CNL-25-067, Application for Subsequent Renewed Operating Licenses, Sixth Safety Supplement

Application for Subsequent Renewed Operating Licenses, Sixth Safety Supplement

ML25121A174
Person / Time
Site:	Browns Ferry
Issue date:	05/01/2025
From:	Hulvey K Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
CNL-25-067, EPID L-2024-SLE-0000
Download: ML25121A174 (1)

Text

1101 Market Street, Chattanooga, Tennessee 37402 CNL-25-067 May 1, 2025 10 CFR 54 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application for Subsequent Renewed Operating Licenses, Sixth Safety Supplement (EPID L-2024-SLE-0000)

Reference:

1. TVA Letter to NRC, CNL-24-001, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application for Subsequent Renewed Operating Licenses, dated January 19, 2024 (ML24019A010, ML24019A011)

2. TVA Letter to NRC, CNL-24-011, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application for Subsequent Renewed Operating Licenses, Supplemental Information - Neutron Fluence Analyses Methodology, dated January 22, 2024 (ML24022A292, ML24022A293)

3. TVA Letter to NRC, CNL-24-043, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application for Subsequent Renewed Operating Licenses, Second Safety Supplement (EPID L-2024-SLE-0000), dated November 1, 2024 (ML24306A203)

4. TVA Letter to NRC, CNL-24-081, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application for Subsequent Renewed Operating Licenses, Third Safety Supplement (EPID L-2024-SLE-0000), dated December 17, 2024 (ML24352A216, ML24352A217)

5. TVA Letter to NRC, CNL-25-021, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application for Subsequent Renewed Operating Licenses, Fourth Safety Supplement (EPID L-2024-SLE-0000), dated February 12, 2025 (ML25043A035)

6. TVA Letter to NRC, CNL-25-047, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Application for Subsequent Renewed Operating Licenses, Fifth Safety Supplement (EPID L-2024-SLE-0000), dated March 4, 2025 (ML25063A184)

By Reference 1, the Tennessee Valley Authority (TVA) submitted a Subsequent License Renewal Application (SLRA) for the Browns Ferry Nuclear Plant, Units 1, 2, and 3, Renewed Facility Operating Licenses in accordance with Title 10 of the Code of Federal Regulations,

U.S. Nuclear Regulatory Commission CNL-25-067 Page 2 May 1, 2025 Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. By Reference 2, TVA provided the first safety supplement to the SLRA.

From March 2024 until January 2025, TVA has been engaged with the Nuclear Regulatory Commission (NRC) staff in the safety audit of the SLRA. By References 3, 4, 5, and 6, the second, third, fourth, and fifth SLRA safety supplements, respectively, were submitted to address additional NRC information requests resulting from the audit as well as miscellaneous errata changes identified by TVA since the submittal of the SLRA. This sixth safety supplement is provided to address additional NRC information requests resulting from post-audit discussions with the NRC.

The enclosures to this supplement address SLRA changes made at NRC request for completion of their review. The enclosures provide a description of the change, the affected pages in the SLRA, and a markup of the SLRA pages.

There are no new commitments made in this letter. However, modifications to existing commitments are made in Enclosure 1 (Commitments 7, 16, and 33 as shown on Table A.5) and in Enclosure 2 (Commitment 27 as shown on Table A.5). Should you have any questions regarding this submittal, please contact Peter J. Donahue, Director, Subsequent License Renewal at pjdonahue@tva.gov.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 1st day of May 2025.

Respectfully, Kimberly D. Hulvey General Manager, Nuclear Regulatory Affairs and Emergency Preparedness

Enclosures:

1.

SLRA Admin Supplement #3 2.

TRP-014 Buried and Underground Piping and Tanks cc: (Enclosures)

NRC Regional Administrator - Region II NRC Branch Chief - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager, License Renewal Projects Branch (Safety)

State Health Officer, Alabama Department of Public Health (w/o Enclosures)

Digitally signed by Edmondson, Carla Date: 2025.05.01 07:42:29

-04'00'

CNL-25-067 ENCLOSURE 1 SLRA Admin Supplement #3 (13 pages)

Title of Supplement Enclosure Document SLRA Admin Supplement #3 Description of SLRA change(s) attached The changes made (as described below) reflect the final configuration of the changes as compared to the original SLR Application, Revision 0 and should be used in replacement of changes made past the original submittal.

