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)

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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

~r t l I\I' 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 P I.I 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

\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 0'I~'

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 ll months for units 2 and 3.Current NRC policy is to issue operating licenses for a 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 P C*I'I 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.

r I pl<I i)r L I,)'S.i 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.

A A 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.

I pig'f I.4 I 1 I II 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 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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~I Enc.2-7 Potential Environmental Health and Safet Im acts (Cont'd)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.

J.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.

I 4 I 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).

kl fg Enc.2-9 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 III.l of the BFN Nuclear Performance Plan (NPP).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).

l I I 1 C 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.

~I I 4 k K 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.

~'h I I'I" II'hh TABLE 1 BROWNS FERRY NUCLEAR POWER PLANT-UNIT 1 STARTUP SHUTOOWN~Y L OATE DATE ACTUAL SCHEDULED CYCLE E(}UIVALENT CYCLE CYCLE THERHAL OPERATING OUTAGE LENGTH FULL POWER AVAILABILITY CAPACITY OUTPUT DAYS~DAY DAYS DAYS FACTOR~FA TOR TBTU NEW ELECTRICAL OUTPUT GROSS ELECTRICAL OUTPUT 1 2 3 4 5 6 7 8 9 10 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 10/15/1973 1/15/1978 1/18/1979 3/22/1980 10/01/1981 1/02/1984 10/15/1994 8/26/1996 6/22/1998 4/17/2000.2/11/2002 12/08/2003 10/03/2005 7/30/2007 5/25/2009 3/21/2011 1/16/2013 11/14/2014

" 9/09/2016 7/06/2018 5/01/2020 2/25/2022 12/22/2023 10/17/2025 8/13/2027 9/13/1977 11/26/1978 1/02/1980 4/10/1981 4/16/1983 3/19/1985 5/18/1996 3/14/1998 1/08/2000 11/03/2001 8/30/2003 6/25/2005 4/21/2007 2/14/2009 12/11/2010 10/08/2012 8/06/2014 6/01/2016 3/28/2018 1/22/2020 11/17/2021 9/13/2023 7/09/2025 5/05/2027 2/28/2029 1429 315 349 384 562 442 581 565 565 565 565 565 565 565 565 567 567 565 565 565 565 565 565 565 565 124 53 80 174 261 3497 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 0 1553 368 429 558 823 3939 681 665 665 665 665 665 665 665 665 667 667 665 665 665 665 665 665 , 665.565 526.755 232.894 298.154 333.967 478.768 371.426 399.023 398.994 398.971 398.964 398.964 398.960 398.964 398.968 398.968 400.002 400.354 399.157 399.157 399.157 399.157 399.157 399.157 399.157 399.157 0.3686 0.7393 0.8543 0.8697 0.8519 0.8403 0.6868 0.7062 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7055 0.7061 0.7065 0.7065 0.7065 0.7065 0.7065 0.7065 0.7065 0.7065 0.3392 0.6329 0.6950 0.5985 0.5817 0.0943 0.5859 0.6000 0.6000 0.5999 0.5999 0.5999 0.5999 0.6000 0.6000 0.5997 0.6002 0.6002 0.6002 0.6002 0.6002 0.6002 0.6002 0.6002 0.7065 142.085 62.820 80.423 90.083 129.141 100.187 107.631 107.623 107.617 107.615 107.615 107.614 107.615 107.616 107.616 107.895 107.990 107.667 107.667 107.667 107.667 107.667 107.667 107.667 107.667 13463944 5952810 7620866 8536246 12237373 9493698 10199090 10198332 10197764 10197574 10197574 10197479 10197574 10197669 10797669 10224107 10233109 10202502 10202502 10202502 10202502 10202502 10202502 10202502 10202502 13880911 6137163 7856878 8800606 12616354 9787710.10514947" 10514166 10513580 10513384 10513384 10513286 10513384 10513482 10513482 10540739 10550020 10518464 10518464 10518464 10518464 10518464 10518464 10518464 10518464

