View source for CNL-19-003, Tennessee Valley Authority, Browns Ferry Nuclear Plant, Unit 1, Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions

{{Adams
| number = ML19022A305
| issue date = 01/22/2019
| title = Tennessee Valley Authority, Browns Ferry Nuclear Plant, Unit 1, Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions
| author name = Henderson E
| author affiliation = Tennessee Valley Authority
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000259
| license number = DPR-033
| contact person = 
| case reference number = CAC MF4540, CNL-19-003
| document type = Letter type:CNL
| page count = 18
| project = CAC:MF4540
| stage = Other
}}

=Text=
{{#Wiki_filter:Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-19-003 January 22, 2019 10 CFR 2.202 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Unit 1 Renewed Facility Operating License No. DPR-33 NRC Docket No. 50-259

==Subject:==
Tennessee Valley Authority, Browns Ferry Nuclear Plant, Unit 1, Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (CAC No. MF4540)

==References:==
: 1. NRC Order Number EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013 (ML13143A321)
: 2. NRC Interim Staff Guidance JLD-ISG-2013-02, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated November 14, 2013 (ML13304B836)
: 3. NEI 13-02, Industry Guidance for Compliance with Order EA-13-109, BWR Mark I & II Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, Revision 1, dated April 23, 2015 (ML15113B318)
: 4. Letter from TVA to NRC, Tennessee Valley Authoritys Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident (Order Number EA-13-109), dated June 30, 2014 (ML14181B169)
: 5. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant First Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 19, 2014 (ML14353A428)

U.S. Nuclear Regulatory Commission CNL-19-003 Page 2 January 22, 2019
: 6. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -
Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents)
(TAC Nos. MF4540, MF4541 and MF4542), dated February 11, 2015 (ML14356A362)
: 7. NRC Interim Staff Guidance JLD-ISG-2015-01, Compliance with Phase 2 of Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, Revision 0, dated April 29, 2015 (ML15104A118)
: 8. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant Second Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 29, 2015 (ML15181A338)
: 9. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant Third Six-Month Status Report and Phase 1 and Phase 2 Overall Integrated Plan in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 29, 2015 (ML15365A554)
: 10. Letter from TVA to NRC, Tennessee Valley Authoritys Browns Ferry Nuclear Plant Fourth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2016 (ML16182A517)
: 11. Letter from TVA to NRC, Tennessee Valley Authority Browns Ferry Nuclear Plants Fifth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 22, 2016 (ML16357A577)
: 12. Letter from TVA to NRC, Tennessee Valley Authority Browns Ferry Nuclear Plants Sixth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2017 (ML17181A333)
: 13. Letter from TVA to NRC, Tennessee Valley Authority Browns Ferry Nuclear Plants Seventh Sixth-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 20, 2017 (ML17354A250)

U.S. Nuclear Regulatory Commission CNL-19-003 Page 3 January 22, 2019
: 14. Letter from TVA to NRC, Tennessee Valley Authority Browns Ferry Nuclear Plants Eighth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 27, 1018 (ML18179A139)
: 15. Letter from TVA to NRC, Tennessee Valley Authority Browns Ferry Nuclear Plants Ninth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 27, 2018 (ML18361A801)
: 16. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -
Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents)
(CAC Nos. MF4540, MF4541, and MF4542), dated September 6, 2016 (ML16244A762)
On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to Tennessee Valley Authority (TVA). Reference 1 was immediately effective and directed TVA to install a reliable hardened venting capability for instances of pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris. Specific requirements are outlined in Attachment 2 of Reference 1.
Reference 1 required submission of a Phase 1 and Phase 2 Overall Integrated Plan (OIP) pursuant to Section IV, Condition D for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3.
References 2 and 7 endorsed industry guidance document Nuclear Energy Institute (NEI) 13-02, Revision 1 (Reference 3) with clarifications and exceptions identified in References 2 and 7. Reference 3 provides direction regarding the content of the Phase 1 and Phase 2 OIPs and includes guidance for combining the OIPs.
Reference 4 provided TVAs Phase 1 OIP, and Reference 9 provided TVAs combined Phase 1 and Phase 2 OIP. The NRC issued its Interim Staff Evaluation relating to the BFN Phase 1 OIP on February 11, 2015 (Reference 6). The NRC issued its Interim Staff Evaluation relating to Phase 2 OIP on September 6, 2016 (Reference 16).
Reference 1 also requires submission of status reports at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports. TVA submitted the first six-month status report on December 19, 2014 (Reference 5), and has provided subsequent six-month status reports in References 8 through 15.
The purpose of this letter is to provide the notification required by Item IV.D.4 of Order EA-13-109 that full compliance (Phase 1 and Phase 2) with the requirements described in  of the Order has been achieved for Browns Ferry Nuclear Plant, Unit 1.
There are no new regulatory commitments resulting from this submittal. If you have any question regarding this submittal, please contact Mike Oliver at (256) 729-7874.