Item 1: SLRA Appendix A on page A-88 is being revised to reflect the previously updated verbiage of Enhancement 3 to the BWR Vessel and Internals Program, with an editorial correction incorporated to reflect the sample size being 100 "percent."

Item 2: SLRA Appendix A and Appendix B on pages A-50, A-129, and B-170 are being revised to reflect the previously updated verbiage of Enhancement 34 to the Structures Monitoring Program.

Item 3: SLRA Appendix A on page A-100 is being revised to reflect the previously updated verbiage of Enhancement 4 to the Fire Water System Program, with an administrative correction incorporated to clarify the enhancement number as 4.

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Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

A-88 7

BWR Vessel Internals The existing program is credited and will be enhanced as follows:

 Revise implementing procedures to explicitly state that the approved guidelines contained in BWRVIP-14-A, BWRVIP-59-A, BWRVIP-60-A, and BWRVIP-62 Revision 2 are used as a source of repair design criteria for reactor vessel internals components, as applicable.

 Revise implementing procedures to implement BWRVIP-315-A and subsequent revisions approved by the NRC for BFN to use during the subsequent period of extended operation.

 Revise implementing procedures to incorporate the requirement WKDWLI FUDFNLQJLVGHWHFWHGDIWHUWKHLQLWLDOLQVSHFWLRQforjustifying the frequency of subsequent inspections VKRXOGEHMXVWLILHGbased on appropriatefracture toughness properties DSSURSULDWHIRUWKHFRQGLWLRQ RIWKHFRPSRQHQWif component cracking is detected duringinspection.

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 Revise implementing procedures to explicitly state that the approved guidelines contained in BWRVIP-14-A, BWRVIP-59-A, BWRVIP-60-A, BWRVIP-80-A and BWRVIP-99-A are used, as applicable, as a source of guidelines for evaluating crack growth in stainless steels, nickel alloys, and low-alloy steels, and that BWRVIP-100 Revision 2 is used as a source for flaw evaluation methodologies and fracture toughness data for SS core shroud exposed to neutron irradiation.

 Revise implementing procedures to explicitly state that the guidelines contained in BWRVIP-97 Revision 1 are used as a source of guidelines for performing weld repairs to irradiated vessel internal components.

 Revise implementing procedures to explicitly state that the guidelines in BWRVIP-84, Revision 3 (or a later revision if approved and issued) are used to provide guidance on procurement, design and welding requirements, fabrication limitations, and numerous other issues (including maintaining operating tensile stresses below a threshold limit that mitigates IGSCC) for the four specific material types used for in-vessel repairs:

300Series austenitic stainless steel, Alloy X-750, Type XM-19 and Alloy718. The resulting specification is then used for designing repairs to the following internal components that fall within the scope of the BWRVIP program: core shroud, shroud support, core spray, top guide, core plate, standby liquid control line, jet pumps, control rod drive components, instrument penetrations, and vessel brackets.

Program will be enhanced no later than six months prior to the subsequent period of extended operation.

Section A.2.1.7 Table A.5, Subsequent License Renewal Commitment List (Continued)

No.

Program or Topic Commitment Implementation Schedule Source

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Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

A-50 Elastomeric membranes, structural sealants, and seismic joint fillers are acceptable if the observed loss of material, cracking, hardening, separation, and/or leakage will not result in the loss of sealing.

Elastomeric vibration isolation elements are acceptable if there is no loss of material, cracking, hardening, separation, and/or leakage that could lead to the reduction or loss of isolation function.

26.Revise implementing procedures to add following acceptance criteria for earth berms:

No significant loss of material No significant loss of form No evidence of erosion, settlement, sedimentation, frost action, waves, currents, surface runoff, or seepage that could lead to a loss of material or form.

