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Ninth Six-Month Status Report in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events(Order No. EA-12-049)
	ML17243A299
Person / Time
Site:	Browns Ferry
Issue date:	08/31/2017
From:	James Shea; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNL-17-107, EA-12-049, TAC MF0902, TAC MF0903, TAC MF0904
	Download: ML17243A299 (19)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-17-107 August 31, 2017 10 CFR 2.202 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 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:

Ninth Six-Month Status Report in Response to the March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904)

References:

1. NRC Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A735)

2. NRC Interim Staff Guidance JLD-ISG-2012-01, Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, Revision 0, dated August 29, 2012 (ML12229A174)

3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, dated August 2012 (ML12242A378)

4. Letter from TVA to NRC, Tennessee Valley Authority - Initial Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 29, 2012 (ML12307A104)

U.S. Nuclear Regulatory Commission CNL-17-107 Page 2 August 31, 2017

5. Letter from TVA to NRC, Tennessee Valley Authority (TVA) - Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant, dated February 28, 2013 (ML13064A465)

6. Letter from TVA to NRC, First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant, dated August 28, 2013 (ML13247A284)

7. 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 Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0902, MF0903, and MF0904), dated December 19, 2013 (ML13225A541)

8. Letter from TVA to NRC, Second Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 28, 2014 (ML14064A240)

9. Letter from TVA to NRC, "Third Six-Month Status Report and Revised Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 28, 2014 (ML14248A496)

10. Letter from TVA to NRC, Fourth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 27, 2015 (ML15064A162)

11. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -

Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 (TAC Nos. MF0902, MF0903, MF0904, MF0881, MF0882, and MF0883), dated April 6, 2015 (ML15069A358)

U.S. Nuclear Regulatory Commission CNL-17-107 Page 3 August 31, 2017

12. Letter from TVA to NRC, Fifth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 28, 2015 (ML15240A228)

13. Letter from TVA to NRC, Sixth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 26, 2016 (ML16063A470)

14. Letter from TVA to NRC, Seventh Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 26, 2016 (ML16242A030)

15. Letter from TVA to NRC, Eighth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 28, 2017 (ML17060A187)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference 1) to Tennessee Valley Authority (TVA). Reference 1 was immediately effective and directed TVA to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities following a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan (OIP) pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document Nuclear Energy Institute (NEI) 12-06 Revision 0 (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the TVA initial status report regarding mitigation strategies. Reference 5 provided the TVA Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3 OIP. Reference 9 provided Revision 1 of the OIP.

U.S. Nuclear Regulatory Commission CNL-17-107 Page4 August 31, 2017 Reference 1 requires submission of a status report at six-month intervals following submittal of the OIP. Reference 3 provides direction regarding the content of the status reports. TVA provided the first six-month status report on August 28, 2013 (Reference 6). The NRG issued its Interim Staff Evaluation regarding TVA's OIP on December 19, 2013 (Reference 7). TVA has provided the subsequent six-month status reports in References 8 through 10, and 12 through 15. Additionally, Revision 1 of the OIP was provided in Reference 9. The NRG issued its onsite Audit Report on April 6, 2015 (Reference 11 ).

The purpose of this letter is to provide the ninth six-month status report pursuant to Section IV, Condition C.2, of Reference 1. The enclosed report provides an update of milestone accomplishments since submittal of the eighth six-month status report, including any changes to the compliance method or schedule.

There are no new regulatory commitments contained in this letter. If you have any question regarding this submittal, please contact Mike Oliver at (256) 729-7874.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31st day of August 2017 .