U.S . Nuclear Regulatory Commission CNL-19-003 Page 4 January 22, 2019 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22nd day of January 2019.
E. K. Henderson Director, Nuclear Regulatory Affairs

==Enclosure:==
Tennessee Valley Authority, Browns Ferry Nuclear Plant, Unit 1, Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions cc (w/Enclosure):
NRR Director - NRC Headquarters NRO Director - NRC Headquarters NRC Regional Administrator - Region II NRR Project Manager - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Browns Ferry Nuclear Plant

ENCLOSURE Tennessee Valley Authority, Browns Ferry Nuclear Plant, Unit 1, Completion of Required Action for NRC Order EA-13-109, Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions BACKGROUND On June 6, 2013, the Nuclear Regulatory Commission (NRC) issued Order EA-13-109, Order Modifying Licenses with Regard to Requirements for Reliable Hardened Containment Vents (HCVS) Capable of Operation Under Severe Accident Conditions (Reference 1), to Tennessee Valley Authority (TVA). This Order was immediately effective and directs the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, to install a reliable hardened venting capability for pre-core damage and under severe accident conditions, including those involving a breach of the reactor vessel by molten core debris in response to Order EA-13-109. BFN developed an Overall Integrated Plan (OIP) (Phase 1 in Reference 2 and Phases 1 and 2 in Reference 5) to provide HCVS. The information provided herein, as well as the implementation of the OIP, documents full compliance for BFN, Unit 1, in response to the Order (Reference 1).
OPEN ITEM RESOLUTION The Phase 1 and 2 NRC Interim Staff Evaluation (ISE) Open Items (References 11 and 12, respectively) have been addressed and documented in the subsequent Order EA-13-109 six-month status reports (References 3-10, and 14). A list of the ISE open items and a summary of the closure action is listed below:
Browns Ferry Nuclear Plant, Unit 1                                Response HCVS Phase 1 ISE Open Items 1     Make available for NRC staff      An evaluation of temperature and radiological conditions audit an evaluation of            was performed to ensure that Operating personnel can temperature and radiological      safely access and operate controls at the Remote conditions to ensure that         Operating Station located in the Diesel Buildings and in operating personnel can safely    the Reactor Building. This evaluation is documented in access and operate controls       Unit 1 DCN 71389 Design Change Technical Evaluation.
and support equipment.            MDQ0000642015000351, HCVS Operator (Mission) Dose Calculation, and MDQ0009992014000291, Temperature Response of the Reactor Building Following an Extended Loss of AC Power, were used to validate the evaluation.
This ISE Open Item was closed as documented in Reference 13.
2     Make available for NRC audit      For Unit 1, 1-EOI Appendix-13 Revision 3 was revised to documentation that procedure      include venting for loss of DC power.
1/2/3-EOI Appendix-13 has         This ISE Open Item was closed as documented in been revised to include venting   Reference 13.
for loss of DC power.
CNL-19-003                                      E-1

