View source for CNL-17-109, Response to NRC Request for Additional Information for License Amendment Request to Revise Modifications and an Implementation Item Related to NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Genera

{{Adams
| number = ML17261B179
| issue date = 09/18/2017
| title = Response to NRC Request for Additional Information for License Amendment Request to Revise Modifications and an Implementation Item Related to NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generati
| author name = Shea J
| author affiliation = Tennessee Valley Authority
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000259, 05000260, 05000296
| license number = DPR-033, DPR-052, DPR-068
| contact person = 
| case reference number = CNL-17-109, TAC MF1185, TAC MF1186, TAC MF1187
| document type = Letter type:CNL, Response to Request for Additional Information (RAI)
| page count = 42
| project = TAC:MF1185, TAC:MF1186, TAC:MF1187
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-17-109 September 18, 2017 10 CFR 50.90 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

==Subject:==
Response to NRC Request for Additional Information for License Amendment Request to Revise Modifications and an Implementation Item Related to NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187) - Revision to Table S-3

==References:==
: 1. Letter from TVA to NRC, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition), (Technical Specification Change TS-480)," dated March 27, 2013 (ML13092A393)
: 2. Letter from TVA to NRC, CNL-15-074, "Update to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187)," dated June 19, 2015 (ML15174A149)
: 3. Letter from TVA to NRC, CNL-15-166, Update to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187), dated August 18, 2015 (ML15230A419)

U.S. Nuclear Regulatory Commission CNL-17-109 Page 2 September 18, 2017
: 4. Letter from TVA to NRC, CNL-15-191, Update to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187) - Revised Safe Shutdown Analysis Request for Additional Information 15, dated September 8, 2015 (ML15251A598)
: 5. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Issuance of Amendments Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c) (CAC Nos. MF1185, MF1186, and MF1187), dated October 28, 2015 (ML15212A796)
: 6. Letter from TVA to NRC, CNL-16-165, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 34, Revised Proposed License Conditions and Technical Specification Changes, dated October 31, 2016 (ML16305A370)
: 7. Letter from TVA to NRC, CNL-17-024, Update to License Amendment Request to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187) - Revision to Tables S-2 and S-3, dated June 7, 2017 (ML17158B285)
: 8. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Request for Additional Information Related to License Amendment Request to Revise Modifications and Implementation item Related to National Fire Protection Association 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (CAC Nos. MF9814, MF9815, and MF9816),
dated August 18, 2017 (ML17216A006)
By letter dated March 27, 2013 (Reference 1), Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, to transition to National Fire Protection Association Standard (NFPA) 805. By letter dated June 19, 2015 (Reference 2), TVA provided an update to Reference 1. By letter dated August 18, 2015 (Reference 3), TVA provided an update to information provided in Reference 2. By letter dated September 8, 2015 (Reference 4), TVA provided revised Tables S-2 and S-3 in their entirety.

U.S. Nuclear Regulatory Commission CNL-17-109 Page 3 September 18, 2017 The NRC issued a Safety Evaluation (SE) on October 28, 2015 (Reference 5) regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c). The SE included a statement that, The licensee shall implement the following modifications to its facility as described in Attachment S, Table S-2, Plant Modifications. Likewise, the SE also included a statement that, The licensee shall complete the implementation items as listed in Table S-3, Implementation Items.
During the implementation of modifications identified in the TVA NFPA 805 program, TVA determined that clarifications and revisions were required to certain NFPA 805 modifications (Reference 7). This letter identified one request to clarify and two requests to delete identified NFPA 805 changes. Two requested changes revise Table S-2, and one requested change revises Table S-3.
In Reference 8, NRC issued a request for additional information (RAI) based on information provided in Reference 7. Enclosure 1 of this letter provides TVAs response to that RAI.
Based on the TVA discussion with NRC on August 31, 2017, Implementation Item 09 regarding the requirement on the length of flexible conduit is restored to Attachment S, Table S-3, and a note is added to Table S-3 that is consistent with the request contained in Reference 7. In addition, as a result of the recent NRC approval of the BFN Extended Power Uprate (EPU) (Reference 6), Implementation Item 49 is being deleted from Attachment S, Table S-3.
The NRC approval of the BFN EPU also added a letter reference to NFPA 805 Transition License Condition 3 of the BFN Operating Licenses; the letter reference is no longer needed and as such, is being removed by this LAR. Also, as a result of the TVA discussion with NRC staff on August 31, 2017, a reference to the second part of Implementation Item 47 from Attachment S, Table S-3 is being included in the changes to the NFPA 805 Transition License Condition 3 of the BFN Operating Licenses.
The revised pages and clean typed pages of the BFN Operating Licenses are provided in Enclosures 2 and 3, respectively. The appropriate Operating License Conditions were modified for consistency with the above changes, and to add a reference to the original LAR (Reference 7), this letter, and a place holder for the revised safety evaluation. provides a revised Attachment S, Table S-3 in its entirety that replaces the previously submitted Table S-3.
TVA has determined that there are no changes to the significant hazards consideration associated with the proposed changes in Reference 7 and still qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).
Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and enclosures, to the Alabama State Department of Public Health.

Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to RAIs Probabilistic Risk Assessment (PRA)-Request for Addition Information (RAI) 01 In Enclosure 1 of the licensee's letter dated June 7, 2017, the licensee provided its basis for the proposed changes.
In Change Request 1, the licensee proposed to revise Table S-2 Plant Modifications 52a and 52b (PM-52a and b) to clarify the modification descriptions.
The licensee proposed to change PM-52a from: "For Drywell wide range pressure instruments P-64-160A and B, provide isolation of associated circuits and make appropriate power supply available such that both division instruments are not lost in the same fire scenario," to "Modify power supplies and associated circuits for drywell pressure indication instruments such that indication is available in the MCR [main control room] for all fire scenarios except those in Fire Area (FA) 16."
The licensee proposed to change PM-52b from: "Provide containment pressure indication on the Backup Control Panel," to "Provide isolation from circuits in FA 16 for containment pressure indication on the Backup Control Panel."
In Change Request 2, the licensee proposed to delete Plant Modification 84 (PM-
: 84) from Table S-2. Modification 84 reduced the time overcurrent setting (TOC) for breakers 1126, 1132, 1226, and 1232 in the offsite power circuits so that the breakers would trip prior to incurring any thermal damage. Thus, the modification would enable subsequent recovery actions to clear the spurious loads and reclose the off-site power breakers. Competing design elements were identified during the design process that limit the amount that the TOC settings could be reduced.
NFPA 805, Section 4.2.4.2, requires that the "use of fire risk evaluation for the PB [performance-based] approach shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, and safety margins."
In the risk impact discussion for the proposed Change Request 1, the licensee stated that "the final modification is expected to be equal to or better than the modification originally described in Table S-2 of the NFPA 805 LAR with respect to fire risk."
In the risk impact discussion for the proposed Change Request 2, the licensee calculated the change in risk and total risk for Units 1, 2, and 3. However, the licensee did not evaluate the change in risk from the compliant NFPA 805 PRA model, and thus did not establish that Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," Revision 2, (ADAMS Accession No. ML100910006), guidelines would have been met if the proposed configurations had been part of the NFPA 805 LAR upon which the NRC staff safety evaluation (SE) was based.
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Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to RAIs A. Provide the change in core damage frequency (CDF) and large early release frequency (LERF), and total CDF and LERF for Units 1, 2, and 3 with both Change Requests 1 and 2 integrated simultaneously into the PRA results for the transition plant.
(1) Calculate the change in risk using the compliant PRA model supporting the NFPA 805 SE, adjusted for Change Requests 1 and 2 as appropriate. Summarize any changes made to the compliant PRA model due to proposed Change Requests 1 and 2. Alternately, provide a justification for the choice of another compliant PRA model.
(2) Indicate how the risk from these plant changes compares with the guidelines in RG 1.174, Revision 2.
B. Confirm that Option A of the NRC letter to Nuclear Energy Institute (NEI),
         "Recommended Content for License Amendment Requests that Seek Changes to License Conditions that were Established in Amendments to Adopt National Fire Protection Association Standard 805, but Have Yet to be Fully Implemented," dated March 2, 2016 (ADAMS Accession No. ML16015A416), is still appropriate for this proposed LAR, given the new risk analysis to be performed. If not, provide the necessary information for Option B or C, whichever is appropriate.
TVA Response to PRA RAI 01:
BACKGROUND DISCUSSION of MODIFICATION 52 The objective of Modification 52 is to make at least one drywell pressure indication available in each fire scenario for the purpose of supporting operator actions to vent the containment using the Hardened Wetwell Vent (HWWV). Note that each Browns Ferry Nuclear Plant (BFN) unit has four instrument loops providing drywell pressure indication:
P-64-50, P-64-67B, P-64-160A and P-64-160B. There were three separate fire separation issues with the pre-transition plant design requiring modification and there are three separate modifications, Modifications 52a, 52b, and 52c to address them.
Modification 52a Drywell pressure loops P-64-160 A and B had common power supply/associated circuit issues resulting in numerous fire damage vulnerabilities. Modification 52a changed the power supply for these two loops on each unit as part of a Fukushima battery backed instrumentation modification, which resolved the associated circuit power supply failures for these loops. Modification 52a has been completed on all three BFN units (U1R11, U2R18, and U3R17).
CNL-17-109                                   E1 Page 2

Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to RAIs Modification 52b For fires in the control building, Fire Area (FA) 16, drywell pressure loop P-64-50, located at the Backup Control Panel, is credited to support use of the HWWV. However, drywell pressure loop P-64-50 was not properly isolated from cables and equipment located in FA 16. Modification 52b adds an isolator that prevents fire damage in FA 16 from affecting the indication on the Backup Control Panel. Modification 52b was implemented on BFN Units 1 and 2 (U1R11 and U2R19) and is scheduled to be implemented on BFN Unit 3 (U3R18) in Spring 2018.
Modification 52c Separation in the reactor buildings was not adequate to ensure one drywell pressure loop was available for each fire scenario in those fire areas. Modification 52c re-routes cables associated with loop P-64-160A within the reactor buildings to resolve this issue.
Modification 52c has been implemented on BFN Units 1 and 2 (U1R11 and U2R19) and is scheduled to be implemented on BFN Unit 3 (U3R18) in Spring 2018.
RESPONSE TO PART A.1 Post-Transition Plant CDF/LERF The post transition model that was utilized to calculate the fire CDF and LERF presented in Reference 1, Enclosure 1 was updated with the following changes:
: 1. The PRA fault tree was modified to correctly model the failure of shutdown busses and shutdown boards resulting from overload. The model used for the BFN NFPA 805 LAR was non-conservative in that the Fire PRA logic did not recognize that overload of a Unit 1/2 4.16kV Shutdown Board could result in an overload of the normally connected 4.16kV Shutdown Bus. As a result, the PRA model did not recognize that an overload condition on one shutdown board could also cause the loss of offsite power (OSP) to the second shutdown board supplied from the same shutdown bus. In order to quantify the risk worth of Modification 84, a corrected base model was created such that the loss of a shutdown board due to spurious overloading would cause the loss of the second shutdown board supplied from the same shutdown bus.
: 2. Credit for Modification 84 was removed from the model.
CNL-17-109                                   E1 Page 3

Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to RAIs
: 3. Modeling of the drywell pressure loops due to Modifications 52a, 52b, and 52c was as-constructed on BFN Units 1 and 2 and as-designed on BFN Unit 3 in cases where the modifications had not been implemented.
This model was used to calculate the post-transition fire risk values shown in Table 1 for changes to Modifications 52 and 84 combined.
Compliant Plant CDF/LERF The analysis performed for this RAI response utilizes the NFPA 805 final compliant plant risk results from Reference 1 in lieu of re-calculating the compliant plant CDF and LERF. The results of the compliant model by definition do not change based on the NFPA 805 modifications as explained in LAR Attachment W, Section W.2.1. Therefore, changes to how Modification 52 is modeled and removal of Modification 84 from the compliant model would not affect the results. The modeling corrections that were made to the post-transition model to properly evaluate the risk worth of Modification 84, explained above, would affect the compliant model results by making the compliant risk increase due to the failure of off-site power to the additional 4.16kV Shutdown Board. A larger compliant plant risk would result in a smaller post-transition delta risk comparison. Therefore, utilizing the compliant plant risk numbers, as previously submitted in Reference 1, is conservative in all cases with respect to compliance with RG 1.174 in that they yield a larger transition delta risk, which is appropriate for use in justifying the requested changes.
-Risk of Transition
-risk values were calculated using the same methodology used in the NFPA 805 LAR.
Deterministically compliant fire areas are not included in the total for each BFN unit. The post transition risk calculated with the corrected model is compared with the compliant plant risk calculated using the compliant model used for the NFPA 805 LAR, excluding fire areas that were deterministically compliant.
CNL-17-109                                   E1 Page 4

Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to RAIs TABLE 1
                                                    -Risk of Transition U1 CDF           U1 LERF         U2 CDF           U2 LERF           U3 CDF          U3 LERF Corrected Post 6.08E-05                      6.06E-06        6.68E-05         5.81E-06          6.12E-05        5.10E-06 Transition model with PM-84 and PM-52 changes included
* Corrected Post 5.94E-05                      5.92E-06        6.55E-05         5.70E-06          5.96E-05        4.98E-06 Transition model with PM-84 and PM-52 changes excluding deterministically compliant fire areas**
Compliant PRA 1.89E-04                       2.78E-05        1.67E-04         2.35E-05          1.80E-04        2.36E-05 model for NFPA 805 LAR Utilized in the NRC Safety Evaluation***
    -risk of                   -1.30E-04        -2.19E-05       -1.02E-04        -1.78E-05         -1.20E-04       -1.86E-05 transition
*These values differ slightly from those provided in Reference 3 due to differences in the base model used. The earlier model used for the Reference 3 calculation did not have PM-93 removed whereas values presented here were calculated using the base model from Reference 1 with PM-93 removed.
** Deterministically compliant fire areas are noted in LAR Attachment W, Tables W-8, W-9 and W-10 as follows:
Fire Area 24, 25-02, 25-03, and SWITCH for Unit 1 are deterministically compliant and, therefore, the delta CDF and LERF values are not applicable.
Fire Area 24, 25-02, 25-03, and SWITCH for Unit 2 are deterministically compliant and, therefore, the delta CDF and LERF values are not applicable.
Fire Area SWITCH for Unit 3 is deterministically compliant and, therefore, the delta CDF and LERF values are not applicable.
*** Compliant CDF/LERF values taken from Reference 1, Enclosure 1.
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Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to RAIs RESPONSE TO PART A.2 Based on the results in Table 1 the -risk of transition remains negative and meets the
-risk guidelines of RG 1.174. The total baseline fire plus internal events values shown in Table 2 remain within the guidelines provided in RG 1.174 for NRC consideration of the requested change.
Table 2 Total Risk U1 CDF      U1 LERF        U2 CDF       U2 LERF      U3 CDF     U3 LERF Internal Events /      6.93E-06    1.26E-06       6.29E-06     1.21E-06     7.72E-06   1.45E-06 Internal Flood External Floods /      1.00E-06    Negligible     1.00E-06    Negligible    1.00E-06   Negligible High Winds /
Tornadoes / Other Seismic                3.70E-06    Negligible     5.40E-06    Negligible    5.40E-06   Negligible Fire Including         6.08E-05    6.06E-06       6.68E-05     5.81E-06     6.12E-05   5.10E-06 PM-84 and PM-52 changes TOTAL                  7.24E-05    7.32E-06       7.95E-05     7.02E-06     7.53E-05   6.55E-06 RESPONSE to PART B Modifications 84, 52a, 52b, and 52c have been evaluated using the same PRA methods and approaches as summarized in the NRC Safety Evaluation (Reference 2) approving the BFN NFPA 805 LAR. Therefore use of Option A is appropriate.
CNL-17-109                                E1 Page 6

Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to RAIs PRA RAI 02 In the Defense-in-Depth/Safety Margin Discussion for the proposed change 1, the licensee stated that "the changes to drywell pressure instrumentation made available through PM-52 (a, b, and c) do not affect any defense-in-depth (DID) or Safety Margin."
NFPA 805, Section 4.2.4.2, requires that the "use of fire risk evaluation for the PB approach shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, and safety margins."
NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," Revision 2 (ADAMS Accession No. ML081130188), Section 5.3.5.3, "Safety Margins," lists two specific criteria that should be addressed when considering the impact of plant changes on safety margins:
* Codes and standards or their alternatives accepted for use by the NRC are met; and,
* Safety analysis acceptance criteria in the licensing basis (e.g., FSAR
[Final Safety Analysis Report], supporting analyses, etc.) are met, or provides sufficient margin to account for analysis and data uncertainty.
Based on the information provided by the licensee, the NRC is unable to complete its review because the application did not provide sufficient information regarding the acceptability of DID and safety margins for this proposed change. Provide the following:
A.      A discussion regarding DID that includes the basis for why the proposed changes do not impact each echelon of DID.
B.      A discussion of safety margins that includes the basis for why the proposed changes do not impact the safety margin criteria discussed in NEI 04-02.
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Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to RAIs TVA Response to PRA RAI 02:
A. Defense-in-Depth (DID)
The purpose of Modification 52 is to provide at least one drywell pressure instrument for each fire scenario. Drywell pressure indication is used to support operator actions to vent the containment using HWWV, serving as one of the options to achieve the Decay Heat Removal performance criteria. Drywell pressure indication and operation of the HWWV are not related to Echelon 1, preventing fires, or Echelon 2, detecting and extinguishing fires.
Drywell pressure indication is related to Echelon 3, providing adequate level of fire protection for structures, systems, and components important to safety; so that a fire that is not promptly extinguished will not prevent essential plant safety functions from being performed. If fires are not promptly extinguished, Modification 52 ensures, through separation and electrical isolation, that drywell pressure indication free of fire damage would be available should operation of the HWWV for decay heat removal be required. This change continues to provide an appropriate balance between the three echelons of DID.
B. Safety Margin The instruments affected by Modification 52 and the requested changes to Modifications 52a and 52b are classified as nuclear safety related and designed to applicable codes and standards. The Fire PRA utilized to evaluate changes to Modification 52, including fire modeling, applies the same methodologies and inherent safety margins that were utilized for the risk values provided in Reference 1. The evaluation of plant system performance related to the use of drywell pressure indication and operation of the HWWV was not changed. Therefore, safety margin, as discussed in NEI 04-02, is not affected by these changes.
PRA RAI 03 In the DID/Safety Margin Discussion for the proposed Change Request 2, the licensee stated that "non-implementation of PM-84 does not affect DID Echelons 2 or 3." No basis is cited for its conclusion with respect to Echelon 3, "Provide adequate level of fire protection for systems and structures so that a fire will not prevent essential safety functions from being performed," even though the removal of the PM-84 no longer prevents the failure of the offsite power supply to inventory makeup and decay heat removal systems for the fire-induced spurious operation cited in the discussion on this modification.
NFPA 805, Section 4.2.4.2, requires that the "use of fire risk evaluation for the PB approach shall consist of an integrated assessment of the acceptability of risk, defense-in-depth, and safety margins."
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Enclosure 1 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Response to RAIs Provide a justification that Echelon 3 of DID is still sufficiently robust after removal of modification, PM-84.
TVA Response to PRA RAI 03:
Deletion of PM-84 will no longer allow credit for Operator recovery of one success path that could have been used to recover Offsite Power to Shutdown Busses in scenarios involving fire induced overload. The Shutdown Busses would support core cooling and decay heat removal success criteria. Other modifications being installed, specifically the Emergency High Pressure Makeup Pump (PM-35) and the Hardened Wetwell Vent (PM-51 and PM-103), are capable of performing these functions and do not depend on recovery of OSP.
Additionally, other NFPA 805 modifications reduce the instances of spurious operation that contribute to Shutdown Bus overload, specifically removal of local control stations for 4kV equipment (PM-5, PM-28a and PM 28b). Therefore, Echelon 3 of DID remains sufficiently robust after removal of modification PM-84 to maintain a balance between the three Echelons.
References
: 1. Letter from TVA to NRC, CNL-15-166, Update to License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187), dated August 18, 2015 (ML15230A419)
: 2. Letter from NRC 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) (CAC Nos. MF1185, MF1186, and MF1187)," dated October 28, 2015 (ML15212A796)
: 3. Letter from TVA to NRC, CNL-17-024, Update to License Amendment Request to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187) - Revision to Tables S-2 and S-3, dated June 7, 2017 (ML17158B285)
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Enclosure 2 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Revised Operating License - Markup Pages CNL-17-109

