Capability Assessment (NSCA) to meet the nuclear safety goals. Delaying completion of the modification until October 14, 2019, would have a negligible impact on Core Damage Frequency (CDF) /

Incremental Core Damage Probability (ICDRP) and Large Early Release Frequency (LERF) /

Incremental Large Early Release Probability (ILERP) due to the small impact that routine operation of the fire pumps has on fire suppression reliability combined with the limited time duration of the extension.

3.2 Safety Margin NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Revision 2 (Reference 8), Section 5.3.5.3, "Safety Margins,"

lists two specific criteria that should be addressed when considering the impact of plant changes on safety margins:

• Codes and standards or their alternatives accepted for use by the NRC are met; and,

• Safety analysis acceptance criteria in the licensing basis (e.g., FSAR [Final Safety Analysis Report], supporting analyses, etc.) are met, or provides sufficient margin to account for analysis and data uncertainty.

With the elimination of Modification 85, the CO2 design maintains codes and standards in the BFN code of record and only affects life safety aspects of NFPA 12. The elimination of Modification 85 does not affect the nuclear safety margin. Modifications 102 and 106 also maintain codes and standards; this LAR only involves implementation timeframes. The proposed changes associated with Modifications 85, 102, and 106 do not involve any licensing basis analyses.

Therefore, the safety margin inherent in the analyses for fire events has been preserved.

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

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

2. 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)

CNL-18-100 E1-8 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106

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 affected systems do not prevent fires from starting and are not used for plant shutdown.

Therefore, these changes do not affect echelons 1 or 3. Modifications 85, 102, and 106 are specific to fire suppression and detection systems. Therefore, the proposed changes are related to echelon 2. Modification 85 only affects life safety aspects of the CO2 suppression system and does not impact the ability to detect and suppress a fire. The fire pumps and the transformer detection and suppression systems are capable of detecting and suppressing fires as they are currently designed. Therefore, the affected fire protection systems remain capable of detecting, controlling and extinguishing fires without Modifications 85, 102, and 106.

Therefore, defense-in-depth is maintained.

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 2) 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 have been included in other LARs to transition to fire protection licensing basis under NFPA 805. The following examples are provided as similar type of requests;

1. Southern Nuclear Operating Company (SNC), Joseph M. Farley Nuclear Plant Units 1 and 2 NFPA-805 Transition Due Date Extension, dated August 11, 2017 (ML17226A291)

2. Duke Entergy Carolinas, LLC, Oconee Nuclear Station Units 1, 2 and 3, NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition), Supplement 1 to LAR 2012-09, License Amendment Request for Revision to License Condition 3.D, Transition License Conditions #1 and #2, dated September 5, 2012 (ML12251A010)

CNL-18-100 E1-9 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 4.3 No Significant Hazards Consideration Determination TVA requests an amendment to the Browns Ferry Nuclear Plant (BFN) Renewed Facility Operating License (RFOL), Transition Condition 2, 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 deletion of Modification 85 in Attachment S, Table S-2 of the BFN NFPA Transition Report, and the extension of the due date of Modification 102 by four months and the due date of Modification 106 by six months.

The proposed change deletes Modification 85 in its entirety from Table S-2. Modification 85 would have installed pneumatic pre-discharge alarms and pneumatic time delays in the CO2 systems to meet NFPA 12, Carbon Dioxide Extinguishing Systems, 2008 Edition. NFPA 12, 2008 Edition requires pneumatic pre-discharge alarms and pneumatic time delays for CO2 systems. The BFN CO2 system pre-discharge alarms and time delays are currently electric and meet the NFPA 12, 1966 Edition code of record.

The deletion of Modification 85 does not affect the FPRA or the fire suppression system currently in place at BFN. This proposed change does not affect other items listed in Attachment S or adversely affect the BFN implementation of NFPA 805, Performance Based Standard for Fire Protection for Light Water Reactor Generating Plants at BFN.