. Shea Vi e President, Nuclear Regulatory Affairs & Support Services

Enclosure:

Tennessee Valley Authority Browns Ferry Nuclear Plant's Ninth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) cc (Enclosure):

NRR Director - NRG Headquarters NRO Director - NRG Headquarters NRG JLD Director - NRG Headquarters NRG Regional Administrator - Region II NRG Project Manager - Browns Ferry Nuclear Plant NRG JLD Project Manager - Browns Ferry Nuclear Plant NRG Senior Resident Inspector - Browns Ferry Nuclear Plant

ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANTS NINTH SIX-MONTH STATUS REPORT IN RESPONSE TO THE MARCH 12, 2012, COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (ORDER NUMBER EA-12-049) 1 Introduction In response to Order EA-12-049 (Reference 2 in Section 8), Browns Ferry Nuclear Plant (BFN) developed an Overall Integrated Plan (OIP) (Reference 1 in Section 8) documenting the diverse and flexible strategies (FLEX). OIP Revision 1 was submitted with the third six-month status report (Reference 7 in Section 8). This enclosure provides an update of milestone accomplishments since the submittal of the eighth six-month status report (Reference 14 in Section 8) regarding the OIP, including any changes to the compliance method or schedule.

2 Milestone Accomplishments The following milestones have been completed since the submittal of the eighth six-month status report regarding the OIP. Milestone accomplishments are current as of August 21, 2017.

Unit 2 FLEX Implementation 3 Milestone Schedule The following provides an update to Attachment 2, Milestones, of OIP Revision 1. The update provides the activity status of each item and whether the target date has changed.

The target completion dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates do not impact the order implementation date.

CNL-17-107 Enclosure - Page 1 of 15

Revised Original Target Target Activity Activity Status Date Completion Date Submit Overall Integrated Plan February 2013 Complete Submit 6 Month Updates:

Update 1 August 2013 Complete Update 2 February 2014 Complete Update 3 August 2014 Complete Update 4 February 2015 Complete Update 5 August 2015 Complete Update 6 February 2016 Complete Update 7 August 2016 Complete Update 8 February 2017 Complete Update 9 August 2017 Complete Update 10 February 2018 Not Started FLEX Strategy Evaluation March 2014 Complete Unit 1 - Validation of connection points for FLEX Phase 2 & 3 via November 2016 Complete walkthrough or demonstration.

(Graded approach)

Unit 2 - Validation of connection points for FLEX Phase 2 & 3 via April 2015 Complete walkthrough or demonstration.

(Graded approach)

Unit 3 - Validation of connection points for FLEX Phase 2 & 3 via April 2016 Complete walkthrough or demonstration.

(Graded approach)

Perform Staffing Analysis January 2015 Complete Modifications:

Modifications Evaluation March 2014 Complete Unit 1 N-1 Walkdown October 2014 Complete Unit 1 Design Engineering November 2014 Complete Unit 1 Implementation Outage November 2016 Complete Unit 2 N-1 Walkdown March 2013 Complete Unit 2 Design Engineering December 2014 Complete Unit 2 Implementation Outage April 2015 Complete Unit 3 N-1 Walkdown March 2014 Complete Unit 3 Design Engineering November 2014 Complete Unit 3 Implementation Outage April 2016 Complete Storage:

Storage Design Engineering August 2014 Complete Storage Implementation April 2015 Complete FLEX Equipment:

Procure On-Site Equipment January 2015 Complete Develop Strategies with RRC February 2015 Complete Identify Off-Site Delivery Station April 2015 Complete Procedures:

CNL-17-107 Enclosure - Page 2 of 15

Revised Original Target Target Activity Activity Status Date Completion Date BWROG issues FSG guidelines April 2014 Complete Create Browns Ferry FSIs April 2015 Complete Create Maintenance Procedures April 2015 Complete Training:

Develop Training Plan December 2014 Complete Implement Training February 2015 Complete Unit 1 FLEX Implementation November 2016 Complete Unit 2 FLEX Implementation April 2015 Complete April 2017 Unit 3 FLEX Implementation April 2016 In-Progress April 2018 Full Site FLEX Implementation November 2016 In-Progress April 2018 Submit Completion Report December 2016 Not Started May 2018 4 Changes to Compliance Method The following is a list of changes made to the information provided in OIP Revision 1 (Reference 7 in Section 8) and not provided in previous 6 month updates. These changes meet the NEI 12-06 compliance method.

