Safety

wevaluiation Ileiort

NUREG-0061

Suppl. 1

U. S. Nuclear

Regulatory Commission

related to operation of

Browns Ferry,

Units 1 and 2

Following the March 22, 1975 Fire

Office of Nuclear

Reactor Regulation

Division of

Operating Reactors

June 1976

L I

- I .
NAvailable from

National Technical Information Service

Springfield, Virginia 22161

Price: Printed Copy $5.00; Microfiche $2.25
SUPPLEMENT NO. 1

TO THE

SAFETY EVALUATION

BY THE

DIVISION OF OPERATING REACTORS

SUPPORTING THE OPERATION AFTER THE

RESTORATION AND MODIFICATION OF THE

BROWNS FERRY NUCLEAR PLANT, UNITS 1 AND 2

FOLLOWING THE MARCH 22, 1975 FIRE

DATE: JUN 18 1976

TABLE OF CONTENTS

page

1.0 Introduction 1

2.4.1 Stainless Steel Piping and Tubing and Surveillance Programs 2

2.4.2 Cable Encapsulation 4

6.2 Procedures (Fire-related) 5

6.4 Quality Assurance 6

7.5.1 Fixed Water Systems 10

7.5.2 Heat and Detection Systems 11

7.5.3 Heat and Detection Systems

7.6.1 Automatic Fixed Fire Water Systems 13

7.6.2 Automatic Fixed Fire Water Systems

8.0 Technical Specifications 14

9.1 Fire Protection Systems Preoperational Retest Program 15

9.2 Program for Component and System Retests 16

II. ACRS Items 17.

11.1 Surveillance of Encapsulated Cables 18

11.2 Chemical Behavior of Fire Retardent Coating on a Fire 20

11.3 Use of an Outside Fire Protection Review Agency 21

11.4 Results of the Retest Program 22

11.5 Results of Chloride Contamination Surveillance Program 23

11.6 Fire Protection Procedures and Training 24

11.7 Special Review Group Recommendations 25

12.0 Consultants' Report 26

13.0 Environmental 27
TABLE OF CONTENTS (continued)

page

14.0 Common Defense and Security 28

15.0 Financial Qualification 29

16.0 Conclusions 30

Appendix A Chronology A-I

Appendix B ACRS Report B-1

Appendix C ARL, Inc. Report C-1

Appendix D Comparison with SRG Report D-1
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1.0 Introduction

The Safety Evaluation Report by the Division of Operating Reactors

Supporting the Operation After the Restoration and Modification of

the Browns Ferry Nuclear Plant Units 1 and 2 Following the March 22, 1975

Fire (SER) was issued on February 23, 1976. The SER identified matters

requiring additional submittals by the Tennessee Valley Authority

(TVA) with subsequent NRC evaluation. Since the date of the SER

issuance, there have been meetings with TVA, additional revisions to

the "Plan for Evaluation, Repair and Return to Service of Browns Ferry

Units 1 and 2 (March 22, 1975 Fire)" dated April 13, 1975 (the Plan),

and meetings with the ACRS resulting in an ACRS report dated March 11,

1976.

The purpose of this supplement is to update the SER based on the NRC

evaluation work performed since February 23, 1976. The section numbers

of this supplement are the section numbers of the SER wherein the

matter was identified except for Sections 11, 12, 13, 14,

15 and 16. Section 11 discusses ACRS items which were identified

for additional information or evaluation in the ACRS report dated

March 11, 1976. Sections 12 through 16 are new sections. In addition,

the supplement contains an updated chronology as Appendix A, the report

of the Advisory Committee on Reactor Safeguards (ACRS) as Appendix B,

a report by the Analytical Research Laboratories, Inc. on combustion

test results for Flamemastic 71A as Appendix C, and a comparison of

the Browns Ferry Plant with the "Recommendations Related to Browns

Ferry Fire, Report by Special Review Group" (NUREG-0050) as Appendix D.
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2.4.1 Stainless Steel Piping and Tubing and Surveillance Programs

We have evaluated the additional metallographic and surface replication

test results provided by TVA. These results have confirmed our findings

that TVA has conducted an adequate program of investigation of the effects

of soot contamination, component cleaning, cleanliness verification,

evaluation and testing.

The initial sampling program of stainless steel piping and piping components exposed to the fire residues disclosed only one sample that had

indications of stress corrosion cracking initiation. This sample was a

1/4 inch diameter thin wall tube. To determine the extent of corrosion

on the small instrument lines, TVA removed at least one tube sample

from each of the critical instrument panels. Six of the samples were

found to have indications of the initiation phase of stress corrosion

cracking.

The instances of corrosion displayed a general pattern that indicated

that a major concentration of fire residue had moved from the fire area

and proceeded around the west side of the drywell to a stairwell in the

southwest corner of the reactor building. All the affected panels were

along the residue path ,to the stairwell or adjacent to the stairwell on

lower elevations. In the six panels in which corroded tubes were

observed, all the instruments were retubed. In addition, instruments

in three other panels adjacent to the six affected ones were also

retubed.

None of the other sampled panels were located in the path of the residue

and none had signs of corrosion. The sampling program will be continued

so that a sample tube will be removed for evaluation from each of these

remaining unretubed critical panels during the first refueling outage

of Unit 1 and again during the fourth refueling outage. This is in

addition to the visual surveillance that these lines will receive.

We find TVA's instrument line sampling, testing, replacement and

surveillance programs to be satisfactory.

In the SER, we stated that we were in basic agreement with TVA's

surveillance program approach, but would evaluate the need for an increased

scope and longer period of surveillance. As a result of our review,

the surveillance program to be set forth in the Technical Specifications

has been extended through the fifth refueling outage. At each refueling

outage, prior to the fifth, penetrant examination will be performed on the

stainless steel piping and components on a sampling basis in accordance

with Browns Ferry Mechanical Maintenance Instruction Number 53. During

the fifth refueling the penetrant examination will have the same scope as

the examination performed to qualify the plant to return to power according

to Browns Ferry Mechanical Maintenance Instruction Number 46. Reports of
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results of these examinations will be submitted to NRC. We conclude that

this program will provide adequate assurance that any deleterious effects

of residual chlorides will be detected prior to causing a safety hazard.
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2.4.2 Encapsulation of Fire Residue in Cable Trays

In Revision 38 to the Plan, TVA reported that cleaning of the fire residue

from cables in cable trays was found to be impractical because the large

number of cables in the tray and the short intervals between tie-down

points precluded access. In addition, the use of steam cleaning or high

velocity sprays would have led to recontamination of the reactor building

and possible damage to cables.

The encapsulation action of the Flamemastic coating provides an effective

barrier to any transport of possible chloride residue from the tray area

to other parts of the reactor building. This is the most important

consideration, since the greatest concern is the effect of chlorides

on primary coolant system piping and tubing.

We have evaluated any possible adverse effects due to residual chlorides

that might remain in the cable trays. The PVC cables themselves would

be uneffected by any chlorides present. The Flamemastic coating limits

the moisture ingress thereby minimizing the possibility of corrosion on

the trays and supports. Any corrosion or rusting would be inhibited by

the chemical neutralizing action of the calcium carbonate content of the

Flamemastic. The electrical cables, cable trays, and supports would not

be adversely affected by the products of the neutralizing actions of the

Flamemastic.

Further, all cable trays and supports will be inspected annually for five

years for indication of degradation of the cable tray systems. If

degradation of the trays and supports are found, they will be replaced.

In addition, at the first and second refueling outages of Unit 1

and at approximately every three years thereafter, a cable tray on elevation

593 ft. in Unit 1 that has fire residue in the cable bundle shill have

a portion of the Flamemastic cocoon opened and the cables and Flamemastic

inspected for any signs of deterioration.

We conclude that encapsulation of the chloride containing residue within

the cable trays by the Flamemastic coating provides reasonable assurance

against any adverse affects of the residue so contained and that the

surveillance of cable trays, cable tray supports, and cables will ensure

that any degradation of the components will be detected and corrected,

if found, prior to causing a safety hazard.
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6.2 Procedures (Fire-related)

In Section 6.2 of the SER we stated a concern regarding the development

of procedures for assessing transient fire loads in critical areas of

the plant and the additional fire protection requirements that may be

required, if any. Our specific concern related to taking credit for fire

protection systems installed to protect critical systems or cabling in

the transient fire load procedure. We further stated that we would require

a continuous fire watch with charged fire hose where transient fire

loads could be'located in critical areas where, due to obstructions,'the

installed fire protection system may not be effective for the transient

fire load.

TVA has proposed a procedure for control of transient fire loads at

nuclear-plants in Revision 43, Part XII of the Plan. The criteria set

forth in these proposed guides for the procedure which are now required by

the Technical Specifications remove our concern in that no credit will be

taken for fixed fire water spray or sprinkler systems in regard to

extinguishing capability for transient fire loads. Another section of the

procedure specifies the fire load limits and when additional fire

protection methods must be provided with relation to these limits. The

procedure further requires a periodic inspection of the area for low

loads and a continuous fire watch for medium and high fire loads.

Our requirement as stated in the SER included the need for charged fire

hoses in the area of the transient fire loads. Based on our evaluation

of the transient fire load procedure we find that the charged fire hose

requirement is not necessary but that the hoses be laid out, if required.

The charged hose does represent a personnel safety hazard. The valves that

are used to charge the fire hose are located at the hose rack or reel and

are quickly accessible by the fire watch that would be stationed in the

area.