27.Revise implementing procedures to ensure the groundwater chemistry has been determined to be within the following parameters: pH > 5.5, chlorides < 500 ppm, and sulfates <1,500 ppm. Groundwater chemistry values indicative of aggressive groundwater/

soil (pH < 5.5, chlorides > 500 ppm, or sulfates > 1,500 ppm) will be assessed for impact on concrete structural elements. This may include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed five years.

These program enhancements will be implemented no later than six months prior to the subsequent period of extended operation. Baseline inspections that are to be completed prior to the subsequent period of extended operation will be completed no later than six months prior to the subsequent period of extended operation, or no later than the last refueling outage prior to the subsequent period of extended operation.

A.2.1.34 Inspection of Water-Control Structures Associated with Nuclear Power Plants The BFN Inspection of Water-Control Structures Associated with Nuclear Power Plants aging management program is an existing condition monitoring program that consists of inspection and surveillances of raw water-control structures associated with emergency cooling systems and/or flood protection to identify aging effects prior to loss of intended functions. The program also includes requirements for structural steel and structural bolting associated with water-control structures.

The program addresses age-related deterioration, degradation due to environmental conditions, and the effects of natural phenomena that may affect the intended design basis functions of water-control structures and components within the scope of the program. The program recognizes the importance of periodic monitoring and maintenance of water-control structures so that the consequences of age-related deterioration and degradation can be prevented or mitigated in a timely manner. The monitoring methods described in the program are effective in detecting aging effects and the frequency of the monitoring is sufficient to prevent the loss of the intended design functions due to age related degradation.

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Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

NRC Regulatory Guide 1.127 Revision 2, Positions C.1 through C.10 delineates current NRC practice in evaluating inspection programs for water-control structures. BFN does not commit to this regulatory guide. The program however, does incorporate the detailed guidance in accordance with NRC Regulatory Guide 1.127, Revision 2, Positions C.1 through C.10 for the inspection programs and surveillances for water-control structures, including guidance on

Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

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26. Revise implementing procedures to add following acceptance criteria for earth berms:

• No significant loss of material

• No significant loss of form

• No evidence of erosion, settlement, sedimentation, frost action, waves, currents, surface runoff, or seepage that could lead to a loss of material or form.

27. Revise implementing procedures to ensure the groundwater chemistry has been determined to be within the following parameters: pH > 5.5, chlorides < 500 ppm, and sulfates <1,500 ppm. Groundwater chemistry values indicative of aggressive groundwater/soil (pH < 5.5, chlorides > 500 ppm, or sulfates > 1,500 ppm) will be assessed for impact on concrete structural elements. This may include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.

Table A.5, Subsequent License Renewal Commitment List (Continued)

No.

Program or Topic Commitment Implementation Schedule Source Monitoring (continued)



Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) 34 Inspection of Water-Control Structures associated with Nuclear Power Plants The existing program is credited and will be enhanced as follows:

1. Revise implementing procedures to add Circulating Water Conduits to the scope of the program.

2. Ensure preventive actions are included to ensure bolting integrity for replacement and maintenance activities by specifying proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting. For structural bolting consisting of ASTM A325, ASTM A490, ASTM F1852 and/or ASTM F2280 bolts, the preventive actions for storage, lubricant selection, and bolting and coating material selection discussed in Section 2 of the Research Council for Structural Connections publication, Specification for Structural Joints Using High-Strength Bolts, dated August 2014, will be used.

3. Revise implementing procedures for monitoring and inspection of water-control concrete structures to also include those parameters as described in ACI 201.1R, these include cracking, movements (e.g.,

settlement, heaving, and deflection), conditions at junctions with abutments and embankments, loss of material, increase in porosity and permeability, seepage, and leakage.

Program will be implemented no later than six months prior to the subsequent period of extended operation. Baseline inspections that are to be completed prior to the subsequent period of extended operation will be completed no later than six months prior to the subsequent period of extended operation, or no later than the last refueling outage prior to the subsequent period of extended operation.

Section A.2.1.34 Table A.5, Subsequent License Renewal Commitment List (Continued)

No.