4.1 Section 4, discussion of time constraints identified in Attachment 1A table, revised to read as follows:

Item 15: Units 1 and 2 are equipped with a Hardened Containment Vent System that complies with NRC Order EA-13-109 Phase 1. Unit 3 is scheduled to be in compliance in April 2018 and will rely on the existing Hardened Wetwell Vent System venting capabilities in the interim.

4.2 Section 13, Maintain Containment, BWR Installed Equipment Phase 1, revised to read as follows:

For Unit 3, the current, as-designed Hardened Wetwell Vent System (HWWV) is capable of preventing the pressure in the pressure suppression chamber (torus) from exceeding the primary containment pressure limit of 56 psig by releasing 1 percent thermal power. This vent will later be modified in accordance with the schedule for NRC Order EA-13-109, Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions. The revised schedule and implementation timeline contained in NRC Order EA-13-109 impacts the ability to achieve full implementation of the mitigations strategy requirements of NRC Order EA-12-049 with respect to current required dates for Unit 3. Relaxation and request for extension of the requirements contained in NRC Order EA-12-049 has been approved (References 8 and 9 in Section 8). In the interim, the primary strategy for maintaining containment is through the use of the current as-designed HWWV to remove heat from the Suppression Pool.

For Units 1 and 2, modifications have been completed that implement a reliable, severe accident capable Hardened Containment Vent System (HCVS) wetwell path, capable of releasing 1 percent thermal power at a power uprate of 3952 MWt, to ensure compliance with NRC Order EA-12-049 and Phase 1 of EA-13-109.

CNL-17-107 Enclosure - Page 3 of 15

4.3 Section 14, Maintain Containment, BWR Portable Equipment Phase 2, revised to read as follows:

The Phase 2 strategy to maintain containment uses the Unit 3 Hardened Wetwell Vent System (HWWV) and the Units 1 and 2 Hardened Containment Vent System (HCVS) for torus (wetwell) venting to maintain containment parameters within EOI limits. This is a continuation of the Phase 1 strategy, with the addition of portable 4kV or 480V FLEX Generator as discussed in Section 11, Maintain Core Cooling, BWR Portable Equipment Phase 2 section.

The HWWV/HCVS are normally powered from the Class 1E Unit Batteries. As described in Section 11, Maintain Core Cooling, BWR Portable Equipment Phase 2 section, the 4kV or 480V FLEX Generator will be deployed to provide power to all 3 Unit Battery Chargers to maintain sufficient battery power to operate the HCVS DC solenoids. In addition, the Units 1 and 2 HCVS includes an independent battery bank, charger, and distribution equipment with the ability to power all required HCVS equipment for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . An alternate HCVS motive air supply from nitrogen bottles is also provided to assure 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of operation without bottle change out. If necessary, these independent systems can be manually aligned to provide power/motive force to the HCVS system.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation TVA requested and received relaxation from full implementation until the completion of the Spring 2017 refueling outage for BFN Unit 2 and the spring 2018 refueling outage for BFN Unit 3 to allow sufficient time to implement a severe accident capable hardened containment wetwell vent (References 8 and 9 in Section 8). The Milestone Schedule (Section 3 and OIP Attachment 2) has been revised to reflect this relaxation.

6 Open Items from Overall Integrated Plan and NRC Evaluation The following tables provide a summary of the open items documented in the OIP or the NRC Evaluation and the status of each item.

Overall Integrated Plan Open Item Status OI-1: Flood and seismic Open pending NRC review. No further TVA action required.

re-evaluations pursuant The flood and seismic reevaluations pursuant to the 10 CFR to the 10 CFR 50.54(f) letter 50.54(f) letter of March 12, 2012 are complete. Reference of March 12, 2012 are not TVA to NRC letter, Flood Hazard Reevaluation Report for completed and therefore not Browns Ferry Nuclear Plant, Response to NRC Request for assumed in this submittal.