'r I',P I hl-a<C TABLE 1 BROWNS FERRY NUCLEAR POWER PLANT-UNIT 2 STARTUP SHUTDOWN DATE ACTUAL SCHEDULED CYCLE EQUIVALENT CYCLE CYCLE THERHAL OPERATING OUTAGE LENGTH FULL POWER AVAILABILITY CAPACITY OUTPUT RAYS~OAY~OAY~OAY~FA TOR~FA T R TBTIO NEW ELECTRICAL OUTPUT GROSS ELECTRICAL OUTPUT HWH 1 8/28/1974 2 6/27/1978 3 6/01/1979 4 11/23/1980 5 3/20/1983 6 12/15/1988 7 4/07/1991 8 3/29/1993 9 1/23/1995 10 11/18/1996 11.9/14/1998 12 7/10/2000 13 5/06/2002 14 3/01/2004 15 12/26/2005 16 10/22/2007 17 8/17/2009 18 6/13/2011 19 4/08/2013 20'2/02/2015 21 11/28/2016 22 9/24/2018 23 ,7/20/2020 24 5/16/2022 25 3/11/2024 3/18/1978 4/27/1979 9/05/1980 7/30/1982 9/15/1984 9/19/1990 12/19/1992 10/15/1994 8/10/1996 6/06/1998 4/01/2000 1/26/2002 11/22/2003 9/17/2005 7/14/2007 5/09/2009 3/05/2011 12/29/2012 10/25/2014 8/20/2016 6/16/2018 4/11/2020 2/05/2022 12/02/2023 9/27/2025 1298 304 462 614 545 643 622 565 565 565 565 565 565 565 565 565 565 565 565 565 565 565 565 565 565 101 35 79 233 1552 200 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 0 1399 339 541 847 2097 843 722 665 665 665 665 665 665 665 665 665 665 665 665 665 665 665 665 665 565 475.279 263.750 370.013 498.483 414.905 436.230 432.956 398.994 398.971 398.971 398.968 398.964 398.960 398.960 398.960 398.956 398.960 398.960 398.960 398.960 398.960 398.960 398.960 398.960 399.960 0.3662 0.8676 0.8009 0.8119 0.7613 0.6784 0.6961 0.7062 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.3397 0.7780 0.6839 0.5885 0.1979 0.5175 0.5997 0.6000 0.6000 0.6000 0.6000 0.5999 0.5999 0.5999 0.5999 0.5999 0.5999 0.5999 0.5999 0.5999 0.5999 0.5999 0.5999 0.5999 0.7061 128.200 71.143 99.806 134.459 111.915 117.667 116.784 107.623 107.617 107.617 107.616 107.615 107.614 107.614 107.614 107 613 107.614 107.614 107.614 107.614 107.614 107.614 107.614 107.614 107.614 12148204 6741495 9457595 12741306 10605041 11150099 11066427 10198332 10197764 10197764 10197669 10197574 10197479 10197479 10197479 10197385 10197479 10197479 10197479~10197479 10197479 10197479 10197479 10197479 10197479 12524424 6950274 9750488 13135893 10933470 11495408.11409144'0514166 10513580 10513580 10513482 10513384 10513286 10513286 10513286 10513189 10513286 10513286 10513286 10513286 10513286 10513286 10513286 10513286 10513286 II~'I I, IA II%I TABLE 1 BROWNS FERRY