Program or Topic Commitment Implementation Schedule Source

Appendix B - Aging Management Programs Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

B-170 23.Revise implementing procedures to require no signs of distress that could indicate degradation of the underlying material for painted or coated areas.

Program Element Affected: Element 6 - Acceptance Criteria 24.Revise implementing procedures to ensure there are no indications of excessive loss of material due to corrosion or wear and no debris or dirt that could restrict or prevent sliding of the surfaces as required by design.

Program Element Affected: Element 6 - Acceptance Criteria 25.Revise implementing procedures to ensure inspections for elastomeric vibration isolators, membranes, structural sealants, and seismic joint fillers the following acceptance criteria are met:

Elastomeric membranes, structural sealants, and seismic joint fillers are acceptable if the observed loss of material, cracking, hardening, separation, and/or leakage will not result in the loss of sealing.

Elastomeric vibration isolation elements are acceptable if there is no loss of material, cracking, hardening, separation, and/or leakage that could lead to the reduction or loss of isolation function.

Program Element Affected: Element 6 - Acceptance Criteria 26.Revise implementing procedures to add following acceptance criteria for earth berms:

No significant loss of material No significant loss of form No evidence of erosion, settlement, sedimentation, frost action, waves, currents, surface runoff, or seepage that could lead to a loss of material or form.

Program Element Affected: Element 6 - Acceptance Criteria 27.Revise implementing procedures to ensure the groundwater chemistry has been determined to be within the following parameters: pH > 5.5, chlorides < 500 ppm, and sulfates <1,500 ppm. Groundwater chemistry values indicative of aggressive groundwater/soil (pH < 5.5, chlorides > 500 ppm, or sulfates > 1,500 ppm) will be assessed for impact on concrete structural elements. This may include evaluations, destructive testing, and/or focused inspections of representative accessible (leading indicator) or below-grade, inaccessible concrete structural elements exposed to aggressive groundwater/soil, on an interval not to exceed 5 years.

Program Element Affected: Element 6 - Acceptance Criteria Operating Experience The following examples of operating experience provide objective evidence that the Structures Monitoring Program will be effective in assuring that intended functions are maintained consistent with the current licensing basis for the subsequent period of extended operation.

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Appendix B - Aging Management Programs Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

1. In 2022, a program effectiveness review was performed for Structures Monitoring Program described in FSAR Section O.1.33 in support of preparing the BFN Subsequent License Renewal Application. The purpose of the program effectiveness review was to verify that the intent of the existing aging management program activities to identify and correct, as warranted, age-related degradation of structures and structural components within the scope of the License Renewal, is being effectively implemented in the initial license renewal period of extended operation. The original activities included visual inspection of structures and structural components, documentation of findings, and follow-up actions in the Corrective Action Program. The Structures Monitoring Program existed prior to License Renewal and

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Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

A-100 Table A.5, Subsequent License Renewal Commitment List (Continued)

No.

Program or Topic Commitment Implementation Schedule Source 16 Fire Water System The existing program is credited and will be enhanced as follows:

 Revise implementing procedures to ensure that flushes are in accordance with NFPA 25, 2011 Edition, section 7.3.2.1, to mitigate or prevent fouling, which can cause flow blockage or loss of material, by clearing corrosion products and sediment.

 Revise implementing procedures to perform periodic flow tests, flushes, internal and external visual inspections, and testing of sprinklers systems.

 Revise implementing procedures to ensure that, when visual inspections are used to detect loss of material, the inspection technique will be capable of detecting surface irregularities that could indicate an unexpected level of degradation due to corrosion and corrosion product deposition. Where such irregularities are detected, follow-up volumetric wall thickness examinations will be performed. Additionally, volumetric wall thickness inspections will be conducted on portions of water-based fire protection system components that are periodically subjected to flow but are normally dry.

 Revise implementing procedures to ensure that visual examinations of cementitious materials will be conducted to detect indications of loss of material and cracking that could affect the system's ability to maintain pressure.