(8)    Deleted.
(9)    Deleted.
(10)   Deleted.
(11 )(a) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:
                        "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(b) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 279, as amended by changes approved by License Amendment Nos. 286 and 297.
(12)   Deleted.
s                                      and June 7, 2017, (13)   TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50 48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated March 27, 2013, 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; s
  ; and September September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; 18, 2017              April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; and October 20, 2015, as approved in the Safety Evaluation dated October 28, 2015. Except where NRC approval for changes or deviations is required by 10 CFR 50 48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee
, and XXX               may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the BFN-UNIT 1                                                        Renewed License No. DPR-33 Amendment No. 297 CNL-17-109           Enclosure 2 Page 1 of 7

                                                               -Sb-
: 2. Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation dated October 28, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.
Transition License Conditions CNL-17-024 dated
: 1. Before achieving full compliance with 10 CFR 50.48(c), as specified      June 7,  by2017 (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)
NFPA 805 License above.                                                                              Amendment dated October 28, 2015.
: 2. The licensee shall implement the following modifications to its facility, as described in Table S-2, "Plant Modifications," of Tennessee Valley Authority letter CNL-17-109 dated          CNL-15-191, dated September 8, 2015, to complete the transition to full September 18, 2017.       compliance      with 10 CFR Implementation             32c) no later than the end of the second refueling 50.48(
Items outage  and 33, and the second issuance of the license amendment. The (for each unit) following licensee shall maintain appropriate compensatory measures in place until part of Implementation completion of these modifications.
Item 47
: 3. The licensee shall complete the implementation items as listed in Table S-3, "Implementation Items," of Tennessee Valley Authority letters CNL-15-191, dated September 8, 2015; and CNL-16-165, dated October 31, 2016, within 240 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.
(14)    The licensee shall maintain the Augmented          Quality ProgramItems Implementation         for the32Standby and 33, and Liquid Control System to provide quality control       elements    to ensure    component and the second part of Implementation reliability for the required alternative sourceItemterm 47,function  defined in i.e., resolving      the Updated Finding    level Final Safety Analyses Report (UFSAR).
Facts and Observations, (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. 299 CNL-17-109               Enclosure 2 Page 2 of 7

(8)    Deleted.
(9)    Deleted.
(10)     Deleted.
(11 )(a) The licensee shall fully implement and maintain in effect all provisions of the commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:
                       "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(b) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 306, as amended by changes approved by License Amendment Nos. 312 and 321.
(12)     Deleted.
(13)     Deleted.                              , and June 7, 2017 s
(14)     TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated March 27, 2013, 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,
; and September        2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 18, 2017               2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; and October 20, 2015, as approved in the Safety Evaluation dated October 28, 2015. Except where NRC approval for s  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
     , and XXX         change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be BFN UNIT 2                                                         Renewed License No. DPR-52 Amendment No. 321 CNL-17-109         Enclosure 2 Page 3 of 7

                                                          -5b-
* Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);
* Gaseous Fire Suppression Systems (Section 3.10); and
* Passive Fire Protection Features (Section 3.11 ) .
                           .This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
: 1. Fire Protection Program Changes that Have No More than Minimal Risk 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)
CNL-17-024 dated          below, risk-informed changes to the licensee's fire protection program may June 7, 2017              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.                                               NFPA 805 License Amendment dated
: 2.      The licensee shall implement the following modifications to its facility, as October    28, 2015.
described in Table S-2, "Plant Modifications," of Tennessee Valley Authority letter CNL-15-191, dated September 8, 2015, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the license Implementation Items       amendment. The licensee shall maintain appropriate compensatory 32 and 33, and the         measures in place until completion of these modifications.
second part of
: 3.      The licensee shall complete the implementation items as listed in Table S-3, Implementation Item 47     "Implementation Items," of Tennessee Valley Authority letters CNL-15-191, dated September 8, 2015; and CNL-16-165, dated October 31, 2016, within CNL-17-109 dated 240 days after issuance of the license amendment unless that date falls within a September 18, 2017.         scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage. Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.
Implementation Items 32 and 33, (15)   The licensee shall maintain the Augmented Quality Program for and and        the second the Standby        part of Liquid Control System to provide quality control elements to ensure    component reliability Implementation     Item 47,for i.e.,
the required alternative source term function defined in theresolving Updated Final  Safety Finding   level Facts and Analysis Report (UFSAR).                                     Observations, (16)   Upon complementation of Amendment No. 302, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3. 7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 2                                                   Renewed License No. DPR-52 Amendment No. 323 CNL-17-109                Enclosure 2 Page 4 of 7

(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, 1O 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.
s                                                              , and June 7, 2017, (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
                                                                                     ; and September amendment request dated March 27, 2013, as supplemented by letters dated May 16, 2013; December20, 2013; January 10, 2014; January      18, 14, 2017 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; s     August 18, 2015; September 8, 2015; and October 20, 2015, as approved in the Safety Evaluation dated October 28, 2015. 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                      , and XXX                     Renewed License No. DPR-68 Amendment No. 281 CNL-17-109       Enclosure 2 Page 5 of 7

                                            -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 NFPA 805 License (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the  Amendment change hasdated October been demonstrated to have no more than a minimal risk impact, as described28, 2015in (2) above.
: 2. The licensee shall implement the following modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-15-191, dated September 8, 2015, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the license amendment. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
CNL-17-024 dated June 7, 2017, BFN-UNIT 3                                                         Renewed License No. DPR-68 Amendment No. 273 October 28, 2015 CNL-17-109      Enclosure 2 Page 6 of 7

Implementation Items 32 and 33, and and the second part of Implementation Item
: 3. The licensee shall complete the implementation items as listed in CNL-17-109 dated             Table S-3, "Implementation Items," of Tennessee Valley Authority  47 letters September 18, 2017.          CNL-15-191, dated September 8, 2015; and CNL-16-165, dated October 31, 2016; within 240 days after issuance of the license amendment unless that date falls within a scheduled refueling outage, then implementation will occur within 60 days after startup from that scheduled refueling outage.
Implementation items 32 and 33 are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.                                         Implementation Items 32 and 33, and the second part of (8) Deleted.
Implementation Item 47, i.e.,
(9) The licensee shall maintain the Augmented Qualityresolving        Finding Program for         level Facts and the Standby Liquid Control System to provide quality control elements to ensure component Observations, reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(10) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:
(a) Fire fighting response strategy with the following elements:
: 1. Pre-defined coordinated fire response strategy and guidance
: 2. Assessment of mutual aid fire fighting assets
: 3. Designated staging areas for equipment and materials
: 4. Command and control
: 5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:
: 1. Protection and use of personnel assets
: 2. Communications
: 3. Minimizing fire spread
: 4. Procedures for implementing integrated fire response strategy
: 5. Identification of readily-available pre-staged equipment
: 6. Training on integrated fire response strategy
: 7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:
: 1. Water spray scrubbing
: 2. Dose to onsite responders (11) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.
(12) Upon completion of Amendment No. 261, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measurement of the CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 3                                                            Renewed License No. DPR-68 Enclosure 2 Page 7 of 7                                   Amendment No. 283 CNL-17-109