NUCLEAR POWER PLANT-UNIT 3 STARTUP SHUTDOWN~Y LE DATE DATE ACTUAL SCHEDULED CYCLE EQUIVALENT CYCLE CYCLE THERHAL OPERATING OUTAGE LENGTH FULL POWER AVAILABILITY CAPACITY OUTPUT DAYS~OAY~OAY DAYS~FA TOR~FA TOR TOTO NEW ELECTRICAL OUTPUT GROSS ELECTRICAL OUTPUT 1 2 3 4 5 6 7 8 9 10 ll 12 13 14 15 16'7 18 19 20 21 22 23 24 25 8/19/1976 11/22/1978 12/08/1979 1/18/1981 4/12/1982 11/29/1984 6/30/1994 4/25/1996 2/19/1998 12/16/1999 10/11/2001 8/07/2003 6/02/2005 3/29/2007 1/22/2009 11/18/2010 9/13/2012 7/10/2014 5/05/2016 3/01/2018 12/26/2019 10/21/2021 8/17/2023 6/12/2025 4/08/2027 9/08/1978 8/24/1979 11/23/1980 10/30/1981 9/06/1983 3/22/1994 1/16/1996 11/11/1997 9/07/1999 7/03/2001 4/29/2003 2/22/2005 12/19/2006 10/14/2008 8/10/2010 6/05/2012 4/Ol/2014 1/26/2016 11/21/2017 9/17/2019 7/13/2021 5/09/2023 3/04/2025 12/29/2026 10/24/2028 750 275 351 285 512 3400 565 565 565 565 565 565 565 565 565 565 565 565 565 565 565 565 565 565 565 75 106 56 164 450 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 100 0 825 381 407 449 962 3500 665 665 665 665 665 665 665 665 665 665 665 665 665 665 665 665 665 665 565 540.725 225.376 284.741 246.941 410.052 482.405 398.994 398.982 398.968 398.960 398.964 398.968 398.964 398.964 398.968 398.968 398.968 398.968 398.968 398.968 398.968 398.968 398.968 398.968 398.968 0.7210 0.8195 0.8112 0.8665 0.8009 0.1419 0.7062 0.7062 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061'0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.7061 0.6554 0.5915 0.6996 0.5500 0.4262 0.1378 0.6000 0.6000 0.6000 0.5999 0.5999 0.6000 0.5999 0.5999 0.6000 0.6000 0.6000 0.6000 0.6000 0.6000 0.6000 0.6000 0.6000 0.6000 0.7061 145.853 60.792 76.805 66.609 110.606 130.122 107.623 107.620 107.616 107.614 107.615 107.616 107.615 107.615 107.616 107.616 107.616 107.616.107.616 107.616 107.616 107.616 107.616 107.616 107.616 13820999 5760637 7278025 6311854 10481001 12330333 10198332 10198048 10197669 10197479 10197574 10197669 10197574 10197574 10197669 10197669 10197669 10197669 10197669 10197669 10197669 10197669 10197669 10197669 10197669 14249023 5939039 7503419 6507327 10805588 12712192.10514166'0513873 10513482 10513286 10513384 10513482 10513384 10513384 10513482 10513482 10513482 10513482 10513482 10513482 10513482 10513482 10513482 10513482 10513482 r