Revise implementing procedures to manage the aging effects ofrecurring internal corrosion (RIC) to:

x Perform periodic fire water system piping flushes, flow testing, and non-intrusive volumetric inspections to identify pipe degradation prior to loss of system intended function.

x Perform trending of flow testing and non-intrusive volumetric inspections to provide sufficient data on fire water system pipe wall conditions prior to loss of intended function. Evaluate Ldentified degradation of piping due to corrosion and replace piping, when necessary, prior to loss of intended function.

x Perform trending during piping flushes to include flow rates, pressure drops, calculated friction losses and signs of debris from corrosion.

x Perform non-intrusive volumetric inspections to track and trend pipe wall thickness in areas where degraded conditions are identified.

x Perform engineering evaluations when degraded conditions are identified to determine the cause. If corrosion is identified, Program enhancements, associated with inspections/

tests required to be implemented prior to the subsequent period of extended operation, will be implemented prior to performance of the required inspections/tests. Remaining program enhancements will be implemented no later than six months prior to the subsequent period of extended operation.

Inspections/tests that are to be completed prior to the subsequent period of extended operation will be completed no later than five years prior to the subsequent period of extended operation.

Section A.2.1.16

Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) engineering evaluation will determine if additional inspections are required, the appropriate frequency of the inspection based on the projected corrosion rate, extent of condition for other areas in the system, and necessary repairs if required.

x Perform opportunistic inspections on piping that is hard to access.

5. Revise implementing procedures to meet guidelines of Revision 0 of NUREG-2191, Table XI.M27-1, Fire Water System Inspection and Testing Recommendations (NFPA 25, 2011 Edition, Guidelines).

6. Revise implementing procedures to ensure visual inspections are capable of evaluating: (i) the condition of the external surfaces of components, (ii) the conditions of the internal surfaces of components that could indicate wall loss or cracking, and (iii) the inner diameter of the piping as it applies to the design flow of the fire protection system (i.e., to verify that corrosion product buildup has not resulted in flow blockage due to fouling). Internal visual inspections used to detect loss of material are capable of detecting surface irregularities that could be indicative of an unexpected level of degradation due to corrosion and corrosion product deposition. Where such irregularities are detected, follow-up volumetric examinations will be performed.

CNL-25-067 ENCLOSURE 2 TRP-014 Buried and Underground Piping and Tanks (13 pages)

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Appendix B - Aging Management Programs Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

B-12

contain asbestos. Either wrap system is effective, therefore the BFN coating system is in accordance with Table 1 of NACE SP0169-2007.

Field applied coating materials at BFN are in compliance with AWWA C203-08. Application of field applied coatings is in compliance with AWWA C203-08. In addition, BFN design documents specify that after field repair of coating, checks for holidays were performed by either the ring or chain type electrode method using not less than 10,000 volts and that any faults detected were repaired. While full compliance with AWWA C203-08 could not be confirmed, the ability of the field applied coating to perform its intended function is demonstrated based in the results of BFN-specific operating experience. BFN reviewed opportunistic and planned buried piping inspections conducted since 2009. Based on this review, BFN has concluded that plant-specific operating experience is acceptable, i.e., there were no leaks in the subject buried piping due to external corrosion and no significant coating degradation was observed. In addition, this review of BFN operating experience did not identify any failures associated with field applied coatings. As a result, it is concluded that BFN field applied coatings are considered to be adequate for providing protection of associated buried piping components during the subsequent period of extended operation. To provide assurance that field applied coatings will continue to perform their intend function during the period of subsequent period of extended operation, enhancements are provided to ensure compliance with Table 1 of NACE SP0169-2007 for new and replacement field applied coating and to ensure direct inspections include fittings (e.g., elbows, tees, etc.) to capture the factory applied to field applied coating interfaces and the associated field applied coatings used at these locations.

Ductile iron and gray cast iron piping used in the Fire Protection System are coated with a coal tar varnish in accordance with the design BOM (Bill of Materials). The coal tar varnish is PLO

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The copper alloy piping associated with the High Pressure Fire Protection System is not coated, but installed under NFPA 24 and will continue to be managed under NFPA 

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In most cases, the best option for installing copper underground is to bury it in direct contact with the soil. Copper is naturally corrosion resistant to most soils and underground environments. Wrapping or sleeving the copper tube in an effort to provide an additional layer of protection, while well intended, can lead to failure due to improper sleeving or wrapping practices. Unless aggressive soil conditions are present or expected, installers should carefully consider whether sleeving or wrapping is necessary or prudent. In cases where it is necessary, installers should consider the following steps to ensure reliable installations and long-system life.