Extending the due dates of Modifications 102 and 106 would ensure that the installation of these modifications maintain the safe operation of the BFN units.

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, Transition Condition 2, 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 delete Modification 85 in Attachment S, Table S-2 of the BFN NFPA 805 Transition Report, and to extend the due dates of Modifications 102 and 106.

CNL-18-100 E1-10 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed 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.

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, Transition Condition 2, paragraphs 2.C.(13), 2.C.(14), and 2.C.(7) for BFN Units 1, 2, and 3, respectively. The changes encompassed by the proposed amendment are to delete Modification 85 in Attachment S, Table S-2 of the BFN NFPA 805 Transition Report, and extend the due dates of Modifications 102 and 106.

There is no risk impact to Core Damage Frequency (CDF) or Large Early Release Frequency (LERF) because these proposed changes do not impact the FPRA results.

These proposed changes are an NFPA 805 Chapter 3 compliance issue only and do not require a change to the FPRA. This level of detail is not modeled in the FPRA.

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, Transition Condition 2, 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 delete Modification 85 in Attachment S, Table S-2 of the BFN NFPA 805 Transition Report, and extend the due dates of Modifications 102 and 106.

The proposed change deletes Modification 85 in its entirety from Table S-2. Modification 85 would have installed pneumatic pre-discharge alarms and pneumatic time delays in the CO2 systems to meet NFPA 12, 2008 Edition. NFPA 12, 2008 Edition requires pneumatic pre-discharge alarms and pneumatic time delays for CO2 systems. The CO2 system pre-discharge alarms and time delays are currently electric and meet the NFPA 12, 1966 Edition code of record.

The deletion of Modification 85 does not affect the Fire PRA or the fire suppression system currently in place at BFN. This proposed change does not affect other items listed in Attachment S or adversely affect the BFN implementation of NFPA 805 at BFN.

CNL-18-100 E1-11 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106 The proposed changes associated with Modifications 85, 102, and 106 do not involve any licensing basis analyses. Therefore, the safety margin inherent in the analyses for fire events has been preserved.

These proposed changes 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.

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. TVA Letter to NRC, CNL-17-024, Update to License Amendment Request to Revise Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. - MF1185, MF1186, and MF1187) Revision to Tables S-2 and S-3, dated June 7, 2017 (ML17158B285)

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

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)

CNL-18-100 E1-12 of 13

Enclosure 1 Request for Revisions to NFPA 805, Table S-2 Modifications 85, 102, and 106

4. TVA Letter to NRC, CNL-14-208, Response to NRC Request for Additional Information Regarding the License Amendment Request to Adopt NFPA 805 Performance-Base Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186 and MF1187) - Probabilistic Risk Assessment Follow Up (162-Day Responses), dated December 17, 2014 (ML14363A057)

5. TVA Letter to NRC, CNL-18-001, 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, dated May 3, 2018 (ML18124A053)

6. NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2008 Edition, dated August 15, 2007

7. NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 2001 Edition, dated August 2, 2001

8. NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Revision 2 (ML081130188)

9. 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)

CNL-18-100 E1-13 of 13

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

Attachments 1 and 2 to this letter contains Security-Related Information.

Upon removal of these Attachments, this letter is uncontrolled.

Enclosure 1 Attachment 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Revised Table S Markup Pages CNL-18-100

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

Attachments 1 and 2 to this letter contains Security-Related Information.

Upon removal of these Attachments, this letter is uncontrolled.