TABLE 2 BFN UNIT 1 Projected Occupational Exposure Man-Rem*YEAR OUTAGE NON-OUTAGE XOTAL 2007 400 100 500 2008 2009 No outage 500 240 175 240 675 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.

~~

Table 2 BFN Unit 2 Projected Occupational Exposure Man-Rem YEAR 2007 OUTAGE 500~0-OUTAGE 70 TOTAL 570 2008 2009 No outage 500 240 175 240 675 2010 2011 No outage 500 240 175 240 675 2012 No outage 240 240 2013 500 175 675 2014 150 220 370 I~~y 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 2012 No outage 500 240 175 240 675 2013 2014 No outage 500 240 175 240 675 2015 2016 No outage 500 240 175 240 675 1 l'I II II~st TABLE 3 NUMBER OF PERSONNEL AND MAN-REM BY WORK AND 308 FUNCTION PLANT: BROWNS FERRY 1 2 STATION~EHPLOYEE 16.600 22;000 7.700 0.0 BWR 1982 NUMBER OF PERS NNEL)1 M-REM STATION UTILITY CONTRACT TOTAL YORK&OS PUHCTT H~EHPL YEES EHPLOYEES~STHER PERSOEH REA T R OPERATIONS 5 SURV.MAINTENANCE PER ONNEL 48 23 OPERATING PERSONNEL 90 0 HEALTH PHY ICS PERSONNEL 25 58 UPERVISORY PERSONNEL 0 0-ENGINEERING PERSONNEL 0 0 29.600 0.0 0.0 0.0 21.600 16.500 0.0 26.900 0.0 0.UTILITY CONTRACT~EHPLOYEE T OTHERS TOTAL HAN-REMS T TAL 163 15 1 3 4.00.51.2 0 43.40 140.900 R UTINE MAINTENANCE MAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHY I PERSONNEL PERVISORY PERSONNEL EN INEERING PERSONNEL TOTAL IN-SERVICE IN PECTION HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHY ICS PERSONNEL UPERVISORY PERSONNEL ENGINEERING PERS NNEL TOTAL PE IAL MAINTENAN E MAINTENANCE PER ONNEL OPERATING PERSONNEL HEALTH PHYSIC PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PER NNEL TOTAL WASTE PROCESSING MAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL PERVISORY PERSONNEL ENGINEERIN PER ONNEL TOTAL REFUELING MAINTENAN E PERSONNEL PERATING PERSONNEL HEALTH PHYSICS PERSONNEL T SUPERVISORY PERSONNEL ENGINEERING PERSONNEL TOTAL TOTA BY JOB FUNCTION MAINTENAN E PERSONNEL PERATING PERS NNEL HEALTH PHYSICS PERSONNE PERVISORY PER NNEL EN INEERING PERSONNEL RAND TOTAL 324 161 30 0 0 15 32 8 3 0 0 26 15 5 0 46 0 19 0 0 0 430 293 63 0 936 0 0 0 o 3 102 623 0 0 0 3 659 20 0 0 0 20 1694 0 0 0 172 1866 195 0 68 0 0 26 95 0 ll 0 0 106 317 0 139 0 0 456 1 07 0 808 43 2441 293 202 0 172 10 184.800 75.200 13.000 0.0 0.27.0 0 0.0 0.0 0.0 0.0.0 8.800 1.300.400 0.0 1.'0 9.300 6.800 1.700 0.0 0.0 18.700 0.0 6.300 0.0 0.0 0.0 6.30 219.500 112.200 22.800 0.0 0 4.8 0 696.100 0.0 0.0 0.0 45.000 741.10 0.700 0.0 0.0 0.0 0.0 0.700 317.000 0.0 0.0 0.0 1.0 3 0.100 1.000 0.0 0.0 0.0.0 1.000 3.600 0.0 0.0 0.0 1048.000 0.0 0.0 0.0 79.700 1127.70 125.600 0.0 41.400 0.0 167.000 0.500 0.0 0.0 0.0 0.0 00 31.000 0.0 3.200 0.0 0.0-'.220 0.0 0.0 0.900 0.0 0.0 00 1.000 0.0 0.0 0.0.0 1.000 174.600 0.0 72.400 0.0 0.0 247.0 1.2 374.800 20.600 1.0 1442.100 112.200 95.200 , 0.0 80.000 1729.5 0 11 1.100