Therefore, based upon a determination by the Office of Inspection and

Enforcement (OIE) that TVA has established procedures that fully conform

to the criteria set forth in Revision 43, Part XII of the Plan, we concluded

that our concern and requirements stated in the SER have been resolved.
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6.4 Quality Assurance

General

The description of the quality assurance (QA) program for the Browns Ferry

Nuclear Plant, Units No. 1 & 2 for the operation phase is contained in

Appendix D of the Final Safety Analysis Report (FSAR) through Amendment

62 and in the docketed J. E. Gilleland's letter to B. C. Rusche dated

June 7, 1976. This letter commits TVA to interpret the "shoulds" contained

in the ANSI standards referenced in the QA programs as requirements and

will be implemented accordingly. Our evaluation of the QA program is based

on a review of this information and discussions with Tennessee Valley

Authority (TVA) personnel to determine that the QA program meets with the

requirements of Appendix B to 10 CFR Part 50 and the acceptance criteria

described in Section 17.2, "Quality Assurance During the Operating Phase,"

of the Standard Review Plan.

The QA program for the restoration of the damaged facilities at the

Browns Ferry Plant is described in the Browns Ferry Recovery Plan Part

XIII. This program contains additional controls especially in the areas

of design, procurement, installation and inspection associated with the

restoration phase beyond those in the QA program prior to March 1975.

These additional controls and requirements are contained in WASH documents

1284 "Guidance on Qality Assurance During the Operations Phase of Nuclear

Power Plants," 1309 "Guidance on Quality Assurance Requirements During

the- Construction Phase of Nuclear Power Plant," and 1283 "Guidance on

Quality Assurance Requirements During the Construction Phase of Nuclear

Power Plants." We find that this QA program is acceptable and satisfactorily

addresses each of the criteria of Appendix B to 10 CFR Part 50.

Organization

The Office of Power has overall responsibility for the TVA power program,

and the Manager of Power who heads the Office of Power has responsibility

for the implementation and effectiveness of the QA program for operations.

Figure 17.2-1 shows the TVA organizations which directly affect the QA

program for the operations phase.
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Reporting to the Manager of Power is the QA Manager who is responsible for

establishing and controlling the QA program manual, assuring its implementation, measuring its effectiveness through audits, documenting and reporting

deficiencies, verifying effective corrective action, developing and coordinating QA training programs and keeping upper management abreast of quality

problems. The onsite QA coordinators, reporting independent of plant supervision, to the QA Manager, have primary responsibility for monitoring and

evaluating the implementation and effectiveness of the onsite QA program.

When quality assurance problems are identified (such as through the onsite

QA coordinator), the QA Manager has the responsibility and authority'to

initiate the appropriate corrective action, including that necessary to

stop work through appropriate managerial action, when manufacturing,

maintenance, repair, refueling, operator or modification work fails to

comply with approved specifications and plans.

The primary responsibility and authority for reactor operation and safety

of Browns Ferry is vested in the Power Plant Superintendent. Inplant QA

and quality control (QC) are his responsibilities. The supervisor of the

Plant QA staff is at the same organizational level but independent from the

Supervisor for Plant Operations who is directly responsible for maintenance,

operations, and engineering. Both supervisors report directly to the Power

Plant Superintendent. The QA staff supervisor has the responsibility for

developing, planning, initiating, and directing a comprehensive QA/QC

program which implements the Office of Power QA program. He also reviews

the plant procedures and instructions and signs them off prior to their

use, attesting that they contain the necessary QA requirements. Further,

his responsibilities include developing and implementing an inspection

program covering operations, maintenance, repairs, and testing of safetyrelated items.

When QA problems are identified, the QA staff supervisor has the

responsibility and authority to initiate corrective action, including that

necessary to stop work through the Power Plant Superintendent when

manufacturing, maintenance, repair, refueling, operation, or modification

activities fail to comply with approved specifications and plans. Should

the plant superintendent fail to follow the recommendations of the plant

QA staff supervisor, the supervisor has the authority to report directly

to the Nuclear Generation Branch Chief to whom the Power Plant Superintendent

reports.

We find that there are sufficient responsibilities delegated to the QA

organization to assure that the QA program can be carried out effectively

in accordance with controlled procedures without undue influence from other

groups.
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Quality Assurance Program

The Office of Power Quality Assurance Manual, prepared and controlled by

the QA Manager, sets forth the QA policies and requirements on how each

of the eighteen criteria of Appendix B to 10 CFR Part 50 are to be

followed by each division. From this manual, the Division of Power

Production is guided in structuring their detailed QA operating control

procedures forming the basis for their Operational Quality Assurance

Manual. The Browns Ferry QA program has been upgraded to include those

controls (with acceptable exceptions) described in Regulatory Guides and

ANSI standards provided in WASH document 1284 (Orange Book), "Guidance on

Quality Assurance During the Operations Phase of Nuclear Power Plants,"

dated October 26, 1973; WASH document 1309 (Green Book), "Guidance on

Quality Assurance Requirements During the Construction Phase of Nuclear

Power Plants," dated May 10, 1974; and WASH document 1283 - Revision 1

(Gray Book), "Guidance on Quality Assurance Requirements During Design and

Procurement Phase of Nuclear Power Plants," dated May 24, 1974. These

QA provisions are in such areas as design control, procurement control,

qualifications of inspection, examination and testing personnel and controls

for the installation, inspection and testing of instrumentation and

electric equipment. These additional requirements and controls, which were

not previously addressed in the QA program, provide further definition on

the implementation of important elements of Appendix B to 10 CFR Part 50.

This upgraded QA program is extended to cover the installation, testing,

surveillance testing and administrative controls for the fire prevention

and protection program and equipment for safety-related areas during the

operational phase.

The Browns Ferry program provides for routine inservice and installation

inspection of safety-related structures, systems, and components in

accordance with preestablished and approved procedures, instructions, or

checklists which identify the operation or characteristics to be inspected

and the accept/reject criteria, and also provides for documenting the

inspection results. The QA program requires that personnel performing

the inspection activity be independent of the individual or group that

performed the work being inspected. The program provides for the

identification of material, equipment, and parts throughout receipt,

installation, operation, maintenance, modification and refueling phases

which indicates their inspection, test, and operating status. Nonconforming

items are controlled under the QA program. TVA's QA Manager is

responsible to establish procedures for retention and storage of the QA

records.

A system of planned and documented audits, described in the FSAR, will be

used by TVA to verify compliance with all aspects of the QA program and to

assess its effectiveness. The QA Manager is responsible for the audit

system. In addition, the Manager of Power requires an independent review

of the Office of Power QA program to be performed every two years to

evaluate its overall effectiveness and identify any weaknesses.
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Conclusion

Our review of the Browns Ferry QA program description for the operations

phase has verified that all applicable requirements of Appendix B to 10

CFR Part 50 are included in the QA program requirements. Further, this

review has determined that the QA organizations are structured such that

they can effectively carry out their responsibilities related to quality

without undue influence from other groups.

Based on our detailed review and evaluation of the QA program description

contained in the FSAR for Browns Ferry Nuclear Plant, Units No. 1 & 2,

we conclude that:

1. The QA organization of the TVA isprovided sufficient independence

from cost and schedule when opposed to safety considerations,

authority to effectively carry out the QA programs, and sufficient

access to management at a level necessary to perform their QA

functions.

2. The QA program description contains adequate QA requirements and

controls which address each of the criteria of Appendix B to 10 CFR

Part 50 in an acceptable manner.
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Section 7.5.1 Fixed Water Systems

The hydraulic calculational methods that TVA has used in

the design of the fixed water systems in the plant are not

in exact conformance. with the methods set forth in the

NFPA Code. TVA's consultant questioned these methods and

recommended that all calculations be performed by the NFPA

code methods. We and our consultant have made a review of

TVA's calculational methods and compared them with the NFPA

code methods. One specific system which we reviewed in

detail was one of the zones of the fixed deluge system being

installed prior to restart. The results of this review

indicate that TVA's methods are comparable to the NFPA

methods and result in an adequate design. This is based on

water flow and pressure being available to the system as

used in the calculational methods. The preoperational

testing to be performed will assure that the flows and

pressures will be available. (See Section 9.1 of this report)

Therefore, based on our review of the calculational methods used

and comparison with NFPA code methods, we conclude that the

systems designed using TVA's methods are camparable with

the NFPA code methods and are acceptable. Our concern set

forth in the SER Section 7.5.1 and in Attachment 2 to the

report has been resolved based on this review.

As stated in Section 6.2 of the SER, the fixed fire water

system will be added to the semi-annual chemical treatment

procedure, already existing for other water systems, for

the control of crustacean growth in the system. This

procedure also requires complete flushing of the systems

up to the closed valves in the dry pipe spray systems. The

chemical treatment and flushing will also remove build-up

of other materials, such as sludge from the river water,

to provide assurance that the systems are clean. Crustacean

control is important to assure that spray nozzle performance

is not degraded. TVA's experience with the control of

crustacean growth in water systems at Browns Ferry has

been good and therefore, by adding the fire water system to

the chemical treatment procedure will provide the necessary

assurance that the spray nozzles will perform as designed.

We have incorporated in the Technical Specifications a

surveillance requirement for the twice per year chemical

treatment and system flush. In addition, the specifications

also require a yearly spray header and nozzles blockage test

for detection of any degradation of the headers and nozzles

flow paths.
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7.5.2 & 3 Heat and Smoke Detection Systems

Section 7.5.2 and 7.5.3 of the staff's SER stated that the designs for

the heat detection and.the smoke detection systems were acceptable

for restart, pending resolution of the concern raised by TVA's fire

consultant (Attachment 2 to SER) regarding the design and installation

meeting NFPA Class 1 requirements.