Enclosure 1 Attachment 2 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Revised Table S Entire Table Including Proposed Changes CNL-18-100

Enclosure 1 Attachment 3 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Markups of BFN Units 1, 2, and 3 Renewed Facility Operating Licenses CNL-18-100

(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. and October 18,

October 9, 2018; 2018, and ((INSERT DATE(13) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect of SE)) 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 1 O 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 Renewed License No. DPR-33 Amendment No. 302

-Sb-

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

Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made With the exception without prior NRC review and approval unless the change has been of Modifications demonstrated to have no more than a minimal risk impact, as described in (2) 102 and 106,above.

t

2. The licensee shall implement modifications to its facility, as described in Table S-2, "Plant Modifications," of Tennessee Valley Authority letter CNL 17-024, dated June 7, 2017, to complete the transition to full CNL-18-100, dated compliance with 10 CFR 50.48(c) no later than the end of the second October 18, 2018 refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications. Modifications 102 and 106 as

3. The licensee shall complete Implementation Items 09, 32, described in Table S-2, shall be 33, and the second part of Implementation Item 47 as listed in Tableimplemented S-3, no later than "Implementation Items," of TVA letter CNL-17-130 dated October 23, August 14, 2019 and October 2017. Implementation Item 09 shall be completed by June 14, 29, 2018.

2019, respectively.

Implementation Items 32, 33, and the second part of Implementation Item 47, i.e., resolving Finding level Facts and Observations, are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

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

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

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

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 302

-6e-(h) The results of the visual inspections of the steam dryer shall be submitted to the NRC staff in a report in accordance with 10 CFR 50.4. The report shall be submitted to the NRC within 90 days following startup from each of the first two respective refueling outages.

(i) Within 6 months following completion of the second refueling outage, after the implementation of the EPU, the licensee shall submit a long-term steam dryer inspection plan based on industry operating experience along with the baseline inspection results.

The license condition described above shall expire: (1) upon satisfaction of the requirements in items (g) and (h), provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw(s) or unacceptable flaw growth that is due to fatigue, and; (2) upon satisfaction of the requirements specified in item (i).

(19) Neutron Absorber Monitoring Program The licensee shall, at least once every ten years, withdraw a neutron absorber coupon from the spent fuel pool and perform Boron-10 (B-10) areal density measurement on the coupon. Based on the results of the B-10 areal density measurement, the licensee shall perform any technical evaluations that may be necessary and take appropriate actions using relevant regulatory and licensing processes.

(20) Radiological Consequences Analyses Using Alternative Source Terms TVA shall perform facility and licensing basis modifications to resolve the non-conforming/degraded condition associated with the Alternate Leakage Treatment pathway such that the current licensing basis dose calculations (approved in License Amendment Nos. 251/282 (Unit 1), 290/308 (Unit 2) and 249/267 (Unit 3)) would remain valid. These facility and licensing basis modifications shall be complete prior to initial power ascension above 18-100 3458 MWt. October 18, 2018 (21) Prior to extending the frequency for the Integral Leakage Rate Testing described in TS 5.5.12, the licensee shall implement the modifications, that are modeled in the Fire PRA and described in Table S-2, Plant Modifications," of Tennessee Valley Authority letter CNL-17-024, dated June 7, 2017.

0. The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), shall be included in the next scheduled update to the UFSAR required by 10 CFR 50.71(e)(4) following the issuance of this renewed operating license. Until that update is complete, TVA may make changes to the programs and activities described in the supplement without prior Commission approval, provided that TVA evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

E. The UFSAR supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. TVA shall complete these activities no later than December 20, 2013, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 299

(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.

and October 18, (14) TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all 2018, 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;

October 9, 2018; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; and ((INSERT August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; DATE of SE)) 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 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 Renewed License No. DPR-52 Amendment No. 326

-5b-

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

• Gaseous Fire Suppression Systems (Section 3.1O); and

• Passive Fire Protection Features (Section 3.11).

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

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

Transition License Conditions

1. With the Before achieving fullException compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made of Modifications without prior102NRCandreview 106, tand approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2)

CNL-18-100, dated above.

