ML19037A137

Revisions to Modifications 85, 102 and 106 Related to National Fire Protection Association 805 Performance-based Standard for Fire Protection of Light Water Reactor Electric Generating Plants

ML19037A137
Person / Time
Site:	Browns Ferry
Issue date:	04/02/2019
From:	Farideh Saba Plant Licensing Branch II
To:	James Shea Tennessee Valley Authority
Saba F DORL/LPL2-2 301-415-1447
References
EPID L-2018-LLA-0285
Download: ML19037A137 (43)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Joseph W. Shea Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A Chattanooga, TN 37402-2801 April 2, 2019

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2 AND 3 - ISSUANCE OF AMENDMENTS TO REVISE MODIFICATIONS 85, 102, AND 106 RELATED TO NATIONAL FIRE PROTECTION ASSOCIATION 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION OF LIGHT WATER REACTOR ELECTRIC GENERATING PLANTS (EPID NO. L-2018-LLA-0285)

Dear Mr. Shea:

The U.S. Nuclear Regulatory Commission (NRC and the Commission) has issued Amendment Nos. 307, 330, and 290 to Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant (Browns Ferry), Units 1, 2, and 3, respectively.

These amendments are in response to Tennessee Valley Authority" (TVA) license amendment request dated October 18, 2018, as supplemented by letters dated February 13 and March 8, 2019. The amendments revise license conditions in the Browns Ferry, Units 1, 2, and 3 Renewed Facility Operating Licenses associated with TVA's fire protection program, which is authorized under Title 10 of the Code of Federal Regulations Section 50.48(c), "National Fire Protection Association Standard NFPA 805." The license conditions incorporate changes to Table S-2, "Plant Modifications Committed," of TVA letter dated October 16, 2018, as supplemented by letters dated February 13 and 8, 2019. TVA changed Table S-2, by deleting Modification 85 (install pneumatic pre-discharge alarms and time delays in certain carbon dioxide fire protection systems), and by extending the due date for Modification 102 (modify the actuation circuitry for certain transformer fire protection water spray systems) and Modification 106 (provide an additional water supply for the cooling tower lift pump bearing lubrication water system).

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

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

Enclosures:

1.

• Amendment No. 307 to DPR-33

2. Amendment No. 330 to DPR-52

3. Amendment No. 290 to DPR-68

4. Safety Evaluation cc: Listserv Sincerely,

/m*LJ &~~

Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 307 Renewed License No. DPR-33

1.

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

A.

The application for amendment by Tennessee Valley Authority (the licensee) dated October 18, 2018, as supplemented by letters dated February 13 and March 8, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

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

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

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

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

2.

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

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

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 307, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

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

(13)

TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; 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; October 23, 2017; February 13, 2019; and March 8, 2019, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; October 9, 2018; and April 2, 2019. 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.

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

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 Committed," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as.

supplemented by letter CNL-19-027, dated February 13, 2019, 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.

Paragraph 2.C.(21) of Renewed Facility Operating License No. DPR-33 is hereby amended to read as follows:

(21)

Prior to extending the frequency for ttie 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 Committed, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019.

3.

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

Attachment:

Changes to the Renewed Facility Operating License DPR-33 FOR THE NUCLEAR REGULATORY COMMISSION

~

Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: Apv i l 2, 2 O 1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 307 BROWNS FERRY NUCLEAR PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-33 DOCKET NO. 50-259 Replace the following pages of Renewed Facility Operating License No. DPR-33 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of changes.

REMOVE 3

5 Sb 6e INSERT 3

5 Sb 6e (3)

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

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

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

C.

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

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

( 1)

(2)

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

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 307, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

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

Renewed License No. DPR-33 Amendment No. 307 (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 1 O CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.

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

(12)

Deleted.

(13)

TVA Browns Ferry Nuclear Plant shall implement and maintain in effect BFN-UNIT 1 all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; 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; October 23, 2017; February 13, 2019; and March 8, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; October 9, 2018; and April 2, 2019. 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 dem*onstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the Renewed License No. DPR-33 Amendment No. 307

-5b-

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 Committed," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019, 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 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. 307

-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-1O(B-10) areal density measurement on the coupon. Based on the results of the B-1 O 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 3,458 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 Committed, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019.

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 1 O 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. 307

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-260 BROWNS FERRY NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 330 Renewed License No. DPR-52

1.

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

A.

The application for amendment by Tennessee Valley Authority (the licensee) dated October 18, 2018, as supplemented by letters dated February 13 and March 8, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

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

C.

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

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

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

2.

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

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

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 330, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

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

(14)

TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; and May 3, 2018, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14, 2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; September 18, 2017; October 23, 2017; February 13, 2019; and March 8, 2019, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; and October 9, 2018; and April 2, 2019. 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.

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

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 Committed," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019, 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.

Paragraph 2.C.(21) of Renewed Facility Operating License No. DPR-52 is hereby amended to read as follows:

(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 Committed, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019.

3.

