ML25212A205
| ML25212A205 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/04/2025 |
| From: | Hammock J NRC/NRR/DNRL/NLRP |
| To: | Lauren Gibson NRC/NRR/DNRL/NLRP |
| References | |
| Download: ML25212A205 (13) | |
Text
August 4, 2025 MEMORANDUM TO:
Lauren K. Gibson, Chief Licensing Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation FROM:
Jessica Hammock, Project Manager /RA/
Licensing Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation
SUBJECT:
BROWNS FERRY SLRA - DRAFT REQUESTS FOR ADDITIONAL INFORMATION NOT ISSUED TO TENNESSEE VALLEY AUTHORITY By Subsequent License Renewal Application Appendix E, Applicant’S Environmental Report-Operating License Renewal Stage|letter dated January 19, 2024]] (Agencywide Documents Access and Management System (ADAMS) Package Accession No.ML24019A009), as supplemented by letters dated January 22, 2024 (ML24022A292), October 9, 2024 (ML24283A091), November 1, 2024 (ML24306A203), December 17, 2024 (ML24352A216), January 8, 2025 (ML25008A150),
February 12, 2025 (ML25043A270 & ML25043A035), March 4, 2025 (ML25063A184),
March 26, 2025 (ML25085A283), March 28, 2025 (ML25087A216), April 14, 2025 (ML25104A172), April 16, 2025 (ML25106A149), April 24, 2025 (ML25114A206), and May 1, 2025 (ML25121A174), Tennessee Valley Authority (TVA, the applicant) submitted an application for subsequent license renewal (SLR) of Renewed Facility Operating License Nos.DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, respectively, to the U.S. Nuclear Regulatory Commission (NRC). TVA submitted the application pursuant to Title 10 of the Code of Federal Regulations Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for SLR.
During the staffs review of the application, the NRC staff identified the need for additional information and issued a draft request for additional information (RAI) to the applicant. Following further clarification, the draft RAIs were not issued as final RAIs to the applicant.
Draft RAI Justification for Not Issuing as Final RAI RAI B.3.1.1-1 Applicant volunteered to provide a supplement RAI B.3.1.1-2 Applicant volunteered to provide a supplement RAI 4.3.4-1 Applicant volunteered to provide a supplement RAI 4.3.4-2 Applicant volunteered to provide a supplement RAI 4.3.5-1 Applicant volunteered to provide a supplement
L. Gibson 2
Draft RAI Justification for Not Issuing as Final RAI RAI 4.3.7-1 Applicant volunteered to provide a supplement RAI 4.3.9-1 Applicant volunteered to provide a supplement RAI 4.3.10-1 Applicant volunteered to provide a supplement RAI B.2.1.27-2a Applicant volunteered to provide a supplement RAI B.2.1.28-1 Applicant volunteered to provide a supplement The draft RAIs can be found below:
RAI B.3.1.1-1 Regulatory Basis:
Pursuant to 10 CFR 54.21(a)(3), the subsequent license renewal application (SLRA) must demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the subsequent period of extended operation.
Background:
SLRA Section B.3.1.1 addresses Enhancement 4 regarding the parameters monitored or inspected program element of the Fatigue Monitoring program. Specifically, Enhancement 4 indicates that analysis has been completed to reevaluate the cumulative fatigue limit for the recirculation inlet nozzle safe ends, and the limits will be revised in FatigueProTM (a fatigue monitoring software) prior to entry into the subsequent period of extended operation. Similarly, Enhancement 7 regarding the acceptance criteria program element of the aging management program (AMP) is to revise implementing procedures to reflect the reevaluated cumulative fatigue values for the Units 1, 2, and 3 recirculation inlet nozzle safe end.
Issue:
SLRA Section B.3.1.1 does not clearly address the following items related to Enhancement 4:
(a) the meaning of the reevaluated cumulative usage limit for the recirculation inlet nozzle safe ends in the fatigue reevaluation; and (b) the meaning of the limits that will be revised in the fatigue monitoring software. In addition, it is not clear to the staff which aspect of the acceptance criteria program element will be enhanced in Enhancement 7.
The staff also needs clarification on whether Enhancements 4 and 7 need to include the recirculation inlet nozzles in addition to the recirculation inlet nozzle safe ends given that the recirculation inlet nozzle blend radius location is bounding for the recirculation inlet nozzle safe end location in terms of environmentally adjusted cumulative usage factor (CUFen) as shown in SLRA Table 4.3.1-4.
L. Gibson 3
Request:
- 1.