Enclosure 3 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Revised Operating License - Clean Pages CNL-17-109

(8)    Deleted.
(9)    Deleted.
(10)   Deleted.
(11)(a)  The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:
                   "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(b)  The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan {CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 279, as amended by changes approved by License Amendment Nos. 286 and 297.
(12)   Deleted.
(13)   TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50 48{a) and 10 CFR 50.48{c), as specified in the license amendment requests dated March 27, 2013 and June 7, 2017, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14, 2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; and September 18, 2017, as approved in the Safety Evaluations dated October 28, 2015, and XXX. Except where NRC approval for changes or deviations is required by 10 CFR 50 48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the BFN-UNIT 1        Enclosure 3 Page 1 of 7                           Renewed License No. DPR-33 Amendment No. XXX CNL-17-109

                                                  -5b-
: 2. Fire Protection Program Changes that Have No More than Minimal Risk lmpact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation dated October 28, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.
Transition License Conditions
: 1. Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.
: 2. The licensee shall implement modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-17-024, dated June 7, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
: 3. The licensee shall complete Implementation Items 32 and 33, and the second part of Implementation Item 47 as listed in Table S-3, Implementation Items, of TVA letter CNL-17-109, dated September 18, 2017. Implementation Items 32 and 33, and the second part of Implementation Item 47, i.e., resolving Finding level Facts and Observations, are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.
(14)   The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(15)   The licensee is required to confirm that the conclusions made in TVAs letter dated September 17, 2004, for the turbine building remain acceptable using seismic demand accelerations based on dynamic seismic analysis prior to the restart of Unit 1.
(16)   Upon implementation of Amendment No. 275, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 1                                                         Renewed License No. DPR-33 Amendment No. 000 CNL-17-109            Enclosure 3 Page 2 of 7

(8)     Deleted.
(9)     Deleted.
(10)      Deleted.
(11)(a)   The licensee shall fully implement and maintain in effect all provisions of the commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:
                   "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(b)   The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. 306, as amended by changes approved by License Amendment Nos. 312 and 321.
(12)      Deleted.
(13)      Deleted.
(14)    TVA Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment requests dated March 27, 2013, and June 7, 2017, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14, 2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014; December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; and September 18, 2017, as approved in the Safety Evaluations dated October 28, 2015, and XXX. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be BFN UNIT 2        Enclosure 3 Page 3 of 7                            Renewed License No. DPR-52 Amendment No. xxx CNL-17-109

                                                      -5b-
* Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);
* Gaseous Fire Suppression Systems (Section 3.10); and
* Passive Fire Protection Features (Section 3.11).
This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
: 2. Fire Protection Program Changes that Have No More than Minimal Risk lmpact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC Safety Evaluation dated October 28, 2015, to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.
Transition License Conditions
: 1. Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensees fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.
: 2. The licensee shall implement modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-17-024, dated June 7, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
: 3. The licensee shall complete Implementation Items 32 and 33, and the second part of Implementation Item 47 as listed in Table S-3, Implementation Items, of TVA letter CNL-17-109, dated September 18, 2017. Implementation Items 32 and 33, and the second part of Implementation Item 47, i.e., resolving Finding level Facts and Observations, are associated with modifications and will be completed after all procedure updates, modifications, and training are complete.
(15)     The licensee shall manintain the Augumented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(16)     Upon implementation of Amendment No. 275, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 2                                                                   Renewed License No. DPR-52 Amendment No. 000 CNL-17-109                 Enclosure 3 Pages 4 of 7

(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 and June 7, 2017, as supplemented by letters dated May 16, 2013; December 20, 2013; January 10, 2014; January 14,2014; February 13, 2014; March 14, 2014; May 30, 2014; June 13, 2014; July 10, 2014; August 29, 2014; September 16, 2014; October 6, 2014;December 17, 2014; March 26, 2015; April 9, 2015; June 19, 2015; August 18, 2015; September 8, 2015; October 20, 2015; and September 18, 2017, as approved in the Safety Evaluations dated October 28, 2015 and XXX.
Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee BFN-UNIT 3                                                      Renewed License No. DPR-68 Amendment No. XXX CNL-17-109      Enclosure 3 Page 5 of 7

                                            -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. The licensee shall implement modifications to its facility, as described in Table S-2, Plant Modifications, of Tennessee Valley Authority letter CNL-17-024 dated June 7, 2017, to complete the transition to full compliance with 10 CFR 50.48(c) no later than the end of the second refueling outage (for each unit) following issuance of the NFPA 805 License Amendment dated October 28, 2015. The licensee shall maintain appropriate compensatory measures in place until completion of these modifications.
BFN-UNIT 3                                                         Renewed License No. DPR-68 Amendment No. XXX CNL-17-109      Enclosure 3 Page 6 of 7
: 3. The licensee shall complete Implementation Items 32 and 33, and the second part of Implementation Item 47 as listed in Table S-3, Implementation Items, of TVA letter CNL-17-109, dated September 18, 2017. Implementation Items 32 and 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.
(8)    Deleted.
(9)    The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(10) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:
(a) Fire fighting response strategy with the following elements:
: 1. Pre-defined coordinated fire response strategy and guidance
: 2. Assessment of mutual aid fire fighting assets
: 3. Designated staging areas for equipment and materials
: 4. Command and control
: 5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:
: 1. Protection and use of personnel assets
: 2. Communications
: 3. Minimizing fire spread
: 4. Procedures for implementing integrated fire response strategy
: 5. Identification of readily-available pre-staged equipment
: 6. Training on integrated fire response strategy
: 7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:
: 1. Water spray scrubbing
: 2. Dose to onsite responders (11) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.
(12) Upon completion of Amendment No. 261, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measurement of the CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 3                                                               Renewed License No. DPR-68 Amendment No.XXX CNL-17-109            Enclosure 3 Page 7 of 7

Enclosure 4 Tennessee Valley Authority Browns Ferry Nuclear Plant, Units 1, 2, and 3 Revised Attachment S, Table S-3, Implementation Items CNL-17-109

TVA BFN                                                                                      Attachment S - Modifications and Implementation Items Table S The items in this table were completed on or before June 22, 2016, i.e., prior to the implementation of new NFPA 805 fire protection program, except for Implementation Items 32 and 33, and the second part of Implementation Item 47.
Implementation Items 32 and 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.
Table S-3 Implementation Items Item           Unit                                      Description                                            LAR Section / Source 01          1, 2, 3    Implement the results of the Radioactive Release Review:                                4.4.2 and Attachment E
: a. Within each pre-fire plan that has an access point to a non-RCA area, enhance the pre-fire plan to better identify concerns for radioactive release by incorporating one of the following options:
: a. Identifying the RCA in the written text or the pre-fire plan drawings is intended to aid the Incident Commander in avoiding radioactive release. For consistency, it is recommended that hardened barriers be identified.
Examples of these would include: the Unit 1 Reactor Building truck bay hatch, water tight doors to the outside as well as passage doors and roll-up door.
: b. Incorporate a descriptive text in the pre-fire plan that highlights escape path concerns specific to that pre-fire plan.
: b. Add generic wording to area fire plans to prompt measures to avoid radioactive release.
: c. Pre-fire plans with doorways to the outside or to non-RCA areas will be revised and will have the plan drawing revised to include the door and an identification method to allow the BFN-FERO to recognize this as an RCA boundary.
: d. Add an appendix to the pre-fire plans for building sump drainage and site storm drains.
: e. Develop a standard operating procedure to support actions to prevent radioactive release. This document will stress actions to prevent the escape of potentially contaminated materials from a building or area boundary. Additional guidance will be provided for fires in yard areas and locations with limited or no engineering controls.
: f. Develop new pre-fire plans for the following areas:
: 1. East Access Building Page S-41 CNL-17-109                                       Enclosure 4 Page 1 of 12