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

Attachment:

Changes to the Renewed Facility Operating License DPR-52 FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: April 2, 201 9

ATTACHMENT TO LICENSE AMENDMENT NO. 330 BROWNS FERRY NUCLEAR PLANT, UNIT 2 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-52 DOCKET NO. 50-260 Replace the following pages of Renewed Facility Operating License No. DPR-52 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas ofchanges.

REMOVE 3

5 5b 6e INSERT 3

5 5b 6e sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

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

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

C.

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

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

( 1)

(2)

(3)

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

Technical Specifications The Technical Specifications contained in Appendices A and 8, as revised through Amendment No. 330, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

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

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

Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's Renewed License No. DPR-52 Amendment No. 330 (8)

Deleted.

(9)

Deleted.

(10)

Deleted.

(11 )(a) The licensee shall fully implement and maintain in effect all provisions of the commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.

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

(12)

Deleted.

(13)

Deleted.

(14)

TVA Browns Ferry Nuclear Plant shall implement and maintain in effect BFN-UNIT 2 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; October 23, 2017; February 13, 2019; and March 8, 2019, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; October 9, 2018, and April 2, 2019. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be Renewed License No. DPR-52 Amendment No. 330

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

Gaseous Fire Suppression Systems (Section 3.1 O); 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.

2.

3.

(15)

(16)

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.

With the exception of Modifications 102 and 106, the licensee shall implement modifications to its facility, as described in Table S-2, "Plant Modifications Committed," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019, 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.

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.

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).

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. 330

-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 3,458 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 Committed, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019.

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 NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.

BFN-UNIT 2 Renewed License No. DPR-52 Amendment No. 330

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-296 BROWNS FERRY NUCLEAR PLANT, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 290 Renewed License No. DPR-68

1.

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

A.

The application for amendment by Tennessee Valley Authority (the licensee) dated October 18, 2018, as supplemented by letters dated February 13 and March 8, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

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

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

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

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

2.

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

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

(2)

Technical Specifications The Technical Specifications contained in Appendices A and 8, as revised through Amendment No. 290, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

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

(7)

TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013; June 7, 2017; 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; October 23, 2017; February 13, 2019; and March 8, 2019, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; October 9, 2018, and April 2, 2019. Except where NRG 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 NRG 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.

Paragraph 2.C.(7), Item 2 under "Transition License Condition" of Renewed Facility Operating License No. DPR-68 is hereby amended to read as follows:

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; as supplemented by letter CNL-19-027, dated February 13, 2019, 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.

Paragraph 2.C.(17) of Renewed Facility Operating License No. DPR-52 is hereby amended to read as follows:

(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 Committed, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019.

3.

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

Attachment:

Changes to the Renewed Facility Operating License DPR-68 FOR THE NUCLEAR REGULATORY COMMISSION u~~

Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:

April 2, 201 9

ATTACHMENT TO LICENSE AMENDMENT NO. 290 BROWNS FERRY NUCLEAR PLANT, UNIT 3 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-68 DOCKET NO. 50-296 Replace the following pages of Renewed Facility Operating License No. DPR-68 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of changes.

REMOVE 3

4 4b 6f INSERT 3

4 4b 6f (3)

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

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

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

C.

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

(1)

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

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 290, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

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

Renewed License No. DPR-68 Amendment No. 290 (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; 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; October 23, 2017; February 13, 2019; and March 8, 2019, as approved in the Safety Evaluations dated October 28, 2015; December 19, 2017; October 9, 2018, and April 2, 2019. 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. 290

-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 Committed," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019, 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 measures in place until completion of these modifications.

BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 290

-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 3,458 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 Committed, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019.

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. 290

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 307 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-33 AMENDMENT NO. 330 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-52 AND AMENDMENT NO. 290 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-68 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296

1.0 INTRODUCTION

By letter dated October 18, 2018 (Reference 1 ), as supplemented by letters dated February 13, 2019 (Reference 2); and March 8, 2019 (Reference 3), Tennessee Valley Authority (TVA, the licensee) submitted a license amendment request (LAR) regarding the Browns Ferry Nuclear Plant (Browns Ferry or BFN) Units 1, 2, and 3, requesting a change to the Browns Ferry's approved fire protection program (FPP). The amendments revise license conditions in the Browns Ferry, Units 1, 2, and 3 Renewed Facility Operating Licenses (RFOLs) associated with TVA's FPP, which is authorized under Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.48(c), "National Fire Protection Association [NFPA] Standard NFPA 805." The license conditions incorporate Table S-2, "Plant Modifications Committed," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; and as supplemented by letter CNL-19-027, dated February 13, 2019. TVA changed Table S-2 by deleting Modification 85 (install pneumatic pre-discharge alarms and time delays in certain carbon dioxide (CO2) fire protection systems), and by extending the due dates for Modification 102 (modify the actuation circuitry for certain transformer fire protection water spray systems) and Modification 106 (provide an additional water supply for the cooling tower lift pump bearing lubrication water system).

The supplements dated February 13 and March 8, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC or the Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on December 18, 2018 (83 FR 64897).

