ML18033A427

Proposed Tech Specs Re Extension of License to 40 Yrs from Issuance of OL

ML18033A427
Person / Time
Site:	Browns Ferry
Issue date:	10/24/1988
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML18033A426	List: ML18033A425 ML18033A427
References
NUDOCS 8810310081
Download: ML18033A427 (80)

Text

ENCLOSURE 1 PROPOSED OPERATING LICENSE AMENDMENT BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296 (TVA-BFN-TS-88-258)

LIST OF AFFECTED PAGES UNIT 1 DPR- 3 page 6, item 2.D page 6, item 2.E Unit' DPR-page 6, item 2.F 8810310081 861024 PDR ADOCK 05000259 PDC

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NOV 24 1981 (ll) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Safeguards Contingency Plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p). The approved Contingency Plan, which was submitted pursuant to 10 CFR 73.40, consists of documents withheld from public disclosure pursuant to 10 CFR 2.790(d) and is identified as "Browns Ferry Nuclear Power Station Safeguards Contingency Plan" dated March 1, 1979, as revised by page changes dated September 1, 1979, April 15, 1980, December 21, 1980, and March 30, 1981, as as may subsequently be revised in accordance with 10 CFR 50.54(p).

The Contingency Plan shall be fully implemented, in accordance with 10 CFR 73.40(b) within 30 days of issuance of amendment no. 73 dated June 19, 1981.

(12) The licensee is authorized to temporarily store low-level radioactive waste in an existing covered pavilion that is situated outside the security fence, as presently located, but inside the site exclusion area. The total amount of low-level waste to be stored shall not exceed 1320 curies of total activity. This authorization expires two years from the effective date of this amendment~ and is subject to all the conditions and restrictions in TVA's application dated January 21, 1980.

D. This amended license is effective as of the date of issuance and shall expire at midnight on December 20, 2013.

FOR THE ATOMIC ENERGY COMMISSION S/ A Giambusso A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Date of Issuance: DEC 20 1973 BFN-Unit 1

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FEB 12 1985 The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Safeguards Contingency Plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p). The approved Contingency Plan, which was submitted pursuant to 10 CFR 73.40, consists of documents withheld from public disclosure pursuant to 10 CFR 2.790(d) and is identified as "Browns Ferry Nuclear Power Station Safeguards Contingency Plan" dated March 1, 1979, as revised by page changes dated September 1, 1979, April 15, 1980, December 21, 1980, and March 30, 1981, and as may subsequently be revised in accordance with 10 CFR 50.54(p).

The Contingency Plan shall be fully implemented', in accordance with 10 CFR 73.40(b) within 30 days of issuance of amendment no. 70 dated June 19, 1981.

(12) The licensee is authorized to temporarily store low-level radioactive waste in an existing covered pavilion that is situated outside the security fence, as presently located, but inside the site exclusion area. The total amount of low-level waste to be stored shall not exceed 1320 curies of total activity. This authorization expires two years from the effective date of this amendment and is subject to all the conditions and restrictions in TVA's application dated January 21, 1980.

(13) Commission Order dated March 25, 1983 is modified as follows:

in Attachment 1, for item II.F.l.l and II.F.1.2 change "12/31/84" to "Prior to startup in Cycle 6."

E. This license is effective as of the date of issuance and shall expire at midnight, June 28, 2014.

FOR THE ATOMIC ENERGY'OMMISSION S/ A Giambusso A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing

Attachment:

Appendices A 6c B Technical Specifications Date of Issuance: JUN 28, 1974 BFN-Unit 2

APR 11 1985 (2) The licensee is required, upon completion of the Mark I Owners Group containment long-term program related to relief valve operation, to make such modifications on a timely basis as may be necessary to restore the original design safety margins approved for the construction permit and used for the design of the torus structures when subjected to relief valve operation."

(3) The facility may be modified as described in 'Browns Ferry Nuclear Plant Unit 3 Emergency Cor'e Cooling Systems Low Pressure Coolant Injection Modifications for Performance Improvement (October 1977)'nd as described in TVA's letter of December 28, 1977 transmitting the aforementioned report and in TVA's supplemental letter of December 13, 1978.

(4) Commission Order dated March 25, 1983 is modified as follows:

In Attachment 1, for item II.F.l.l and II.F.1.2 change "12/31/84" to "Prior to Unit 2 startup in Cycle 6."

F. This license is effective as of the date of issuance and shall expire at midnight, July 2, 2016.

FOR THE NUCLEAR REGULATORY COMMISSION

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S R C DeYoun for Roger S. Boyd, Director Division of Project Management Office of Nuclear Reactor Regulation

Attachment:

Appendices A 6 B-Technical Specifications Date of Issuance: JUL 2 1976 BFN-Unit 3

ENCLOSURE 2 PROPOSED OPERATING LICENSE AMENDMENT BROWNS FERRY NUCLEAR PLANT UNITS I, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296 (TVA-BFN-TS-88-258)

DESCRIPTION AND JUSTIFICATION FOR OPERATING LICENSE AMENDMENT TO EXTEND EXPIRATION DATE TO 40 YEARS FROM DATE OF ISSUANCE OF THE FULL-POWER LICENSE

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ENCLOSURE 2 Descri tion of Chan e TVA, pursuant to 10 CFR 50.90, requests an amendment to the BFN operating license for unit 1 (DPR-33), unit 2 (DPR-52), and unit 3 (DPR-68). Currently the BFN Operating License for units 1, 2, and 3 state that this license is effective as of the date of issuance and shall expire at midnight on May 10, 2007 (Unit 1 Item 2.D), May 10, 2007 (Unit 2 Item 2.E), and July 31, 2008 (Unit 3 Item 2.F). These dates were established as 40 years from the issuance of the respective construction permits. TVA is requesting that the subject operating license sections be amended using the following expiration dates: Unit 1 December 20, 2013; Unit 2 June 28, 2014; and Unit 3 July 2, 2016. These dates are established by taking the 40-year life from the issuance of, the respective operating license.

Reason for Chan e The current operating license expiration date is 40 years from the date of issuance of the construction permit (May 10, 1967 for units 1 and 2 and July 31, 1968 for unit 3). Because of the time required between the issuance of the construction permit and the full-power operating license for unit 1 (6 years and 7 months), unit 2 (7 years and 2 months), and unit 3 (8 years and 1 month), the effective period for the operating license would be approximately 33 years and 5 months for unit 1 and 31 years and units 2 and 3. Current NRC policy is to issue operating licenses for a ll months for 40-year period beginning with the date of issuance. The requested amendment to the expiration date of the BFN operating licenses would provide for the 40-year period of operation that the units were initially designed for.

The proposed amendment is an administrative change that allows TVA to operate BFN for the full-design life and spread the capital cost of BFN over a longer period of time. This change will effectively lower the cost of electricity and thereby benefit the residential and industrial customers'ithin TVA's service area.

Justification for Chan e The justification for this change is patterned after the suggested guidelines issued by NRC to supplement the April 30, 1985 policy letter by H. L. Thompson to H. R. Denton covering extending the operating license for nuclear power plants. These guidelines suggest that the licensee address: significant environmental impacts, equipment qualification, and technical specifications for in-service inspection and testing.

Section 103.c of the Atomic Energy Act of 1954 provides that a license is to be issued for a specified period not exceeding 40 years. 10 CFR 50.51 specifies that each license will be issued for a fixed period of time not to exceed 40 years from date of issuance. 10 CFR 50.56 and 10 CFR 50.57 allow the issuance of an operating license pursuant to 10 CFR 50.51 after the

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Enc. 2-2 construction of the facility has been substantially completed, in conformity with the construction permit, and when other provisions specified in 10 CFR 50.57 are met. The currently licensed term for the BFN Units 1, 2, and 3 is 40 years, commencing with the issuance of the construction permits.

Accounting for the time that was required for plant construction, this represents an effective operating license term of approximately 32 effective full-power years (EFPY). Consistent with section 103.c of the Atomic Energy Act and sections 50.51, 50.56 and 50.57 of the Commission's regulations, BFN seeks extensions of the operating license terms for units 1, 2, and 3 such that the fixed period of the licenses would be 40 years from the date of the issuance of the operating license.

BFN's request for extension of the operating licenses is based on the fact that a 40-year service life was considered during the design and construction of the plant. Although this does not mean that some components will not wear out during the plant lifetime, design features were incorporated which maximize the inspectability of structures, systems, and equipment.