TVA has taken the following actions to show conformance with the NFPA

Class 1 requirements:

1. TVA has modified the electrical power supply for the detection systems

such that power is available from the offsite and onsite emergency

power sources. The onsite capability exceeds NFPA Class 1 requirements.

2. TVA has installed additional detectors to improve coverage.

3. TVA has demonstrated that the installation techniques which are used

at Browns Ferry are superior to the NFPA Class 1 requirements.

We have reviewed the modifications which have been made and the

installation techniques which are used by TVA. As a result of this review

we find that the designs meet the requirements for NFPA Class 1 systems

and are, therefore, acceptable.

TVA has also committed to installing additional NFPA Class 1 supervised

smoke detection systems in the general plant areas. These systems will,

by definition, meet the TVA fire consultant's recommendations. However,

TVA has taken exception to providing supervised smoke detection systems

in place of the existing systems and TVA also takes exception to purchasing

a supervised heat detection system to replace the non-supervised system

they recently obtained.

The purpose of a supervisory circuit is to continuously monitor the

detector circuits to detect a break or ground fault condition which

prevents the required operation of the system and to detect a failure of

the main power source. The design of the Class 1E onsite power system

is such that the onsite power system annunciates the loss of offsite

power as well as onsite power. We conclude, therefore, that the fire

detection systems have adequate power supervision and TVA has satisfied

the consultant's recommendations.

With regard to the detection of ground faults, TVA has demonstrated that

their systems will operate in spite of the existence of a single

unintentional ground. NFPA 72B specifically states that "A multiple

ground condition is considered the equivalent of a short circuit fault"

and "Electrical supervision of conductors for a short circuit fault is

,not contemplated" by the supervisory requirements. As a result we conclude

that automatic ground supervision is not required at Browns Ferry and,

therefore, thepresent and proposed designs are acceptable with respect

to ground supervision.
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With respect to the lack of continuous supervision for the detection

of breaks in the signal circuits, TVA has pointed out that their use

of less flammable electrical insulation, larger gauge wires, wire

lugs, and conduit and the controlled access to the Browns Ferry site

provide additional protection for the fire detection circuitry over

that which is provided in a public building for systems which meet

the minimum installation requirements of the NFPA standards. Therefore,

TVA contends that supervision is not required in the Browns Ferry fire

protection system. In considering this argument, we noted that the

fire detection circuits at Browns Ferry are installed to more

stringent requirements similar to reactor protection systems (which

could also be exposed to open circuits) and we concluded that the fire

detection circuits need not be continuously supervised for open circuits

if they are subjected to periodic, manual testing on the same basis as

the reactor protection system (including testing after installation,

modification, maintenance, or repair).

We find that the periodic testing required by the Technical Specifications will ensure adequate reliability of the smoke and heat detection

systems.
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Section 7.6.1 Automatic Fixed Fire Water Systems

&7.6.2

In Sections 7.6.1 and 7.6.2 of the SER we took the position

that TVA must use preaction valves for the automatic deluge

and sprinkler systems that have-been tested and approved by

an independent laboratory to be acceptable for their intended

function. In Revision 41 to Part X of the Plan TVA has

revised the design criteria to include the criterion that

all automatically actuated valves used in these systems will

be Factory Mutual (FM) approved or Underwriters Laboratbry

(UL) listed.

With this revision to the design criteria for the automatic

deluge and sprinkler systems, we conclude that the design

criteria for these systems are acceptable. We will review

the final design of these systems prior to their installation.
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8.0 Technical Specifications

In Section 8.0 of the SER we stated that proposed Technical Specifications

for the fire protection systems had been submitted by TVA. We stated that

these specifications were currently being reviewed and final specifications

would be developed prior to restart of Units 1 and 2.

We have been working with TVA to complete the Technical Specifications

that will be issued with a license amendment to authorize restart of

Units 1 and 2.

The new specifications incorporate limiting conditions for operation

for (1) operability of the high pressure fire pumps and unit shutdown

requirements if the system does not meet these limits, (2) minimum system

pressure and flow limits, (3) minimum storage limits for CO2 in the

storage tank, (4) limits for CO 2 system operability and unit shutdown

requirements if the system does not meet these limits, (5) limits on the

minimum fire detection system operability and requirements for a fire

watch if the detectorsystem limits are not met, (6) requirements for a

roving fire watch during the period between restart and the first

refueling, (7) requirements for an annual independent fire protection

and loss prevention inspection, (8) requirements for an inspection and

audit by an outside qualified fire consultant every three years, and

(9) requirements for the minimum in-plant fire protection organization

and duties to be maintained.

Surveillance requirements are also incorporated in the specifications to

require periodic testing and inspection of the fire protection systems

and the fire detection systems that must be performed at specified time

intervals to ensure that the fire protection systems are operable. The

majority of the surveillance intervals are consistent with the NFPA code.

The other intervals were determined based on the as-built plant systems

and unique requirements for the Browns Ferry Plant.

We conclude that the Fire Protection Technical Specifications will provide

for fire protection operability and maintenance to assure acceptable fire

protection for plant operations.
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9.1 Fire Protection Systems Preoperational Retest Program

In Section 9.1 of the SER we stated that TVA had provided retest outlines

and criteria for those parts of the fire protection systems that have been

modified or where additions were made to the original system. We also

stated that TVA would provide a total preoperational testing program.

By Revision 40 to the Plan, TVA has provided in Part XI the outline for

the total preoperational program to be performed prior to restart of

Units 1 and 2.

We have evaluated the retest and total preoperational testing program to

determine that the fire protection systems will be thoroughly tested for

the total plant. In addition, other features of the plant design that

performed a fire protection function were also reviewed to assure adequate

testing will be performed. The preoperational testing will demonstrate that

the systems, controls and equipment required for the fire protection of

the plant will meet manufacturer's operational requirements, design

objectives and applicable NFPA code testing requirements. As a result

of our evaluation, three items were noted as not being clearly set forth

in the preoperational testing criteria. These items were discussed with

TVA and we have been informed that the preoperational testing procedures

have been modified to include them. These items are: 1) in conducting

the yard hydrant flow and residual pressure tests for the main plant

loop and the cooling tower loop, the residual pressure measurements will

be taken at the first hydrant upstream of the hydrant being flow tested,

2) in addition to the stated systems within the plant where flow and

pressure curves will be generated from the testing, curves will also be

generated for the conditions at the top of each riser in the plant and

3) each fire hose will be tested to demonstrate flow capability. OI&E has

verfied that the preoperational testing procedures were modified to include

these items.

Based on our evaluation and the addition of the items described above to

the testing procedures, we conclude that the retest and preoperational

testing program for the fire protection features of the plant are

acceptable and will form an adequate basis for future surveillance

testing as required by the Technical Specifications.
16

9.2 Program for Component and System Retests

TVA has proposed a program for component and system retest which is

described in Part XI of the Plan. The program included testing of all

systems and components that: (1) sustained direct or indirect fire

damage, (2) were disrupted to comply with interim license requirements,

(3) were potentially damaged by cleanup and restoration work, or (4)

have received significant modifications or maintenance. We have

completed our review of the tests that will be conducted prior to fuel

loading and the tests that will be conducted during the initial rise to

full power operation. We requested that TVA conduct load discharge

tests of the 250V unit batteries prior to fuel loading and TVA has

conducted such tests. We now conclude that the test program proposed for

Browns Ferry Units 1 and 2 is acceptable and is sufficiently comprehensive

to provide assurance that systems and components that were disrupted or

damaged by the fire will function in accordance with design requirements.
- 17-

11.0 ACRS Items

The ACRS reviewed the proposed restoration and operational testing of

Browns Ferry Nuclear Plant, Units 1 and 2, at a March 4, 1976 meeting

and has reported its findings to the Commission. The ACRS report dated

March 11, 1976 is attached as Appendix B. Specific items that were

identified in the ACRS report are addressed in the following subsections

of this supplement.
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11.1 Surveillance of Encapsulated Cables

The ACRS expressed a concern that the gross application of the fire

retardant coating, Flamemastic 71A, might involve long-term effects

that warrant surveillance. The cocooning of the electrical and control

cables with Flamemastic 71A changes the working environment, and an

arrangement for opening some portion of the cable bundles to inspect

their condition periodically would seem appropriate.

We requested TVA to propose a surveillance program for periodic

inspection of the coated cables.

In Revision 42 to the Plan, TVA proposed that "In response to an ACRS

concern that the Flamemastic cocooning of electrical cables changes the

working environment, approximately every three years during the nearest

refueling outage, a nondivisional low-voltage power cable tray on Unit 1

(floor elevation 593) shall have a portion of the Flamemastic cocoon

opened, the cables inspected, and a sample of the cable jacketing

removed. The jacket sample shall be given an ASTM D412 physical and

dimensional test for elongation and tensile strength. The test values

shall be compared to previously obtained values to determine the aging

of the cable materials.

Repairs to the cable jacket shall be made with a cable jacket repair

kit, and the open area shall be recoated with Flamemastic."

TVA maintains that the jacket sample is a more sensitive indicator of

insulation aging because the PVC jacketing material has a rating of

75 0 C and the conductor insulating material (cross linked polyethelene)

has a 90 0 C rating.

In order to demonstrate that the jacket sample will be valid, TVA tested

a typical power cable of similar materials at 335 amperes and measured a

12 0 F (6.670 C) temperature difference from the conductor to the inside of

the jacket. This test current represents the heaviest type duty that

would be experienced by a continuously energized nondivisional power

circuit. This test compares favorably with a calculated average value of

3.470 C which TVA expects to experience with the divisional control and

power cables which will only see periodic operation under normal circumstances.