Clarify the following in relation to Enhancement 4 of the Fatigue Monitoring program:
(a) the meaning of the reevaluated cumulative usage limit for the recirculation inlet nozzle safe ends in the fatigue reevaluation; and (b) the meaning of the limits that will be revised in the fatigue monitoring software. In addition, clarify which aspect of the acceptance criteria program element will be enhanced in Enhancement 7.
- 2.
Clarify whether Enhancements 4 and 7 of the AMP need to include the recirculation inlet nozzles in addition to the recirculation inlet nozzle safe ends given that the recirculation inlet nozzle blend radius location is bounding for the recirculation inlet nozzle safe end location in terms of CUFen as shown in SLRA Table 4.3.1-4. If not, provide justification for why the addition of the recirculation inlet nozzles in these enhancements is not needed. If so, revise the enhancements and related Final Safety Analysis Report (FSAR) supplement accordingly.
RAI B.3.1.1-2 Regulatory Basis:
Pursuant to 10 CFR 54.21(a)(3), the SLRA must demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the subsequent period of extended operation.
Background:
SLRA Section B.3.1.1 addresses Enhancement 5 regarding the parameters monitored or inspected program element of the Fatigue Monitoring program. Enhancement 5 indicates that FatigueProTM Version 4 will be implemented prior to entry into the subsequent period of extended operation.
Issue:
SLRA Section B.3.1.1 does not clearly address the following items related to the use of the fatigue monitoring software and implementation of Enhancement 5: (a) currently used version of the FatigueProTM software; (b) differences between the currently used version of FatigueProTM and Revision 4; (c) whether the applicant has a plan to perform stress-based fatigue monitoring by using the fatigue monitoring software; and (d) how the applicant evaluated and addressed the potential concern discussed in NRC Regulatory Issue Summary 2008-30, Fatigue Analysis of Nuclear Power Plant Components (i.e., the use of only one value of stress in the fatigue analysis rather than considering the six components of the stress).
Request:
Clarify the following items related to the use of the fatigue monitoring software and implementation of Enhancement 5: (a) currently used version of the FatigueProTM software; (b) major differences between the currently used version of FatigueProTM software and Revision 4; (c) whether the applicant has a plan to perform stress-based fatigue monitoring by using the fatigue monitoring software; and (d) how the applicant evaluated and addressed the potential
L. Gibson 4
concern discussed in NRC Regulatory Issue Summary 2008-30, Fatigue Analysis of Nuclear Power Plant Components.
RAI 4.3.4-1 Regulatory Basis:
Pursuant to 10 CFR 54.21(c), the SLRA must include an evaluation of time-limited aging analyses (TLAAs). The applicant must demonstrate that: (i) the analyses remain valid for the subsequent period of extended operation; (ii) the analyses have been projected to the end of the subsequent period of extended operation; or (iii) the effects of aging on the intended function(s) will be adequately managed for the subsequent period of extended operation.
Background:
SLRA Section 4.3.4 addresses the fatigue TLAAs for the non-Class 1 piping systems (i.e., ASME Section III Class 2 and 3 and ANSI B31.1 piping systems). The TLAA is also related to the allowable stress analyses for the piping systems. The TLAAs regarding allowable stress analyses relies on the implicit fatigue analysis provisions in the ANSI B31.1 code. These provisions allow no reduction in the allowable stress range for thermal expansion stresses if the number of equivalent full temperature cycles does not exceed 7,000 cycles. In addition, SLRA Tables 4.3.4-3 and 4.3.4-4 describe the 80-year projected cycles for the non-Class 1 piping systems other than the high temperature process sample system lines and the 80-year projected cycles for the high temperature process sample system lines, respectively.
Issue:
SLRA Section 4.3.3 does not clearly describe how the 80-year projected cycles were determined (e.g., based on piping system design information, plant operation procedures, test requirements, FSAR information and specific system-level knowledge).
Request:
Describe how the 80-year projected cycles were determined (e.g., based on piping system design information, plant operation procedures, test requirements, FSAR information and specific system-level knowledge). As part of the discussion, clarify whether transient cycles per unit time period (e.g., annual cycles) are used in the 80-year cycle projections.
RAI 4.3.4-2 Regulatory Basis:
Pursuant to 10 CFR 54.21(c), the SLRA must include an evaluation of time-limited aging analyses (TLAAs). The applicant must demonstrate that: (i) the analyses remain valid for the subsequent period of extended operation; (ii) the analyses have been projected to the end of the subsequent period of extended operation; or (iii) the effects of aging on the intended function(s) will be adequately managed for the subsequent period of extended operation.