Browns Ferry Nuclear Plant, Unit 1                           Response HCVS Phase 1 ISE Open Items 3    Make available for NRC staff    Calculation EDQ0009992013000202, 250V DC Unit audit documentation             Batteries, 1, 2, & 3 Evaluation for the Beyond Design demonstrating that all load     Basis External Event (BDBEE) Extended Loss of AC sheds will be accomplished      Power (ELAP), has been issued to determine load within one hour of event        shedding impact on the unit batteries. The performance of initiation and will occur in an the load shed is directed by 0-FSI-1, FLEX Support area not impacted by a          Instruction, and performed in accordance with 0-FSI-3F, possible radiological event. Load Shed of 250V Main Bank Battery 1, 2, 3. The load shed is performed in the Control Bay and Electrical Board rooms only and will not require entry into areas that are impacted by a possible radiological event.
This ISE Open Item was closed as documented in Reference 13.
4    Make available for NRC staff    A conceptual meeting was held in November 2014, and a audit documentation that        staging plan was used to separate the existing Hardened demonstrates that operating     Wetwell Vent (HWWV) from the HCVS. The HCVS has units that have not             been implemented on all BFN Units.
implemented the order will be   This ISE Open Item was closed as documented in able to vent through the        Reference 13.
existing vent system unaffected by the implementation of HCVS on other units.
5    Make available for NRC staff    The existing wetwell vent and the HCVS have been audit analyses demonstrating    designed for 1 percent of rated thermal power at Extended that HCVS has the capacity to   Power Uprate (3952 MWt) conditions. This analysis is vent the steam/energy           available and documented in Calculation equivalent of one percent of    NDQ0000642015000341, HCVS MAAP Analysis.
licensed/rated thermal power    This ISE Open Item was closed as documented in (unless a lower value is        Reference 13.
justified), and that the suppression pool and the HCVS together are able to absorb and reject decay heat, such that following a reactor shutdown from full power containment pressure is restored and then maintained below the primary containment design pressure and the primary containment pressure limit.
CNL-19-003                                   E-2

Browns Ferry Nuclear Plant, Unit 1                           Response HCVS Phase 1 ISE Open Items 6    Make available for NRC staff   A communication system has been implemented audit documentation that       (DCN 70852) that uses hand held radios for demonstrates adequate          communication between the main control room (MCR) and communication between the      the remote operating station. This Radio System consists remote HCVS operation          of a Ultra High Frequency (UHF)/Very High Frequency locations and HCVS decision    (VHF) trunked system and an independent VHF channel makers during ELAP and         (F4). The In-plant Radio System is accessed by handheld severe accident conditions. radios. The In-plant Radio System has normal and emergency diesel generator backed power supply. The radio system is powered from two Class 1E redundant power sources, the 480V DG Auxiliary Boards A and B.
Primary power source will be from the 480V DG Auxiliary Board A via a second 480-208V/120V transformer/distribution center. In the event of loss of primary power source, power to radio equipment will be automatically transferred to backup source via transfer switches located in each cabinet, with exception of cabinet 4, which receives power via cabinet 1 transfer switch.
Backup power source includes Uninterrupted Power Supply (UPS) with battery capacity to supply four (4) UHF channels for three hours. Therefore, in this configuration, capacity is reduced from five simultaneous conversations to three. The loads supplied via UPS can be alternatively supplied from a portable generator via a transfer switch (0-FSI-4B).
UPS conservation can be accomplished by switching off one of the two UPSs until such time the active UPS reaches low level. Then, the UPS previously switched off can be returned to service extending the overall time the radio system can remain operable without portable generator power to approximately 6 hours.
BFN maintains a large number of handheld radios, batteries, and charging units. The FLEX program does not maintain dedicated handheld radios. These units, spare batteries, and chargers will be gathered if not readily available in the control rooms.
Handheld Radios can additionally be operated in Radio-to-Radio mode enabling communications not affected by shielding or distance.
This ISE Open Item was closed as documented in Reference 13.
CNL-19-003                                  E-3