October 18, 2018

2. The licensee shall implement modifications to its facility, as described in Table S-2, "Plant Modifications," of Tennessee Valley Authority letter CNL-17-024, dated June 7, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

Modifications 102 and 106 as

3. The licensee shall complete Implementation Items 09, 32,described in Table S-2, shall 33, and the second part of Implementation Item 47 as listed in Table S-3,be implemented no later than "Implementation Items," of TVA letter CNL-17-130 dated August 14, 2019, and October October 23, 2017. Implementation Item 09 shall be completed by respectively.

14, 2019, June 29, 2018. Implementation Items 32, 33, and the second part of Implementation Item 47, i.e., resolving Finding level Facts and Observations, are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

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

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

BFN-UNIT 2 Renewed License No. DPR-52 Amendment No. 326

-6e-(h) The results of the visual inspections of the steam dryer shall be submitted to the NRG staff in a report in accordance with 10 CFR 50.4. The report shall be submitted to the NRG within 90 days fallowing startup from each of the first two respective refueling outages.

(i) Within 6 months following completion of the second refueling outage, after the implementation of the EPU, the licensee shall submit a long-term steam dryer inspection plan based on industry operating experience along with the baseline inspection results.

The license condition described above shall expire: (1) upon satisfaction of the requirements in items (g) and (h), provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw(s) or unacceptable flaw growth that is due to fatigue, and; (2) upon satisfaction of the requirements specified in Item (i}.

( 19} Neutron Absorber Monitoring Program The licensee shall, at least once every ten years, withdraw a neutron absorber coupon from the spent fuel pool and perform Boron-10 (B-10) areal density measurement on the coupon. Based on the results of the B-10 areal density measurement, the licensee shall perform any technical evaluations that may be necessary and take appropriate actions using relevant regulatory and licensing processes.

(20} Radiological Consequences Analyses Using Alternative Source Terms TVA shall perform facility and licensing basis modifications to resolve the non-conforming/degraded condition associated with the Alternate Leakage Treatment pathway such that the current licensing basis dose calculations (approved in License Amendment Nos. 251/282 (Unit 1), 290/308 (Unit 2) and 249/267 (Unit 3)) would remain valid.

These facility and licensing basis modifications shall be complete prior 18-100 to initial power ascension above 3458 MWt. October 18, 2018 (21) Prior to extending the frequency for the Integral Leakage Rate Testing described in TS 5.5.12, the licensee shall implement the modifications, that are modeled in the Fire PRA and described in Table S-2, "Plant Modifications," of Tennessee Valley Authority letter CNL-17-024, dated June 7, 2017.

D. The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d),

shall be included in the next scheduled update to the UFSAR required by 10 CFR 50.71(e)(4) following the issuance of this renewed operating license.

Until that update is complete, TVA may make changes to the programs and activities described in the supplement without prior Commission approval, provided that TVA evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

E. The UFSAR supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. TVA shall complete these activities no later than June 28, 2014, and shall notify the NRG in writing when implementation of these activities is complete and can be verified by NRG inspection.

BFN-UNIT 2 Renewed License No. DPR-52 Amendment No. 323

- 4-(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 1 O 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 October 18, 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;

October 9, 2018; and March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8,

((INSERT 2015; October DATE 20, 2015; SE)) 18, 2017; and October 23, 2017, as September 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 BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 286

-4b-The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is "adequate for the hazard." Prior NRG review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• Fire Alarm and Detection Systems (Section 3.8);

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

• Gaseous Fire Suppression Systems (Section 3.1O); and

• Passive Fire Protection Features (Section 3.11).

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

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

Transition License Conditions

1. Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without priorCNL-18-100, NRG review and approval unless the change has dated With the exception been demonstrated to have no more than a minimal risk impact, as of Modifications described in {2) above. October 18, 2018 102 and 106, t 2. The licensee shall implement modifications to its facility, as described in Table S-2, "Plant Modifications," of Tennessee Valley Authority letter CNL-17-024, dated June 7, 2017, to complete the transition to full compliance with 10 CFR 50.48{c) no later than the end of the second refueling outage {for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

Modifications 102 and 106 as described in BFN-UNIT 3 Table S-2, shall be implemented no later Renewed License No. DPR-68 than August 14, 2019 and October 14, Amendment No. 286 2019, respectively.