Information Pursuant to Title 10 of the Code of Federal As the re-evaluations are Regulations 50.54(f) Regarding Recommendations 2.1, 2.3 completed, appropriate and 9.3 of the NearTerm Task Force Review of Insights issues will be entered into from the Fukushima Daiichi Accident, dated March 12, the corrective action system 2015; and calculation BFN Expedited Seismic Evaluation and addressed.

Process (ESEP) HCLPF [High-Confidence-of-Low-Probability-of-Failure] Capacity Evaluations, CDQ0009992014000268 R2, respectively.

CNL-17-107 Enclosure - Page 4 of 15

Overall Integrated Plan Open Item Status OI-2: Liquefaction of haul routes Closed - A liquefaction study for path from Staging Area B to for FLEX will be analyzed the West Access Portal was performed by Amec from Staging Area B to Environment and Infrastructure Inc. and documented in their Staging Area A. Also, an report dated August 19, 2014. The report concluded that evaluation will be conducted liquefaction induced settlement will not exceed 2.5 and of haul routes from Staging cracking due to lateral spreading will be insignificant. The Area D and Staging Area C Staging Areas inside the Protected Area (PA) were to Staging Area B. evaluated during construction of ISFSI Pad, and it was determined that there would be no significant displacement

(< 1.0) due to SSE seismic event (Ref Calc No.

CDQ007920030261, Soil Structure Interaction Analysis for BFN ISFSI Pad ). Therefore, it can be concluded that paths to the staging areas inside the protected area will not be susceptible to any significant deformations that would impact deployment of FLEX Equipment after any severe seismic event.

OI-3: TVA will confirm that they Closed - The duration of the ELAP is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and all have enough fuel onsite for permanent plant sources of AC power are considered the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . A diesel unavailable. The T/Gs will burn No. 2 Diesel Fuel at a full fuel storage and refueling load consumption rate of 110 gallons/hour per T/G. The plan also has to be T/Gs are not provided with their own fuel oil storage tanks.

developed. Two portable trailer mounted Transcube fuel oil storage tanks with 1200 gallon of No. 2 Diesel Fuel each will be stored in the FESB and available for deployment with the 480V and 4kV generator sets. Each Transcube will be equipped with adequate hose, valves, manual priming pump, and compatible connections necessary to support initial generator operation. One dedicated Transcube for the 480V generator will provide adequate fuel for the first 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months of operation, and one shared Transcube between the two 4kV generators will provide adequate fuel for the first 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . Three Gorman-Rupp portable diesel engine driven self-priming centrifugal diesel fuel pumps will be stored in the FESB. These pumps can be staged to transfer fuel oil from any of the eight Diesel 7 Day fuel oil storage tanks with a Technical Specifications minimum capacity of >35,280 gallons each or from one of two fuel oil storage tank located on the east side of the plant. The total combined Technical Specification minimum volume for the 8 installed EDGs is 282,240 gallons.

CNL-17-107 Enclosure - Page 5 of 15

Overall Integrated Plan Open Item Status OI-4: BFN will evaluate SRV Open pending NRC review. No further TVA action required.

qualification against the Based on review of Environmental Qualification (EQ) predicted containment BFNEQSOL009 D4 for the SRV solenoid, testing results response with FLEX indicate that the SRV solenoid will actuate sufficiently with implementation to ensure the following DC bus voltage and pneumatic pressure there will be sufficient supply:

DC bus voltage and pneumatic pressure to Drywell Temperature < 340°F operate the SRVs Pressure at least 45 psig > containment pressure throughout Phase 1 and Phase 2. DC voltage > 105 VDC MAAP analysis calculation NDN0009992014000242 provides accident progression timelines for cases that predict peak Drywell temperatures to be less than 317°F, which is well within qualifications (340°F).

TVA calculation MDQ0009992014000239 provides sizing and requirements for the alternate nitrogen system to ensure adequate 100 psig pneumatic supply is available under Beyond Design Basis External Event (BDBEE) conditions.