After discussions with the staff, TVA has agreed to an accelerated

surveillance schedule in which the first sample will be made at the

first refueling of Unit 1 (6 months-12 months) and the second sample taken

at the next refueling outage (about 18 months-24 months).
-19 -

As a result of our review, we have concluded that there should not be

any perceptible increase in the aging rate of the insulation material

covered by Flamemastic 71A. We have also concluded that, even if there

is a perceptible increase, the proposed test. has a sufficient sensitivity

to detect accelerated thermal aging, that a jacket sample is a valid

indicator of insulation damage, and that the test frequency is sufficiently

high to provide timely warning of any deterioration prior to causing a

safety hazard. Therefore, we find that the resolution proposed by TVA

is' acceptable.
- 20 -

11.2 Chemical Behavior of Fire Retardant Coating in a Fire

The ACRS expressed a concern that more information about the chemical

behavior of the fire retardant coating, Flamemastic 71A, in the

presence of a fire would be desirable. As a result of this concern

we requested the supplier of the coating, Flamemaster Corporation,

to provide us with a more detailed breakdown of the products of combustibn of Flamemastic 71A. In response to our request the supplier

provided the results of a test performed by Analytical Research

Laboratories, Inc., which were summarized as follows:

"Combustion tests indicate that Flamemastic 71A does

not propagate flame but burns only with difficulty

and is self extinguishing upon removal of the heat

source. The pyrolosis-combustion process evolves

a white smoke and leaves a dense char that makes

complete combustion difficult. Chemical analysis

of the products of combustion indicates carbon

dioxide, water, antimony chlorides, some hydrogen

chloride and traces of various chlorinated and

other organic compounds."

A description and the results of this test are' set forth in Appendix C

of this report. Based on the test results and the already known

products of combustion of the coating-material we find no compound that

would be a significant detriment to safety related equipment. The

hydrogen chloride and its resultant hydrochloric acid formation was

taken into account in our original evaluation of the use of the coating.

The amount of chloride contamination from this source is greatly reduced

compared to the chlorides that would be produced by the burning of the

cable insulation if it were not protected with Flamemastic 71A, such as

occurred during the March 22, 1976 fire.

Therefore, based on this test and information already available in the

literature, we conclude that the products of combustion of the coating

do not preclude the use of the coating as it is being applied to Browns

Ferry Plant. In fact, the use of the coating as applied will greatly

reduce any potential fire from producing large quantities of combustion

products from the electrical cabling it is protecting.
- 21 -

11.3 Use of an Outside Fire Protection Review Agency

The ACRS expressed a concern that, "Since the TVA is self-insured

in accordance with federal policy, its installations do not have the

normal fire insurance surveillance used by private installations.

The TVA... should be supplemented by an outside review agency to

assure a broad and unconstrained evaluation of fire protection

requirements."

In response to this concern, TVA has committed, in Revision 42, Part XII

of the Plan, to procure the services of a qualified fire protection

engineering consultant or firm to conduct audits at the plant at three

year intervals. We have incorporated the audit as a limiting condition

of operation requirement in the Technical Specifications and established

the date for the first audit to be during the period of June-September

1977. This audit in conjunction with the annual audit, also required

by the Technical Specifications, will adequately cover the concern

expressed by the ACRS.
- 24 -

11.6 Fire Protection Procedures and Training

The ACRS letter stated that verification of the adequacy of the fire

protection training programs proposed by TVA should be part of the

NRC regulatory plan and that the training program should include both

initial training and periodic retraining of personnel. The Office

of Inspection and Enforcement (OI&E) inspects the procedures and

training course content of the licensee to ensure their adequacy.

A fire protection consultant was engaged by NRC to provide guidance

and criteria for OI&E personnel to perform this function.

He is completing his review and recommendation with respect to these

subjects. These are expected shortly and will be covered by a further

safety evaluation covering the adequacy of training and procedures for

return to operation of the Browns Ferry facility that will be verified

by OI&E. Such safety evaluation will form the basis for our final

position with respect to these subjects.
- 25 -

11.7 Special Review Group Recommendations

The ACRS wished to be kept informed of the specific application of the

Special Review Group's recommendations as they apply to Browns Ferry.

Appendix D presents a tabulation of the comparison of Browns Ferry-with

the Special Review Group's recommendations.
. 26- ...

12. Consultants' Reports

In Attachment 2 to the SER, it was stated that summary reports of the

IVA and NRC consultants would be placed in the Docket File and Public

Document Rooms prior to NRC authorizing return to operation. The

NRC consultant did submit a summary report. His report's conclusion,

however, was conditioned upon the satisfactory completion of the TVA

consultants' evaluation and report. We have not yet received a summary

report by the TVA. consultants; however, it is presently scheduled for

submittal on June 18, 1976. NRC and its consultant will determine that

there are no unresolved items or that any that may exist are resolved

prior to authorizing return to operation. We will issue a final report

on this subject very shortly.
-27 -

13. Environmental

We have determined that the proposed amendments do not authorize

a change in effluent types or total amounts nor an increase in

power level and will not result in any significant environmental

impact. Having made this determination, we have further concluded

that the proposed amendment involve an action which is insignificant

from the standpoint of environmental impact and pursuant to 10 CFR

51.5(d)(4), that an environmental statement, negative declaration,

or environmental impact appraisal need not be prepared in connection

with the issuance of the proposed amendments.
16. Conclusions

Based on our analysis of the restoration and modifications of the Browns

Ferry Nuclear Power Plant Units 1 and 2, we have determined that upon

favorable resolution of the outstanding matters set forth in Sections

11.6 and 12.0, we will be able to conclude that:

(1) the application for amendment filed by Tennessee Valley Authority

dated August 13, 1975, complies with the requirements of the Atomic

Energy Act of 1954, as amended (Act), and the Commission's regulation!

set forth in 10 CFR Chapter 1;

(2) Restoration and construction of the Browns Ferry Nuclear Plant Unit

2 has been substantially completed and of Unit 1 will be substantiall,

completed in conformity with "Plan for Evaluation, Repair and Return

to Service of Browns Ferry Units 1 and 2 (March 22, 1975 Fire)" dated

April 13, 1975, as revised, the provisions of the Act, and the rules

and regulations of the Commission;

(3) The facility will operate in conformity with the application as

amended, the provisions of the Act, and the rules and regulations

of the Commission;

(4) There is reasonable assurance (i) that the activities authorized by

the license amendments can be conducted without endangering the

health and safety of the public, and (ii) that such activities Will

be conducted in compliance with the regulations of the Commission

set forth in 10 CFR Chapter 1;

(5) The applicant is technically and financially qualified to engage in

the activities authorized by the license amendments, in accordance

with the regulations of the Commission set forth in 10 CFR Chapter

1; and

(6) The issuance of the license amendments will not be inimical to the

common defense and security or to the health and safety of the

public.
A-I

APPENDIX A

February 19, 1976

February 25, 1976

February 27, 1976

March 2, 1976

March 10, 1976

March 17, 1976

April 6, 1976

April 9, 1976

April 16, 1976

April 19, 19-76

April 23, 1976

April 30, 1976

May 10, 1976

May 11, 1976

TVA letter transmitting Consultants' responses to TVA

Letter to TVA transmitting Safety Evaluation dated

February 23, 1976, regarding our evaluation of the

restoration and modifications at the Browns Ferry

Nuclear Plant, Units 1 and 2

TVA letter transmitting Revision 38 to "Plan for

Evaluation, Repair, and Return to Service...

TVA letter transmitting Standard Practice dated 1/21/76

for training Requirements for Operations Employees

Letter to TVA transmitting Summary Report received from

NRC's Fire Protection Consultant, Mr. Andrew J. Prior,

USERDA, Alburquerque Operations Office

TVA letter transmitting Revision 39 to "Plan for

Evaluation, Repair, and Return to Service..."

TVA letter transmitting Revision 40 to "Plan for

Evaluation, Repair, and Return to Service..."

TVA letter transmitting requested amendment to licenses

re removal of fuel pool gates

Letter to TVA transmitting Amendment No. 21 to DPR-33

and Amendment No. 18 to DPR-52 re removal of the canal

gate and three canal blocks in order to allow safe

transfer of the neutron sources from the reactor vessel

to the fuel storage pool

TVA letter transmitting Revision 41 to "Plan for

Evaluation, Repair, and Return to Service..."

TVA letter documenting verbal commitments re completion

of certain items before startup of either of the fireaffected units

TVA letter regarding fuel loading for Units 1 and 2

Unit 1 - 6/11/76, Unit 2 - 5/30/76

TVA letter transmitting Revision 42 to "Plan for

Evaluation, Repair, and Return to Service..."

TVA letter requesting Amendment relating to MCPR and

MAPLHGR limits, LPCI modification, and supplement to

proposed fire protection Technical Specifications
- 2 ý Appendix A-2

May 21, 1976

May 28, 1976

June 10, 1976

June 10, 1976

June 15, 1976

June 16, 1976

June 16, 1976

June 17, 1976

TVA letter transmitting a report entitled "Browns Ferry

Nuclear Plant Units 1-3, RHR Pump Protection Against

Operation in Excess of Design Runout"

TVA letter requesting Amendment to load fuel in

Units 1 and 2

TVA letter regarding the addition of a Safety

Engineer to the Browns Ferry Nuclear Plant staff

TVA letter transmitting Revision 43 to "Plan for

Evaluation, Repair, and Return to Service..."