Surveillance and maintenance practices which have been implemented in accordance with the American Society of Mechanical Engineers code and the technical specifications provide assurance that any unexpected degradation in plant equipment will be identified and corrected.

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Enc. 2-3 I. POTENTIAL ENVIRONMENTAL HEALTH A D SAFETY IMPACTS TVA has reviewed the BFN Final Environmental Statement (FES) dated June 15, 1972. As discussed below, the proposed extension of the period of facility operations poses no significant environmental effects that have not been already considered.

A. RADIOLOGICAL IMPACTS

1. General Public a ~ Po ulation Estimates As forecasted in the Final Safety Analysis Report (FSAR) of 1982, the population of the 10-mile Emergency Planning Zone (EPZ), projected to be 48,390 in 2020, has increased from 26,740 to 39,945 in 1987.

In spite of the increase, population density has remained clustered with higher density occurring in Morgan County in the urban industrial area around Decatur on the eastern edge of the EPZ and in the city of Athens in Limestone County. Decatur has experienced a population growth which has occurred predominantly to the south and east of the city outside of the 10-mile EPZ.

Limestone County has a seasonal influx of population for recreation on the Tennessee and Elk Rivers.

Other areas of the 10-mile EPZ are primarily agrarian with corresponding low density population concentration. Lawrence County is primarily agrarian with seasonal influx on the Tennessee River for recreation. Fifty new homes have been built in the Mallard Creek and Flower Hill areas of Lawrence County.

State Highway 24 in that county has been expanded from two lanes to four lanes, thereby increasing traffic flow. Lauderdale County's area of the 10-mile EPZ is primarily recreational on the Tennessee River and has seasonal influx.

Highway 24 has been expanded in the area where population density has increased. The areas of highest population density occur at or near the perimeter of the 10-mile EPZ. The predominant land users are agriculture workers which have a lower population density. With sufficient State and Federal roads and highways, there continues to be assurance that appropriate measures can be taken to protect the population in the event of a nuclear accident.

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Enc. 2-4 Potential Environmental Healt and Safet Im acts (Cont'd)

b. Dose Conse ue ces From Eff uents

1. A endix I Dose Limits Radiological impacts to offsite individuals due to releases of radioactive liquid and gaseous wastes from the plant remain well within all applicable regulatory limits.

Computed gaseous offsite doses are typically less than 10 percent of the 10 CFR 50, Appendix I, guidelines (for a three-unit plant) of 30 millirad/year gamma and 60 millirad/year beta air dose and 45 millirem/year organ dose. Computed offsite liquid doses are typically less than 15 p'ercent of the 10 CFR 50, Appendix I, guidelines of 9 millirem/year total body and 30 millirem/year organ dose.

Radioactive effluent releases are controlled by technical specification section 3.8. These specifications implement the release limits specified in 10 CFR 20 and set performance goals based on 10 CFR 50, Appendix I.

2. Pa t Sitin Criter a TVA does not expect any significant increase in the annual offsite population dose because of the operations of BFN for the years of 2007 to 2016. Doses calculated for offsite populations in the year 2016 would be about 10 percent greater than those estimated for the 2007 population. This increase would be due solely to an estimated growth of population during 2007 through 2016. However, population doses would remain less than 0.02 percent of the natural background dose to the offsite population. We expect decommissioning doses beginning in 2017 to be reduced as compared to doses that would be expected for a 2008 decommissioning due to improvements made in decommissioning technology and improved ALARA practices.

2. Occu ational Ex osure TVA has also evaluated the impact of the proposed extension on predicted radiological occupational exposures, on individual worker as low as reasonably achievable (ALARA) measures, and on 10 CFR Part 20 dose limits. Tables 2, and 3 (attached) provide data regarding occupational exposures at BFN.

a. ALARA Considerations NUREG 0713 Volume 7 reported occupational radiation exposures at 17 BWR nuclear plant. sites (25 reactors) from the period between 1981-1985. This evaluation yielded an industry average of 996 Japan rem/reactor/year. NUREG 0713 reported the occupational radiation exposures for BFN to be .737 man rem/reactor/year for the same period of time.

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Enc. 2-5 Potential Environmental Health and Safet Im acts (Cont'd)

The BFN values were below the average of U.S. boiling water nuclear generating plants. This is attributed to a management commitment to as low as reasonably achievable (ALARA) exposures. We expect that below average occupational exposures will continue to be "normal" for the life of the BFN facility.

TVA has an aggressive ALARA program at BFN. Exposure goals have been established for station man-rem to minimize collective doses. ALARA reviews and analysis are conducted for workplans for proposed jobs which are projected to exceed five man-rem.

Steps are built into the jobs to reduce dose. All proposed facility modifications receive similar reviews. Prejob briefings are held with workers to cover dose savings measures.

In addition, mock-ups are used, as appr'opriate, to train workers.

Table 1 shows TVA's historical and projected operational schedule for BFN. Table 2 shows projected occupational exposure for BFN. Table 3 shows TVA's past personnel exposure for BFN for the years 1982 through 1987. The man-rem exposure is by plant area regardless of how these exposures were obtained (normal operations, maintenance, repair or refueling operations, etc.) and by whom (plant operations/maintenance personnel, contractor/vendor personnel, etc.). This data is the same data provided yearly as required by 10 CFR 20.407(b) and BFN Technical Specification 6.9.1.2.

b. Personnel Dose Limits The above-described ALARA considerations provide assurance that occupational exposures will satisfy 10 CFR Part 20 limits during the additional years of service. Further assurance that those limits will be satisfied throughout the life of the facility is provided by existing technical specifications which require compliance with 10 CFR Part 20. In addition, one of the primary focuses of the existing Radiological Control program is to ensure compliance with 10 CFR Part 20.

B. Uranium Fuel C cle The following information is furnished consistent with 10 CFR 51.52(a):

1. The licensed reactor core thermal power limit for BFN is 3293 megawatts thermal.

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Enc. 2-6 Potential Fnvironmental

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Health and Safet Im acts (Cont'd)

2. The initial uranium-235 enrichment for fuel assemblies at BFN is less than 4 percent by weight. Fuel pellets are clad in zircaloy rods. These parameters are controlled by technical specification 1.1.

3 ~ The average expected level of burnup of the irradiated fuel from BFN is. about 32,000 megawatt-days per metric ton of uranium (MWD/MTU). This is consistent with the burnup of 10 CFR 51.52(a),

the effective levels of radioactivity from a fuel assembly with an average burnup of 32,000 MWD/MTU will be cooled for a period of time and will be within the requirements of a fuel assembly with an average burnup of 33,000 MWD/MTU that has cooled for 90 days.

4~ All radioactive waste, that will be sent to a burial facility, other than irradiated fuel, is packaged and transported in solid form by either truck or rail. BFN Technical Specification 3.8 establishes requirements for the Solid Radioactive Waste System.

5. Irradiated fuel assemblies will be transported from the BFN site either by truck, rail, or barge.

6. The transportation of radioactive material is regulated by the Department of Transportation and the NRC. The regulations provide for protection of the public and transport workers from radiation.

This protection is achieved by a combination of standards and requirements applicable to packaging, limitations on the contents of packages, radiation levels from packages, and procedures to limit the exposure of persons under normal and accident conditions.

Primary reliance for safety in transport of radioactive material is placed on the packaging. The packaging must meet regulatory standards (10 CFR 71 and 49 CFR 173), established according to the type and form of material for containment, shielding, nuclear criticality safety, and heat dissipation.

The standards provide that the packaging shall prevent the loss or dispersal of the radioactive contents, retain shielding efficiency, assure nuclear criticality safety, and provide adequate heat dissipation under normal conditions of transport and under specified accident damage test conditions. The contents of packages not designed to withstand accidents are limited, thereby limiting the risk from releases which could occur in an accident.

The contents of the package also must be limited so that the standards for external radiation levels, temperature, pressure, and containment are met.

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Furthermore, the additional amount of nuclear fuel and waste resulting from an extended operating period will continue to be within the limits assumed for the original licensing basis.

Because of improved fuel cycle designs and longer operation between refueling outages, the total amount of spent fuel produced over a 40-year operating lifetime will be less than that originally projected by the FSAR for BFN.

Based on the above, TVA concludes that the radiological impact from the transportation of irradiated fuel and solid radioactive waste is in accordance with the impacts set 'forth in Table S-1 of 10 CFR 51.52. The environmental costs will not be significantly affected during the additional years of operation.