2.0

2.1 REGULATORY EVALUATION

Licensee's Proposed Changes In its LAR dated October 18, 2018, as supplemented by its letter dated February 13, 2019, the licensee proposed to modify its NFPA 805 FPP by deleting Modification 85 and extending the completion dates for Modifications 102 and 106, which are required to be completed per FPP Transition License Condition 2 of 2.C.(13), 2.C.(14), and 2.C.(7). As described in the LAR dated October 18, 2018 (Reference 1) Modification 85 is to install pneumatic pre-discharge alarms and pneumatic time delays in certain carbon dioxide (CO2) fire protection systems, Modification 102 is to modify the actuation circuitry for certain transformer fire protection water spray systems so they are supervised, and Modification 106 is to provide an additional water supply for the cooling tower lift pump bearing lubrication water system so it no longer has to rely on the fire protection water ~upply under certain conditions.

The licensee is proposing a revision to its FPP Transition License Condition 2 of 2.C.(13),

2.C.(14), and 2.C.(7), which currently state:

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 [icense Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.

The current FPP transition license condition wording requires the licensee to complete the NFPA 805 modifications before the end of the second refueling outage. The licensee is requesting to revise FPP transition license condition 2.C.(13), 2.C.(14), and 2.C.(7) for Browns Ferry Units 1, 2, and 3, respectively, to state (changes shown in bold):

With the exception of Modifications 102 and 106, the licensee shall implement modifications to its facility, as described in Table S-2, "Plant Modifications Committed," of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018; as supplemented by letter CNL-19-027, dated February 13, 2019, 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.

In addition, license conditions 2.C.(21 ), 2.C.(21 ), and 2.C.(17) in the Browns Ferry Units 1, 2, and 3 RFOLs associated with Integral Leakage Rate Testing will be revised to update the reference to the revised Table S-2 as a result of this LAR.

2.2 Regulatory Requirements The following regulations address fire protection:

Section 50.48, "Fire protection," of 10 CFR, provides the NRC requirements for nuclear power plant fire protection. The NRC regulations include specific requirements for requesting approval for a risk-informed and performance-based (RI/PB) FPP based on the provisions of NFPA 805.

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

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

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

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

of an application for license amendment under §50.90. The application must identify any orders and license conditions that must be revised or superseded, and contain any necessary revisions to the plant's technical specifications and the bases thereof. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the licensee has identified orders, license conditions, and the technical specifications that must be revised or superseded, and that any necessary revisions are adequate. Any approval by the Director or the designee must be in the form of a license amendment approving the use of NFPA 805 together with any necessary revisions to the technical specifications.

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

Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room.

The Browns Ferry units were designed and constructed based on the proposed GDC published by the Atomic Energy Commission (AEC) in the Federal Register (32 FR 10213) on July 11, 1967 (for Browns Ferry called "Criteria"). The AEC published the final rule that added Appendix A to 10 CFR part 50, GDC for Nuclear Power Plants, in the Federal Register (36 FR 3255) on February 20, 1971.

Differences between the draft GDC and final GDC included a consolidation from 70 to 64 criteria. As discussed in the NRC Staff Requirements Memorandum (SRM) for SECY 92-223, dated September 18, 1992 (Reference 11 ), the Commission decided not to apply the final GDC to plants with construction permits issued prior to May 21, 1971. At the time of promulgation of Appendix A to 1 O CFR part 50, the Commission stressed that the final GDC were not new requirements and were promulgated to more clearly articulate the licensing requirements and practice in effect at that time.

Each plant licensed before the final GDC were formally adopted was evaluated on a plant specific basis, determined to be safe, and licensed by the Commission.

Appendix A to Browns Ferry Updated Final Safety Analysis (Reference 12),

Criterion 3 - Fire Protection (Category A) states:

The reactor facility shall be designed (1) to minimize the probability of events such as fires and explosions and (2) to minimize the potential effects of such events to safety. Noncombustible and fire resistant materials shall be used whenever practical throughout the facility, particularly in areas containing critical portions of the facility such as containment, control room, and components of engineered safety features.

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

Pursuant to 10 CFR 50.92(a),' in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations, which govern the issuance of initial licenses to the extent applicable and appropriate. Under 10 CFR 50.40, common standards for issuance of licenses include considerations of safety and satisfaction of the requirements of the National Environmental Policy Act of 1969 as implemented in 10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." Under 1 O CFR 50.57(a), to issue an operating license, the Commission must find, among other things, that (1) there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public; (2) there is reasonable

. assurance that such activities will be conducted in compliance with the regulations in this chapter; and (3) the issuance of the license will not be inimical to the common defense and security or to the health and safety of the public. Additional findings required to issue amendments related to fire protection are provided in 10 CFR 50.48, as discussed below.

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

2.3 Applicable Codes, Standards, and Regulatory Guides Revision 1 of Regulatory Guide (RG) 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light Water Nuclear Power Plants," December 2009 (Reference 13),

provides guidance for use in complying with the requirements that the NRC has promulgated for RI/PB FPPs that comply with 10 CFR 50.48 and the referenced 2001 Edition of the NFPA standard. Revision 1 of RG 1.205 sets forth regulatory positions; emphasizes certain issues, clarifies the requirements of 10 CFR 50.48(c) and NFPA 805, clarifies the guidance in Nuclear Energy Institute (NEI) 04-02, Revision 2, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," April 2008 (Reference 14) and provides exceptions to the NEI 04-02 guidance where required. Should a conflict occur between NEI 04-02 and RG 1.205, the regulatory positions in RG 1.205 govern.