Browns Ferry Nuclear Plant, Unit 1                             Response HCVS Phase 1 ISE Open Items 7    Make available for NRC staff     An evaluation was performed and concluded that the audit documentation of an        containment isolation valves will open under the maximum evaluation verifying the         expected differential pressure and is documented in existing containment isolation   Flowserve Report RAL-70181, Design Review Report of valves, relied upon for the      Size 14 Class 150 Wafer Butterfly Valve with Pneumatic HCVS, will open under the        Actuator, Revision 1.
maximum expected differential    This ISE Open Item was closed as documented in pressure during BDBEE and        Reference 13.
severe accident wetwell venting.
8    Make available for NRC staff     Electrical and instrument and control components were audit documentation of a         procured as seismically qualified or as Seismic Class I to seismic qualification evaluation ensure their functionality following a seismic event.
of HCVS components.              Seismic qualification reports of HCVS components are available for audit.
This ISE Open Item was closed as documented in Reference 13.
9    Make available for NRC staff     Instrumentation and controls necessary to implement this audit descriptions of all        order including equipment description, location, and instrumentation and controls     qualifications are available for audit.
(existing and planned)           This ISE Open Item was closed as documented in necessary to implement this      Reference 13.
order including qualification methods.
10   Make available for NRC staff     Descriptions of local conditions (temperature, radiation audit the descriptions of local  and humidity) anticipated during ELAP and severe conditions (temperature,         accident for the components (valves, instrumentation, radiation and humidity)          sensors, transmitters, indicators, electronics, control anticipated during ELAP and      devices, and etc.) required for HCVS venting including severe accident for the          confirmation that the components are capable of components (valves,              performing their functions during ELAP and severe instrumentation, sensors,        accident conditions are available for audit.
transmitters, indicators,        This ISE Open Item was closed as documented in electronics, control devices,    Reference 13.
and etc.) required for HCVS venting including confirmation that the components are capable of performing their functions during ELAP and severe accident conditions.
CNL-19-003                                    E-4

Browns Ferry Nuclear Plant, Unit 1                             Response HCVS Phase 1 ISE Open Items 11 Make available for NRC staff        HCVS batteries/battery charger final sizing evaluation was audit the final sizing evaluation performed and documented in the Design Change for HCVS batteries/battery        Technical Evaluation of DCN 71389 for Unit 1. There is no charger including incorporation   incorporation of the HCVS battery/battery charger required into FLEX DG loading              into the FLEX DG loading calculation due to no plans or calculation.                      requirements to recharge the HCVS battery after depletion. The HCVS electrical loads will be aligned back to their normal power supply which is the Unit Battery.
The recharging of the Unit Battery is incorporated into the FLEX DG loading calculations. Calculation EDQ0003602014000281 Revision 3, Electrical Evaluation for Portable Power Supply for Unit Battery Chargers, and calculation EDQ0003602015000325 Revision 1, Electrical Evaluation for 4KV Spare FLEX Turbine Generators, were used to validate the evaluation.
This ISE Open Item was closed as documented in Reference 13.
12   Make available for NRC staff      The HCVS evaluation has been completed and audit documentation of the        documented in DCN 71389 for Unit 1 and calculation HCVS nitrogen pneumatic           MDQ0000322015000347, HCVS Nitrogen System Sizing system design including sizing    Analysis. As documented in DCN 71389 Design Change and location.                     Technical Evaluation (Page 29 of 81), there are 9 Nitrogen Cylinders required for Unit 1 for 7 days of Hardened Vent operation. There are 5 Nitrogen Cylinders installed to support Hardened Vent operation for Unit 1. 24 Nitrogen Cylinders are required for Units 2 and 3 for 7 days simultaneous operation. There are 5 Nitrogen Cylinders installed to support Hardened Vent operation for Units 2 and 3. There are 6 Nitrogen Cylinder carts with 6 Nitrogen Cylinders on each cart available in the FLEX Storage building with no other committed use of them.
This ISE Open Item was closed as documented in Reference 13.
13   Make available for NRC staff      Tornado and seismic missile criteria are located in the audit the seismic and tornado     Primary Containment System (64A) Design Criteria missile final design criteria for Document (DCD). As part of DCN 71389 for Unit 1, a the HCVS stack.                   markup reflecting these changes was generated and the DCD was revised.
This ISE Open Item was closed as documented in Reference 13.
CNL-19-003                                      E-5