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C. Non adio o a a ts In the approximately 16 years since the environmental statement, was issued, a number of modifications have been made to the BFN and the surrounding site and facilities. These modifications, in general, had the effect of improving the reliability and safety of the plant or reducing the environmental impact of plant operation. They include:

1. Facilities Many modifications to the plant have been made since the original operating license has been issued. Significant modifications are described in the BFN updated Final Safety Analysis Report.

Modifications made without prior NRC approval, in accordance with the provisions of 10 CFR 50.59, were reported on an annual basis to the Commission. Modifications requiring prior NRC approval were made following receipt of an NRC safety evaluation report. No modification was found to affect the conclusions of the BFN Final Environmental Statement.

2. ~and Use The use of the BFN site was considered in the FES for BFN unit 1, 2, and 3. The total area of land dedicated to the operation of the three units remains the same as originally contemplated, although the proportions used for parking, temporary storage, construction, permanent buildings, and fill areas have changed. The proposed extension does not create new or alter previously established land uses as discussed and/or evaluated in the BFN FSAR or its updates.

Thus, no new land use impacts result from the proposed extension.

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Enc. 2-8 Potential Environmental Health and Safet Im acts (Cont'd)

3. A uatic Im acts No significant aquatic impacts have been observed as a result of thermal or chemical discharges attributable to BFN or from the withdrawal of cooling water. In addition, study methodologies have changed over the years to provide improved sampling programs in order to better quantify aquatic impacts from operations at BFN.

Again, however, there is no evidence of significant aquatic impacts resulting from operations at BFN.

Thermal discharges from BFN are regulated through the National Pollutant Discharge Elimination System (NPDES) Permit. Data collected to date has indicated that the water quality and indigenous biota of Wheeler Reservoir are protected by the thermal limits specified in the NPDES Permit. Operation of BFN will continue to be in compliance with the NPDES Permit.

D. Ph sical Protection and Trainin

l. ~Secerlt BFN has implemented and will maintain in effect all provisions of the following commission approved documents, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).

These approved documents consist of information withheld from public disclosure pursuant to 10 CFR 2.790 (d):

a. "BFN Physical Security Plan" dated June 15, 1982 including revisions.

b. "BFN Safeguards Contingency Plan" initially dated June 15, 1982 and as amended and submitted pursuant to 10 CFR 73.40.

c. "BFN Guard Training and Qualification Plan" initially dated August 17, 1979 including revisions. This plan shall be implemented in accordance with 10 CFR 73.55 (b)(4). BFN may make changes to this plan without prior commission approval if the changes do not decrease the safeguards effectiveness of the plan. BFN will maintain records of and submit reports concerning such changes in the same manner as required for changes made to the Safeguards Contingency Plan pursuant to 10 CFR 50.54(p).

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2. Emer enc Pre aredness Plan BFN has implemented and will maintain throughout the plant life emergency plans which meet the standards of 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E, including amendments and changes made pursuant to the authority of 10 CFR 50.54(q). BFN will continue to meet the requirements of 10 CFR 50.54(s), 50.54(t) and 50.54(u).

3. Fire Protection BFN is currently upgrading various plant fire protection systems as identified in various documents submitted to NRC. BFN will continue to maintain in effect an adequate fire protection program throughout plant life.

4. ~ra ~nin; BFN will maintain required training programs in accordance with 10 CFR 55, INPO and BFN Technical Specifications Chapter 6.0.

These programs will be implemented throughout the life of BFN.

E. Environ e tal Assessment The above information demonstrates that there are no significant adverse impacts on the quality of the human environment which result from the proposed extension. Although some additional impacts will occur as a result of normal plant operations, none of these effects are significant. For example, additional radioactive releases associated with normal operation will occur. However, the proposed extension does not alter the fact that such releases are negligible compared to natural background regardless of the period of operation.

In addition, any adverse impacts have previously been analyzed and continue to be outweighed by the benefits attributable to extending operation.

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Enc. 2-10 II. EVALUATION OF PLANT DESIC TVA reviewed the safety analyses set forth in both the FSAR and facility technical specifications and the Commission's Safety Evaluation Report (SER), as supplemented (including the supplement for the full term operating license), for BFN. As discussed herein, structures, systems and components either are designed and maintained to perform at least for the full 40-year operating term, or are subject to detailed inspection, surveillance and maintenance requirements which provide assurance that abnormal degradation will be detected and corrective action taken. Only the reactor pressure vessel (RPV) is considered an essentially nonreplaceable plant component. TVA has determined that the RPV, consistent with its original design, will maintain its functional capability at least for the full 40-year operating term.

A. E UIPMENT UALIFICATIO The environmental qualification (EQ) program for electrical equipment operating in a harsh environment is described in section BFN Nuclear Performance Plan (NPP).

III.l of the The program ensures that EQ is maintained for electrical equipment necessary to prevent or mitigate the consequences of accidents that could result in offsite exposures comparable to the 10 CFR 100 guidelines. In addition, nonsafety-related electrical equipment whose failure under postulated harsh environmental conditions could prevent safety-related equipment from performing its intended safety function was also included in the program.

Aging analyses are being performed for all safety-related electrical equipment within the scope of 10 CFR 50.49 (harsh environment). The qualified life of the equipment or component will be incorporated within BFN's maintenance and replacement practices to ensure that the subject safety-related electrical equipment remains qualified and available to perform its intended safety function regardless of the overall age of the plant.

B. INSERVICE INSPECTION ISI AND INSERVICE TEST PROGRAMS IST TVA has ongoing ISI and IST programs for- BFN that are maintained in accordance with 10 CFR 50.55(a). The surveillance requirements for these programs are contained in the BFN Technical Specifications and are required to conform to Section XI of the ASME Boiler and Pressure Vessel Code. Where specific relief from the Section XI code was necessary, TVA has provided written relief requests to NRC for review and approval in accordance with 10 CFR 50.55(a)(g)(6)(i).

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Enc. 2-11 EVALUATION OF PLANT DESIG (cont'd)

In addition to the ISI and IST programs, the following BFN Technical Specifications also provide additional requirements for monitoring component aging and the cumulative effects of power operation over the life of the plant.

Technical S ecification .A Thermal and Pressurization Limits Temperature and pressure changes during heatup, cooldown, and during inservice hydrostatic testing of the reactor pressure vessel are limited to protect against nonductile failure. These limits were established using the methods derived from Appendix G in Section III of the ASME Boiler and Pressure Vessel Code as required by 10 CFR 50 Appendix H. Reactor vessel irradiation specimens are removed and examined at specific intervals to determine changes in material properties. The results of the examinations are used to update the pressure and temperature limits.

2 ~ echnical S ecification G Structural Inte rit 1

The ISI program for ASME Code Class 1, 2, and 3 components performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code ensure that the structural integrity of these components will be maintained at an acceptable level throughout the life of the plant.

3. Technical S ecification 1 1 Desi n Fati ue Usa e Evaluation A fatigue usage evaluation is performed for the reactor pressure vessel. The following locations are monitored: the feedwater nozzles, the shell near the water line, and the flange studs.

Transients that occur during plant operation are reviewed and a cumulative fatigue usage factor, for each location is determined.

The cumulative fatigue usage factors for each location are reported in the annual operating report. The worst cumulative usage factor experienced at BFN is less than 0.3 as of December 31, 1987. This is well below the technical specification limit of 1.0. When the cumulative usage factor reaches a value of 1.0, an inservice inspection's included for the specific location at the next scheduled inspection (3 and 1/3 year interval) and 3 and 1/3 year intervals thereafter. An evaluation is performed in accordance with the ASME Section XI Code if any flaw indications are detected and the results are submitted to NRC in a special report.

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Enc. 2-12 EVALUATION OF PLANT DESIG (cont'd)

C. REACTOR RESSURE VESSEL The original design of the reactor pressure vessel (RPV) and associated internals considered the effects of 40 years of operation within the cyclic limits given in the BFN FSAR (Section 4.2). Those cyclic limits equate to 40 years of operation at full power (MH thermal) with a plant capacity factor of 80% (i.e., 32 EFPY),

including expected operational and thermal transients. Further, the design of the RPV meets the intent of 10 CFR 50, Appendix A, GDC 31 "Fracture Prevention of Reactor Coolant Pressure Boundary". In addition, the FSAR provides that the reactor vessel shall not be exposed to more than 1019 nvt of neutrons with energies exceeding 1 mev (FSAR Section 4.2.5).