TVA letter transmitting Revision 44 to "Plan for

Evaluation, Repair, and Return to Service..."

TVA letter transmitting Revision 45 to "Plan for

Evaluation, Repair, and Return to Service...

TVA letter transmitting infinite multiplication factor

for Unit 2 fuel

TVA letter transmitting Quality Assurance for fire

protection systems
APPENDIX B B-1

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

NUCLEAR REGULATORY COMMISSION

WASHINGTON. D. C. 20555

March 11, 1976

Jbnorable William A. Anders

Chairman

U. S. Nuclear Regulatory Conunission

Washington, DC 20555

Subject: RETOF ON PROPOSED REEMORATION AND OPERATIONAL TESTI=M O BROINS

FERRY NIiXLEAR PIANT, UNITS 1 AND 2

Dear Mr. Anders:

At its 191st meeting, March 4-6, 1976, the Advisory Committee on Reactor

Safeguards met with the Tennessee Valley Authority (TVA) to review repairs

and rodifications to be made to the Browns Ferry Nuclear Plant, Units 1

and 2 prior to restart of tlese units following the fire on March 22,

1975. These matters wre previously considered at a Subccmittee meeting

on February 27, 1976, in Washington, DC. During its review, the Committee

had the benefit of discussions with representatives and consultants of the

Tennessee Valley Authority a!nd the Nuclear Pegulatcry Commission (NIC)

Staff. The Committee also had the benefit of the documents listed.

The Browns Ferry Nuclear Plant consists of three boiling water reactors.

At the time of the fire Units 1 and 2 were operating -and Unit 3 was still

under construction. Following the fire the fuel was reroved from Units 1

and 2 and since has remained stored in the fuel storage pools. The Technical Specifications wre changed to provide for protective measures for

the fuel while in the storage pools.

TVA has conducted an extensive program to determine damage from the fire.

It was concluded that the major damage occurred in the reactor building,

outside the cable spreading room where the fire started. There has been

no evidence of significant structural damage and only minor damage to

piping systems. There was extensive damage to electrical cables, trays

and conduits. There was extensive deposition of soot on all equipnent

located in the reactor building below the refueling floor. This soot

contained an estimated 1400 pounds of chloride. All damage occurred in

the reactor building outside the containment.

Based on its assessnent of the damage from the fire, TVA has developed

and carried out a program for restoration of Units 1 and 2. This has

consisted of replacing, from terminal to terminal, all damaged cables in

the reactor protection system, primary containment isolation systen and

engineered safeguards systems. Some other cables that were damaged have

been repaired by splicing.
APPENDIX B - 2

Honorable William A. Anders -2- March 11, 1976

Because of the extensive nature of these repairs it is extremely important

that preoperational tests ascertain that repairs have been adequate to

restore required functions. Test procedures are being prepared by TVA

and are being reviewed by the NI Staff. The ACRS wishes to be informed

of the results of these tests prior to st 'tup of Units 1 and 2. A

cleanirg program has been carried out to remove the soot, and tests have

been conducted to determine damage from the soot. WMile the cleaning

program seems adequate, effects of the chlorides, such as stress corrosion

cracking, may not be evident for some time. TVA has proposed a surveillance

program to detect future deterioration that might be caused by these chlorides.

The NKIC Staff is reviewing the program to determine its ýdequacy. The ACIS

emphasizes the importance of such a program and wishes to be kept informed

of the results.

Of the 9500 electrical conductors involved, 45% have been replaced entirely

and criteria for splicinq the ramainder have been developed and followed.

Additional heat and saoke detectors have been installed. A fire retardant

coating, Flamnenastic 71A, has been used to reduce flammability. Fire watches

have been establish-ed. Autaratic fire protection systems and hand-held

fire suppression systems will be installed to proaptly suppress fires that

may occur. Vater spray will be used at critical locations. Changes in

communications are planned. The Corrmittee believes that these represent

significant improvements in fire protection.

Some of the fire control provisions and in particular the gross application

of Flc--.-aastic 71A might involve long-term effects that warrant surveillance.

The cocooning of the electrical and control cables with Flamemastic 71A

changes the working environment, and an arrangement for opening some portion

of the cable bundles to inspect their condition periodically would seem

to be appropriate.

The fire retardant action of the Flamemastic 71A has not been clearly

described arA, while tests indicate that it is effective, more information

about its chemical behavior in the presence of a fire would be desirable.

If the su-pplier of the material cannot provide the chemical information,

the NRC Staff should request an independent laboratory to investigate its

behavior as a precautionary measure to determine the toxicity and corrosive

properties of the chemicals evolved during a fire.

The criteria for access for fire fighting purposes, while difficult to

define, should be set forth by the NRC Staff for Applicants, so that there

is a basis for judging the adequacy of the provisions. The situation at

Browns Ferry is governed largely by the already constructed installation,

but there may be opportunities for improving or modifying what is proposed.
APPENDIX B -3

Honorable William A. Anders -3- March 11, 1976

Since the TVA is self-insured in accordance with federal policy, its

installations do not have the normal fire insurance surveillance used

by private installations. The r1VA has established an independent fire

protection staff within its organization. However, a newly established

unit may not have either adequate status or experience to be wholly

effective and should be supplemented by an outside review agency to

assure a broad and unconstrained evaluation of fire protection requirements.

Verification of the adequacy of the fire protection training programs proposed by TVA should be part of the NIC regulatory plan. The training

progran, should include both initial training and periodic retraining of

personnel.

Following the Browns Ferry fire the NRC Executive Director for Operations

set up a special review group to determine what should be learned from

this incident. This group has made reconmmndations that apply to future

reactors, to reactors that are already operating, and to the NIC regulatory

process. The review group points out that its reccar)endations are not

specific to any single plant and that its recommendations are based on

knowledge at the time of this investigation. The ACRS wishes to be kept

informed of the specific application of the review group's reccarhndations

as they apply to browns Ferry, to the development of additional information on fire prevention, fire fighting and quality assurance and the

improvement of NIRC policies, procedures and criteria.

The Cormittee expects to review generically several safety questions related

to boiling water reactors, including Park 1 torus response, during the next

several months. These questions as they may relate to Browns Ferry will

be addressed in the Committee's generic reports on these subjects.

The Advisory Cocamittee on Reactor Safeguards believes that, if due regard

is given to the itrms mentioned above, and subject to satisfactory completion of the planned restoration and subsequent operational testing, there

is reasonable assurance that the Browns Ferry Nuclear Plant, Units 1 and

2, can be operated at power levels up to 3293 Ywt, subject to the conditions

of the Cormittee's reports of September 21, 1972, and December 11, 1973,

without undue risk to the health and safety of the public.

Sincerely yours,

Da4eW. &eller

Chairman
APPENDIX B-4

Honorable William A. Anders -4- March 11, 1976

References

1. "Plan for Evaluation, Repair, and Return to Service of Brorwns Ferry

Nuclear Plant, Units 1 and 2 as a Result of the March 22, 1975,

Fire" by the Tennessee Valley Authority and Revisions 1 through 37

to that plan.

2. 'Recommendations Related to Browns Ferry Fire" (NUREG-0050)

Report by Special Review Group dated February 1976.

3. Safety Evaluation by the Division of Operating Reactors Supporting

the Operation After the Restoration and Modification of the Browns

Ferry Nuclear Plant, Units 1 and 2 following the March 22, 1975,

Fire dated February 23, 1976.

4. NIRC letter to Tennessee Valley Authority dated May 9, 1975, issuing

temporary Tech Specs for use during recovery from fire damage.

5. Tennessee Valley Authority letter dated June 11, 1975, regarding QA

provisions during cable splicing operations.

6. NIC letter to Tennessee Valley Authority dated June 13, 1975, modifying,

the Tech Specs for the period when Units 1 and 2 were defueled and the

fuel stored in the fuel pools.

7. Tennessee Valley Authority letter dated August 18, 1975, forwarding

responses to N1C questions relating to the Browns Perry fire.

8. Tennessee Valley Authority letter dated August 21, 1975, commenting

on the capability of obtaining total independence of redundant systems.

9. Tennessee Valley Authority letter dated August 29, 1975, caititting

itself to certain actions.

10. Tennessee Valley Authority letter dated September 15, 1975, formally

comuitting TVA to actions regarding fire protection systems.

11. Tennessee Valley Authority letter dated November 17, 1975, regarding

procedures for full-scale flame tests of wall penetration seal designs.

12. Tennessee Valley Authority letter dated December 8, 1975, regarding

heat shield barrier design.

13. NRC letter to Tennessee valley Authority dated December 19, 1975,

modifying the Tech Specs to reflect reduced cooling requirements

for the fuel stored in the fuel pools.
APPENDIX B -S

Honorable William A. Anders -5- March 11, 1976

References - Continued

14. Tennessee Valley Authority letter dated January 15, 1976, transmitting

data from fire tests performed on candidate electrical cable wall

penetration seal/fire stop designs.

15. Tennessee Valley Authority letter (undated) to B. C. Rusche transmitting

Enclosures 1, 2 and 3 re: Recommendations of fire consultants and TVAresponses; and additional information on the "Plan for Evaluation,

Repair, and Return to Service of Browns Ferry Nuclear Plant, Unit 1

and 2.

16. Tennessee Valley Authority consultant's (Associated Fire Protection

Consultants, Inc.) letter reports dated February 25 and March 4, 1976.

17. NYC letter to ACPS dated March 4, 1976, forwarding the Summary Report

of the NRC's Fire Protection Consultant.

* V.-.