TVA BFN                                                                            Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                  Description                                             LAR Section / Source
: 2. Low Level Radwaste Storage Modules
: 3. Low Level Radwaste Tool Warehouse
: 4. South Access Building
: 5. Condensate Storage Tank Area
: 6. Auxiliary Decay Heat Removal
: 7. Outage Rad Material Storage Warehouse
: 8. Off-Gas Stack
: 9. Units 1, 2 A and B Chillers (Fire Area 27)
: g. Revise the guidance within RWI-001 and/or RWI-111 to address storage of radioactive material for compliance with the radioactive release criteria. The recommended practices would include:
: 1. A screening process.
: 2. A boundary process.
: 3. A source term process.
: 4. When radioactive materials are handled outdoors and outside of containers that exceed the source term limits, consideration should be given to reducing the potential for a fire to occur.
: h. Each fire brigade member will be provided training to identify potential points for radioactive release and the actions that can be taken to mitigate a release. To support the training, guidance will be provided in pre-fire plans and standard operating procedures to outline these expectations and actions.
02    1,2,3 The Fire Protection Report will be updated to include the statement that              4.1 and Attachment A, 3.2.2.4 the NRC is the authority having jurisdiction (AHJ) for fire protection changes requiring approval.
03    1,2,3 The monitoring program required by NFPA 805 Section 2.6 will be                   4.1, 4.6.2 and Attachment A, 3.2.3(3) implemented as part of the fire protection program transition to NFPA 805, in accordance with NFPA 805 FAQ 10-0059, and will include a process that reviews fire protection performance and trends in performance. Program specifics are provided in LAR Section 4.6.2.
Page S-42 CNL-17-109                                            Enclosure 4 Page 2 of 12

TVA BFN                                                                              Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                   Description                                              LAR Section / Source 04    1,2,3 Revise procedure NPG-SPP-18.4.7 to only allow untreated lumber with a                 4.1 and Attachment A, 3.3.1.2(1) cross section dimension of 6" x 6" or larger to be used.
05    1,2,3 Procedure NPG-SPP-18.4.7 allows plastic sheeting materials that meet                  4.1 and Attachment A, 3.3.1.2(2) the requirements of NFPA 701 or UL Standard 214. UL Standard 214 has been withdrawn and will be removed from NPG-SPP-18.4.7.
06    1,2,3 Revise procedure NPG-SPP-18.4.8, to include controls on the use of                    4.1 and Attachment A, 3.3.1.3.4 electric heaters, and to prohibit the use of portable fuel-fired heaters in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.
07    1,2,3 Revise appropriate procedures to inspect and ensure guides and                        4.1 and Attachment A, 3.11.3(1) bearings of active NFPA 805 required sliding fire doors are maintained well lubricated.
08    1,2,3 Plant specifications do not include requirements for wiring installed above            4.1 and Attachment A, 3.3.5.1 suspended ceilings. Revise Specification G-38 to specify that future wiring above suspended ceilings shall be listed for plenum use, routed in armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers.
09    1,2,3 To ensure future plant design meets the requirements for electrical 4.1 and Attachment A, 3.3.5.2 raceway construction limits, revise Specification G-40 to state that flexible conduit shall only be used in lengths up to three feet.
Note: Item 09 was completed prior to June 22, 2016. Item 09 is subsequently deleted by the letter from TVA to NRC, CNL-17-024, "Update to License Amendment Request to Revise NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 (TAC Nos. MF1185, MF1186, and MF1187) - Revision to Tables S-2 and S-3," dated June 7, 2017 (ML17158B285) 10    1,2,3 Revise current plant transformer fire protection testing procedures (FP              4.1 and Attachment A, 3.3.9 026-INS007A, FP-0-026-INS007B, FP-0-026-INS007D, FP-1-026-INS007, FP-2-026-INS007, and FP-3-026-INS007) to ensure that the gravel drainage areas around the transformers are free of debris and capable of performing their design function.
Page S-43 CNL-17-109 Enclosure 4 Page 3 of 12

TVA BFN                                                                               Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                   Description                                               LAR Section / Source 11    1,2,3 Procedure NPG-SPP-1.3 will be revised to include a requirement for the prompt                4.1 and Attachment A, 3.3.10 cleanup of combustible liquids discovered on insulation, including high flashpoint lubricating oils. Procedure NPG-SPP-18.4.7 will be updated to keep such fluids from coming in contact with hot pipes and surfaces, including insulated pipes and surfaces.
12    1,2,3 There are corrective actions identified in MDQ099920100012 that will be           4.1 and Attachment A, 3.4.1(a)(1), 3.4.3(a)(1) completed prior to NFPA 805 implementation, as follows:
Update FPDP-1 to document annual funds for equipment, vehicles, training and education, medical and job-related physical performance evaluations, and other necessary items to accomplish the fire brigade's objectives.
Update FPDP-4 to identify the roles and responsibilities of any responding public fire department and other outside agencies.
Update Fire Brigade procedures to document how the FBL accounts for each member of the FERO present at the scene of emergency.
Update FPDP-4 to document that standard operating procedures shall:
o be maintained in written form and shall address the site-specific functions identified in the industrial fire brigade organizational statement.
o include information regarding site-specific hazards to which industrial fire brigade members can be exposed during a fire or other emergency.
o address the site-specific limitations of emergency response organizations.
o be accessible to all industrial fire brigade members.
Establish a risk management policy for the fire brigade in accordance NFPA 600.
Update training documentation to include training in accordance with NFPA 600 to all personnel who may enter the warm zones.
Update procedures to include standard operating procedures requiring Fire Brigade members to wear SCBA when entering the hot zone.
Update procedures to provide identification that is easily recognizable to indicate FERO members.
Update training documentation to include pre-fire plan awareness as part of the training for support personnel.
Page S-44 CNL-17-109 Enclosure 4 Page 4 of 12