BFN technical specifications establish a reactor pressure vessel surveillance program to monitor the radiation-induced changes in the mechanical and impact properties of pressure vessel materials in accordance with 10 CFR Part 50, appendix H. Changes in the impact properties of the material contained in surveillance capsules placed inside the reactor vessel are evaluated at prescribed times using preirradiation and postirradiation Charpy impact test specimens.

Changes in mechanical properties are evaluated by a similar comparison from tensile test specimens. Three (3) representative RPV materials are evaluated: base metal; weld metal; and heat-affected zone. A complete record of the chemical analyses, fabrication history, and impact and mechanical properties of all surveillance test materials is maintained. This program provides additional assurance that adverse cumulative effects of power operation will be detected.

In summary, the RPV vessel stress analyses includes appropriate consideration of thermal transient and fatigue effects which may be expected during the extended period of operation..',Thus the RPV will not be adversely affected by the requested extension.

D. STRUCTURES AND SYSTEMS BFN structures and systems are adequately designed to accommodate a forty year operating life. BFN has applicable surveillance and maintenance procedures in place to assure that any potential degradation of functional capabilities of facility structures and systems will be detected in a timely manner, without regard to the period of authorized operation.

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Enc. 2-13 VALUATION OF PLANT DESIGN (cont'd)

1. Structures The original design basis for structures at BFN considered normal, operating static and dynamic loads, as well as accident loads due to design basis accidents and external phenomena such as earthquakes, hurricanes, and floods.

Industry experie'nce has demonstrated that reinforced concrete and steel building structures that are properly maintained do not degrade significantly with time. The structures at BFN are well maintained to prevent against problems associated with corrosion.

In addition, surveillance and maintenance measures provide assurance that any unexpected degradation of structures will be identified and corrected. Thus, the additional period of operation poses no safety concern which has not already been adequately addressed.

In addition, the containment structure has a formal inspection program that is structured to satisfy the intent of 10 CFR Part 50, Appendix J. The inspection program calls for three integrated leak rate tests (ILRT) in every ten year cycle. These tests include visual examination of both the interior and exterior surfaces for signs of deterioration which could affect structural integrity.

The containment is also pressurized and leakage is measured to insure the design functions of the containment are maintained.

These inspections are well documented and are at closely spaced intervals such that any deterioration affecting structural integrity will be noted and repaired.

.Finally, corrosion of structures exposed to the outside environment are also monitored. If any signs of deterioration are identified; appropriate repairs would be made at that time.

Based on the above considerations, the extension of the operation license for BFN should have no adverse impact. on the safety of structures.

2. ~Sstems BFN has numerous programs and procedures to provide assurance that degradation of those systems can be detected and corrected to assure necessary performance and availability throughout plant life.

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Enc. 2-14 EVALUAT ON OF PLANT DESIGN (cont'd)

One such program identifies the measures BFN is taking to mitigate Intergranular Stress Corrosion Cracking (IGSCC). This program will provide assurance of continued long-term piping integrity and reliability for each unit. The mitigation plans for each unit have been prepared in accordance with NRC positions as stated in Generic Letter 88-01 "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping." This plan addresses the three factors that cause IGSCC which consist of (1) replacement of material with resistant material when replacement is required; (2) stress improvement of welds, and (3) water chemistry improvement. BFN's detailed response and long-term IGSCC plans were submitted to NRC by TVA letter dated August 1, 1988 (L44 880801 804).

In addition to the above programs, BFN technical specifications set forth limiting conditions for operation and surveillance requirements concerning the prevention of equipment degradation, including equipment and components within the reactor pressure boundary. In accordance with technical specifications, transient and operational cycles are recorded, maintained and evaluated over the duration of the operating license. Also in-service testing and in-service inspection (IST/ISI, respectively) programs are conducted in accordance with ASME Code Section XI, as well as performance of periodic surveillance (tests, visual inspections, etc.) of safety related equipment normally in standby, programmed.

periodic maintenance, and trending of periodic test results.

Continuation of these provisions provide assurance that potential fatigue of those components will be detected and corrected in a timely manner.

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TABLE 1 BROWNS FERRY NUCLEAR POWER PLANT UNIT 1 NEW GROSS ACTUAL SCHEDULED CYCLE E(}UIVALENT CYCLE CYCLE THERHAL ELECTRICAL ELECTRICAL STARTUP SHUTOOWN OPERATING OUTAGE LENGTH FULL POWER AVAILABILITY CAPACITY OUTPUT OUTPUT OUTPUT

~Y L OATE DATE DAYS ~DAY DAYS DAYS FACTOR ~FA TOR TBTU 1 10/15/1973 9/13/1977 1429 124 1553 526.755 0.3686 0.3392 142.085 13463944 13880911 2 1/15/1978 11/26/1978 315 53 368 232.894 0.7393 0.6329 62.820 5952810 6137163 3 1/18/1979 1/02/1980 349 80 429 298.154 0.8543 0.6950 80.423 7620866 7856878 4 3/22/1980 4/10/1981 384 174 558 333.967 0.8697 0.5985 90.083 8536246 8800606 5 10/01/1981 4/16/1983 562 261 823 478.768 0.8519 0.5817 129.141 12237373 12616354 6 1/02/1984 3/19/1985 442 3497 3939 371.426 0.8403 0.0943 100.187 9493698 9787710.

7 10/15/1994 5/18/1996 581 100 681 399.023 0.6868 0.5859 107.631 10199090 10514947 8 8/26/1996 3/14/1998 565 100 665 398.994 0.7062 0.6000 107.623 10198332 10514166 9 6/22/1998 1/08/2000 565 100 665 398.971 0.7061 0.6000 107.617 10197764 10513580 10 4/17/2000 11/03/2001 565 100 665 398.964 0.7061 0.5999 107.615 10197574 10513384 ll .2/11/2002 8/30/2003 565 100 665 398.964 0.7061 0.5999 107.615 10197574 10513384 12 12/08/2003 6/25/2005 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 13 10/03/2005 4/21/2007 565 100 665 398.964 0.7061 0.5999 107.615 10197574 10513384 14 7/30/2007 2/14/2009 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 15 5/25/2009 12/11/2010 565 100 665 398.968 0.7061 0.6000 107.616 10797669 10513482 16 3/21/2011 10/08/2012 567 100 667 400.002 0.7055 0.5997 107.895 10224107 10540739 17 1/16/2013 8/06/2014 567 100 667 400.354 0.7061 0.6002 107.990 10233109 10550020 18 11/14/2014 6/01/2016 565 100 665 399.157 0.7065 0.6002 107.667 10202502 10518464 19 9/09/2016 3/28/2018 565 100 665 399.157 0.7065 0.6002 107.667 10202502 10518464 20 7/06/2018 1/22/2020 565 100 665 399.157 0.7065 0.6002 107.667 10202502 10518464 21 5/01/2020 11/17/2021 565 100 665 399.157 0.7065 0.6002 107.667 10202502 10518464 22 2/25/2022 9/13/2023 565 100 665 399.157 0.7065 0.6002 107.667 10202502 10518464 23 12/22/2023 7/09/2025 565 100 665 , 399.157 0.7065 0.6002 107.667 10202502 10518464 24 10/17/2025 5/05/2027 565 100 665 399.157 0.7065 0.6002 107.667 10202502 10518464 25 8/13/2027 2/28/2029 565 0 . 565 399.157 0.7065 0.7065 107.667 10202502 10518464

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TABLE 1 BROWNS FERRY NUCLEAR POWER PLANT UNIT 2 NEW GROSS ACTUAL SCHEDULED CYCLE EQUIVALENT CYCLE CYCLE THERHAL ELECTRICAL ELECTRICAL STARTUP SHUTDOWN OPERATING OUTAGE LENGTH FULL POWER AVAILABILITY CAPACITY OUTPUT OUTPUT OUTPUT DATE RAYS ~OAY ~OAY ~OAY ~FA TOR ~FA T R TBTIO HWH 1 8/28/1974 3/18/1978 1298 101 1399 475.279 0.3662 0.3397 128.200 12148204 12524424 2 6/27/1978 4/27/1979 304 35 339 263.750 0.8676 0.7780 71.143 6741495 6950274 3 6/01/1979 9/05/1980 462 79 541 370.013 0.8009 0.6839 99.806 9457595 9750488 4 11/23/1980 7/30/1982 614 233 847 498.483 0.8119 0.5885 134.459 12741306 13135893 5 3/20/1983 9/15/1984 545 1552 2097 414.905 0.7613 0.1979 111.915 10605041 10933470 6 12/15/1988 9/19/1990 643 200 843 436.230 0.6784 0.5175 117.667 11150099 11495408.