NEI 04-02, Revision 2, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c) (Reference 14), provides guidance for implementing the requirements of 10 CFR 50.48(c), and represents methods for implementing in whole or in part a RI/PB FPP. This implementing guidance for NFPA 805 has two primary purposes: (1) provide direction and clarification for adopting NFPA 805 as an acceptable approach to fire protection, consistent with 10 CFR 50.48(c); and (2) provide additional supplemental technical guidance and methods for using NFPA 805 and its appendices to demonstrate compliance with fire protection requirements. Although there is a significant amount of detail in NFPA 805 and its appendices, clarification and additional guidance for select issues help ensure consistency and effective utilization of the standard.

The NEI 04-02 guidance focuses attention on the RI/PB FPP goals, objectives, and performance criteria contained in NFPA 805 and the RI/PB tools considered acceptable for demonstrating compliance. Revision 2 of NEI 04-02 incorporates guidance from RG 1.205 and approved Frequently Asked Questions.

NFPA 12, 1966 and 2008 Editions, "Carbon Dioxide Extinguishing Systems" (Reference 15) and (Reference 16), provide requirements for carbon dioxide fire-extinguishing systems to help ensure that such equipment will function as intended throughout its life.

• NFPA 805, Section 1.8, "Code of Record," states that:

The codes and standards referenced in this standard refer to the edition of the code or standard in effect at the time the fire protection systems or feature was designed or specifically committed to the authority having jurisdiction.

NFPA 805, Section 3.10, "Gaseous Fire Suppression Systems," states in part, that:

If an automatic total flooding and local application gaseous fire 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:

o NFPA 12, Standard on Carbon Dioxide Extinguishing Systems Automatic total flooding carbon dioxide systems shall be equipped with an audible pre-discharge alarm and discharge delay sufficient to permit egress of personnel. The carbon dioxide system shall be provided with an odorizer.

o NFPA 12, 1966 Edition, states in part that:

Section 122, "Safety Requirements," In any proposed use of carbon dioxide where there is a possibility that men may be trapped in or enter into atmospheres made hazardous by a carbon dioxide discharge, suitable safeguards shall be provided to insure prompt evacuation of and to prevent entry into such atmospheres and also to provide means for prompt rescue of any trapped personnel. Such safety items as personnel training, warning signs, discharge alarms, pre-discharge alarms and breathing apparatus shall be considered.

Section 1452. An alarm should be provided to indicate the operation of automatic systems in case an immediate personnel response is desired.

Section 1453. Alarms should be provided to give positive warning of a discharge where hazard to personnel may exist. Such alarms should function to warn against personnel entry into hazardous areas as long as such hazards exist or until such hazards are properly recognized.

Section A-122, 3. Provisions of alarms within such areas that will operate

. immediately upon detection of the fire, with the discharge of the carbon dioxide and the activation of automatic door closures delayed for sufficient tirrie to evacuate the area before discharge begins.

NFPA 12, 2008 Edition, Section 1.3.3, states that:

The retroactive requirements of this standard shall be permitted to be modified if their application clearly would be impractical in the judgment of the authority having jurisdiction and only where it is clearly evident that a reasonable degree of safety is provided.

3.0 TECHNICAL EVALUATION

3.1 Change to Modification 85 in Table S-2 The licensee stated that modification 85 was to install pneumatic pre-discharge alarms and pneumatic time delays in carbon dioxide (CO2) systems to meet the retroactive life-safety requirements of NFPA 12 "Carbon Dioxide Extinguishing Systems," 2008 Edition (Reference 9), Section 4.5.6.1, "Pre-discharge Alarm and Time Delay." The licensee further stated that 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 licensee further stated that the NFPA 805 code compliance review performed in support of its original NFPA 805 LAR, Attachment A, "NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements," established that the Browns Ferry code of record is NFPA 12, 1966 Edition (Reference 8), 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 conservatively included in the compliance review.

3.1.1 Licensee's Technical Basis for Requested Change In its LAR, the licensee stated that it has encountered design difficulties related to interfacing modern equipment with its older system, which expanded the scope of the modification beyond what was originally envisioned. The licensee further concluded in the course of design development and review that it is not advisable to proceed with the modification. In a public meeting held on August 28, 2018 (Reference 10), the licensee indicated that the modification affects 20 separate control stations, will require a custom design and Underwriters Laboratories and seismic qualification of the systems will be difficult to maintain. The licensee also indicated that vendor qualification of the modification is uncertain.

The licensee stated that the CO2 fire suppression system is currently designed with an electrical pre-discharge time delay and alarm and that the system design is in compliance with NFPA 12 1966, which is the code of record for BFN. The licensee further stated that NFPA 12, 2008 Edition, introduced a new requirement in paragraph 4.5.6.1 for the pre-discharge time delay and alarm to be pneumatic, and that this paragraph was made retroactive by paragraph 1.3.4 and was, therefore, considered in the code compliance review performed in support of its original NFPA 805 LAR, Attachment A, "NEI 04-02 Table B-1 Transition of Fundamental Fire Protection Program & Design Elements." The licensee further stated that its review against the retroactive requirements resulted in the implementation items in the B-1 Table.