TVA BFN                                                                             Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                   Description                                             LAR Section / Source 13    1,2,3 Update Procedure FPDP-2 to require that pre-fire plans are made                    4.1 and Attachment A, 3.4.2, 3.4.2.3 available in the control room and to the plant industrial fire brigade.
14    1,2,3 Revise TPD-FBT to require fire brigade members to receive training in fire          4.1 and Attachment A, 3.4.3(a)(2) fighting considerations of radioactivity and health physics on a quarterly basis.
15    1,2,3 Revise TPD-FBT to include training for the secondary response group as                4.1 and Attachment A, 3.4.3(b) to their responsibilities, potential hazards to be encountered, and interfacing with the fire brigade.
16    1,2,3 Revise FPDP-4 to detail specific plans for plant security and radiation               4.1 and Attachment A, 3.4.5.3 protection responsibilities regarding off-site fire authority response.
17    1,2,3 There are corrective actions identified in MDQ099920100008 that will be                 4.1 and Attachment A, 3.5.3 completed prior to NFPA 805 implementation as follows:
Revise pre-fire plans to indicate that for hose stations on elevations 617' and below that are not already provided with the fire pump start buttons, a fire pump shall be started prior to operating the hose station if a fire pump is not already operating.
Verify the pump motor can meet the requirements of Section 6-3.1.3 of NFPA 20 Verify the pump motor and controller can meet the requirements of Section 6-3.1.4 of NFPA 20 Verify the power supply protective devices can meet the requirements of Section 6-3.4.1 of NFPA 20 Verify the power supply protective devices can meet the requirements of Section 6-3.4.2 of NFPA 20.
Revise inspection procedures to perform inspections of the battery chargers at the same time as the batteries are inspected in 0-SI-4.11.B.3.c.
Revise current testing procedures to operate the electric fire pumps weekly, with at least one operation accomplished by utilizing the automatic fire pump start functions.
18    1,2,3 Equip all fire apparatus with 12 spanner wrenches and 6 hose connection                4.1 and Attachment A, 3.5.15 gaskets for each size hose. Update procedure FP-0-000-INS005 to include this information.
Page S-45 CNL-17-109 Enclosure 4 Page 5 of 12

TVA BFN                                                                            Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                  Description                                             LAR Section / Source 19    1,2,3 There are corrective actions identified in MDQ099920110005 and                        4.1 and Attachment A, 3.8.1 MDQ099920100017 that will be completed prior to NFPA 805 implementation as follows:
Revise the applicable procedure to include retention of fire alarm signals received for at least one year.
Update Control of Fire Protection Impairment documentation to indicate a retention period of 1 year from the impairment correction date for impairments related to the fire alarm and detection systems in the Impairment Tracking Log.
Update applicable testing procedures to exclude test magnets from being used during smoke detector testing and to ensure smoke detectors are tested and activated using chemical smoke designed solely for smoke detector testing.
20    1,2,3 There are corrective actions identified in MDQ099920100005,                          4.1 and Attachment A, 3.9.1(1)
MDQ099920110001, MDQ099920110002, and MDQ099920110003 that will be completed prior to NFPA 805 implementation as follows:
Update hydraulic calculations for sprinkler systems to clearly indicate the allowance for hose streams.
Page S-46 CNL-17-109 Enclosure 4 Page 6 of 12

TVA BFN                                                                            Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                  Description                                             LAR Section / Source 21    1,2,3 There are corrective actions identified in MDQ099920100007 and                       4.1 and Attachment A, 3.9.1(2)
MDQ099920110004 that will be completed prior to NFPA 805 implementation as follows:
Revise current plant inspections/walkthroughs to include a visual check for obvious defects, such as broken or missing parts, nozzle loading, or other evidence of impaired protection for the water spray systems protecting cable trays in the Unit 3 Diesel Generator Building cable and pipe tunnel, and Turbine Building El 586 south wall, for selected cable trays.
Revise BFN Procedure 3-SI-4.11.C.1.c to include operation of the manual tripping device for the Diesel Generator Building cable tray water spray system.
Revise Surveillance Procedures (1- and 3-SI.4.11.C.1.c) to include an inspection of the spray nozzles for proper positioning, external loading, and corrosion, and cleaning when necessary.
Revise Surveillance Procedures (1- and 3-SI.4.11.C.1.c) to include verification that the means of system actuation (heat detector, smoke detector, or test valve) cause the deluge valve to operate within 40 seconds.
Revise the transformer water spray system inspection procedures to (1) verify that the water supply at the riser has not deteriorated and (2) if the reading taken at the riser indicates that the water supply has deteriorated, a gauge shall be placed on the hydraulically most remote nozzle and the results compared with the required design pressure.
22    1,2,3 There are corrective actions identified in MDQ099920100004 that will be             4.1 and Attachment A, 3.10.1(1) completed prior to NFPA 805 implementation as follows:
Install warning signs in conspicuous locations in and around the Lube Oil Purification Room.
Replace the existing CO2 system safety signs with signs that comply with the three-panel format retroactively required by NFPA 12 - 2008.
Page S-47 CNL-17-109 Enclosure 4 Page 7 of 12

TVA BFN                                                                           Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                   Description                                           LAR Section / Source 23    1,2,3 Post-transition, for personnel performing fire modeling or Fire PRA                              4.7.3 development and evaluation, TVA will develop and maintain qualification requirements for individuals assigned various tasks. Position Specific Guides will be developed to identify and document required training and mentoring to ensure individuals are appropriately qualified per the requirements of NFPA 805 Section 2.7.3.4 to perform assigned work.
24    1,2,3 For program documentation and configuration control, implement the                      4.7.1, 4.7.2, and 4.7.3 following:
The Fire Protection Design Basis Document described in Section 2.7.1.2 of NFPA 805 and necessary supporting documentation described in Section 2.7.1.3 of NFPA 805 will be created as part of transition to 10 CFR 50.48(c) to ensure program implementation following receipt of the safety evaluation.
The configuration control procedures which govern fire protection-related documents and databases will be revised to reflect the new NFPA 805 licensing bases requirements.
Several NFPA 805 document types, such as NSCA Supporting Information and Non-Power Mode NSCA Treatment, will generally require new control procedures and processes to be developed since they are new documents and databases created as a result of the transition to NFPA 805. The new procedures will be modeled after the existing processes for similar types of documents and databases.
System level design basis documents will be revised to reflect the NFPA 805 role that the system components now play.
Configuration control of the Fire PRA model will be maintained by integrating the Fire PRA model into the existing processes used to ensure configuration control of the Internal Events PRA model.
25    1,2,3 The additional considerations of NEI 00-01, Revision 2, Chapter 3 will be                       4.2.1.1 addressed by linking the EOIs to fire safe shutdown procedures consistent with the recommendations of BWROG document, BWROG-TP-11-011, entitled, BWROG Assessments of Generic Multiple Spurious Operations (MSOs) in Post-Fire Safe Shutdown Circuit Analysis for the Operating BWR Plants, dated June, 2011. with the exception of the MCR abandonment Fire Safe Shutdown procedures. The MCR abandonment Fire Safe Shutdown procedures will include procedure steps for fires impacting the ability to scram from the MCR.
Page S-48 CNL-17-109                                   Enclosure 4 Page 8 of 12