7 4/07/1991 12/19/1992 622 100 722 432.956 0.6961 0.5997 116.784 11066427 11409144 8 3/29/1993 10/15/1994 565 100 665 398.994 0.7062 0.6000 107.623 10198332 '0514166 9 1/23/1995 8/10/1996 565 100 665 398.971 0.7061 0.6000 107.617 10197764 10513580 10 11/18/1996 6/06/1998 565 100 665 398.971 0.7061 0.6000 107.617 10197764 10513580 11 .9/14/1998 4/01/2000 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 12 7/10/2000 1/26/2002 565 100 665 398.964 0.7061 0.5999 107.615 10197574 10513384 13 5/06/2002 11/22/2003 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 14 3/01/2004 9/17/2005 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 15 12/26/2005 7/14/2007 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 16 10/22/2007 5/09/2009 565 100 665 398.956 0.7061 0.5999 107 613 10197385 10513189 17 8/17/2009 3/05/2011 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 18 6/13/2011 12/29/2012 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 19

' 4/08/2013 10/25/2014 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 20 2/02/2015 8/20/2016 565 100 665 398.960 0.7061 0.5999 107.614 ~

10197479 10513286 21 11/28/2016 6/16/2018 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 22 9/24/2018 4/11/2020 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 23 ,7/20/2020 2/05/2022 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 24 5/16/2022 12/02/2023 565 100 665 398.960 0.7061 0.5999 107.614 10197479 10513286 25 3/11/2024 9/27/2025 565 0 565 399.960 0.7061 0.7061 107. 614 10197479 10513286

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TABLE 1 BROWNS FERRY NUCLEAR POWER PLANT UNIT 3 NEW GROSS ACTUAL SCHEDULED CYCLE EQUIVALENT CYCLE CYCLE THERHAL ELECTRICAL ELECTRICAL STARTUP SHUTDOWN OPERATING OUTAGE LENGTH FULL POWER AVAILABILITY CAPACITY OUTPUT OUTPUT OUTPUT

~Y LE DATE DATE DAYS ~OAY ~OAY DAYS ~FA TOR ~FA TOR TOTO 1 8/19/1976 9/08/1978 750 75 825 540.725 0.7210 0.6554 145.853 13820999 14249023 2 11/22/1978 8/24/1979 275 106 381 225.376 0.8195 0.5915 60.792 5760637 5939039 3 12/08/1979 11/23/1980 351 56 407 284.741 0.8112 0.6996 76.805 7278025 7503419 4 1/18/1981 10/30/1981 285 164 449 246.941 0.8665 0.5500 66.609 6311854 6507327 5 4/12/1982 9/06/1983 512 450 962 410.052 0.8009 0.4262 110.606 10481001 10805588 6 11/29/1984 3/22/1994 3400 100 3500 482.405 0.1419 0.1378 130.122 12330333 12712192.

7 6/30/1994 1/16/1996 565 100 665 398.994 0.7062 0.6000 107.623 10198332 8 4/25/1996 11/11/1997 565 100 665 398.982 0.7062 0.6000 107.620 10198048 10514166'0513873 9 2/19/1998 9/07/1999 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 10 12/16/1999 7/03/2001 565 100 665 398.960 0.7061 0.5999 107.614 10197479 ll 10/11/2001 4/29/2003 565 100 665 398.964 0.7061 0.5999 107.615 10197574 10513286 10513384 12 8/07/2003 2/22/2005 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 13 6/02/2005 12/19/2006 565 100 665 398.964 0.7061 0.5999 107.615 10197574 10513384 14 3/29/2007 10/14/2008 565 100 665 398.964 0.7061 0.5999 107.615 10197574 10513384 15 1/22/2009 8/10/2010 565 100 665 398.968 '0.7061 0.6000 107.616 10197669 10513482 16'7 11/18/2010 6/05/2012 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 9/13/2012 4/Ol/2014 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 18 7/10/2014 1/26/2016 565 100 665 398.968 0.7061 0.6000 107.616 . 10197669 10513482 19 5/05/2016 11/21/2017 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 20 3/01/2018 9/17/2019 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 21 12/26/2019 7/13/2021 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 22 10/21/2021 5/09/2023 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 23 8/17/2023 3/04/2025 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 24 6/12/2025 12/29/2026 565 100 665 398.968 0.7061 0.6000 107.616 10197669 10513482 25 4/08/2027 10/24/2028 565 0 565 398.968 0.7061 0.7061 107.616 10197669 10513482

r TABLE 2 BFN UNIT 1 Projected Occupational Exposure Man-Rem*

YEAR OUTAGE NON-OUTAGE XOTAL 2007 400 100 500 2008 No outage 240 240 2009 500 175 675 2010 100 225 325 2011 400 185 585 2012 425 185 610 2013 75 230 305

> Assumes 20 man-rem per month during non-outage and 150 man-rem per month during outage.

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Table 2 BFN Unit 2 Projected Occupational Exposure Man-Rem YEAR OUTAGE ~0 -OUTAGE TOTAL 2007 500 70 570 2008 No outage 240 240 2009 500 175 675 2010 No outage 240 240 2011 500 175 675 2012 No outage 240 240 2013 500 175 675 2014 150 220 370

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Table 2 BFN Unit 3 Projected Occupational Exposure Man-Rem YEAR OUTAGE ~0 -OUTAGE TOTAL 2008 375 50 425 2009 125 225 350 2010 500 175 675 2011 No outage 240 240 2012 500 175 675 2013 No outage 240 240 2014 500 175 675 2015 No outage 240 240 2016 500 175 675

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TABLE 3 NUMBER OF PERSONNEL AND MAN-REM BY WORK AND 308 FUNCTION PLANT: BROWNS FERRY 1 2 BWR 1982 NUMBER OF PERS NNEL )1 M-REM STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL YORK & OS PUHCTT H ~EHPL YEES EHPLOYEES ~STHER PERSOEH ~EHPLOYEE ~EHPLOYEE T OTHERS HAN-REMS REA T R OPERATIONS 5 SURV.

MAINTENANCE PER ONNEL 48 23 16.600 29.600 16.500 OPERATING PERSONNEL 90 0 22;000 0.0 0.0 HEALTH PHY ICS PERSONNEL 25 58 7.700 0.0 26.900 UPERVISORY PERSONNEL 0 0- 0.0 0.0 0.0 ENGINEERING PERSONNEL 0 0 21.600 0.

T TAL 163 15 1 3 4. 00. 51.2 0 43.40 140.900 R UTINE MAINTENANCE MAINTENANCE PERSONNEL 324 936 195 184.800 696.100 125.600 OPERATING PERSONNEL 161 0 0 75.200 0.0 0.0 HEALTH PHY I PERSONNEL 30 0 68 13.000 0.0 41.400 PERVISORY PERSONNEL 0 0 o 0 0.0 0.0 0.0 EN INEERING PERSONNEL 0 3 0 0. 45.000 TOTAL 15 102 26 1 07 27 .0 0 741. 10 167.000 11 1.100 IN-SERVICE IN PECTION HAINTENANCE PERSONNEL 0.0 0.700 0.500 OPERATING PERSONNEL 0.0 0.0 0.0 HEALTH PHY ICS PERSONNEL 0.0 0.0 0.0 UPERVISORY PERSONNEL 0.0 0.0 0.0 ENGINEERING PERS NNEL .0 0.0 0.0 TOTAL 0 0.700 00 1.2 PE IAL MAINTENAN E MAINTENANCE PER ONNEL 32 623 95 8.800 317.000 31.000 OPERATING PERSONNEL 8 0 0 1.300 0.0 0.0 HEALTH PHYSIC PERSONNEL 3 0 ll .400 0.0 3.200 SUPERVISORY PERSONNEL 0 0 0 0.0 0.0 0.0 ENGINEERING PER NNEL 0 3 0 1.'0 1.0 0.0 TOTAL 659 106 808 3 0.100 -'.220 374.800 WASTE PROCESSING MAINTENANCE PERSONNEL 26 9.300 1.000 0.0 OPERATING PERSONNEL 15 6.800 0.0 0.0 HEALTH PHYSICS PERSONNEL 5 1.700 0.0 0.900 PERVISORY PERSONNEL 0 0.0 0.0 0.0 ENGINEERIN PER ONNEL 0.0 .0 0.0 TOTAL 46 18.700 1.000 00 20 .600 REFUELING MAINTENAN E PERSONNEL 0 20 0.0 3.600 1.000 PERATING PERSONNEL 19 0 6.300 0.0 0.0 HEALTH PHYSICS PERSONNEL 0 0 0.0 0.0 0.0 T SUPERVISORY PERSONNEL 0 0 0.0 0.0 0.0 ENGINEERING PERSONNEL 0 0.0 .0 TOTAL 20 43 6.30 1.000 1.0 TOTA BY JOB FUNCTION MAINTENAN E PERSONNEL 430 1694 317 2441 219.500 1048.000 174.600 1442.100 PERATING PERS NNEL 293 0 0 293 112.200 0.0 0.0 112.200 HEALTH PHYSICS PERSONNE 63 0 139 202 22.800 0.0 72.400 95.200 PERVISORY PER NNEL 0 0 0 0 0.0 0.0 0.0 , 0.0 EN INEERING PERSONNEL 172 0 172 0 79.700 0.0 80.000 RAND TOTAL 1866 456 10 4.8 0 1127.70 247.0 1729.5 0