Th_e licensee stated that its CO2 control stations operate with electrical components and timers 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. The licensee further stated that NFPA 12, 2008 Edition and LAR Attachment S, Table S-2, 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 licensee stated that the purpose of the pre-discharge time delay and alarm is to allow time for personnel occupying the hazard area to safely evacuate. The licensee further stated that 10 CFR 50.48(c)(2)(i) and NEI 04-02, Revision 2, do not include life safety provisions as part of an NFPA 805 transition. The licensee stated that 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 and that the existing electrical components perform the same function and meet applicable NFPA code requirements with respect to system reliability.

The licensee stated that 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 and that 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 licensee further stated that the Main Control Room is not equipped with CO2 suppression and therefore, control room habitability and control room abandonment are not affected, and that Modification 85 is not credited in the fire probabilistic

• risk assessment (FPRA).

3.1.2 Safety Margins The licensee stated that with the elimination of Modification 85, the CO2 design maintains the codes and standards in its code of record and only affects life safety aspects of NFPA 12. The licensee further stated that elimination of Modification 85 does not affect the nuclear safety margin and does not involve any licensing basis analyses, and therefore, the safety margin inherent in the analyses for fire events has been preserved.

3.1.3 Defense-in-Depth The licensee stated that the three echelons of Defense-in-Depth (DID) are: (1) Prevent fires from starting (i.e., combustible/hot work controls); (2) Rapidly detect fires, control, and extinguish fires that do occur, thereby limiting fire damage (i.e., fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans); (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (i.e., fire barriers, fire rated cable, success path remains free of fire damage, recovery actions).

The licensee stated that the affected systems do not prevent fires from starting and are not used for plant shutdown and, therefore, the proposed changes do not affect echelons 1 or 3, and that Modification 85 is specific to fire suppression and detection systems. The proposed change is related to echelon 2. The licensee stated that Modification 85 only affects life safety aspects of the CO2 suppression system and does not impact the ability to detect and suppress a fire, and that 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 modification. The licensee further concluded that DID is maintained.

3.1.4 NRC Staff Evaluation In accordance with 10 CFR 50.48(c)(3)(i), the licensee submitted a LAR to revise its NFPA 805 license conditions 2.C.(13), 2.C.(14), and 2.C.(7). The NRC staff reviewed the information provided by the licensee in its LAR that included discussions of the impact of the proposed change on DID and safety margins. The NRC staff reviewed the applicable requirements of NFPA 805 Section 1.8 and 3.10; and NFPA 12, Section 1.3.3, and compared them to the licensee's proposed change to determine if the proposed change is being made in accordance with the applicable requirements.

NFPA 805, Section 1.8, "Code of Record," indicates that the codes and standards referenced in NFPA 805 refer to the edition of the code or standard in effect at the time the fire protection systems or feature was designed or specifically committed to the authority having jurisdiction.

Based on the information provided by the licensee in this LAR and in the original NFPA 805 LAR (Reference 11 ), the NRC staff determined that the code of record for CO2 systems at Browns Ferry is the 1966 Edition of NFPA 12.

NFPA 805, Section 3.10, "Gaseous Fire Suppression Systems," indicates that total flooding and local application CO2 systems required to meet the performance or deterministic requirements of NFPA 805 Chapter 4, shall be designed and installed in accordance with NFPA 12, and that automatic total flooding CO2 systems shall be equipped with an audible pre-discharge alarm and discharge delay sufficient to permit egress of personnel and shall also be provided with an odorizer. Based on the information provided by the licensee, the NRC staff determined that the edition of NFPA 12 referenced in Section 3.10 of NFPA 805 is the 1966 Edition, that the 1966 Edition is Browns Ferry's code of record for CO2 systems, and that the CO2 systems are equipped with audible pre-discharge alarms and discharge delays sufficient to permit egress of personnel and are provided with an odorizer.

NFPA 12, 2008 Edition, Section 1.3.3, indicates that the retroactive requirements of the 2008 Edition of NFPA 12, are permitted to be modified if their application clearly would be impractical in the judgment of the authority having jurisdiction and only where it is clearly evident that a reasonable degree of safety is provided. The NRC staff determined that the 2008 Edition of NFPA 12 is not applicable to Browns Ferry based on the requirements of NFPA 805. The NRC staff did determine that the licensee demonstrated that the changes originally proposed in Modification 85 are impractical due to the difficulties related to interfacing modern equipment with a much older system, and that a reasonable degree of safety continues to be provided even if Modification 85 is not completed because the licensee has demonstrated compliance with _NFPA 805, Section 3.10.

Regarding risk, DID, and Safety Margins, the NRC staff confirmed that the proposed change is not included in the FPRA and risk insights presented in the NFPA 805 LAR. The proposed change is based on compliance with the requirements of NFPA 805 Chapter 3, Section 3.10, and the fire protection program elements and minimum design requirements discussed in Chapter 3 are not subject to any performance-based methods permitted by NFPA 805.