L. Gibson 5
Background:
SLRA Section 4.3.4 indicates that the non-Class 1 piping portions of the following piping systems are only affected by the same pressure and temperature transients as the reactor coolant system (RCS) transients that are listed in SLRA Table 4.3.4-2: (a) control rod drive, (b) core spray, (c) feedwater, (d) main steam, (e) containment atmosphere dilution, (f) residual heat removal (RHR) including residual heat removal service water (RHRSW) since the RHRSW transients are bounded by the RHR transients, and (g) standby liquid control piping systems.
Issue:
SLRA Section 4.3.4 does not clearly discuss why the non-Class 1 piping portions of the piping systems discussed in the background section are not subject to piping-specific transients other than the RCS transients listed in SLRA Table 4.3.4-2.
Request:
Clarify why the non-Class 1 piping portions of the following piping systems are not subject to piping-specific transients other than the RCS transients listed in SLRA Table 4.3.4-2: (a) control rod drive, (b) core spray, (c) feedwater, (d) main steam, (e) containment atmosphere dilution, (f) RHR (including RHRSW), and (g) standby liquid control piping systems.
RAI 4.3.5-1 Regulatory Basis:
Pursuant to 10 CFR 54.21(c), the SLRA must include an evaluation of time-limited aging analyses (TLAAs). The applicant must demonstrate that: (i) the analyses remain valid for the subsequent period of extended operation; (ii) the analyses have been projected to the end of the subsequent period of extended operation; or (iii) the effects of aging on the intended function(s) will be adequately managed for the subsequent period of extended operation.
Background:
SLRA Section 4.3.5 addresses the environmentally-assisted fatigue (EAF) TLAA. SLRA Section 4.3.5 explains that, during the EAF screening evaluation, a maximum Fen (environmental fatigue correction factor) was calculated based on material type, maximum temperature, and chemistry and a screening 80-year CUFen (environmentally adjusted CUF) value was calculated.
Issue:
The SLRA does not clearly discuss how the maximum Fen value was calculated in the EAF screening evaluation (e.g., how the bounding strain rate and sulfur content were determined). In addition, SLRA Section 4.3.5 indicates that the threshold screening CUFen is 1.0 for the conservative screening CUFen. Therefore, the staff needs clarification on how the screening CUFen values were further refined to determine the 80-year CUFen values after the screening evaluation.
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Request:
- 1.
Describe how the applicant calculated the maximum Fen value in the EAF screening (e.g., how the bounding strain rate and sulfur content were determined).
- 2.
Describe how the screening CUFen values were further refined to determine the 80-year CUFen values after the screening evaluation.
RAI 4.3.7-1 Regulatory Basis:
Pursuant to 10 CFR 54.21(c), the SLRA must include an evaluation of time-limited aging analyses (TLAAs). The applicant must demonstrate that: (i) the analyses remain valid for the subsequent period of extended operation; (ii) the analyses have been projected to the end of the subsequent period of extended operation; or (iii) the effects of aging on the intended function(s) will be adequately managed for the subsequent period of extended operation.
Background:
SLRA Section 4.3.7 addresses the fatigue crack growth analyses for emergency equipment cooling water system (EECW) weld flaws. SLRA Section 4.3.7 indicates that the inspections performed in 1987 found 27 flaws that needed fatigue crack growth analyses. The SLRA indicates that the crack growth analyses determined a cycle limit of 125 for these welds. The SLRA also explained that 17 flaws of the 27 flaws were reevaluated and that the number of cycles to exceed the allowable crack depth was increased from 125 to 2,600 cycles.
Issue:
SLRA Section 4.3.7 does not clearly address the following items: (a) ASME Code Class of the EECW piping; (b) which weld flaws were reevaluated to have an increased acceptable cycle of 2600; (c) whether the reevaluation of the 17 flaws is also applied to the other 10 flaws (i.e., whether the increased acceptable cycle number of 2,600 is applied to all the 27 flaws);
(d) what transients are evaluated in the crack growth analyses (i.e., what specific transients are associated with the 125 and 2,600 cycles evaluated in the crack growth analyses); and (e) whether the effects of the water environment on the fatigue crack growth rates are considered in the fatigue crack growth analyses.
Request:
- 1.
Clarify the following items: (a) ASME Code Class of the EECW piping; (b) which weld flaws were reevaluated to have an increased acceptable cycle of 2,600; (c) whether the reevaluation of the 17 flaws is also applied to the other 10 flaws (i.e., whether the increased acceptable cycle number of 2,600 is applied to all the 27 flaws); and (d) what transients are evaluated in the crack growth analyses.