Browns Ferry Nuclear Plant, Unit 1                             Response HCVS Phase 1 ISE Open Items 14 Provide a description of the       The final design of HCVS at BFN to address hydrogen final design of the HCVS to      detonation and deflagration is the installation of a check address hydrogen detonation      valve near the vent discharge release point. A description and deflagration.                of this design is contained in the Technical Evaluation for DCN 71389 for Unit 1.
This ISE Open Item was closed as documented in Reference 13.
15   Provide a description of the     The HCVS provides a direct vent path from the wetwell to strategies for hydrogen control  an exhaust point above the Reactor Building Roof in that minimizes the potential for accordance with NEI 13-02, Section 4.1.5. This is a leak hydrogen gas migration and       tight system with no boundary valves outside the primary ingress into the reactor         containment isolation valves (PCIVs) that would allow building or other buildings      hydrogen gas migration and ingress into the Reactor Building or other buildings. Per NEI 13-02 Frequently Asked Question FAQ-04, an effluent release velocity of 8000 feet per minute will assure that the effluent plume will not be entrained into the roof recirculation zone of a given building. A description of this design is contained in the Technical Evaluation for DCN 71389 for Unit 1.
This ISE Open Item was closed as documented in Reference 13.
16   Provide design details that      The BFN design includes a separate HCVS stack for each minimize unintended cross        unit as well as meeting the testing criteria and valve flow of vented fluids within a   requirements for PCIVs and control and boundary valves.
unit and between units on the    A description of this design is contained in the Technical site.                            Evaluation for 71389 for Unit 1.
This ISE Open Item was closed as documented in Reference 13.
Browns Ferry Nuclear Plant, Unit 1                            Response HCVS Phase 2 ISE Open Items 1    Licensee to perform a            Calculation MDN0003602014000233, Hydraulic Analysis hydraulic evaluation to ensure   for Fukushima FLEX Connection Modifications, was flow adequacy can be met for     revised to include a bounding case that concluded that a all 3 units using 1 FLEX pump    single FLEX pump (with booster pump) can provide to support SAWA flow             500 gallons per minute (gpm) to Unit 1 RPV (each at RPV requirement.                     pressure of 106 psig) in response to a Severe Accident Water Addition (SAWA) event.
This ISE Open Item was closed as documented in Reference 13.
CNL-19-003                                     E-6

Browns Ferry Nuclear Plant, Unit 1                             Response HCVS Phase 2 ISE Open Items 2    Licensee to evaluate the       Equipment and Controls SAWA equipment and controls, Plant instrumentation for Severe Accident Water as well as the ingress and     Management (SAWM) is qualified to NRC Regulatory egress paths for the expected  Guide (RG) 1.97 or equivalent and is considered qualified severe accident conditions     for the sustained operating period without further (temperature, humidity,        evaluation. The following plant instruments are qualified radiation) for the sustained   to RG 1.97:
operating period.
Drywell (DW) Pressure Indicators, 1,2,3-PI-64-67B, and Suppression Pool Level Indicators, 1,2,3-LI-64-159A.
Passive components that do not need to change state after initially establishing SAWA flow do not require evaluation beyond the first 8 hours, at which time they are expected to be installed and ready for use to support SAWA/SAWM.
The following additional equipment performing an active SAWA/SAWM function is considered:
SAWA/SAWM flow instrument, SAWA/SAWM pump, FLEX generator, and SAWA throttle valve.
These components will be used at a remote location (outside Reactor Building) and have been evaluated for the environmental conditions applicable at those locations.
Ingress and Egress For locations outside the Reactor Building between 7 hours and 7 days when SAWA is being utilized, BFN performed a qualitative evaluation of equipment and deployment locations and confirmed they are protected by distance and/or buildings with substantial shielding to minimize dose rates. A quantitative evaluation of expected dose rates, AREVA document 51-9262174-003, Projected Dose Rate Contour Map of Shine from the HCVS Vent Line Extending Above Refueling Floor (BFNP), has been performed per HCVS-WP-02 and found the dose rates at deployment locations including ingress/egress paths are acceptable.
This ISE Open Item was closed as documented in Reference 13.
CNL-19-003                                   E-7