-. - -o

8 4

CC

*.] '•:, U..SEA _•LabIS-.ippc- ICl.LABOlATiOF) ES, IC. Log Nurnbc--

36075 160 TAYLOR STREEl. P.O. BOX 369. MONROVIA. CAUFORNIA 91016 (213) 357-3247

APPENDIX C -i

Material/Sarmple Identity Date Receivcd

Flarmemaster/Flamemastic 71A Batch 030086 3/23/76

P.O. or R.P. Numoer Requested By

5783 Dr. Ro er Peterson

Work Order Sample Disposition Nature of Hazard Due Date

6951-01 ORetain OReturn Destroy

Ship To:

FlatiemasLer Corp.

11120 Sherman Way

Sun Valley. Ca. 9135:.

Nature of YW"ork and information Desired

Deti:arnine nature of gaseows combustion products.

Summary of i.aboratory Report

Q.C. Level

C.r-bustion tests indicate that Flamemastic 7iA does not propagate flame

but burn.s only with difficulty and is self extinguishing upon removal of the heat

source. The pyrolysis-combustion process evolves a white smoke and leaves

a dense char that makes complete combustion difficult. Chemical analyses of

the combustion products indicates carbon dioxide, water, antimony chlorides,

some hydrogen chloride, and traces of various chlorinated and other organic

compounds.

A discussion of the analytical methods is attached. Most of the work was

qualitative or semi-quantitative in nature due to time constraints.

As o n ., - tcol z'et .- 1 to cden.. . this e cpr 4 ; *ub I I.Jod o. , t eset.,..s.• iose of Sh. O|, 1 lo -11,- iS is

odd're..-. T.ehis repor oppl;e, -ly 1t Il- !o-'IC(8; tsIýtcJ ond i, not .. Ir ;I- ;nwcot.ve of thc C•oIte, Ot of pornt'ly .;.n.-o, or ;-n1. -!

IFrodi., . Usý of 1.1;, r,• .w.t t.-., ,rr jhklI or in p•ort. r of ont seals or insignio "onnected Sh-,ewdh. in cv y otv.rliýt.rw or pob4ic.fy t,•.'.:•r .•;thow| Pr;C,•;tnouhtz~~ ;I p'ohihsoemd ýf

Research and Dcveloprnait
Afv4 APPENDIX C C-2 ANALUTICAL nESEARCIN LA"O ATORIESI, ,C.

- 160 TAYLOR STREET. P.O. BOX 369. MONROVIA, CALIFORNIA 91016 (213) 357-3247

St-vlC.

Lab Log 36075, WO 695].01

Scope

The following studies are of a general survey nature to develop the

maximum useful information concerning pyrolysis-combustion characteristics of Flamemastic-71A in a short time.

Test Methods

A sample of Flamemastic 71A was suspended on a wire a'nd heated

with a gas burner until a dense white smoke was evolved. The flame

was then removed and the specimen was quickly covered with a glass

bell jar to trap the products of combustion and pyrolysis. The experiment was thus designed to yield incomplete combustion in order to

simul.ate conditions that might be expected in an actual plant fire.

The gases trapped under the bell jar were sampled and analyzed by

mass spectrometry. Qualitative chemical tests and emission spectrometry were used to determine the nature of the solid and liquid components.

R e sult s

Burning Observations - The specimen of Flamemastic 71A did not

support flame propagation. Holding it in a gas burner flame produced

a heavy white smnoke and only a small flame that was immediately

extinguished upon removal of the burner flame. The material subjected

to the burner flame left a dense residual char indicating incomplete

combustion.

Analysis of Gaseous Combustion Products - Mass spectrometric analysis

of the atmosphere and combustion gases trapped in the bell jar gave the

following:

Vol. -%

N2 77.3

0z 19.9

A 0.91

co 2 1.83

The above data indicate only slight combustion of the sample after removal

of the burner as much excess air is still present. It is conceded that soeic

Page 1 of 3
APPENDIX C -3

Lab Log 36075. WO 6951-01

carbon monoxide also may be present but not detected by mass spectrometry in the presence of much nitrogen. In order to obtain an analysis

of the minor amounts of organic species, a sample was concentrated by

liquid nitrogen trapping to give the following:

_ppm

Dichloroethane 500.

Alcohol (probably CH3 OI-I) 600.

Acetone 10.

B enz ene 5.

Toluene 30.

Ethyl chloride 100.

Carbon tetrachloride 30.

Vinyl acetate::: 1,000.

`Tentative. identification-the mass spectrum is

consistent with the presence of vinyl acetate

monomer, but further work is needed for

unequivocal identification.

The above data indicate only the ratios and types of compounds produced

under the laboratory burning/pyrolysis conditions. Concentrations and

even species will vary widely with the degree of air dilution and actual

fire conditions.

Water and some hydrogen chloride are expected in the burning of

Flamemastic 71A, but these spe.cies were not detected by mass spectrometry due to predictable surface adsorption retention.

Analysis of Condensible Products - The firing of a sample of Flamemastic 71A gave a white smoke with minute aqueous droplets that were

condensed on a cold glass surface in a separate qualitative test. The

condensate gave a slight but definite test for strong acid but a much

higher chloride level. Emission spectrographic analysis of the white

deposit confirms antimony as the major element with a minor of iron,

and a trace of silicon. Qualitative tests also indicated the presence

of traces of phosphates, as would be expected.

From the known formulation of the material, the above is readily

explained. Burning of the chlorinated hydrocarbons is known to produce hydrogen chloride and some does enter the atmosphere where it

is quickly condensed as a hydrochloric acid mist in the presence of the

water from both the combustion and normal atmosphere. Much of the

hydrogen chloride, however, reacts with the antimony oxide under the

fire conditions to produce, presumably, antimony trichloride. The

*:The level of HMI evolution is further reduced by the presence of calcium

carbonate in the formulation.

Page Z of 3
APPENDIX C-4

Lab Log 36075. WO 6951-01

insitu production of this material and its reaction with the concurrently

evolved moisture probably accounts for the white smoke. This heavy

fume acts to retard combustion. While the quantitative composition of

the smoke, or white deposit. was not determined, it probably consists

mainly of a finely dispersed mixture of antimony chlorides, and oxychlorides, with some entrained oxide and aqueous hydrogen chloride mist.
APPENDIX D

COMPARISON OF BROWNS FERRY PLANT, AS MODIFIED, WITH

"RECOMMENDATIONS RELATED TO BROWNS FERRY FIRE REPORT

BY SPECIAL REVIEW GROUP" (NUREG-00S0)

NUREG-0050

Section & Page

Section 3.2 Criteria for Fire Prevention and Control

1. Page 15 RECOMMENDATION

More comprehensive regulatory-guidance is needed - develop

standards for acceptable fire protection design methodology.

RESPONSE

This recommendation concerns future guidance or requirements

to be developed by NRC. When the guidance is forthcoming in

the form of Regulatory Guides or when Standards or Regulations

are issued on this topic, the area will be re-evaluated for

the Browns Ferry Plant to the same extent required for other

licensed plants.

Section 3.3.1 Fire Prevention in Design

2. Page 16 RECOMMENDATION

Include measures to avoid potential problems with areas

containing a high density of combustible material - provide

system for maintaining an inventory of combustible material.

Assess combustible material in each safety-related area and

take appropriate combination of measures for protection.

RESPONSE

TVA has assessed the installed combustible materials at the

Browns Ferry Plant (Section 4.0 of SER) and provided measures

including fire detection (Section 7.5.2 and 7.5.3), coating

all exposed cable surfaces with a fire retardant material

(Section 7.2), installing fixed water spray or sprinkler

systems (Section 7.5.1), adding fire hose stations to enhance.

coverage of accessible areas with combustible materials

(Section 5.0), improved training, procedures, and organization

for fire protection activities (Section 6.1, 6.2 and 6.3),

and an improved overall Quality Assurance Program (Section 6.4)

to provide the proper amount of control of combustibles and

extinguishment capability for the associated loading of

installed combustibles.
-2- D-2

For combustibles that are temporarily brought into areas of

the plant, administrative controls have been established

to increase the fire protection appropriately (Section 6.3).

3. Page 16 RECOMMENDATION

Section 3.3.2

4. Page 16

Alternative for future plants is establishment of fire

zones arranged for adequate isolation of redundant safety

equipment.

RESPONSE

This recommendation applies to future plants.

Operating Considerations in Fire Prevention

RECOMMENDATION

Measures available for fire protection should be embodied

in written procedures.

RESPONSE

TVA has provided additional written procedures for fire

protection (Section 6.2). This recommendation has been

incorporated in the Technical Specifications as a

requirement.

5. Page 16 RECOMMENDATION

Develop regulatory guides - allot review and inspection

resources.

RESPONSE

This recommendation applies to the review of future plants and

the re-review of the other operating plants and those for

which licenses have already been requested.

Criteria for Combustibility of Materials

RECOMMENDATION

More development work on materials and testing methods and

development of selection criteria - decrease combustibility

of present materials needing protection.

Section 3.4

6. Page 17
- 3 - D-3

Section 3.4.1

7. Page 18

RESPONSE

The basic objective of this recommendation is to decrease,

combustibility. TVA has decreased the combustibility of

present materials needing protection by the application

of fire retardant coating to all exposed cable surfaces in

all areas containing equipment required for safe shutdown (Section 7.2).

Cable Insulation Criteria

RECOMMENDATION

Follow Sandia and NELPIA-UL programs - Following completion

of the programs implement changes in existing plants where

significant safety improvement is indicated.

RESPONSE

We intend to follow this recommendation..