~~a TABLE 3 PLANT: BROWN FERRY 1 2 STATION H RK S JOR TUMCTIOM~EMPT YEE REACTOR PERATION 8 SURV HAINTENANCE PERSONNEL 80 OPERATING PERSONNEL-148 HEALTH PHYSICS PERSONNEL 34 UPERVISORY PERSONNEL 0 EN INEERING PERSONNEL UTILITY CONTRACT TOTAL STATION~EMPLOYEE O OOTHER~PER~M EHPLOYEES 169 29 0 0 0 103 0 0 73 36 7.0 242 132 T TAL 262 NUHBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION BWR 1983 NUMBER OF PERSONNEL (>100 H-REH)41.500 0.0 0.0 0.0 24.6 0 6.1 0 14.900 0.0 54.300 0.0 0.6.2 TOTAL HAN-REHS UTILITY CONTRACT~EMPLOYEE&~OTHER TOTAL MLM-REHS 210.RO TINE HAINTEMANCE HAINTENANCE PERSONNEL PERATING PERSONNEL HEALTH PHY I S PERSONNEL UPERVISORY PERSONNEL EN INEERING PERSONNEL TOTAL IN-SERVICE INSPECTION HAINTENANCE PER ONNEL PERATIN PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVI ORY PERSONNEL ENGINEERING PERSONNEL T TAL PECIAL HAINTEMANCE MAINTENANCE PERSONNE OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL S PERVISORY PERSONNEL ENGINEERING PERSONNEL TOTAL WA TE PROCESSING HAINTEMANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PER NNEL SUPERVI ORY PERSONNEL ENGINEERING PER ONNEL TOTAL REFUELING HAINTENANCE PERSONNEL OPERATING PERS NNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PER NNEL T TAL T TAL BY OB NCTI M HAINTENAN E PERSONNEL PERATIN PERSONNEL HEALTH PHY ICS PER ONNEL S PERVI RY PERSONNEL EN INEERING PER NNEL RAND T TAL 290 148 33 0 471 ll 2 0 0 0 35 ll 10 0 25 10 5 0 40 3 25 0 0 28 444 344 82 0 0 870 1090 0 0 0 7 95 0 0 0 2 753 0 0 0 29 782 71 0 0 0 6 77 2184 0 0 0 18 2 73 254 0 109 0 40 0 10 0 0 50 261 0 48 0 0 3 9 586 0 279 0 0 2003 1147 114 3214 344 361 0 1 410 154.900 57.000 14.500 0.0 0.0 226.400 5.600 0.400 0.0 0.0 0.0.000 12.600 2.200 2.700 0.0 0.0 17.500 9.100 6.800 1.700 0.00 17.00 0.400 9.600 0.0 0.0 0.200.0 118.600 34.200 0.0 2.0 940.300 0.0 0.0 0.0 38.40 78.700 46.400 0.0 0.0 0.0.200 46.60 406.500 0.0 0.0 0.0.200 414.700 1.700 0.0 0.0 0.0.0 1.700 13.100 0.0 0.0 0.0 1.2 14.0 1449.500 0.0 0.0 0.0 72.00 22.167.100 0.0 57.900 0.0 0.0 225.0 51.200 0.0 2.600 0.0.800 319.900 0.0 23.300 0.0 0.34.20 0.0 0.0 1.200 0.0 0.0 1.200 0.800 0.0 1.2 0.0 0.0 2.0 553.900 0.0 140.500 0.0 0.0 6 4.40 1430.1 10.40 77.400 20.0 2.30 2203.400 118.600 174.700 0.0 72.0