TVA BFN                                                                              Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                   Description                                              LAR Section / Source 26    1,2,3 Revise Shutdown Risk Management procedures to reflect the following                        4.3.2 and Attachment D recommendations during higher risk evolutions (e.g., OPDRV and moving irradiated fuel assemblies) from the calculation entitled, NFPA 805 Transition - Non-Power Operation Modes Analysis:
Restriction of hot work in areas during periods of increased vulnerability.
Restriction of combustible loading.
Restriction of transient combustible materials in areas during periods of increased vulnerability.
Consider plant equipment configuration changes (e.g., removing power from equipment once it is placed in its desired position).
Provision of additional fire patrols at periodic intervals or other appropriate compensatory measures (such as surveillance cameras) during increased vulnerability.
Reschedule the work to a period with lower risk or higher defense-in-depth.
Housekeeping.
Presence of functional fire detection and suppression equipment.
27    1,2,3 The following implementation item is required based on the results of the                       Attachment G Operator Action Feasibility Analysis:
Develop / revise post-fire response procedures to reflect the NSCA.
28    1,2,3 The following implementation item is required based on the results of the                       Attachment G Operator Action Feasibility Analysis:
Identify required tools during the procedure validation and verification.
29    1,2,3 The following implementation item is required based on the results of the                       Attachment G Operation Action Feasibility Analysis:
Document staffing requirements for revised post-fire response procedures.
Page S-49 CNL-17-109 Enclosure 4 Page 9 of 12

TVA BFN                                                                                Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item     Unit                                    Description                                              LAR Section / Source 30     1,2,3   The following implementation item is required based on the results of the                     Attachment G Operation Action Feasibility Analysis:
Train operators on revised post-fire response procedures.
31     1,2,3  The following implementation item is required based on the results of the                      Attachment G Operation Action Feasibility Analysis:
Revise training requirements for post-fire response procedures to include periodic drills.
32    1, 2, 3 Update the Fire PRA model, as necessary, after all modifications are                           Section 4.8.2 complete (returned to operation) and in their as-built configuration. The update will include a verification of the validity of the reported change in risk on as-built conditions after the modifications are completed. If this verification determines that the risk metrics have changed such that the RG 1.174 acceptance guidelines are not met, the Nuclear Regulatory Commission (NRC) will be notified and additional analytical efforts, and/or procedure changes, and/or plant modifications will be made to assure the RG 1.174 risk acceptance criteria are met.
33     1,2,3  Update the fire HRA (Human Reliability Analysis) upon completion of all                    Attachments G and V procedure updates, all modifications and all training. The update will include a verification of the validity of the reported change in risk on as-built conditions after the procedure updates, modifications, and training are completed. If this verification determines that the risk metrics have changed such that the RG 1.174 acceptance guidelines are not met, the Nuclear Regulatory Commission (NRC) will be notified and additional analytical efforts, and/or procedure changes, and/or plant modifications will be made to assure the RG 1.174 risk acceptance criteria are met.
Page S-50 CNL-17-109 Enclosure 4 Page 10 of 12

TVA BFN                                                                           Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                  Description                                              LAR Section / Source 34    1,2,3 Revise the following EEEEs to meet the administrative requirements for                             4.2.2 engineering evaluations in accordance with the applicable criteria provided in RG 1.205 and NEI 04-02, as supplemented by FAQ 06-0008 and FAQ 07-0054.
The following EEEEs documented in the Fire Hazard Analysis:
o FHA Section 3.3.4.e SBGT Duct Penetrations o FHA Section 4.1 Flood Control Doors o FHA Section 4.2 Personnel and Equipment Access Locks o FHA Section 4.3 Main Steam and Feedwater Piping Tunnel Barriers MDQ0100890035 - Fire Boundary Seal Design for Gypsum Walls RIMS B22 911004 003 Engineering Evaluation of the Bus Duct Penetrations RIMS B22 911004 201 Engineering Evaluation for the Unprotected Openings in 1-Hour Floor Ceiling Assemblies on Elevation 621.25 and 639 Reactor Buildings 35    1,2,3 Revise NPG-SPP-18.4.7 to establish limits on the types and quantities of             4.1 and Attachment A, 3.3.1.2(4) materials in designated storage areas.
37    1,2,3 Revise design output to ensure interior epoxy floor finishes meet the                   4.1 and Attachment A, 3.3.3 Class I requirements and interior carpet floor finishes meet the Class I requirements.
38    1,2,3 Develop specific guidance and restrictions on bulk flammable gas storage       4.1 and Attachment A, 3.3.7, 3.3.7.1, 3.3.7.2 onsite.
39    1,2,3 Revise FPDP-4 to require that off-site fire authorities be offered a plan for         4.1 and Attachment A, 3.4.5.1 their interface during fire emergencies onsite.
40    1,2,3 Establish a contract for maintenance and hydrostatic testing of fire                     4.1 and Attachment A, 3.7 extinguishers in accordance with NFPA 10.
41    1,2,3 Revise flow drawings for the CO2 systems to note the CO2 shutoff valves                4.1 and Attachment A, 3.10.5 are locked in the open position.
42    1,2,3 Revise design output procedure to ensure interior wall and ceiling finishes             4.1 and Attachment A, 3.3.3 meet the NFPA 101 material requirements.
Page S-51 CNL-17-109 Enclosure 4 Page 11 of 12

TVA BFN                                                                            Attachment S - Modifications and Implementation Items Table S-3 Implementation Items Item    Unit                                   Description                                            LAR Section / Source 43    1,2,3 Revise the procedure NPG-SPP-18.4.8, Control of Ignition Sources (Hot               4.1 and Attachment A, 3.3.1.3.1 Work), to incorporate corrective actions identified in MDQ0009992013000160.
45    1,2,3 Revise procedures NPG-SPP-18.4.7, Control of Transient Combustibles,                      Attachment C and V and NPG-SPP-18.4.8, Control of Ignition Sources (Hot Work), to strengthen risk and defense in-depth administrative controls (e.g., no storage and no hot work designated areas).
46    1,2,3 Verification of the condition of electrical cabinet doors to meet Fire                Response to RAI PRA 01.d.i Modeling Assumptions will be included in the monitoring Program.
47    1,2,3 1. Perform a focused-scope peer review of the Fire PRA. The peer                  Response to RAI PRA 11.a, b and c, review will include, as a minimum, the following elements: Fire PRA               PRA RAI 23.d and PRA RAI 24 Part b Cable Selection and Location (CS), Human Reliability Analysis (HRA),
Fire Risk Quantification (FQ), Uncertainty and Sensitivity Analysis (UNC),
Accident Sequence Analysis (AS), and LERF Analysis (element LE-C6).
: 2. Any focused scope peer review Finding level Facts and Observations (F&Os) will be resolved prior to self-approval of post-transition changes.
48    1,2,3 Develop and deliver training to Fire Operations on incipient detection            Response to FPE RAI 10, Revision 1 systems alarm response procedures.
CNL-17-109                                                                                                                       Page S-52 Enclosure 4 Page 12 of 12}}