Therefore, the NRC staff determined that NFPA 805, Section 4.2.4.2 concerning fire risk evaluations that require evaluations of risk, DID, and safety margins is not applicable.

3.2 Changes to Modifications 102 and 106 in Table S-2 In its LAR dated October 18, 2018, as supplement by its letter dated February 13, 2019, the licensee requested due date extensions for Modifications 102 and 106 to mitigate schedule risks from unforeseen circumstances. The licensee stated that it intends to complete these modifications by the original schedule of startup from the second refueling outage for each unit, which occurs with U2R20 [Unit 2 Refueling Outage 20] 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 licensee further indicated that these modifications are fire protection system upgrades to meet the requirements of NFPA 805, Sections 3.5 and 3.9 and are not credited in its FPRA, and therefore, they have no direcf impact on fire risk.

3.2.1 Licensee's Technical Bases for Requested Change In its LAR dated October 18, 2018, as supplemented by letter dated February 13, 2019, the licensee discussed its rationale for requesting an extension of the due date for Modifications 102 and 106.

The licensee stated that 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. The licensee further stated that Modification 102 is divided into 10 separate modification stages to cover five sets of transformers and the plant conditions required to implement the modifications, and that three of the modification stages require a unit outage. The licensee stated that one of the stages is complete, the remaining two are scheduled for the upcoming outages in fall 2018 (Browns Ferry Unit 1) and spring 2019 (Browns Ferry Unit 2), and that the remaining stages do not require a unit outage, but are subject to work restrictions during plant conditions requiring protection from offsite power, such as Emergency Diesel Generator allowable outage times.

The licensee stated that Modification 102 is currently in progress and is scheduled to be completed 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. An extension of 4 months, to August 14, 2019, is being requested in case there are unforeseen work delays.

The licensee stated that Modification 102 upgrades the fire detection and suppression features for the Main, USST, and CSST transformers to be supervised. The licensee further stated that the transformers are protected by a water deluge system that is initiated by heat detectors and transformer protective relays and that the current design is not supervised such that certain types of failures are not immediately detected and alarmed and would only be discovered during periodic testing. The licensee stated that the affected detection and suppression systems are not credited in the FPRA, and 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.

The licensee stated that Modification 106 installs a new water intake pumping station to supply bearing lubrication water to the cooling tower lift pumps. The licensee further stated that the Raw Service Water (RSW) and High-Pressure Fire Protection 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. The licensee stated that contractors have been selected to design and construct the new station and contracts are being finalized.

The licensee stated that it intends to complete Modification 106 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. The licensee is requesting an extension of 6 months, to October 14, 2019, to accommodate unforeseen delays such as delivery of equipment.

The licensee stated that 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 and that due to limited capability of the existing 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 licensee further stated that the goal of Modification 106 is to eliminate reliance on fire pumps for this routine operational purpose.

The licensee stated that fire pumps are not modeled in the FPRA but their availability and reliability is considered to support fire suppression and that they are not credited in the deterministic Nuclear Safety Capability Assessment to meet the nuclear safety goals. The licensee further stated that delaying completion of the modification until October 14, 2019, would have a negligible impact on Core Damage Frequency/Incremental Core Damage Probability and Large Early Release Frequency/Incremental Large Early Release Probability 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.

3.2.2 Safety Margins The licensee stated that Modifications 102 and 106 maintain codes and standards and that this LAR only involves implementation timeframes. The licensee further stated that the proposed changes associated with Modifications 102 and 106 do not involve any licensing basis analyses and therefore, the safety margin inherent in the analyses for fire events has been preserved.

3.2.3 Defense-in-Depth The licensee stated that the three echelons of DID are: (1) Prevent fires from starting (i.e.,

combustible/hot work controls); (2) Rapidly detect fires, control, and extinguish fires that do occur, thereby limiting fire damage (i.e., fire detection systems, automatic fire suppression, manual fire suppression, pre-fire plans); and (3) Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed (i.e., fire barriers, fire rated cable, success path remains free of fire damage, recovery actions).

The licensee stated that the affected systems do not prevent fires from starting and are not used for plant shutdown and therefore, these changes do not affect echelons 1 or 3. The licensee further stated that Modifications 102 and 106 are specific to fire suppression and detection systems, and therefore, the proposed changes are related to echelon 2. The licensee stated that the fire pumps and the transformer detection and suppression systems are capable of detecting and suppressing fires as they are currently designed, and that the affected fire protection systems remain capable of detecting, controlling and extinguishing fires without Mc;,difications 102 and 106, and therefore, DID is maintained.

3.2.4

NRC Staff Evaluation

In accordance with 10 CFR 50.48(c)(3)(i), the licensee submitted a LAR to revise its NFPA 805 license conditions 2.C.(13), 2.C.(14), and 2.C.(7). The NRC staff reviewed the information provided in the LAR and also 10 CFR 50.48(c) and RG 1.205, Section 2.1 to determine if the licensee's proposed changes to extend the due dates for Modifications 102 and 106 are acceptable.