)I~~~~A TABLE 3 NUHBER OF PERSONNEL AND HAN-REH BY WORK AND JOB FUNCTION PLANT: BROWNS FERRY 1 2 STATION~EHPLOYEE 8.200 30.300 29.000 0.100 0.0 0 95 16 0 7.0 46 12 TOTAL 22 BWR 1984 NUHBER OF PERSONNEL (>100 H-REH)STATION UTILITY CONTRACT TOTAL WORK 8 JOB F NCTI N EHPLOYEES EHPLOYEES 5 OTHERS PERSONS REACTOR OPERATIONS 5 SURV.HAINTENAN E PERSONNEL 45 43 OPERATING PER ONNEL 121 0 HEALTH PHYSICS PERSONNEL 62 3 SUPERVI ORY PERSONNEL 1 56 ENGINEERING PERSONNEL 0 24 12.400 0.0 0.500 17.900 4.70 5.00 0.0 0.0 60.500 4.000 64.TOTAL HAN-REHS UTILITY CONTRACT~EMPLOYEE O OTHERS TOTAL~HRH-REH 167.600 ROUTINE HAINTENAN E HAINTENAN E PERSONNEL PERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL TOTAL IN-SERVI E IN PECTION HAINTENANCE PER ONNEL PERATING PERSONNEL HEALTH PHY ICS PERSONNEL PERVISORY PERSONNEL EN INEERING PER ONNEL TOTAL PECIAL HAINTENANCE HAINTENANCE PERSONNEL OPERATIN PERSONNEL HEALTH PHYSIC PER ONNEL SUPERVISORY PERSONNEL ENGINEERING PER NNEL TOTAL WASTE PRO ESSING HAINTENANCE PER ONNEL PERATING PERSONNEL HEALTH PHY ICS PERSONNEL SUPERVISORY PER ONNEL ENGINEERING PERSONNEL TOTAL R fu lin HAINTENANCE PERSONNEL OPERATING PER ONNEL HEALTH PHYSIC PER ONNEL UPERVISORY PER ONNEL ENGINEERING PERS NNEL T TAL T TAL BY OB FUNCTI k HAINTENAN E PER ONNEL OPERATIN PERSONNE HEALTH PHYSIC PER ONNEL UPERVI RY PERS NNEL EN INEERING PER NNEL T TAL 452 95 49 0 39 0 13 1 0 23 ll 4 0 0 2 15 0 0 0 17 586 242 128 2 0 557 0 2 13 28 600 0 0 0 14 0 14 385 0 0 61 13 31 0 0 0 1 32 1016 0 5 144 6 12 1 0 0 96 47 0 14 1 0 41 177 0 21 1 0 242 240 0 1 39 21 7 1 41 56 1585 242 375 386 2 4 252.000 24.300 14.300 0.0 2 0.600 0.806 0.0 0.0 0.0 0.0 0.8 16.600 0.0 4.600 0.100 0.0 21.00 7.300 5.400 1.300 0.0 0.0 14.00 1.200 4.200 0.0 0.0 0..40 286.106 64.200 49.200 0.200 317.400 0.0 0.300 4.200 11.200 0.0 0.0 0.0 2.800 2.00 160.800 0.0 0.0 79.200 4.300 244.00 0.0 0.0 0.0 0.0.0 0.0 2.00 0.0 0.0 0.0: 100 00 496.800 0.0 0.800 104.100 20.0 22.000 0.0 0.0 53.900 26.100 0.00 0.0 0.0 0.0 0.0 0.0 O.0.200 0.0 29.300 216.300 0.0 245.80 0.0 0.0 3.500 0.0 0..500 6.200 0.0 1.500 0.0 0.0 0.200 0.0 148.700 246.400 7.70 3.6 6 11.4 17.500 13.2 783.106 64.200 198.700 350.700 20.30 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)HO~REACTOR OPS SURVEILLANCE TOTAL MAN-REH GROUP STATION UTILITY EMPLOYEES EMPLOYEES CONTRACT TOTAL AND OTHERS PERSONS STATION EMPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 738 77 96 16 133 1060 48 2 4 0 12 66 30 0 111 0 44 185 816 79 211 16 189 1311 35.749 15.936 26.681 2.146 17.519 98.031 3.931 0.280 0.859 0.000 1.792 6.862 2.306 0.000 42.411 0.000 6.103 50.820 41.986 16.216 69.951 2.146 25.414 155.713'GROUP STATION UTILITY EMPLOYEES EHPLOYEES-MD~ROUTINE HAINTENANCE CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 854 75 92 15 137 1173 44 2 3 1.12 62 94 0 109 0 43 246 992 77 204 16 192 1481 249.317 5.654 11.692 1.464 25.903 294.030 4.844 0.007 0.522 0.000 0.865 6.238 28.191 0.000 19.894 0.000 2.604 50.689 232.352 5.661 32.108 1.464 29.372 350.957 GROUP STATION UTILITY EHPLOYEES EHPLOYEES-MO SPECIAL HAINTENANCE CONTRACT TOTAL AND OTHERS PERSONS STATION EMPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 664 31 56 13 96 860 73 0 0 1 5 79 126 0 100 0 22 248 863 31 156 14 123 1187~WASTE PROCESSING 175.136 1.147 4.440 2.699 16.327 199.749 41.738 0.000 0.000 0.314 0.273 42.325 98.323 0.000 29.805 0.000 4.732 132.860 315.197 1.147 34.245 3.013 21.332 374.934 GROUP STATION UTILITY EMPLOYEES EMPLOYEES CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT TOTAL EHPLOYEES AND OTHERS H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 129 13 62 1 3 208 0 0 1 0 0 1 6 0 42 0 4 52 135 13 105 1 7 261 4.613 2.089 1.859 0.000 0.006 8.567 0.000 0.000 0.000 0.000 0.000 0.000 0.560 0.000 0.813 0.000 0.560 1.933 5.173 2.089 2.672 0.000 0.566 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 EHPLOYEES EHPLOYEES CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 2473 218 321 46 399 3457 165 5 8 2.29 209 256 0 383 0 113 752 2894 223 712 48 541 4418 469.097 25.717 44.719 6.309 60.219 RSRSRO 606.061 50.513 0.291 1.381 0.314 2.930 55.429 129.380 0.000 93.658 0.000 13.999~assama 237.037 648.990 26.008 139.758 6.623 77.148 898.527 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 OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 870 76 96 18 131%1LRQ 1191 73 2 4 1 8 aalu 88 151 0 110 0 46 307 1094 78 210 19 185 a a 1586