-6f-(16) Radiological Consequences Analyses Using Alternative Source Terms TVA shall perform facility and licensing basis modifications to resolve the non-conforming/degraded condition associated with the Alternate Leakage Treatment pathway such that the current licensing basis dose calculations (approved in License Amendment Nos. 251/282 (Unit 1), 290/308 (Unit 2) and 249/267 (Unit 3}) would remain valid. These facility and licensing basis modifications shall be complete prior to initial power ascension above 3458 MWt.18-100 (17) Prior to extending the frequency for the Integral Leakage Rate Testing described in TS 5.5.12, the licensee shall implement the modifications, that are modeled in the Fire PRA and described in Table S-2, "Plant Modifications," of Tennessee Valley Authority letter CNL-17-024, dated June 7, 2017.

D. The UFSAR supplement, as revised, submitted pursuant toOctober 10 CFR 54.21(d},

18, 2018.

shall be included in the next scheduled update to the UFSAR required by 10 CFR 50. 71(e)(4} following the issuance of this renewed operating license.

Until that update is complete, TVA may make changes to the programs and activities described in the supplement without prior Commission approval, provided that TVA evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

E. The UFSAR supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. TVA shall complete these activities no later than July 2, 2016, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 283

Enclosure 1 Attachment 4 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Clean Typed Pages of BFN Units 1, 2, and 3 Renewed Facility Operating Licenses CNL-18-100

(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 request dated March 27, 2013, June 7, 2017, and October 18, 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 Evaluation dated October 28, 2015; December 19, 2017; October 9, 2018; and ((INSERT DATE SE)). 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.

(14) 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 Renewed License No. DPR-33 Amendment No. 000

-5b-

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

Transition License Conditions

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

2. With the exception of Modifications 102 and 106, the licensee shall implement modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. Modifications 102 and 106 as described in Table S-2, shall be implemented no later than August 14, 2019, and October 14, 2019, respectively. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete implementation items 09, 32, 33, and the second part of Implementation Item 47 as listed in Table S-3, Implementation Items, of TVA letter CNL-17-130 dated October 23, 2017. Implementation Item 09 shall be completed by June 29, 2018. Implementation Items 32, 33, and the second part of Implementation Item 47, i.e., resolving Finding level Facts and Observations, are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

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

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

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

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

-6e-(h) The results of the visual inspections of the steam dryer shall be submitted to the NRC staff in a report in accordance with 10 CFR 50.4. The report shall be submitted to the NRC within 90 days following startup from each of the first two respective refueling outages.

(i) Within 6 months following completion of the second refueling outage, after the implementation of the EPU, the licensee shall submit a long-term steam dryer inspection plan based on industry operating experience along with the baseline inspection results.

The license condition described above shall expire: (1) upon satisfaction of the requirements in items (g) and (h), provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw(s) or unacceptable flaw growth that is due to fatigue, and; (2) upon satisfaction of the requirements specified in item (i).

(19) Neutron Absorber Monitoring Program The licensee shall, at least once every ten years, withdraw a neutron absorber coupon from the spent fuel pool and perform Boron-10 (B-10) areal density measurement on the coupon. Based on the results of the B-10 areal density measurement, the licensee shall perform any technical evaluations that may be necessary and take appropriate actions using relevant regulatory and licensing processes.

(20)

(20) Radiological Consequences Analyses Using Alternative Source Terms TVA shall perform facility and licensing basis modifications to resolve the non-conforming/degraded condition associated with the Alternate Leakage Treatment pathway such that the current licensing basis dose calculations (approved in License Amendment Nos. 251/282 (Unit 1), 290/308 (Unit 2) and 249/267 (Unit 3)) would remain valid. These facility and licensing basis modifications shall be complete prior to initial power ascension above 3458 MWt.