DCNs 71387, 70810, & 71386 (for Units 1, 2 & 3, respectively) have been completed that provides an alternate nitrogen supply to each of the two Drywell control air headers on each unit.

CNL-17-107 Enclosure - Page 6 of 15

Overall Integrated Plan Open Item Status OI-5: A reference source for the Closed - 1/2/3-FSI-6C, Key Instrument Readings During plant operators will be Loss of DC Power, are new FLEX procedures that have developed that provides been developed to provide guidance during a BDBEE with approaches to obtaining the loss of instrument power. A 3-Tiered approach to FLEX necessary instrument measurement strategies as follows (all three tiers may not be readings to support applicable for every measurement to be obtained):

the implementation of TIER 1: Provide power to primary instruments (i.e.,

the coping strategy transmitter or RTD) and measure at locations directly (NE 12-06, Section 3.2.1.1 accessible from the Control Bay. These locations are the 0). This reference source Auxiliary Instrument Rooms or Electric Board Rooms.

should include control room Primary instrument wiring would be lifted and handheld and non-control room devices connected which provide both power and measuring readouts and should also capabilities.

provide guidance on how and where to measure key TIER 2: Provide power to primary instruments and measure instrument readings at at Reactor Building locations. These locations are within containment penetrations, Secondary Containment. Primary instrument wiring would where applicable, using a be lifted and handheld devices connected which provide both portable instrument (e.g., a power and measuring capabilities.

Fluke meter). Such a TIER 3: Provide alternate instruments to measure the resource could be provided desired parameters as close to the process as is practical.

as an attachment to the plant procedures/guidance.

Guidance will include critical actions to perform until alternate indications can be connected and on how to control critical equipment without associated control power.

OI-6: Validate the preliminary Closed - Calculation EDQ0009992013000202, 250V DC Unit Battery studies that were Batteries 1, 2 & 3 Evaluation for BDBEE Extended Loss of performed to ensure AC Power (ELAP), documents the load calculation for the appropriate battery life will 250 volt unit batteries. This load study strips nonessential be available with regards to loads to allow BFN Units 1, 2, & 3 to last 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

the overall FLEX strategies.

DCN 71470 is the modification that procures fans for Ensure that buildup of installation in the battery rooms during a beyond design hydrogen is considered and basis event to account for the hydrogen production during mitigated appropriately.

battery off gassing during battery charging.

Flex procedure 0-FSI-4A, Control Bay/Reactor Building Lighting And Ventilation During ELAP, installs the fans during a beyond design basis event in the battery rooms on elevation 1C (593) in the control bay.

CNL-17-107 Enclosure - Page 7 of 15

Overall Integrated Plan Open Item Status OI-7: BFN will take actions as Open pending NRC review. No further TVA action required.

necessary to assure RCIC In order to ensure continued operation with high RCIC room can operate at elevated temperatures, 2 Emergency Operating Instruction (EOI) temperatures.

appendices are directed to be performed by the Station Blackout (SBO) flowchart. EOI Appendix-16K is performed to bypass the RCIC area high temperature isolations.

EOI Appendix-20M is performed, and it contains steps to disable the RCIC electronic governor and control flow with the RCIC trip/throttle valve, FCV-71-9. The electronic governor is susceptible to failure at room temperatures above 150°F, which occurs at approximately 7.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months into the event. These appendices are performed as soon as the SBO flowchart is entered. In order to ensure continued operation with high suppression pool temperatures, DCN 71329 included a connection point from the Emergency Equipment Cooling Water (EECW) header, which will supply cooling water to the RCIC oil cooler. This allows the normal cooling water supply (suppression pool) to be valved out and cooler water from the FLEX pumps via the EECW header to be valved in.