As discussed below, BFN does not have aggressive soil conditions for copper.

Copper corrosion analysis Any concern for copper corrosion on the small quantity of abandoned branch take off lines from the FP system is based on high sulfide concentrations that can cause corrosive conditions to copper piping. Corrosion of copper piping can occur by direct acid attack through biological conversion, in this case sulfate reducing bacteria (SRB) to form sulfide and then to hydrogen sulfide (H2S) gas to sulfuric acid and the direct chemical reaction of metals. In order for this to occur there must be SRB present and more importantly the anaerobic conditions for them to actively convert sulfates to sulfides.

Appendix B - Aging Management Programs Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

Sulfides In 2023 RSCS obtained soil samples [RSCS report TSD 23-078] and performed a rigorous soil analysis including sulfides. The results showed all but one of the samples had sulfides levels below the laboratory reporting limit (RL) for the sample. The one sample (1-8) with sulfide detected above the RL reported 13.6 mg/kg (ppm), slightly above the laboratory RL of 11.4 mg/kg.

Redox Potentials The RSCS report indicates positive redox potential (ORP) significantly above 100mV in all samples which indicates that pipe environments are not conducive for sulfate reduction to sulfide under certain conditions including within the micro-environments of biofilms on metallic structures.

In short, the soil environment is too oxidizing to support active anaerobic bacteria and build-up of sulfides in local soil environments tested. All of the soil ORP readings were above 300mV. (Figure

1)

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Soil pH The RSCS report also states that basic to neutral pH levels may also inhibit the production and buildup of sulfides in soil. However, pH could be significantly lower within a biofilm community in contact with structures. The soil samples ranged from a pH of 6.93 to 8.17 and are considered neutral to basic. Soils in this range will typically inhibit sulfide reducing bacteria growth and will buffer acids produced as a function of sulfide and sulfuric acid production in the soil.

Pipe-to-Soil Potentials

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Appendix B - Aging Management Programs Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) d^ŽWŽŽŽŽŽ

Potential-V Versus Copper-Copper Sulfate Corrosion Activity

-0.5 or more negative Copper is well protected; suggests that copper is cathodically protected

-0.25 or more negative No corrosion in most soils

-0.1 or less negative May be corroding 0.0 or positive Probably corroding

• American Water Works Association Journal, August 1984 reprinted, with permission from American Water Works Association. By J.R. Myers Associates Conclusion Copper is essentially immune to corrosion. It behaves like a noble metal in most underground environments because of the naturally protective film that forms on the metal's surface. If this film, which often consists of reddish-brown cuprous oxide (Cu 20) is destroyed and cannot be repaired, copper will corrode. Fortunately, the protective film on copper remains intact or is readily repaired under most soil conditions. The presence of sulfides could represent an abnormally aggressive condition to copper piping.

BFN soil samples indicate that sulfides are below the Laboratory detection limits with the exception of sample location 1-8 that was just above the detectable limit. Given the greater than 100mV ORP values for all sample locations, and the basic to neutral pH, the formation of sulfuric acid is unlikely and therefore copper pipe corrosion is not likely. In addition, the pipe-to-soil potentials support the conclusion that copper is not corroding. Ongoing monitoring is conducted via periodic NFPA 25 flow tests. BFN does not have any OE of degraded copper HPFP piping in the reviewed time period. +RZHYHUZKLOHSODQW2(LQGLFDWHVOHDNVZRXOGEHVHOIUHYHDOLQJLQRUGHUWRSURYLGH