~4~

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)HO~REACTOR OPS SURVEILLANCE TOTAL HAN-REH GROUP STATION UTILITY EHPLOYEES EHPLOYEES CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 706 54 129 18 106 1013 44 1 19 0 2 66 38 1 79 1 261 380 788 56 227 19 369 1459 40.494 5.961 26.014 2.019 9.800 84.288 4.283 0.106 7.348 0.000 0.016 11.753 2.924 0.106 28.809 0.086 48.513 80.438 47.701 6.173 62.171 2.105 58.329 176.479 GROUP STATION EHPLOYEES UTILITY EHPLOYEES HO~ROUTINE HAINTENANCE CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 815 51 124 18 114 1122 48 1 18 0 1 68 63 0 79 0 225 367 926 52 221 18 340 1557 271.757 2.407 12'22 1.531 17.170 305.687 2.651 0.000 4.048 0.000 0.160 6.859 34.294 0.000 16.313 0.000 35.306 89.913 308.702 2.407 33.183 1.531 52.636 398.459 GROUP STATION UTILITY EHPLOYEES EHPLOYEES HO~IN-SERVICE INSPECTION CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 188 49 6 22 265 43 13 3 0 59 7 62 2 35 106 238 124 ll 57 430 29.876 1.442 0.145 2.386 33.849 33.820 1.495 0.562 0.000 35.877 0.081 8.268 0.609 17.747 26.705 63.777 11.205 1.316 20.133 96.431 GROUP STATION UTILITY EHPLOYEES EHPLOYEES-HO~SPECIAL HAINTENANCE CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 687 40 59 14 81 881 24 1 6 0 0 31 109 0 57 0 93 259 820 41 122 14 174 1171 119.067 1.417 14.764 1.641 6.386 143.275 3.707 0.029 0.040 0.000 0.000 3.776 104.050 0.000 8.635 0.000 2.765 113.450 226.824 1.446 23.439 1.641 9.151 262.501

~~\~"4 cc~Q<

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

~~~~llg 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)MOaREFUEL TOTAL HAN-REH GROUP STATION UTILITY EHPLOYEES EHPLOYEES CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 2515 158 439 59 355 3526 164 3 65 3 3 a 238 217 1 317 3 627 aaaa 1165 2896 162 821 65 985 aa a 4929 467.903 11.688 56.176 5.413 36.549 aaaaaaa 577.729 44.482 0.135 13.016 0.562 0.176 aaaaaa 58.371 141.349 0.106 62.199 0.695 104.339 aaaa a 308.688 653.734 11.929 131.391 6.670 141.064 aaaaaaa 944.788