OI-8: Perform modifications, as Closed - Reactor Core Isolation Cooling (RCIC) system has necessary, to ensure that been evaluated using the Expedited Seismic Evaluation RCIC is seismically robust. Process (ESEP). Calculation CDQ0009992014000268, BFN Expedited Seismic Evaluation Process (ESEP) HCLPF Capacity Evaluations, has determined that the RCIC system is seismically rugged and complies with the requirements of BFN FLEX Strategies. Based on the conservative evaluation documented in this calculation, BFN Units 1, 2, & 3 meet all seismic capacity requirements for ESEP. The ESEP review performed for BFN Units 1, 2, & 3 was summarized in AREVA Inc. Document No. 51-9230498 Rev. 1, Expedited Seismic Evaluation Process (ESEP) Summary Report for Browns Ferry Nuclear Plant, dated December 10, 2014.

CNL-17-107 Enclosure - Page 8 of 15

Overall Integrated Plan Open Item Status OI-9: Develop and perform the Closed - DCN 71329 installed connection points in the B design modifications EECW pump room, D Residual Heat Removal Service identified in the FLEX Water (RHRSW) pump room, and the B RHRSW pump Strategy document to permit room for connection of the portable FLEX pump systems.

the timely and safe This DCN also established a connection point and isolation connection of the FLEX and for the RCIC oil coolers. FLEX Support Instructions (FSIs)

NSRC equipment during the direct the connections and operation of FLEX pump systems.

adverse conditions DCN 71454 installed a pump deployment path from the encountered during these FESB to the new FLEX Pump Deployment pads at the Intake beyond design basis events.

Pump Station forebay. 0-FSI-6A, Damage Assessment, (Ref. 13n) provides guidance during a BDBEE. Steps are directed to identify issues that will impede deployment of equipment and implementation of FLEX strategies.

OI-10: Design and construct a Closed - Flex Mitigation System Design Criteria Flexible Equipment Storage BFN-50-7360 identifies the design attributes and storage Building, located above the requirements for the FESB.

probable maximum flood DCN 70745 implemented the design of the building which level, which is adequately complies with the Flex Design Criteria.

protected from the hazards listed in Section 1.

OI-11: Modify currently installed Closed - Proposed modifications to the existing Hardened hardened wetwell vent to Wet Well Vent (HWWV) to comply with NRC Order install backup pneumatic EA-13-109 includes the design for a backup pneumatic supply or provided supply for operation of the Hardened Containment Vent procedural guidance for System (HCVS) valves (FCV-064-0221 & 0222) during an manual operation, to allow BDBEE. However, compliance with Order EA-13-109 does use within current design not support implementation schedule of the FLEX Order limits. EA-12-049. Based on the difference in implementation schedules between Orders EA-13-109 and EA-12-049, BFN has requested and received a relaxation for full compliance with Order EA-12-049.

Valves FCV-064-0221 and -0222 have the ability to be manually operated based on the design implemented under GL 89-16, Installation of a Hardened Wetwell Vent. The event in which operation of the HCVS valves would be needed is a BDBEE. Operations would be performing actions as needed to maintain the plant in a safe condition, and operation of components to vent containment would be performed in accordance with procedure 2-EOI Appendix 13, Emergency Venting Primary Containment. Since the plant is performing mitigation strategies and fuel damage has not occurred, environmental conditions in the area would allow access to the valves for operation.

CNL-17-107 Enclosure - Page 9 of 15

Overall Integrated Plan Open Item Status OI-12: Design and install the Closed - The design and implementation of the Spent Fuel modifications required by Pool Level Instrumentation was completed in accordance Order EA-12-051 for with Engineering Change Packages DCN 71159, DCN enhancing the SFP. 71160, and DCN 71161 for BFN Units 1, 2, & 3, respectively.

The applicable codes, standards, regulatory requirements, and procedures are spelled out within the stated DCNs.

OI-13: Determine the design Closed - BFN has two Ford F550 trucks equipped with specifications for FLEX scraper blades and winches for debris removal and one equipment yet to be ordered, compact track loader CAT 299D for debris removal.

such as the six Portable DCN 71470 provided a 480v supply and connection strategy Ventilation Fans, the Mobil to portable lighting and ventilation during a BDBEE.