8. Page 18 RECOMMENDATION

Include study of airborne products of heating and combustion

in flammability investigations.

RESPONSE

This is a cable selection recommendation aimed at reducing

the atmospheric release of such products. TVA has used a

flame retardant coating to accomplish this purpose.

9. Page 19 RECOMMENDATION

Judicious use of fire retardant coatings - research and

testing on coatings.

RESPONSE

TVA has provided an acceptable fire retardant coating for all

exposed cable surfaces in all areas containing equipment

required for safe shutdown (Section 7.2).
- 4 - D-4

Section 3.4.2

10. Page 21

Criteria for Fire Stops and Seals

RECOMMENDATION

Develop qualification tests for individual materials as

well as assembled fire stop - testing to be performed by

qualified independent testing laboratory.

RESPONSE

We did not require testing by a qualified independent

laboratory. TVA conducted their own series of tests

to develop a fire stop for Browns Ferry at the Watts

Bar Test Facility. NRC reviewed and approved these

results (Section 7.4).

11. Page 21 RECOMMENDATION

Consider the possibility of providing fire stops at

specified intervals in long cable trays.

RESPONSE

All exposed cable insulation surfaces in safety related

areas have been coated with Flamemastic 71A providing

essentially a continuous fire stop.

12. Page 21 RECOMMENDATION

Consider on a case-by-case basis removal of unapproved foam

plastic seals.

RESPONSE

TVA has removed all polyurethane seal material to the extent

practical. Where polyurethane material is left it has been

covered by at least six inches of the new seal material plus

redundant barriers of insulation material (Section 7.4).

13. Page 21 RECOMMENDATION

Replace or demonstrate acceptability of extremely flammable

material in fire stops such as the flexible polyurethane foam

used as dams and plugs at Browns Ferry.

RESPONSE

All flexible polyurethane foam has been removed at Browns

Ferry (Section 7.4).
-5D - D-5

14. Page 21 RECOMMENDATION

Seal all openings in control room in order to protect

habitability.

RESPONSE

TVA has sealed all openings in the control room and the

ventilation system is designed to provide isolation for

habitability (Section 7.4 and 7.5.7).

15. Page 21 RECOMMENDATION

Consideration should be given to the addition of stops

and seals in existing plants to reduce spread of fire,

smoke, and gases.

RESPONSE

The Reactor Building is a complex structure with requirements

for established ventilation patterns to achieve proper

distribution and control of potential radioactivity. There

is no practical way to accomplish this recommendation for

isolation of floors, etc. The intent of the recommendation,

however, i.e., to minimize the spread of the products of

combustion, has been achieved by minimizing the contained

combustible material including Flamemastic coating of

exposed cables. In addition, improvements have been made

in fire related administrative procedures and automatic

detection and extinguishment systems have been added.

Section 3.5.1 Fire Detection and Alarms Systems

16. Page 22 RECOMMENDATION

Assure compatability of smoke detectors with anticipated

products of combustion.

RESPONSE

TVA is providing detectors that are UL approved for the

application with the materials installed in the plant.

Design review and field surveys will have been made to

assure proper location of detectors taking into account

obstructions and air pockets. (Section 7.5.3)
D-6 - 6-

17. Page 22 RECOMMENDATION

Provide better guidance on fire detectors, preferably

based on experiments with existing cables and detectors.

RESPONSE

This recommendation applies to future plants. See response

to Recommendation 18 below.

18. Page 22 RECOMMENDATION

Section 3.5.2

19. Page 24

Review and upgrade, as necessary, installed fire detection

systems in all plants.

RESPONSE

TVA has upgraded the fire detection systems in Browns

Ferry (Sections 7.5.2 and 7.5.3).

Design of Fire Extinguishing Systems

RECOMMENDATION

Emphasize need for quickly putting out all fires - factor

into fire procedures and fire training.

RESPONSE

TVA has added fixed water spray and sprinkler systems for

the purpose of providing a rapid means of distributing the

extinguishing agent (Water) to a cable fire. (Section 7.5.1)

In addition, more fire hose racks have been installed and

the training program and procedures, including prefire plans,

now reflect an emphasis on the ability of water to extinguish

cable fires. (Section 6.1 and 6.2).

RECOMMENDATION

Recommend fixed extinguishing systems, automatic if feasible,

in areas with high density of flammable material especially

where access is difficult.

RESPONSE

TVA is providing such systems for BrowrnFerry. (Sections7.5.1,

7.6.1, 7.6.2 and 7.6.3).

20. Pages 24 &

25
- 7 - D-7

21. Page 24 RECOMMENDATION

Consider drainage needs and potential for water damage in

design of water extinguishment systems.

RESPONSE

TVA has taken into account the drainage and sump capacity

requirements associated with the spray and sprinkler systems.

(Sections7..5.l, 7.6.1, and 7.6.3). Protection of all safety

related equipment from the effects of water drainage from

operation of these systems was also taken into account by

providing shields and covers where required. (Section; 7.5.1

and 7.6).

22. Page 24 RECOMMENDATION

Develop guidance for specification of quality and design

requirement for water sprinkler systems.

RESPONSE

Development of such guidance is underway. The adequacy

of the Browns Ferry sprinkler system was reviewed and,

as modified, are considered acceptable.

23. Page 25 RECOMMENDATION

In design of future plants,continue to provide high pressure

water system (hoses, nozzles, hydrants) in all plant areas

including those protected by sprinklers or sprays.

RESPONSE

At Browns Ferry, all areas, even those with sprays and

sprinklers, will have water coverage available from at

least two hose stations.

Section 3.5.3 Ventilation Systems and Smoke Control

Page 25 RECOMMENDATION

Review and upgrade ventilation systems to (a) assure continued

functioning if needed during a fire and (b) provide capability

of isolating fires by cutout valves or dampers - these

provisions to be compatible with requirements for containment

of radioactivity.
-8- D-8

RESPONSE

The cable spreading rooms' ventilation systems have been

modified and meet this recommendation (Section 7.3). The

measures taken to protect against the two divisions of

cabling from being affected by a fire (Section 7.0) ensure

the availability of at least one Standby Gas Treatment

System Train which could be utilized for ventilation in

the Reactor Building.

The remainder of the areas required for safe shutdown of

the plant have been evaluated and their emergency features

for secondary containment isolation or for isolation to

maintain habitability in the event of radioactive releases

or smoke or toxic gas releases outside the area being

protected, must retain priority over the capability to

exhaust smoke (Section 7.5.7). However, maintenance of

ventilation systems operability has been enhanced by the

protection afforded from the fire-retardant coating of all

exposed cable surfaces and other measures taken to reduce

the effects of a fire.

Section 3.5.4 Fire Fighting

25. Page 25 RECOMMENDATION

Include, in emergency plans, access and escape routes to

cover event of a fire in critical plant area - Consider this

aspect in design of future plants.

RESPONSE

TVA is providing prefire plans which include among other

things the access and egress routes from areas of the plant

where fires are likely to occur or where equipment related

to safe shutdown of the plant is. located. (Section 6.2).

26. Page 26 RECOMMENDATION

Assure compatibility of fire fighting equipment with off

site units.

RESPONSE

TVA has now installed equipment that is compatible with the

Athens, Alabama Fire Department equipment.
- 9 - DD-9

27. Page 26 RECOMMENDATION

Section 3.5.5

28. Page 26

Review and upgrade, as necessary, available breathing

equipment and means of recharging - consider this aspect

in future designs.

RESPONSE

TVA has added requirement to the training program to ensure

that the personnel know how to properly use breathing

apparatus (Section 6.1). TVA has also upgraded plant

breathing apparatus charging capability from bottles and

added a compressor charging system (Section 7.5.4).

Prevention and Readiness Efforts During Construction and

Operation

RECOMMENDATION

Develop plan for periodic testing of fire protection systems

including individuals and their responsibilities.

RESPONSE

TVA has incorporated a testing program and schedule

(Sections 6.2 and 6.3). TVA also has provided a new

position on the operating staff, one of encumbent's

responsibilities is to ensure that the fire protection

equipment is tested and maintained (Section 6.3).

29. Page 26 RECOMMENDATION

Include requirements for operability and surveillance testing

of fire protection systems in Technical Specifications.

RESPONSE

The Technical Specifications for Browns Ferry will include

operability and surveillance requirements for the fire

protection systems (Section 8.0).
-10 - D-10

30. Page 27 RECOMMENDATION

Provide temporary measures when fire protection equipment is

disabled for maintenance or when fire stops are breached.

RESPONSE

TVA has instituted administrative controls for providing

supplemental fire ptorection measures when an installed fire

protection or detection system is disabled for maintenance

or when a fire stop is breached (Section 6.2).

31. Page 27 RECOMMENDATION

Emergency plans should recognize need for fire fighting

concurrent with other activities.

RESPONSE

In regard to plans for fire fighting concurrent with other

activities, TVA has reorganized the Fire Brigade (Section

6.3) to designate a specific portion of the operating shift

crew as Brigade members leaving the remaining portion of the

operating shift for other activities associated with safe

operation or shutdown of the plant.

32. Page 27 RECOMMENDATION

Conduct periodic fire drills to include onsite and offsite

personnel and organizations that would normally respond to

fires.

RESPONSE

The Browns Ferry Plant onsite fire fighting equipment and

personnel (plant fire brigade) are intended to be, and were

found to be by our review, adequate without assistance from

the offsite Athens Fire Department. The offsite fire

department is intended only as backup to onsite capability.