Browns Ferry Nuclear Plant, Unit 1                             Response HCVS Phase 2 ISE Open Items 3    Licensee to demonstrate how    Equipment and Controls SAWA flow is capable to        Plant instrumentation for SAWA that is qualified to perform its intended function  RG 1.97 or equivalent is considered qualified for the for the sustained operating    sustained operating period without further evaluation. The period under the expected      following plant instruments are qualified to RG 1.97:
temperature and radiological DW Pressure Indicators, 1,2,3-PI-64-67B, and conditions.
Suppression Pool Level Indicators, 1,2,3-LI-64-159A.
Passive components that do not need to change state after initially establishing SAWA flow do not require evaluation beyond the first 8 hours, at which time they are expected to be installed and ready for use to support SAWA/SAWM.
The following additional equipment performing an active SAWA/SAWM function is considered for temperature and radiation effects:
* SAWA/SAWM flow instrument,
* FLEX/SAWA pump,
* FLEX generator, and
* SAWA throttle valve.
Temperature The location of SAWA equipment and controls that are the same or similar as FLEX will be bounded by the FLEX evaluations for temperature.
Radiation For equipment locations outside the Reactor Building between 7 hours and 7 days when SAWA is being utilized, BFN performed a qualitative evaluation of equipment and deployment locations and confirmed they are protected by distance and/or buildings with substantial shielding to minimize dose rates. A quantitative evaluation of expected dose rates, AREVA document 51-9262174-003, Projected Dose Rate Contour Map of Shine from the HCVS Vent Line Extending Above Refueling Floor (BFNP), was performed per HCVS-WP-02, Sequences for HCVS Design and Method for Determining Radiological Dose from HCVS Piping, and found the dose rates at deployment locations are acceptable.
This ISE Open Item was closed as documented in Reference 13.
CNL-19-003                                   E-8

Browns Ferry Nuclear Plant, Unit 1                             Response HCVS Phase 2 ISE Open Items 4    Licensee to demonstrate that     The wetwell vent has been designed and installed to meet containment failure as a result  NEI 13-02 Revision 1 guidance which will ensure that it is of overpressure can be           adequately sized to prevent containment overpressure prevented without a drywell      under severe accident conditions.
vent during severe accident      The SAWM strategy will ensure that the wetwell vent conditions.                      remains functional for the period of sustained operation.
BFN will follow the guidance (flow rate and timing) for SAWA/SAWM described in BWROG-TP-15-008, SAWA Timing, and BWROG-TP-15-011, SAWM Supporting Evaluations. The wetwell vent will be opened prior to exceeding the Primary Containment Pressure Limit value of 62 psig. Therefore, containment over pressurization is prevented without the need for a drywell vent.
This ISE Open Item was closed as documented in Reference 13.
5    Licensee to demonstrate how      Using Figure 2.1.C from the combined Phase 1 and 2 OIP, the plant is bounded by the      compare the reference plant parameters to the plant reference plant analysis that    specific parameters.
shows the SAWM strategy is Reference Plant              Browns Ferry successful in making it unlikely that a drywell vent is needed.                                          Nuclear Plant Torus freeboard volume is      Torus freeboard volume is 525,000 gallons                757,544 gallons SAWA flow is 500 gpm at        SAWA flow is 500 gpm at 8 hours followed by            8 hours followed by 100 gpm from 12 hours to       100 gpm from 12 hours to 168 hours                      168 hours The above parameters for BFN compared to the reference plant that determine success of the SAWM strategy demonstrate that the reference plant values are bounding. Therefore, the SAWM strategy implemented at BFN makes it unlikely that a DW vent is needed to prevent containment overpressure related failure.
This ISE Open Item was closed as documented in Reference 13.
6    Licensee to demonstrate that     BFN utilizes the Harris Radio System to communicate there is adequate                between the MCR and the operator at the FLEX pump.
communication between the        This communication method is the same as accepted in MCR and the operator at the      Order EA-12-049. These items will be powered and FLEX pump during severe          remained powered using the same methods as evaluated accident conditions.             under EA-12-049 and continued for the period of sustained operation.
This ISE Open Item was closed as documented in Reference 13.
CNL-19-003                                    E-9

MILESTONE SCHEDULE - ITEMS COMPLETE Milestone                            Target          Activity    Comments Completion Date      Status Submit Phase 1 Overall                June 2014        Complete Integrated Plan Submit Phase 2 Overall              December 2015      Complete Integrated Plan Submit 6 Month Updates:
Update 1                         December 2014      Complete Update 2                           June 2015        Complete Update 3                         December 2015      Complete  Simultaneous with Phase 2 OIP Update 4                           June 2016        Complete Update 5                         December 2016      Complete Update 6                           June 2017        Complete Update 7                         December 2017      Complete Update 8                           June 2018        Complete Update 9                         December 2018      Complete Phase 1 Specific Milestones Phase 1 Modifications:
Hold preliminary/conceptual      November 2014      Complete design meeting Unit 1 Design Engineering On-       April 2016      Complete site/Complete Unit 1 Implementation Outage     November 2016      Complete Unit 1 Walk Through              November 2016      Complete Demonstration/Functional Test Phase 1 Procedure Changes Operations Procedure                July 2016       Complete Changes Developed Site Specific Maintenance           July 2016       Complete Procedure Developed Procedure Changes Active         November 2016      Complete Phase 1 Training:
Training Complete                September 2016     Complete Phase 1 Completion Unit 1 HCVS Implementation       December 2016      Complete CNL-19-003                                 E-10