The NRC staff found that 10 CFR 50.48(c) does not mandate a specific schedule for implementing a FPP that meets NFPA 805. However, the NRC staff noted that the statement of considerations for 10 CFR 50.48(c) states that the NFPA 805 license amendment will include a license condition imposing the use of NFPA 805, together with an implementation schedule.

The NRC staff also found that RG 1.205 provides guidance that states that licensees should include an implementation schedule with their request to adopt a FPP based on NFPA 805.

The NRC staff found that RG 1.205 includes guidance that states for changes that involve acceptance of an existing unapproved condition (i.e., a noncompliance), appropriate compensatory measures should be established and should remain in place until either the plant is modified to achieve compliance or the condition is found acceptable. RG 1.205 includes additional guidance that states that acceptance of the as-found condition may be the result of either the NRC's review and approval, or the self-approval process, according to the licensee's fire protection license condition.

The NRC staff found that the sample license condition in RG 1.205 states, in part, that the licensee shall maintain appropriate compensatory measures in place until completion of the modifications....

Although the licensee included discussions regarding risk, DID, and safety margins in its LAR, the NRC staff determined that 10 CFR 50.48(c) does not mandate any specific requirements for the schedule that implements a FPP that meets NFPA 805, and therefore the requirements of NFPA 805, Section 4.2.4.2 concerning fire risk evaluations that require evaluations of risk, DID, and safety margins is not applicable.

The NRC staff determined that 4-and 6-month extensions to complete Modifications 102 and 106 is acceptable because the license amendments will continue to include a license condition imposing the use of NFPA 805, together with an implementation schedule that follows the guidance of RG 1.205. The fire protection transition license conditions will remain in effect during this period, including maintaining compensatory measures until all the NFPA 805 modifications are completed, which follows the guidance of RG 1.205.

3.3 Changes to the Integral Leakage Rate Testing License Conditions In addition, the licensee proposed to revise License Conditions 2.C.(21 ), 2.C.(21 ), and 2.C.(17) for the Browns Ferry, Units 1, 2, and 3, respectively, related to the Integral Leakage Rate Testing (ILRT} approved-amendments, which were issued on September 27, 2018 (Reference 18). The licensee proposed to revise the ILRT license conditions as follows:

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 Committed, of Tennessee Valley Authority letter CNL-18-100, dated October 18, 2018, as supplemented by letter CNL-19-027, dated February 13, 2019.

By way of background, the ILRT amendments revised Technical Specification 5.5.12, "Primary Containment Leakage Rate Testing Program," by adopting Nuclear Energy Institute 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 Part 50, Appendix J," as the implementation document for the performance-based Option B of 10 CFR Part 50, Appendix J. The ILRT amendments allowed the licensee to extend the Type A containment integrated leak rate testing interval from 10 years to 15 years, and the Type C local leakage rate testing intervals from 60 months to 75 months. Because the PRA analysis to support the ILRT request assumed that modifications associated with NFPA 805 were complete, a license condition requiring that TVA complete modifications that are modeled in the Fire PRA and described in Table S-2, "Plant Modifications," [sic] of Tennessee Valley Authority letter CNL-17-024, dated June 7, 2017 before the ILRT was implemented was added to the license.

This license condition assured that the ILRT interval extension in the amendments would not be implemented before the NFPA modifications used to support the analysis were completed.

The LAR dated October 18, 2018 (Reference 1), as supplemented, proposed to revise the ILRT license conditions by referring to the update Table S-2, "Plant Modifications Committed," of TVA letter CNL-18-100, dated October 18, 2018, as supplemented by letter CNL 19-027, dated February 13, 2019. The licensee, in its letter dated October 18, 2018 (Reference 1), stated that "None of the above Modifications adversely affect the Browns Ferry Fire 'PRA. Therefore, the Fire PRA will remain unaffected by the approval of the requested proposed changes." Also, the licensee, in its letter dated March 8, 2019 (Reference 3), clarified that:

The references to Table S-2 were added by Reference 3 [Reference 5 in this SE], which approved transition of BFN Units 1, 2, and 3 to a fire protection program based on NFPA-805, and by Reference 4 [Reference 18 in this SE],

which approved changes to BFN's containment leakage rate testing program. In adding the reference to Table S-2, the latter approval required that the Table S-2 modifications modeled in the fire PRA be completed before TVA utilized the approval in Reference 4. The proposed changes requested in References 1 and 2 [References 1 and 2 in this SE] are related to modifications that are not modeled in the fire PRA and, therefore, do not impact the containment leakage rate testing program changes.approved in Reference 4.