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TABLE 3 NUHBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWN FERRY 1 2 BWR 1983 NUMBER OF PERSONNEL (>100 H-REH) TOTAL HAN-REHS STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL H RK S JOR TUMCTIOM ~EMPT YEE ~EMPLOYEE O OOTHER ~PER ~M EHPLOYEES ~EMPLOYEE &~OTHER MLM-REHS REACTOR PERATION 8 SURV HAINTENANCE PERSONNEL 80 169 29 41.500 14.900 OPERATING PERSONNEL -

148 0 0 0.0 0.0 HEALTH PHYSICS PERSONNEL 34 0 103 0.0 54.300 UPERVISORY PERSONNEL 0 0 0 0.0 0.0 EN INEERING PERSONNEL 73 24.6 0 0.

T TAL 262 242 132 36 7 . 0 6.1 0 6 .2 210.

RO TINE HAINTEMANCE HAINTENANCE PERSONNEL 290 1090 254 154.900 940.300 167. 100 PERATING PERSONNEL 148 0 0 57.000 0.0 0.0 HEALTH PHY I S PERSONNEL 33 0 109 14.500 0.0 57.900 UPERVISORY PERSONNEL 0 0 0 0.0 0.0 0.0 EN INEERING PERSONNEL 7 0.0 38.40 0.0 TOTAL 471 2003 226.400 78.700 225. 0 1430.1 IN-SERVICE INSPECTION HAINTENANCE PER ONNEL PERATIN PERSONNEL ll 95 40 5.600 46.400 51.200 2 0 0 0.400 0.0 0.0 HEALTH PHYSICS PERSONNEL 0 0 10 0.0 0.0 2.600 SUPERVI ORY PERSONNEL 0 0 0 0.0 0.0 0.0 ENGINEERING PERSONNEL 0 2 0 0.0 .200 T TAL 50 .000 46.60 .800 10 .40 PECIAL HAINTEMANCE MAINTENANCE PERSONNE 35 753 261 12.600 406.500 319.900 OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL ll 0 0 2.200 0.0 0.0 10 0 48 2.700 0.0 23.300 S PERVISORY PERSONNEL 0 0 0 0.0 0.0 0.0 ENGINEERING PERSONNEL 29 0 0.0 .200 0.

TOTAL 782 3 9 1147 17.500 414.700 34 .20 77 .400 WA TE PROCESSING HAINTEMANCE PERSONNEL 25 9.100 1.700 0.0 OPERATING PERSONNEL 10 6.800 0.0 0.0 HEALTH PHYSICS PER NNEL 5 1.700 0.0 1.200 SUPERVI ORY PERSONNEL 0 0.00 0.0 0.0 ENGINEERING PER ONNEL .0 0.0 TOTAL 40 17. 00 1.700 1.200 20. 0 REFUELING HAINTENANCE PERSONNEL 3 71 0.400 13.100 0.800 OPERATING PERS NNEL 25 0 9.600 0.0 0.0 HEALTH PHYSICS PERSONNEL 0 0 0.0 0.0 1.2 SUPERVISORY PERSONNEL 0 0 0.0 0.0 0.0 ENGINEERING PER NNEL 6 0. 1.2 0.0 T TAL 28 77 114 14. 0 2.0 2.30 T TAL BY OB NCTI M HAINTENAN E PERSONNEL 444 2184 586 3214 200.0 1449.500 553.900 2203.400 PERATIN PERSONNEL 344 0 0 344 118.600 0.0 0.0 118.600 HEALTH PHY ICS PER ONNEL 82 0 279 361 34.200 0.0 140.500 174.700 S PERVI RY PERSONNEL 0 0 0.0 0.0 0.0 0 0 0.0 EN INEERING PER NNEL 0 18 0 72. 00 0.0 1 72. 0 RAND T TAL 870 2 73 410 2. 0 22. 6 4.40

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TABLE 3 NUHBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY 1 2 BWR 1984 NUHBER OF PERSONNEL (>100 H-REH) TOTAL HAN-REHS STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL WORK 8 JOB F NCTI N EHPLOYEES EHPLOYEES 5 OTHERS PERSONS ~EHPLOYEE ~EMPLOYEE O OTHERS ~HRH-REH REACTOR OPERATIONS 5 SURV.

HAINTENAN E PERSONNEL 45 43 0 8.200 12.400 0.0 OPERATING PER ONNEL 121 0 0 30.300 0.0 0.0 HEALTH PHYSICS PERSONNEL 62 3 95 29.000 0.500 60.500 SUPERVI ORY PERSONNEL 1 56 16 0.100 17.900 4.000 ENGINEERING PERSONNEL 0 24 0 0. 4.70 TOTAL 22 12 46 7. 0 5. 00 64. 167.600 ROUTINE HAINTENAN E HAINTENAN E PERSONNEL 452 557 0 252.000 317.400 0.0 PERATING PERSONNEL 95 0 0 24.300 0.0 0.0 HEALTH PHYSICS PERSONNEL 49 2 96 14.300 0.300 53.900 SUPERVISORY PERSONNEL 0 13 47 0.0 4.200 26.100 ENGINEERING PERSONNEL 28 0 11.200 TOTAL 600 14 1 39 2 0.600 0.00 7 .70 IN-SERVI E IN PECTION HAINTENANCE PER ONNEL 0 0.806 0.0 0.0 PERATING PERSONNEL 0 0.0 0.0 0.0 HEALTH PHY ICS PERSONNEL 0 0.0 0.0 0.0 PERVISORY PERSONNEL 14 0.0 2.800 0.0 EN INEERING PER ONNEL 0 0.0 0.0 TOTAL 14 21 0.8 2. 00 O. 3.6 6 PECIAL HAINTENANCE HAINTENANCE PERSONNEL 39 385 1 16.600 160.800 0.200 OPERATIN PERSONNEL 0 0 0 0.0 0.0 0.0 HEALTH PHYSIC PER ONNEL 13 0 41 4.600 0.0 29.300 SUPERVISORY PERSONNEL 1 61 177 0.100 79.200 216.300 ENGINEERING PER NNEL 0 13 0 0.0 4.300 0.0 TOTAL 21 7 1 21. 00 244. 00 245.80 11.4 WASTE PRO ESSING HAINTENANCE PER ONNEL 23 7.300 0.0 0.0 PERATING PERSONNEL ll 5.400 0.0 0.0 HEALTH PHY ICS PERSONNEL 4 1.300 0.0 3.500 SUPERVISORY PER ONNEL 0 0.0 0.0 0.0 ENGINEERING PERSONNEL 0 0.0 .0 0.