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BFN Preventative Actions - Backfill and Soil Characteristics and Periodic Inspections Backfill Preventive actions included in NUREG-2191 AMP XI.M41 consider that backfill located within 6 inches of the component that meets ASTM D 448-08 size number 67 meets the objectives of NACE SP0169-2007 and NACE RP0285-2002. ASTM D 448-08 indicates that size number 67 corresponds to a bounding value for backfill particles within 6 inches of the component to be no larger than 3/4 inch (nominal size). BFN specifications and design output require sand, clay, and/or rock-free earth backfill be used for buried piping included in the scope of the Buried and Underground Piping and Tanks AMP. However, while the definitions of sand and clay meet this size criteria, TVA General Engineering Specification G-9 allows for earthfill particles to be up to 3 inches. This is an exception to the guidance of NUREG-2191 AMP XI.M41 Section 2.f for meeting the objectives of NACE SP0169-2007. BFN operating experience demonstrates that surveys/tests (i.e., UPTI Inspection Checklist/NPG-SPP 09.15) are capable of detecting and identifying degraded conditions that would pertain to backfill. If found, degraded conditions are entered into the Corrective Action Program and then addressed. If the backfill does not meet acceptance criteria, the degraded condition is evaluated or repaired. BFN has shown no sign of damage done to buried piping due to backfill characteristics. Enhancements are provided to require that new and replacement backfill meet the guidance of NACE SP0169-2007 Section 5.2.3. In addition, backfill quality will be

Appendix B - Aging Management Programs Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) demonstrated in the subsequent period of extended operation by examining the backfill while conducting the inspections described in the associated enhancement and by review of plant

TRP014SLRAAppendix

W

Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

A-39

Revise implementing procedures to require that indications of cracking in metallic pipe be managed in accordance with the Corrective Action Program and require that indications of cracking in underground or buried in-scope piping be evaluated in accordance with applicable codes and plant-specific design criteria.

Revise implementing procedures to state that backfill is acceptable if the inspections do not reveal evidence that the backfill caused damage to the component's coatings or the surface of the component (if not coated).

Revise implementing procedures to state that cracks in cementitious backfill that could admit groundwater to the surface of the component are not acceptable.

Revise implementing procedures to require that where damage to the coating has been evaluated as significant and the damage was caused by nonconforming backfill, an extent of condition evaluation will be conducted to determine the extent of degraded backfill in the vicinity of the observed damage.

Revise implementing procedures to require that coated or uncoated metallic piping that is found to show evidence of corrosion will have the remaining wall thickness in the affected area determined to ensure that the minimum wall thickness is maintained. This may include different values for large area minimum wall thickness and local area wall thickness. If the wall thickness extrapolated to the end of the subsequent period of extended operation meets minimum wall thickness requirements, recommendations for expansion of sample size will not apply.

Revise implementing procedures to explicitly require that where the coatings, backfill, or the condition of exposed piping does not meet acceptance criteria, the degraded condition will be repaired, or the affected component will be replaced. In addition, where the depth or extent of degradation of the base metal could have resulted in a loss of pressure boundary function when the loss of material is extrapolated to the end of the subsequent period of extended operation:

An expansion of sample size will be conducted.

The number of inspections within the affected piping categories will be doubled or increased by five, whichever is smaller.

If the acceptance criteria are not met in any of the expanded samples, an analysis will be conducted to determine the extent of condition and extent of cause.

The number of follow-on inspections will be determined based on the extent of condition and extent of cause.

The expansion of sample inspections may be halted in a piping system or portion of system that will be replaced within the 10-year interval in which the inspections were conducted or, if identified in the latter half of the current 10-year interval, within 4 years after the end of the 10-year interval.

Require that the section of underground carbon steel piping (in an isolation valve pit) in the Hardened Containment Venting System which is not coated consistent with GALL-SLR Element 2 for underground steel piping, will be coated in accordance with Table 1 ofNACE SP0169-2007 prior to the subsequent period of extended operation.

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Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

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These enhancements will be implemented prior to beginning inspections within 10 years before the subsequent period of extended operation. Inspections, tests, and installation of coatings that are to be completed prior to the subsequent period of extended operation will be completed no later than 6 months prior to the subsequent period of extended operation or no later than the last refueling outage prior to the subsequent period of extended operation.

Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

A-116 27 Buried and Underground Piping and Tanks (continued)

• If the acceptance criteria are not met in any of the expanded samples, an analysis will be conducted to determine the extent of condition and extent of cause.

• The number of follow-on inspections will be determined based on the extent of condition and extent of cause.

• The expansion of sample inspections may be halted in a piping system or portion of system that will be replaced within the 10-year interval in which the inspections were conducted or, if identified in the latter half of the current 10-year interval, within 4 years after the end of the 10-year interval.

41. Require that the section of underground carbon steel piping (in an isolation valve pit) in the Hardened Containment Venting System which is not coated consistent with GALL-SLR Element 2 for underground steel piping, will be coated in accordance with Table 1 of NACE SP0169-2007 prior to the subsequent period of extended operation.

Table A.5, Subsequent License Renewal Commitment List (Continued)

No.

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Appendix A - Final Safety Analysis Report Supplement Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) 28 Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks aging management program is a new condition monitoring program that manages degradation of internal coatings/linings exposed to raw water, treated water, air, and condensation where loss of coating or lining integrity could prevent satisfactory accomplishment of any of the component's, or downstream component's, current licensing basis intended functions.

Program will be implemented prior to beginning inspections within 10 years before to the subsequent period of extended operation. Baseline inspections that are to be completed within 10 years prior to the subsequent period of extended operation will be completed no later than six months prior to the subsequent period of extended operation, or no later than the last refueling outage prior to the subsequent period of extended operation.

Section A.2.1.28 Table A.5, Subsequent License Renewal Commitment List (Continued)

No.

Program or Topic Commitment Implementation Schedule Source

Appendix B - Aging Management Programs Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

B-14

37.Revise implementing procedures to state that cracks in cementitious backfill that could admit groundwater to the surface of the component are not acceptable.

Program Element Affected: Element 6 - Acceptance Criteria 38.Revise implementing procedures to require that where damage to the coating has been evaluated as significant and the damage was caused by nonconforming backfill, an extent of condition evaluation will be conducted to determine the extent of degraded backfill in the vicinity of the observed damage.

Program Element Affected: Element 7 - Corrective Actions 39.Revise implementing procedures to require that coated or uncoated metallic piping that is found to show evidence of corrosion will have the remaining wall thickness in the affected area determined to ensure that the minimum wall thickness is maintained. This may include different values for large area minimum wall thickness and local area wall thickness. If the wall thickness extrapolated to the end of the subsequent period of extended operation meets minimum wall thickness requirements, recommendations for expansion of sample size will not apply.

Program Element Affected: Element 7 - Corrective Actions 40.Revise implementing procedures to explicitly require that where the coatings, backfill, or the condition of exposed piping does not meet acceptance criteria, the degraded condition will be repaired, or the affected component will be replaced. In addition, where the depth or extent of degradation of the base metal could have resulted in a loss of pressure boundary function when the loss of material is extrapolated to the end of the subsequent period of extended operation:

An expansion of sample size will be conducted.

The number of inspections within the affected piping categories will be doubled or increased by five, whichever is smaller.

If the acceptance criteria are not met in any of the expanded samples, an analysis will be conducted to determine the extent of condition and extent of cause.

The number of follow-on inspections will be determined based on the extent of condition and extent of cause.

The expansion of sample inspections may be halted in a piping system or portion of system that will be replaced within the 10-year interval in which the inspections were conducted or, if identified in the latter half of the current 10-year interval, within 4 years after the end of the 10-year interval.

Program Element Affected: Element 7 - Corrective Actions

Require that the section of underground carbon steel piping (in an isolation valve pit) in the Hardened Containment Venting System which is not coated consistent with GALL SLR Element 2 for underground steel piping, will be coated in accordance with Table 1 of NACE SP0169-2007 prior to the subsequent period of extended operation.

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Appendix B - Aging Management Programs Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

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3URJUDP(OHPHQW$IIHFWHG(OHPHQW3UHYHQWDWLYH$FWLRQV Operating Experience The following examples of operating experience provide objective evidence that the Buried Piping and Tanks Inspection Program will be effective in assuring that intended functions are maintained consistent with the current licensing basis for the subsequent period of extended operation