(21) Prior to extending the frequency for the Integral Leakage Rate Testing described in TS 5.5.12, the licensee shall implement the modifications, that are modeled in the Fire PRA and described in Table S-2, Plant Modifications," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018.

0. The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), shall be included in the next scheduled update to the UFSAR required by 10 CFR 50.71(e)(4) following the issuance of this renewed operating license. Until that update is complete, TVA may make changes to the programs and activities described in the supplement without prior Commission approval, provided that TVA evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

E. The UFSAR supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. TVA shall complete these activities no later than December 20, 2013, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No.

(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 request dated March 27, 2013; June 7, 2017; and October 18, 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 21, 2015; December 19, 2017; October 9, 2018; and ((INSERT DATE SE)). 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.

(15) 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 Renewed License No. DPR-52 Amendment No. 000

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

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

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

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

Transition License Conditions

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

2. With the exception of Modifications 102 and 106, the licensee shall implement modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. Modifications 102 and 106 as described in Table S-2, shall be implemented no later than August 14, 2019, and October 14, 2019, respectively. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

3. The licensee shall complete Implementation Items 09, 32, 33, and the second part of Implementation Items 47 as listed in Table S-3, Implementation Items, of TVA letter CNL-17-130 dated October 23, 2017. Implementation Item 09 shall be completed by June 29, 2018. Implementation Items 32, 33, and the second part of Implementation Item 47, i.e., resolving Finding level Facts and Observations, are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.

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

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

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

-6e-(h) The results of the visual inspections of the steam dryer shall be submitted to the NRG staff in a report in accordance with 10 CFR 50.4. The report shall be submitted to the NRG within 90 days fallowing startup from each of the first two respective refueling outages.

(i) Within 6 months following completion of the second refueling outage, after the implementation of the EPU, the licensee shall submit a long-term steam dryer inspection plan based on industry operating experience along with the baseline inspection results.

The license condition described above shall expire: (1) upon satisfaction of the requirements in items (g) and (h), provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw(s) or unacceptable flaw growth that is due to fatigue, and; (2) upon satisfaction of the requirements specified in Item (i}.

( 19} Neutron Absorber Monitoring Program The licensee shall, at least once every ten years, withdraw a neutron absorber coupon from the spent fuel pool and perform Boron-10 (B-10) areal density measurement on the coupon. Based on the results of the B-10 areal density measurement, the licensee shall perform any technical evaluations that may be necessary and take appropriate actions using relevant regulatory and licensing processes.

(20} Radiological Consequences Analyses Using Alternative Source Terms TVA shall perform facility and licensing basis modifications to resolve the non-conforming/degraded condition associated with the Alternate Leakage Treatment pathway such that the current licensing basis dose calculations (approved in License Amendment Nos. 251/282 (Unit 1), 290/308 (Unit 2) and 249/267 (Unit 3)) would remain valid.

These facility and licensing basis modifications shall be complete prior to initial power ascension above 3458 MWt.

(21) Prior to extending the frequency for the Integral Leakage Rate Testing described in TS 5.5.12, the licensee shall implement the modifications, that are modeled in the Fire PRA and described in Table S-2, "Plant Modifications," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018.

D. The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d),

shall be included in the next scheduled update to the UFSAR required by 10 CFR 50.71(e)(4) following the issuance of this renewed operating license.

Until that update is complete, TVA may make changes to the programs and activities described in the supplement without prior Commission approval, provided that TVA evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

E. The UFSAR supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. TVA shall complete these activities no later than June 28, 2014, and shall notify the NRG in writing when implementation of these activities is complete and can be verified by NRG inspection.

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

(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 October 18, 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; October 9, 2018; and ((INSERT DATE SE)). Except where NRC approval for changes or deviations is required by10 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.