Phase 2 Specific Milestones Phase 2 Modifications:
Milestone                     Target           Activity           Comments Completion Date        Status Hold preliminary/conceptual         January 2017        Complete design meeting Unit 1 Design Engineering On-         May 2018          Complete site/Complete Unit 1 Walk Through                 October 2018        Complete Demonstration/Functional Test Unit 1 Implementation Outage        October 2018        Complete Phase 2 Procedure Changes Operations Procedure                 March 2018         Complete Changes Developed Site Specific Maintenance            March 2018         Complete Procedure Developed Procedure Changes Active             March 2018         Complete Phase 2 Training:
Training Complete                    March 2018         Complete Phase 2 Completion Unit 1 HCVS Implementation          October 2018        Complete         November 2018 Submit Unit 1 Phase 1 and 2             January 2019        Complete Completion Report                                            with this submittal ORDER EA-13-109 COMPLIANCE ELEMENTS 

==SUMMARY==

The elements identified below for BFN, Unit 1, as well as the HCVS Phase 1 and Phase 2 OIP (Reference 5), the 6-Month Status Reports (References 3-10, and 14) and additional docketed correspondence demonstrate compliance with Order EA-13-109.
HCVS PHASE 1 AND PHASE 2 FUNCTIONAL REQUIREMENTS AND DESIGN FEATURES - COMPLETE The BFN, Unit 1, Phase 1 HCVS provides a vent path from the wetwell to remove decay heat, vent the containment atmosphere, and control containment pressure within acceptable limits. The Phase 1 HCVS will function for those accident conditions for which containment venting is relied upon to reduce the probability of containment failure, including accident sequences that result in the loss of active containment heat removal capability during an extended loss of alternating current power.
The BFN, Unit 1, Phase 2 HCVS provides a reliable containment venting strategy that makes it unlikely that the plant would need to vent from the containment drywell before alternative reliable containment heat removal and pressure control is reestablished. The BFN, Unit 1, Phase 2 HCVS strategies implement SAWA with SAWM as an alternative venting strategy. This strategy consists of the use of the Phase 1 wetwell vent and SAWA hardware to implement a water management strategy that will preserve the wetwell vent path until alternate reliable containment heat removal can be established.
CNL-19-003                                      E-11