TOTAL 41 14. 00 0.0 .500 17.500 R fu lin HAINTENANCE PERSONNEL 2 31 1.200 2.00 6.200 OPERATING PER ONNEL 15 0 4.200 0.0 0.0 HEALTH PHYSIC PER ONNEL 0 0 0.0 0.0 1.500 UPERVISORY PER ONNEL 0 0 0.0 0.0 0.0 ENGINEERING PERS NNEL 0 1 0.  : 100 0.0 T TAL 17 32 56 .40 00 13.2 T TAL BY OB FUNCTI k HAINTENAN E PER ONNEL 586 1016 1 1585 286.106 496.800 0.200 783.106 OPERATIN PERSONNE 242 0 0 242 64.200 0.0 0.0 64.200 HEALTH PHYSIC PER ONNEL 128 5 242 375 49.200 0.800 148.700 198.700 UPERVI RY PERS NNEL 2 144 240 386 0.200 104.100 246.400 350.700 EN INEERING PER NNEL 0 6 0 20. 0 20.30 T TAL 12 1 2 4 22.000 1417.0

t TABLE 3 NUHBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1985 NUHBER OF PERSONNEL (>100 H-REM) TOTAL MAN-REH HO~REACTOR OPS SURVEILLANCE GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EMPLOYEES EMPLOYEES AND OTHERS PERSONS EMPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 738 48 30 816 35.749 3.931 2.306 41.986 OPERATING PERSONNEL 77 2 0 79 15.936 0.280 0.000 16.216 HEALTH PHYSICS PERSONNEL 96 4 111 211 26.681 0.859 42.411 69.951 SUPERVISORY PERSONNEL 16 0 0 16 2.146 0.000 0.000 2.146 ENGINEERING PERSONNEL 133 12 44 189 17.519 1.792 6.103 25.414 1060 66 185 1311 98.031 6.862 50.820 155.713

-MD~ROUTINE HAINTENANCE

'GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EMPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 854 44 94 992 249.317 4.844 28.191 232.352 OPERATING PERSONNEL 75 2 0 77 5.654 0.007 0.000 5.661 HEALTH PHYSICS PERSONNEL 92 3 109 204 11.692 0.522 19.894 32.108 SUPERVISORY PERSONNEL 15 1 0 16 1.464 0.000 0.000 1.464 ENGINEERING PERSONNEL 137 . 12 43 192 25.903 0.865 2.604 29.372 1173 62 246 1481 294.030 6.238 50.689 350.957 MO SPECIAL HAINTENANCE GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EMPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 664 73 126 863 175.136 41.738 98.323 315.197 OPERATING PERSONNEL 31 0 0 31 1. 147 0.000 0.000 1. 147 HEALTH PHYSICS PERSONNEL 56 0 100 156 4.440 0.000 29.805 34.245 SUPERVISORY PERSONNEL 13 1 0 14 2.699 0.314 0.000 3.013 ENGINEERING PERSONNEL 96 5 22 123 16.327 0.273 4.732 21.332 860 79 248 1187 199.749 42.325 132.860 374.934

~WASTE PROCESSING GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EMPLOYEES EMPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 129 0 6 135 4.613 0.000 0.560 5. 173 OPERATING PERSONNEL 13 0 0 13 2.089 0.000 0.000 2.089 HEALTH PHYSICS PERSONNEL 62 1 42 105 1.859 0.000 0.813 2.672 SUPERVISORY PERSONNEL 1 0 0 1 0.000 0.000 0.000 0.000 ENGINEERING PERSONNEL 3 0 4 7 0.006 0.000 0.560 0.566 208 1 52 261 8.567 0.000 1.933 10.500

TABLE 3 NUHBER OF PERSONNEL ANO HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PlANT 1985 NUHBER OF PERSONNEL ()100 H-REH) TOTAL HAN-REH

~REFUEL GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 2473 165 256 2894 469.097 50.513 129.380 648.990 OPERATING PERSONNEL 218 5 0 223 25.717 0.291 0.000 26.008 HEALTH PHYSICS PERSONNEL 321 8 383 712 44.719 1.381 93.658 139.758 SUPERVISORY PERSONNEL 46 2 0 48 6.309 0.314 0.000 6.623 ENGINEERING PERSONNEL 399 . 29 113 541 60.219 2.930 13.999 77.148 RSRSRO ~ assama 3457 209 752 4418 606.061 55.429 237.037 898.527

TABLE 3 NUMBER OF PERSONNEL AND HAN-REM BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1985 TOTAL NUMBERS OF INDIVIOUALS GROUP STATION UTILITY CONTRACT TOTAL MAINTENANCE PERSONNEL 870 73 151 1094 OPERATING PERSONNEL 76 2 0 78 HEALTH PHYSICS PERSONNEL 96 4 110 210 SUPERVISORY PERSONNEL 18 1 0 19 ENGINEERING PERSONNEL 131 8 46 185

%1LRQ aalu a a 1191 88 307 1586

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TABLE 3 NUHBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1986 NUHBER OF PERSONNEL ()100 H-REH) TOTAL HAN-REH HO~REACTOR OPS SURVEILLANCE GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 706 44 38 788 40.494 4.283 2.924 47.701 OPERATING PERSONNEL 54 1 1 56 5.961 0.106 0.106 6.173 HEALTH PHYSICS PERSONNEL 129 19 79 227 26.014 7.348 28.809 62.171 SUPERVISORY PERSONNEL 18 0 1 19 2.019 0.000 0.086 2.105 ENGINEERING PERSONNEL 106 2 261 369 9.800 0.016 48.513 58.329 1013 66 380 1459 84.288 11.753 80.438 176.479 HO~ROUTINE HAINTENANCE GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 815 48 63 926 271.757 2.651 34.294 308.702 OPERATING PERSONNEL 51 1 0 52 2.407 0.000 0.000 2.407 HEALTH PHYSICS PERSONNEL 124 18 79 221 12 '22 4.048 16.313 33.183 SUPERVISORY PERSONNEL 18 0 0 18 1.531 0.000 0.000 1.531 ENGINEERING PERSONNEL 114 1 225 340 17.170 0.160 35.306 52.636 1122 68 367 1557 305.687 6.859 89.913 398.459 HO~IN-SERVICE INSPECTION GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 188 43 7 238 29.876 33.820 0.081 63.777 HEALTH PHYSICS PERSONNEL 49 13 62 124 1.442 1.495 8.268 11.205 SUPERVISORY PERSONNEL 6 3 2 ll 0. 145 0.562 0.609 1.316 ENGINEERING PERSONNEL 22 0 35 57 2.386 0.000 17.747 20.133 265 59 106 430 33.849 35.877 26.705 96.431

-HO~SPECIAL HAINTENANCE GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 687 24 109 820 119.067 3.707 104.050 226.824 OPERATING PERSONNEL 40 1 0 41 1.417 0.029 0.000 1.446 HEALTH PHYSICS PERSONNEL 59 6 57 122 14.764 0.040 8.635 23.439 SUPERVISORY PERSONNEL 14 0 0 14 1.641 0.000 0.000 1.641 ENGINEERING PERSONNEL 81 0 93 174 6.386 0.000 2.765 9. 151 881 31 259 1171 143.275 3.776 113.450 262.501

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TABLE 3 NUMBER OF PERSONNEL AND MAN-REM BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1986 NUMBER OF PERSONNEL (>100 M>>REM) TOTAL MAN-REM

-REACTOR WASTE PROCESSING GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EMPLOYEES EMPLOYEES AND OTHERS PERSONS EMPLOYEES EMPLOYEES AND OTHERS M-REMS MAINTENANCE PERSONNEL 114 5 0 119 6.709 ., 0.021 0.000 6.730 OPERATING PERSONNEL 8 0 0 8 1.837 0.000 0.000 1.837 HEALTH PHYSICS PERSONNEL 76 9 34 119 1.134 0.085 0.169 1.388 SUPERVISORY PERSONNEL 3 0 0 3 0.077 0.000 0.000 0.077 ENGINEERING PERSONNEL 14 0 7 21 0.771 0.000 0.002 0.773 215 14 41 270 10.528 0.106 0.171 10.805 MOsREFUEL GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EMPLOYEES EMPLOYEES AND OTHERS PERSONS EMPLOYEES EMPLOYEES AND OTHERS M-REHS MAINTENANCE PERSONNEL 5 0 0 5 0.000 0.000 0.000 0.000 OPERATING PERSONNEL 5 0 0 5 0.066 0.000 0.000 0.066 HEALTH PHYSICS PERSONNEL 2 0 6 8 0.000 0.000 0.005 0.005 ENGINEERING PERSONNEL 18 0 6 24 0.036 0.000 0.005 0.005 30 0 12 42 0.102 0.000 0.011 0.113 sees mass esse sass aaaaaas seeress sess am ames s a 3526 238 1165 4929 577.729 58.371 308.688 944.788

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TABLE 3 NUMBER OF PERSONNEL AND MAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1986 NUMBER OF PERSONNEL ()100 H-REH) TOTAL HAN-REH MOaREFUEL GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 2515 164 217 2896 467.903 44.482 141.349 653.734 OPERATING PERSONNEL 158 3 1 162 11.688 0.135 0.106 11.929 HEALTH PHYSICS PERSONNEL 439 65 317 821 56.176 13.016 62. 199 131.391 SUPERVISORY PERSONNEL 59 3 3 65 5.413 0.562 0.695 6.670 ENGINEERING PERSONNEL 355 3 627 985 36.549 0.176 104.339 141.064 a aaaa aa a aaaaaaa aaaaaa aaaa a aaaaaaa 3526 238 1165 4929 577.729 58.371 308.688 944.788