Water Purification Unit, 20 Smithlight Battery operated LED work lights were debris removal equipment provided in the DCN.

for the FLEX Equipment Haul path and piping for the A total of 12 fans were provided in the DCN and will be FLEX low pressure pumps. deployed and operated using 0-FSI-4A in the Control Bay.

Fan Quantity TA16-5000 3 Coppus Vano 3 175CV Coppus Vano 2 250CV Pedestal Fan 3 30 inch Barrel Fan 1 CNL-17-107 Enclosure - Page 10 of 15

Overall Integrated Plan Open Item Status OI-14: Deployment strategies and Closed - DCN 70745 (Site Bunker Building), DCN 71454 deployment routes will be (Install Deployment Roads and Pump Landings), DCN 71405 assessed for impact due to (Stage 4kv Diesels for Fukushima Event and Provide identified hazards and Connection Points), and DCN 71470 (Stage 480v power guidance supply and support equipment to charge the Unit Battery developed/provided to Chargers) have ensured sufficient area is available for ensure that 1) sufficient area deployment. Additionally, all deployment accessories such is available for deployment, as pumps, ramps, winches, and other transfer assemblies

2) haul paths remain such as equipment trailers, as appropriate, have been accessible without assessed and are included to ensure OIP timeframes are interference from outage met.

equipment during refueling Haul paths and deployment pads will be observed daily outages and 3) deployment during Nuclear Security rounds to ensure both paths and locations for the pumps pads are accessible without interference.

including ramps, winches or other transfer assemblies as appropriate to deploy all pumps and hoses within the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Phase 1 coping interval.

CNL-17-107 Enclosure - Page 11 of 15

OI-15: Detailed staffing studies Closed - Browns Ferry Nuclear Plant has completed a based on the Phase 2 ELAP ERO Staffing Analysis Report in accordance procedures/guidance with NEI 12-01. The analysis concluded the on-shift ERO developed. staffing present for the no-site access 6-hour time period is sufficient to perform the FSI, EOI, and emergency response tasks.

OI-16. Validation of the time lines Closed - Validation of the time lines for the various for the various strategies. strategies was performed in accordance with 0-FSI-8B, FLEX Strategy Validation Process (Ref. 13s). This FSI utilized NEI 14-01 FLEX Validation Process as a reference.

OI-17: Browns Ferry Nuclear Closed - BFN has utilized the industry-developed guidance Plant (BFN) will utilize the from the BWROG, EPRI, and NEI Task team to develop industry developed site specific procedures that addressed the criteria in guidance from the Owners NEI 12-06 (Ref. 6). Procedure 0-AOI-57-1A, Loss Of Groups, EPRI and NEI Offsite Power (161 and 500 KV)/Station Blackout, the Task team to develop site EOI appendices, and the FSIs support the existing specific procedures or symptom-based command and control strategies in the guidelines to address the current EOIs.

criteria in NEI 12-06.

These procedures and/or guidelines will support the existing symptom based command and control strategies in the current EOIs.

OI-18: New training of general Closed - Procedure TRN-30, Radiological Emergency station staff and EP will be Preparedness Training, requires the Emergency performed prior to the first Preparedness responders to complete INPO Generic Basic BFN unit design Flex Training (NANTEL 00002382), and, for persons implementation outage. assigned key positions, the INPO Generic Advanced Flex These programs and Training (NANTEL 00002385). Training requirements by controls will be position are listed in TRN-30, Attachment 3. This TRN was implemented in developed in accordance with the Systematic Approach to accordance with the Training (SAT).

Systematic Approach to Additional overview training was developed for Training.

Maintenance personnel that may be asked to deploy and connect equipment in various scenarios. This training was developed using the SAT process and approved by the respective Maintenance training oversight committees. The Technical training organizations also documented Training Needs Analysis for their groups with conclusions being that Nantel Basic FLEX overview is sufficient at this time.