~~~~

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 OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 886 54 127 17 101 RR~Ã1185 51 1 8 3 1 li jg 64 124 1 77 2 264 a@a 468 1061 56 212 22 366 SRSQ 1717 r,~I,, 1 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)~REACTOR OPS SURVEILLANCE TOTAL HAN-REH GROUP STATION UTILITY EHPLOYEES EHPLOYEES CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTEMANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 775 65 132 13 132 1117 34 1 2 2 1 40 18 827 8 74 41 175 1 16 173 306 241 1398~ROUTINE HAINTENANCE 55.229 7.766 45.869 1.393 10.021 120.278 1.516 0.087 0.203.0.184 0.017 2.007 0.513 1.108 10.329 0.053 28.666 40.669 57.258 8.961 56.401 1.630 38.704 162.954 GROUP STATION UTILITY EHPLOYEES EHPLOYEES CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 895 63 129 ll 122 1220 34 1 1 1 5 42 48 7 40 3 155 253 977 71 170 15 282 1515 410.051 1.079 16.365 0.891 17.444 445.830 5.387 0.084 0.006 0.000 0.609 6.086 5.908 0.056 2.984 0.024 16.942 25.914 421.346 1.219 19.355 0.915 34.995 477.830 GROUP MAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 138 3 59 5 13 218 27 0 1 0 3 31 3 1 22 0 20 46 168 4 82 5 36 295 HO~WASTE PROCESSING HO~IN-SERVICE INSPECTION STATION UTILITY-.CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS STATION EMPLOYEES 12.258 0.003 0.386 0.487 0.426 13.560 UTILITY EHPLOYEES 5.977 0.000 0.005 0.000 0.039 6.021 CONTRACT AND OTHERS 0.499 0.025 0.174 0.000 6.803 7.501 TOTAL H-REHS 18.734 0.028 0.565 0.487 7.268 27.082 GROUP STATION UTILITY EHPLOYEES EHPLOYEES CONTRACT TOTAL AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS'QINTENANCE PERSONNEL.PERATING PERSONNEL,"AiLTH PHYSICS PERSONNEL'PERVISORY PERSONNEL MGINEERING PERSONNEL 637 35 106 8 92 878 21 0 1 0 3 25 115 1 37 1 75 229 773 36 144 9170 1132 177.342 0.797 24.368 1.239 15.450 219.196 6.927 0.000 0.001 0.000 0.628 7.556 89.462 0.000 11.114 0.030 16.745 117.351 273.731 0.797 35.483 1.269 32.823 344.103 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)-HOrWASTE PROCESSING TOTAL HAN-REH GROUP STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 93 12 72 4 10 191 0 0 0 0 0 0 7 1 11 0 15 34 rREFUEL 100 13 83 25 225 2.844 , 1.004 1.251 0.214 0.481 5.794 0.000 0.000 0.000 0.000 0.000 0.000 0.327 0.005 0.090 0.000 0.207 0.629 3.171 1.009 1.341 0.214.688 6.423 GROUP STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS STATION UTILITY CONTRACT EHPLOYEES.EHPLOYEES AND OTHERS TOTAL H-REHS HAINTENANCE PERSONNEL OPERATING PERSONNEL HEALTH PHYSICS PERSONNEL ENGINEERING PERSONNEL HO 51 30 28 17 126 ar a 3750 0 0 0 1 1 aa'a 139 0 0 12 16 28 aaa 831 51 30 40 34 155 arra 4720 5.971 0.570 0.633 0.573 7.747 812.405 0.000 0.000 0.000 0.005 0.005 aarrrr 21.675 0.000 0.000 0.385 0.326 0.711 192.775 5.971 0.570 1.018 0.904 8.463 ar rraaa 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)-HOaREFUEL TOTAL HAN-REH GROUP STATION UTILITY CONTRACT TOTAL EHPLOYEES EHPLOYEES AND OTHERS PERSONS STATION EHPLOYEES UTILITY CONTRACT EHPLOYEES ANO OTHERS TOTAL H-REMS HAINTENANCE PERSONNEL OPERATING PERSONNEL liEALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 2589 208 526 41 386 aaa 3750 116 2 5 3 13 aaa 139 191 18 163 5 454 aaa 831 2896 228 694 49 853 4720 663.695 11.219 88.872 4.224 44.395 aa~a 812.405 19.807 0.171 0.215 0.184 1.298 aaaaa 21.675 96.709 1.194 25.076 0.107 69.689 aaa 192.775 780.211 12.584 114.163 4.515 115.382 aaaaaa 1026.855

~~1 II 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 OPERATING PERSONNEL!EALTH PHYSICS PERSONNEL SUPERVISORY PERSONNEL ENGINEERING PERSONNEL 946 65 134 14 115 aaaa 1274 44 1 0 0 2 aaaa 47 121 1111 9 75 27 161 3 17 154 271 aaaa aaaaa 314 1635

~0)I A 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 l R 4' 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 BFN Final Safety Analysis Report (FSAR)and Final Environmental Statement's 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.

r r J'a'z 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.

1