Agreements, plans and orientation visits to the Browns

Ferry plant have been arranged with the Athens Fire

Department; however, we do not require their participation

in-fire drills. Periodic drills are held with the offsite

TVA emergency organization and communications drills are

made with non-TVA organizations.
- 11 - D-11

Section 4.1.2

33. Page 31

Section 4.2

34. Page 32

Role of Normal Cooling Systems

RECOMMENDATION

Consider independence of normal and safety systems which

could cool the reactor.

RESPONSE

Although this has never been an NRC review requirement, the

Browns Ferry design demonstrated sufficient independence

of normal systems to provide core cooling during and after

the March 22, 1975 fire. Our primary objective in the

fire protection review was to assure that TVA had provided

sufficient redundancy, diversity, and isolation within the

divisional safety systems without reliance on other

systems to assure reactor cooling in the event of a fire.

Redundancy and Separation - General Considerations

RECOMMENDATION

Consider manual valve manipulation capability in design of

all plants.

RESPONSE

This capability was considered and included in the original

Browns Ferry design.

Common Mode Failures Attributable to Indicator Light

Connections

RECOMMENDATION

Recommends assurance of adequacy of isolation between safety

equipment and non-safety circuits.

RESPONSE

The indicating lamp circuits which led to the loss of redundant

Motor Operator Valve (MOV) boards have been removed at Browns

Ferry (Section 7.1).

Section 4.3.2

35. Page 36
- 12 - D-12

Section 4.3.3.1 Trays.and Conduit

36. Page 36 RECOMMENDATION

Need improved criteria regarding use of conduit.

RESPONSE

Section 7.1 discusses the combined modifications at Browns

Ferry to provide adequate conduit protection. They

include some relocation, coating of exposed cable

surfaces and addition of fixed water systems to wet

the conduit.

Section 4.3.3.3 Cable Spreading Room (CSR)

37. Page 37 RECOMMENDATION

Section 4.3.4.1

38. Page 40

Need improvement in criteria for cable spreading room

including separation and access for fire fighting.

RESPONSE

SER Attachment 3(A.1, A.2) discusses improvements in

the Browns Ferry CSR protection. They include automation

of the CO2 system, coating of all exposed cable surfaces

and the addition of a back-up manual sprinkler system.

Browns Ferry Criteria for Physical Separation and

Isolation of Redundant Circuits

RECOMMENDATION

Steel cable tray covers appear to be inadequate fire barriers.

RESPONSE

Fire barrier credit is not- taken for cable tray covers in the

Browns Ferry redesign.

Section 4.3.4.4

39. Page 42

Criteria for the Future

RECOMMENDATION

Improve existing NRC separation and isolation criteria.
13 D-13

RESPONSE

This is a recommendation for the future not applicable here.

40. Page 45 RECOMMENDATION

Practical to provide separate cable spreading rooms for each

division in future plants.

RESPONSE

This is a recommendation for the future not applicable

to this plant.

41. Page 46 RECOMMENDATION

Section 4.4

42. Page 47

Separate redundant manual control switches by suitable fire

barriers.

RESPONSE

Although this is a recommendation for the future, we noted

that the redundant manual control switches at Browns Ferry

have canned enclosures and have a minimum separation of

6 inches air space. We have not required additional fire

barriers for this plant.

Instrumentation Required for Operator Action

RECOMMENDATION

Urges NRC and industry standard groups to develop standards

and requirements for instrumentation required for operator

information and action.

RESPONSE

This is a recommendation for the future Such standards and.

requirements when developed will be considered to the

extent applicable.

Lapses in Quality Assurance at Browns Ferry

RECOMMENDATION

Reevaluate revised Browns Ferry QA program in light of

experience of the fire.

Section 5.2

43. Page 49
14 -D- 14

RESPONSE

TVA has a new QA program for Operations

which meets the current NRC requirements. In addition,

OI&E will verify that the appropriate portions of the

detailed QA Procedures Manual have been modified to address

the area of fire protection.

44. Page 50 RECOMMENDATION

Operating QA programs in older reactors, known not to

conform to current standards, should be upgraded promptly.

RESPONSE

The Browns Ferry program has been upgraded.

45. Page 50 RECOMMENDATION

Upgrade the NRC Inspection program.

RESPONSE

The NRC inspection program for the restoration and

modification at Browns Ferry has been upgraded to include

fire protection systems, fire prevention, and fire

fighting.

46. Page 50 RECOMMENDATION

Licensee QA programs, and NRC licensing and inspection

programs should include explicit reference to fire

prevention, fire fighting and consequence mitigation in

their written procedures.

RESPONSE

The NRC licensing and inspection programs for the Browns Ferry

restoration and modifications explicitly evaluate fire

prevention, fire fighting, and fire prevention and-the

SER and its supplements and the inspection reports provide

written evidence of this.
- 15 - D-IS5

Section 5.3.1.2 Off'site

47. Page 51 RECOMMENDATION

Consideration should be given to providing alternate or

emergency power supplies for fixed in-plant radiological

monitoring equipment or providing sufficient manpower for

use of portable monitors.

RESPONSE

TVA is preparing emergency procedures to provide added

presonnel and portable equipment.

48. Page 51 RECOMMENDATION

Section 6.2.3

49. Page 54,60

"Standby" classification in emergency plans appears necessary

to cover those incidents (like the fire) with potential

for later triggering one of the four major incident

classification categories.

RESPONSE

TVA is changing their Emergency Procedures to provide for

a "standby alert" condition.

NRC Organization - Application to Unusual Events and

Incidents

RECOMMENDATION

Improve NRC procedures for the safety review of incidents.

Clarify the concept of "Lead responsibility".

RESPONSE

OI&E and ONRR are now holding regular monthly meetings to

discuss issues as they arise regarding interface relationships

between the offices. As an outgrowth of these meetings, new

written guidelines are under development defining more

clearly the responsibility for these interface areas.
-16- D-16

50. Page 55 RECOMMENDATION

Implementation of Review Groups recommendations must be

decided plant-by-plant.

RESPONSE

This tabulation together with the SER for the return to

operation of Browns Ferry shows the implementation of

the SRG recommendations appropriate for this plant at

this time. As the staff implements additional SRG

recommendations in the future, the need for further action

for this plant as well as others, will be considered.

Section 6.3 NRC Action Before the Fire

51. Page 56 RECOMMENDATION

Present NRC programs in fire prevention and control research,

standards and criteria, licensing and inspection should be

continued and expanded as needed and as recommended in

report.

RESPONSE

Additional fire protection requirements generated by such

continued and expanded efforts will be considered for this

plant to the extent that significant improvements in safety

can be achieved,

Section 6.3.3 Inspection of Licensee Operations

52. Page 57 RECOMMENDATION

Reevaluate procedures for resolution by NRC management of

issues involving "poor practice" findings by inspectors.

RESPONSE

The staff recognizes the need for NRR to responsibly

deal with "feedback" from IE inspectors and where appropriate,

will develop enforceable criteria and requirements applicable

to this and other nuclear power plants.
- 17 - D-17

Section 6.4 NRC Action During and After the Fire.

53. Page 58 RECOMMENDATION

Develop alternate modes of transportation for emergency use

to avoid undue delays between a region office and a site.

RESPONSE

Alternative methods of transporatation from house or

Regional Office to the affected nuclear site at any

hour are being evaluated. The objective is to assure

dispatch of appropriate personnel within two hours after

notification.

54. Page 58 RECOMMENDATION

Give attention to availability of back-up management and

technical personnel at Headquarters to provide for a

prolonged emergency.

RESPONSE

Duty Officers are being established in all the offices

necessary to respond to any emergency.

55. Page 58 RECOMMENDATION

Provide improved communications facilities - start with

a system study.

RESPONSE

An Incident Management Center(IMC) has been established in

the IE Headquarters Office in Bethesda, The Center houses

the existing communications equipment for incident management, which consists of telephones with arrangements for

conference calls. During emergency periods, the NRC

operators' services are available for assisting the IMC

on an augmented basis. Four of the IE principal staff and

the IE Duty Officers have been assigned papers for prompt

response to messages. Two facsimile machines and

communicating magnetic card typewriters are located within

the IE offices. Procedures for notification of their

agencies are in effect.
- 18 - D-18

Section 7.0

5"6. Page 61

Acquisition of communications facilities and development

of procedures necessary to establish a link between

Headquarters, Regions and the incident site remains to

be accomplished. AT&T consultation for the discussion of

operational needs and equipment has been arranged.

Internal procedures are under development.

Response to Other Government Agencies

RECOMMENDATION

Alabama and local governments should reassess and strengthen

emergency notifications methods and procedures.

RESPONSE

Meetings have been held with the Alabama and local officials

and training sessions and drills have been held with the

appropriate emergency personnel.

Tennessee

RECOMMENDATION

TVA emergency spokesman needs to use more careful phraseology

to avoid inciting undue alarm in offsite agencies.

RESPONSE

This recommendation has been passed on to TVA.

Section 7.2.2

57. Page 62

58. Page 63 RECOMMENDATION

Recommend continued efforts for helping States develop

radiological emergency response plans.

RESPONSE

Efforts are continuing in this area.

Drills and Exercise

RECOMMENDATION

Recommends that drills and exercises to test emergency interface

between TVA, the State of Alabama and its local governments

be conducted at least annually.

Section 7.3.6

59. Page 64
-19- D-19

RESPONSE

TVA plans to make these periodic drills more effective to

ensure full communications coverage.

60. Page 7-11 RECOMMENDATION

Other licensees should also initiate adequate regular

excercises to promote maintenance of emergency response

capability by local government.

RESPONSE

This recommendation is for other licensees.

Printed <.

on recyciled"

paper