CNL-17-107 Enclosure - Page 12 of 15

OI-19: TVA will establish a Closed - A contract has been established between TVA and contract with the Strategic the SAFER team, AREVA Inc. Document No. 51-9233061 Alliance for FLEX Rev. 0, Browns Ferry Nuclear Plant SAFER Response Emergency Response Plan. Two off-site local staging areas have been identified, (SAFER) team. A local and one onsite staging area has been identified. The assembly area must also onsite staging area (Staging Area B) is located in the be established by SAFER Northeast corner of the Owner Controlled Area at the and TVA for equipment Facility and Vehicles Maintenance Shop. The two off-site moved from the National staging areas are TVA Helicopter Operations at the SAFER Response Center Northwest Alabama Regional Airport (Staging Area C) in (NSRC) to BFN. Muscle Shoals, Alabama, and at the Pryor Field Regional Airport (Staging Area D) in Decatur, Alabama.

OI-20: Evaluate different Closed - New procedures 1/2/3-EOI Appendix-20K, strategies to allow removal Suppression Pool Pump Down Using RCIC (FLEX), utilize of water from the RCIC in test mode to pump the torus to the Condensate Suppression Pool. Storage Tanks. The required valves are dc-powered and Determine if any will be available to be operated from the Main Control modifications are required Room.

and what strategies are deemed feasible.

OI-21: Abnormal operating Closed FSI-6A, Damage Assessment, is a new FLEX procedure, AOI-100-9, procedure that has been developed to provide guidance Turbine Building Internal during a BDBEE. Steps are directed to identify issues that Flooding, provides the will impede deployment of equipment and implementation symptoms and operator of FLEX strategies. Building assessments are performed actions to be taken for this and information provided to the FLEX Response SRO, Shift condition. During Manager, or Site Emergency Director to make decisions development of based on results. Internal plant flooding will be identified, procedures to support and alternate routes are available for performance of these FLEX strategies, adequate strategies. Doors are verified unlocked and available to guidance will be given to allow access to the Control Bay and Reactor Buildings via operators to ensure their Electric Board Rooms on elevations 621 and 593.

travel paths avoid these areas.

7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

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8 References The following references support the updates to the OIP described in this attachment.

1. Letter from TVA to NRC, Tennessee Valley Authority (TVA) - Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant, dated February 28, 2013 (ML13064A465)

2. NRC Order Number EA-12-049, Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 (ML12054A735)

3. NEI 12-06 Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, dated August 21, 2012 (ML12242A378)

4. Letter from TVA to NRC, First Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant, dated August 28, 2013 (ML13247A284)

5. 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 Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0902, MF0903, and MF0904), dated December 19, 2013 (ML13225A541)

6. Letter from TVA to NRC, Second Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 28, 2014 (ML14064A240)

7. Letter from TVA to NRC, "Third Six-Month Status Report and Revised Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 28, 2014 (ML14248A496)

8. Letter from TVA to NRC, Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated August 28, 2014 (ML14247A447)

9. Letter from NRC to TVA, "Browns Ferry Nuclear Plant, Units 2 and 3 - Relaxation of the Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC Nos. MF0903 and MF0904), dated December 23, 2014 (ML14281A198).

10. Letter from TVA to NRC, "Fourth Six-Month Status Report and Revised Overall Integrated Plan in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 27, 2015 (ML15064A162).

CNL-17-107 Enclosure - Page 14 of 15

11. Letter from TVA to NRC, Fifth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 28, 2015 (ML15240A228)

12. Letter from TVA to NRC, Sixth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 26, 2016 (ML16063A470)

13. Letter from TVA to NRC, Seventh Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated August 26, 2016 (ML160242A030)

14. Letter from TVA to NRC, Eighth Six-Month Status Report in Response to the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049) for Browns Ferry Nuclear Plant (TAC Nos. MF0902, MF0903, and MF0904), dated February 28, 2017 (ML17060A187)

CNL-17-107 Enclosure - Page 15 of 15