-4b-The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3 elements are acceptable because the alternative is adequate for the hazard. Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The four specific sections of NFPA 805, Chapter 3, are as follows:

• Fire Alarm and Detection Systems (Section 3.8);

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

• Gaseous Fire Suppression Systems (Section 3.10); and

• Passive Fire Protection Features (Section 3.11).

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

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

Transition License Conditions

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

2. With the exception of Modifications 102 and 106, the licensee shall implement modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. Modifications 102 and 106 as described in Table S-2, shall be implemented no later than August 14, 2019, and October 14, 2019, respectively. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 000

-6f-(16) Radiological Consequences Analyses Using Alternative Source Terms TVA shall perform facility and licensing basis modifications to resolve the non-conforming/degraded condition associated with the Alternate Leakage Treatment pathway such that the current licensing basis dose calculations (approved in License Amendment Nos. 251/282 (Unit 1), 290/308 (Unit 2) and 249/267 (Unit 3}) would remain valid. These facility and licensing basis modifications shall be complete prior to initial power ascension above 3458 MWt.

(17) Prior to extending the frequency for the Integral Leakage Rate Testing described in TS 5.5.12, the licensee shall implement the modifications, that are modeled in the Fire PRA and described in Table S-2, "Plant Modifications," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018.

D. The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d},

shall be included in the next scheduled update to the UFSAR required by 10 CFR 50. 71(e)(4} following the issuance of this renewed operating license.

Until that update is complete, TVA may make changes to the programs and activities described in the supplement without prior Commission approval, provided that TVA evaluates such changes pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

E. The UFSAR supplement, as revised, describes certain future activities to be completed prior to the period of extended operation. TVA shall complete these activities no later than July 2, 2016, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

BFN-UNIT 3 Renewed License No. DPR-68 Amendment No.

Enclosure 1 Attachment 5 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Attachment A, Table B-1 Markup CNL-18-100

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 MDQ099920110004 Rev. 1 [Section 5.7.1.1] - NFPA-15 Code Compliance Evaluation - 2001 Edition 3.9.6 [Fire Suppression System 3.9.6 Complies Valves controlling water-based fire suppression systems are supervised; Valve Supervision] All valves controlling water-based fire suppression systems required to see Section 3.5.14 for discussion.

meet the performance or deterministic requirements of Chapter 4 shall be supervised as described in 3.5.14.

3.10 Gaseous Fire Suppression N/A N/A Section Heading.

Systems.

3.10.1 [Gaseous Suppression 3.10.1 Complies General requirements. The requirements of this Section are addressed in System Code Requirements] If an automatic total flooding and local application gaseous fire Sections 3.10.1(1) through 3.10.1(3).

suppression system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be designed and installed in accordance with the following applicable NFPA codes:

3.10.1 [Gaseous Suppression 3.10.1 (1) NFPA 12, Standard on Carbon Dioxide Extinguishing Systems Complies with Carbon dioxide extinguishing systems at BFN are evaluated to be in System Code Requirements] Use of EEEEs compliance with NFPA 12 - 1966 Edition as shown in the referenced Code (1) Compliance Evaluation.

See Table C-2 of the LAR for required systems.

Item for Implementation:

Corrective actions were identified in the Code Compliance Evaluation.

These corrective actions are identified in Modification 85 in Table S-2 of Attachment S and Implementation Item 22 in Table S-3 of Attachment S.

References Document ID MDQ099920100004 Rev. 0 [All] - NFPA-12 Code Compliance Evaluation 3.10.1 [Gaseous Suppression 3.10.1 (2) NFPA 12A, Standard on Halon 1301 Fire Extinguishing N/A There are no credited Halon 1301 fire extinguishing systems used at BFN.

System Code Requirements] Systems (2) 3.10.1 [Gaseous Suppression 3.10.1 (3) NFPA 2001, Standard on Clean Agent Fire Extinguishing N/A There are no clean agent fire extinguishing systems used at BFN.