The practical effect of the change to the license condition would appear at first glance to be allowing TVA to extend the frequency of the ILRT notwithstanding the status of Modification 85 (install pneumatic pre-discharge alarms and time delays in certain CO2 fire protection systems),

Modification 102 (Transformer water spray actuation systems are not fail safe or fully supervised as required by NFPA 15), and Modification 106 (When the RSW pumps and the water tanks are unable to maintain the pressure in the shared RSW and high pressure fire protection piping, a fore pump is activated to aid in maintaining pressure in the system). However, the ILRT license conditions only concern modifications "that are modeled in the Fire PRA and described in Table S-2" whereas as stated in the LAR and its supplements, Modifications 85, 102, and 106 were not modeled in the FPRA. In other words, under the existing license conditions, completion of Modifications 85, 102, and 106 is not required prior to extending the frequency for the ILRT. Under the amended license conditions, completion of these three modifications continues not to be a prerequisite. The change regarding updated Table S-2 to the license conditions therefore has no practical effect; the ILRT license conditions will continue to assure that the status of the NFPA modifications in Fire PRA would match the assumptions used in the ILRT amendments, and thereby provide the requisite reasonable assurance needed to issue the revised ILRT license conditions. Therefore, the NRC staff found the proposed changes to License Conditions 2.C.(21 ), 2.C.(21 ), and 2.C.(17) for the Browns Ferry, Units 1, 2, and 3, respectively, are acceptable.

3.4 Conclusion Based on its review of the information submitted by the licensee, and in accordance with 10 CFR 50.48(c)(3)(i), the NRC staff concludes that the proposed changes are adequate. The proposed change regarding Modification 85 is acceptable because the licensee demonstrated compliance with NFPA 805, Section 3.10. The proposed changes regarding Modifications 102 and 106 are acceptable because the transition license conditions will remain in effect as will the compensatory measures during the extension periods.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of Alabama official was notified of the proposed issuance of the amendments on February 22, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on December 18, 2018 (83 FR 64897). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

6.0 CONCLUSION

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

7.0 REFERENCES

1 TVA letter to the U.S. NRC, "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," October 18, 2018 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML18295A108).

2 TVA letter to U.S. NRC, "Supplement to 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, Units 1, 2,and 3 - Tables S-2 and B-1," February 13, 2019 (ADAMS Package Accession No. ML19044A707).

3 TVA letter to U.S. NRC, "Supplement 2 to 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, Units 1, 2,and 3 -

Tables S-2 and B-1," dated March, 2019 (ADAMS Accession No. ML19067A284).

4 TVA letter to the U.S. NRC, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition) (Technical Specification Change TS-480)," March 27, 2013 (ADAMS Accession No. ML13092A393).

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

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

7 TVA letter to the U.S. NRC, "Browns Ferry Nuclear Plant, Units 1, 2, & 3, RFOL Nos. DPR-33, DPR-52, and DPR-68, Docket Nos. 50-259, 50-260, and 50-296, Update to LAR to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reacor Electric Generating Plants," June 7, 2017 (ADAMS Accession No. ML171586285).

8 U.S. NRC letter to TVA, "Browns Ferry Nuclear Plant, Units 1, 2, & 3-Issuance Of Amendments To Revise NFPA 805 Performance-Based Standard For Fire Protection For Light Water Reactor Electric Generating Plants - Revision To Table S-2 & Table S-3,"

December 19, 2017 (ADAMS Accession No. ML17317A422).

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

10 U.S. NRC letter to TVA, "Browns Ferry Nuclear Plant, Units 1, 2, and 3-Issuance of Amendment Nos. 306, 329, and 289 to Revise Approved NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants-Revision to Attachment A, Table B-1," October 9, 2018 (ADAMS Accession No. ML18241A319).

11 SRM from Secretary to Executive Director for Operations (EDO), "SECY-92-223 -Resolution of Deviations Identified during the Systematic Evaluation Program," dated September 18, 1992 (ADAMS Accession No. ML003763736).

12 TVA letter to U.S. NRC, "Browns Ferry Nuclear Plant - Updated Final Safety Analysis Report, Amendment 27," dated October 5, 2017 (ADAMS Accession No. ML17286A079).

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

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

15 National Fire Protection Association, "Standard on Carbon Dioxide Extinguishing Systems,"

Standard 12, (NFPA 12) 1966 Edition, Quincy, Massachusetts.

16 National Fire Protection Association, "Standard on Carbon Dioxide Extinguishing Systems,"

Standard 12 (NFPA 12), 2008 Edition, Quincy, Massachusetts.

17 U.S. Nuclear Regulatory Commission, "Summary of August 28, 2018, Pre-Application Conference Call with Tennessee Valley Authority to Discuss Proposed Changes to Modifications Associated with Approved NFPA 805 For Browns Ferry Nuclear Plant Units 1, 2, and 3 (EPID L-2018-LRM-0053)," September 24, 2018 (ADAMS Accession No. ML18242A488).

18 U.S. NRC letter to TVA, "Browns Ferry Nuclear Plant, Units 1, 2, And 3 - Issuance of amendment Nos. 305, 328, And 288 to Revise Technical specification 5.5.12, "Primary Containment Leakage Rate Testing Program"," dated September 27, 2018 (ADAMS Accession No. ML18251A003).

Principal Contributors: Jay Robinson Shivani Mehta Date: April 2, 201 9

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2 AND 3 - REVISIONS TO MODIFICATIONS 85, 102, AND 106 RELATED TO NATIONAL FIRE PROTECTION ASSOCIATION 805 PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION OF LIGHT WATER REACTOR ELECTRIC GENERATING PLANTS (EPID NO. L-2018-LLA-0285)

DATED APRIL 2, 2019 DISTRIBUTION:

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