The BFN, Unit 1, Phase 1 and Phase 2 HCVS strategies are in compliance with Order EA-13-109. The modifications required to support the HCVS strategies for BFN, Unit 1, have been fully implemented in accordance with the station processes.
HCVS PHASE 1 AND PHASE 2 QUALITY STANDARDS - COMPLETE The design and operational considerations of the Phase 1 and Phase 2 HCVS installed at BFN, Unit 1, comply with the requirements specified in the Order and described in NEI 13-02, Revision 1, Industry Guidance for Compliance with Order EA-13-109.
NEI-13-02, Revision 1, was endorsed, in part, by the NRCs Japan Lessons-Learned Project Directorate (JLD) Interim Staff Guidance (ISG), JLD-ISG-2015-01, Revision 0, as an acceptable means for implementing the requirements of Order EA-13-109 (Reference 15).
The Phase 1 and Phase 2 HCVS has been installed in accordance with the station design control process.
The Phase 1 and Phase 2 HCVS components, including piping, piping supports, containment isolation valves, containment isolation valve actuators and containment isolation valve position indication, have been designed consistent with the design basis of the plant. All other Phase 1 and Phase 2 HCVS components including electrical power supply, valve actuator pneumatic supply, and instrumentation have been designed for reliable and rugged performance that is capable of ensuring Phase 1 and Phase 2 HCVS functionality following a seismic event.
HCVS PHASE 1 AND PHASE 2 PROGRAMMATIC FEATURES - COMPLETE Storage of portable equipment for BFN, Unit 1, Phase 1 and Phase 2 HCVS use provides adequate protection from applicable site hazards, and identified paths and deployment areas will be accessible during all modes of operation and during severe accidents, as recommended in NEI 13-02, Revision 1, Section 6.1.2.
Training in the use of the Phase 1 and Phase 2 HCVS for BFN, Unit 1, has been completed in accordance with an accepted training process as recommended in NEI 13-02, Revision 1, Section 6.1.3.
Operating and maintenance procedures for BFN, Unit 1, have been developed and integrated with existing procedures to ensure safe operation of the Phase 1 and Phase 2 HCVS. Procedures have been verified and are available for use in accordance with the site procedure control program.
Site processes have been established to ensure the Phase 1 and Phase 2 HCVS is tested and maintained as recommended in NEI 13-02, Revision 1, Sections 6.1.2 and 6.2.
BFN, Unit 1, has completed validation in accordance with industry developed guidance to assure required tasks, manual actions, and decisions for HCVS strategies are feasible and may be executed within the constraints identified in the HCVS Phase 1 and Phase 2 OIP for Order EA-13-109 (Reference 5).
BFN, Unit 1, has completed evaluations to confirm accessibility, habitability, staffing sufficiency, and communication capability in accordance with NEI 13-02, Sections 4.2.2 and 4.2.3.
CNL-19-003                                    E-12

==REFERENCES:==

The following references support the BFN, Unit 1, compliance with the requirements of Order EA-13-109:
: 1. NRC Order Number EA-13-109, Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions, dated June 6, 2013 (ML13143A321).
: 2. Letter from TVA to NRC, Tennessee Valley Authoritys Phase 1 Overall Integrated Plan in Response to June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident (Order Number EA-13-109), dated June 30, 2014 (ML14181B169)
: 3. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant First Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 19, 2014 (ML14353A428)
: 4. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant Second Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 29, 2015 (ML15181A338)
: 5. Letter from TVA to NRC, Tennessee Valley Authority's Browns Ferry Nuclear Plant Third Six-Month Status Report and Phase 1 and Phase 2 Overall Integrated Plan in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 29, 2015 (ML15365A554)
: 6. Letter from TVA to NRC Tennessee Valley Authoritys Browns Ferry Nuclear Plant Fourth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2016 (ML16182A517)
: 7. Letter from TVA to NRC Tennessee Valley Authority Browns Ferry Nuclear Plants Fifth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 22, 2016 (ML16357A577).
: 8. Letter from TVA to NRC Tennessee Valley Authority Browns Ferry Nuclear Plants Sixth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 30, 2017 (ML17181A333).
CNL-19-003                                   E-13
: 9. Letter from TVA to NRC Tennessee Valley Authority Browns Ferry Nuclear Plants Seventh Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 20, 2017 (ML17354A250).
: 10. Letter from TVA to NRC Tennessee Valley Authority Browns Ferry Nuclear Plants Eighth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated June 27, 1018 (ML18179A139).
: 11. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 1 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (TAC Nos. MF4540, MF4541, and MF4542), dated February 11, 2015 (ML14356A362)
: 12. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Phase 2 of Order EA-13-109 (Severe Accident Capable Hardened Vents) (CAC Nos. MF4540, MF4541, and MF4542), dated September 6, 2016 (ML16244A762)
: 13. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Report for the Audit of Licensee Responses to Interim Staff Evaluations Open Items Related to NRC Order EA-13-109 To Modify Licenses With Regard To Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (CAC Nos. MF4540, MF4541, and MF4542; EPID L-2014-JLD-0044), dated February 21, 2018 (ML18038B606)
: 14. Letter from TVA to NRC, Tennessee Valley Authority Browns Ferry Nuclear Plants Ninth Six-Month Status Report in Response to the June 6, 2013 Commission Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109), dated December 27, 2018 (ML18361A801)
: 15. NRC Interim Staff Guidance JLD-ISG-2015-01, "Compliance with Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," Revision 0, dated April 29, 2015 (ML15104A118)
CNL-19-003                                   E-14}}