System Code Requirements] Systems (3) 3.10.2 [Gaseous Suppression 3.10.2 Complies Pressurization of the CO2 discharge piping downstream of each local System Alarm Location] Operation of gaseous fire suppression systems shall annunciate and hazard valve (which is an indication of system operation) is annunciated at alarm in the control room or other constantly attended location identified. the CFAS in the control room.

References Document ID 0-FPR-VOLUME 1/PART 1 Rev. 14 [Section 4.4.4] - Fire Protection Plan BFN-50-7039 Rev. 4 [Section 3.5.1] - CO2 Storage, Fire Protection, and Purging System Fire Safety Analysis Data Manager (4.129) TVA Browns Ferry Run: 03/23/2013 10:31 Page: 46 of 55 BFN Units 1, 2, and 3 NFPA 805 Transition Report, Page 122 of 1661

Enclosure 1 Attachment 6 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Attachment A, Table B-1 Clean Copy CNL-18-100

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 MDQ099920110004 Rev. 1 [Section 5.7.1.1] - NFPA-15 Code Compliance Evaluation - 2001 Edition 3.9.6 [Fire Suppression System 3.9.6 Complies Valves controlling water-based fire suppression systems are supervised; Valve Supervision] All valves controlling water-based fire suppression systems required to see Section 3.5.14 for discussion.

meet the performance or deterministic requirements of Chapter 4 shall be supervised as described in 3.5.14.

3.10 Gaseous Fire Suppression N/A N/A Section Heading.

Systems.

3.10.1 [Gaseous Suppression 3.10.1 Complies General requirements. The requirements of this Section are addressed in System Code Requirements] If an automatic total flooding and local application gaseous fire Sections 3.10.1(1) through 3.10.1(3).

suppression system is required to meet the performance or deterministic requirements of Chapter 4, then the system shall be designed and installed in accordance with the following applicable NFPA codes:

3.10.1 [Gaseous Suppression 3.10.1 (1) NFPA 12, Standard on Carbon Dioxide Extinguishing Systems Complies with Carbon dioxide extinguishing systems at BFN are evaluated to be in System Code Requirements] Use of EEEEs compliance with NFPA 12 - 1966 Edition as shown in the referenced Code (1) Compliance Evaluation.

See Table C-2 of the LAR for required systems.

Item for Implementation:

Corrective actions were identified in the Code Compliance Evaluation.

These corrective actions are identified in Implementation Item 22 in Table S-3 of Attachment S.

References Document ID MDQ099920100004 Rev. 0 [All] - NFPA-12 Code Compliance Evaluation 3.10.1 [Gaseous Suppression 3.10.1 (2) NFPA 12A, Standard on Halon 1301 Fire Extinguishing N/A There are no credited Halon 1301 fire extinguishing systems used at BFN.

System Code Requirements] Systems (2) 3.10.1 [Gaseous Suppression 3.10.1 (3) NFPA 2001, Standard on Clean Agent Fire Extinguishing N/A There are no clean agent fire extinguishing systems used at BFN.

System Code Requirements] Systems (3) 3.10.2 [Gaseous Suppression 3.10.2 Complies Pressurization of the CO2 discharge piping downstream of each local System Alarm Location] Operation of gaseous fire suppression systems shall annunciate and hazard valve (which is an indication of system operation) is annunciated at alarm in the control room or other constantly attended location identified. the CFAS in the control room.

References Document ID 0-FPR-VOLUME 1/PART 1 Rev. 14 [Section 4.4.4] - Fire Protection Plan BFN-50-7039 Rev. 4 [Section 3.5.1] - CO2 Storage, Fire Protection, and Purging System Fire Safety Analysis Data Manager (4.129) TVA Browns Ferry Page: 46 of 55 BFN Units 1, 2, and 3 NFPA 805 Transition Report, Page 122 of 1661