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TABLE 3 NUHBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1986 TOTAL NUHBERS OF INDIVIDUALS GROUP STATION UTILITY CONTRACT TOTAL HAINTENANCE PERSONNEL 886 51 124 1061 OPERATING PERSONNEL 54 1 1 56 HEALTH PHYSICS PERSONNEL 127 8 77 212 SUPERVISORY PERSONNEL 17 3 2 22 ENGINEERING PERSONNEL 101 1 264 366 RR~Ã lijg a@a SRSQ 1185 64 468 1717

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TABLE 3 NUHBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1987 NUHBER OF PERSONNEL ()100 H-REH) TOTAL HAN-REH

~REACTOR OPS SURVEILLANCE GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTEMANCE PERSONNEL 775 34 18 827 55.229 1.516 0.513 57.258 OPERATING PERSONNEL 65 1 8 74 7.766 0.087 1.108 8.961 HEALTH PHYSICS PERSONNEL 132 2 41 175 45.869 0.203 10.329 56.401 SUPERVISORY PERSONNEL 13 2 1 16 1.393 . 0.184 0.053 1.630 ENGINEERING PERSONNEL 132 1 173 306 10.021 0.017 28.666 38.704 1117 40 241 1398 120.278 2.007 40.669 162.954

~ROUTINE HAINTENANCE GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 895 34 48 977 410.051 5.387 5.908 421.346 OPERATING PERSONNEL 63 1 7 71 1.079 0.084 0.056 1.219 HEALTH PHYSICS PERSONNEL 129 1 40 170 16.365 0.006 2.984 19.355 SUPERVISORY PERSONNEL ENGINEERING PERSONNEL ll 1 3 15 0.891 0.000 0.024 0.915 122 5 155 282 17.444 0.609 16.942 34.995 1220 42 253 1515 445.830 6.086 25.914 477.830 HO~IN-SERVICE INSPECTION GROUP STATION UTILITY -.

CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EMPLOYEES EHPLOYEES AND OTHERS H-REHS MAINTENANCE PERSONNEL 138 27 3 168 12.258 5.977 0.499 18.734 OPERATING PERSONNEL 3 0 1 4 0.003 0.000 0.025 0.028 HEALTH PHYSICS PERSONNEL 59 1 22 82 0.386 0.005 0. 174 0.565 SUPERVISORY PERSONNEL 5 0 0 5 0.487 0.000 0.000 0.487 ENGINEERING PERSONNEL 13 3 20 36 0.426 0.039 6.803 7.268 218 31 46 295 13.560 6.021 7.501 27.082 HO~WASTE PROCESSING GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS

'QINTENANCE PERSONNEL 637 21 115 773 177.342 6.927 89.462 273.731

.PERATING PERSONNEL, 35 0 1 36 0.797 0.000 0.000 0.797 "AiLTH PHYSICS PERSONNEL 106 1 37 144 24.368 0.001 11. 114 35.483

'PERVISORY PERSONNEL 8 0 1 9 1.239 0.000 0.030 1.269 MGINEERING PERSONNEL 92 3 75 170 15.450 0.628 16.745 32.823 878 25 229 1132 219.196 7.556 117.351 344.103

TABLE 3 NUMBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1987 NUHBER OF PERSONNEL ()100 H-REH) TOTAL HAN-REH

-HOrWASTE PROCESSING GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 93 0 7 100 2.844 , 0.000 0.327 3.171 OPERATING PERSONNEL 12 0 1 13 1.004 0.000 0.005 1.009 HEALTH PHYSICS PERSONNEL 72 0 11 83 1.251 0.000 0.090 1.341 SUPERVISORY PERSONNEL 4 0 0 0.214 0.000 0.000 0.214 ENGINEERING PERSONNEL 10 0 15 25 0.481 0.000 0.207 .688 191 0 34 225 5.794 0.000 0.629 6.423 rREFUEL GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES . EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL 51 0 0 51 5.971 0.000 0.000 5.971 OPERATING PERSONNEL 30 0 0 30 0.570 0.000 0.000 0.570 HEALTH PHYSICS PERSONNEL 28 0 12 40 0.633 0.000 0.385 1.018 ENGINEERING PERSONNEL 17 1 16 34 0.573 0.005 0.326 0.904 HO 126 1 28 155 7.747 0.005 0.711 8.463 ar a aa'a aaa arra aarrrr ar rraaa 3750 139 831 4720 812.405 21.675 192.775 1026.855

J TABLE 3 NUHBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1987 NUHBER OF PERSONNEL (>100 H-REH) TOTAL HAN-REH

-HOaREFUEL GROUP STATION UTILITY CONTRACT TOTAL STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS EHPLOYEES EHPLOYEES ANO OTHERS H-REMS HAINTENANCE PERSONNEL 2589 116 191 2896 663.695 19.807 96.709 780.211 OPERATING PERSONNEL 208 2 18 228 11.219 0.171 1.194 12.584 liEALTH PHYSICS PERSONNEL 526 5 163 694 88.872 0.215 25.076 114. 163 SUPERVISORY PERSONNEL 41 3 5 49 4.224 0.184 0.107 4.515 ENGINEERING PERSONNEL 386 13 454 853 44.395 1.298 69.689 115.382 aaa aaa aaa aa~a aaaaa aaa aaaaaa 3750 139 831 4720 812.405 21.675 192.775 1026.855

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TABLE 3 NUMBER OF PERSONNEL AND MAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY NUCLEAR PLANT 1987 TOTAL NUMBERS OF INDIVIOUALS GROUP STATION UTILITY CONTRACT TOTAL

'NINTENANCE PERSONNEL 946 44 121 1111 OPERATING PERSONNEL 65 1 9 75

!EALTH PHYSICS PERSONNEL 134 0 27 161 SUPERVISORY PERSONNEL 14 0 3 17 ENGINEERING PERSONNEL 115 2 154 271 aaaa aaaa aaaa aaaaa 1274 47 314 1635

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ENCLOSURE 3 PROPOSED OPERATING LICENSE AMENDMENT BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296 (TVA-BFN-TS-88-258)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS

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ENCLOSURE 3 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 Descri tion of Amendment Re uest The proposed amendment would change the Browns Ferry Nuclear Plant (BFN)

Technical Specifications for units 1, 2, and 3 by the extension of the current operating licenses expiration date. This would entail taking the 40 year life of BFN from the issuance of the operating license rather than from the issuance of the construction permit.

Basis for Pro osed No Si nificant Hazards Consideration Determination NRC has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92(c). A proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of accident from an accident previously evaluated, or 3) involve a significant reduction in a margin of safety.

1. The proposed change does not involve a significant increase in the probability or consequence of an accident previously evaluated. This change does not involve any changes to the design or operation of BFN.

Therefore, no changes will be made that could alter postulated scenarios regarding accident initiation or response. In addition this proposed amendment does not require any changes to the safety analysis. There are no modifications to the facility procedures or technical specifications.

Existing surveillance, inspection, testing, and maintenance practices provide assurance that degradation in plant equipment, structures, or components will be identified and corrected as necessary throughout the life of the facility. The operation of BFN in accordance with the existing programs will ensure that plant operation will be bounded by the

'sBFN Final Safety Analysis Report (FSAR) and Final Environmental Statement amendment.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated. This amendment does not involve any change to the physical structure or any of the components or systems of the plant. This proposed change is administrative in nature and does not exceed any of the analysis as evaluated in the BFN FSAR.

3. The proposed amendment does not involve a significant reduction in a margin of safety. There are no changes in the design, design basis, or operation of the facility. This change does not require any technical specification changes. Existing surveillance, inspection, testing and maintenance programs will provide assurance that degradation of equipment, structures or components will be identified and corrected throughout the lifetime of the facility. These practices will be maintained throughout the operating life of BFN and therefore assuring that there will not be any significant reduction in the margin of safety.

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Enc. 3-2 Determination of Basis for Pro osed o Si nificant Hazards Since the application for amendment involves a proposed change that is encompassed by the criteria for which no significant hazards consideration exists, TVA has made a proposed determination that the application involves no significant hazards consideration.

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