- 2.
Clarify the specific code provision or standard for the crack growth rate model used in the crack growth analyses. In addition, clarify whether the fatigue crack growth model considers the effects of the water environment on fatigue crack growth. If not, provide justification for why the effects of the water environment do not need to be considered.
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RAI 4.3.9-1 Regulatory Basis:
Pursuant to 10 CFR 54.21(c), the SLRA must include an evaluation of time-limited aging analyses (TLAAs). The applicant must demonstrate that: (i) the analyses remain valid for the subsequent period of extended operation; (ii) the analyses have been projected to the end of the subsequent period of extended operation; or (iii) the effects of aging on the intended function(s) will be adequately managed for the subsequent period of extended operation.
Background:
SLRA Section 4.3.9 addresses the fatigue analysis for the repaired T-box of BFN Unit 3 core spray piping. The SLRA indicates that the BFN Unit 3 has installed a repair on the core spray T-box and adjacent piping using brackets. In addition, SLRA Section 4.3.9 explains that the fatigue analysis considers two configurations of the T-box assembly: (a) configuration where the piping remains attached to the T-box and (b) configuration where the piping has become detached from the T-box. For the hypothetically detached configuration, SLRA Section 4.3.9 indicates that the initially calculated CUF was greater than 1.0 and was subsequently reduced to 0.9 based on an assumption of reduced cycles associated with the remaining life of the plant.
SLRA Section 4.3.9 further explains that inspections are performed on the repaired T-box to ensure that the core spray piping has not been detached.
Issue:
The SLRA does not clearly discuss the following items: (a) specific operating time associated with the CUF value of 0.9 for the detached configuration (i.e., configuration where the piping has become detached from the T-box); (b) specific limiting location associated with the evaluated CUF value; and (c) aging mechanisms that can cause the detachment of the piping from the T-box (e.g., intergranular stress corrosion cracking) and inspections that monitor the cracking growth in the core spray ping. In addition, SLRA Section 4.3.9 does not clearly discuss the method and frequency of the inspections that are performed to: (a) ensure that the core spray piping has not been detached from the T-box; and (b) monitor the crack growth in the piping adjacent to the T-box, respectively.
Request:
- 1.
Clarify the following items: (a) specific operating time associated with the CUF value of 0.9 for the detached configuration of the T-box assembly; (b) specific limiting location associated with the evaluated CUF value (i.e., 0.9); and (c) aging mechanisms that can cause the detachment of the piping from the T-box (e.g., intergranular stress corrosion cracking).
- 2.
Describe the method and frequency of the inspections that are performed to:
(a) ensure that the core spray piping has not been detached; and (b) monitor the crack growth in the piping adjacent to the T-box, respectively.
L. Gibson 8
RAI 4.3.10-1 Regulatory Basis:
Pursuant to 10 CFR 54.21(c), the SLRA must include an evaluation of time-limited aging analyses (TLAAs). The applicant must demonstrate that: (i) the analyses remain valid for the subsequent period of extended operation; (ii) the analyses have been projected to the end of the subsequent period of extended operation; or (iii) the effects of aging on the intended function(s) will be adequately managed for the subsequent period of extended operation.
Background:
SLRA Section 4.3.10 addresses the fatigue analysis for the BFN Unit 3 core spray lower line replaced section. SLRA Section 4.3.10 indicates that inspections are performed to manage the aging effect of fatigue for the replaced section.
Issue:
SLRA Section 4.3.10 does not clearly discuss the method, frequency and locations of the inspections for the core spray lower line replaced section.
Request:
- 1.
Describe the method, frequency and locations of the inspections for the BFN Unit 3 core spray lower line replaced section that will be performed to manage the aging effect of fatigue. As part of the response, clarify the limiting fatigue location (i.e., the maximum cumulative usage factor location) of the replaced section in comparison with the inspection locations.
- 2.
Discuss the technical basis for why the inspection approach is sufficient to manage the effect of fatigue for the replaced section.
RAI B.2.1.27-2a Regulatory Basis:
10 CFR 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the subsequent period of extended operation (SPEO). One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the SPEO on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.
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Background:
The applicants response to RAI B.2.1.27-2 (ML25087A216) related to buried copper alloy piping states the following (in part):
[t]he low pH reading of 5.3, shown below in Figure 2 is from a sample taken in 2009 at approximately 3 feet of depth and does not reflect the in-situ full soil characteristics at the pipe depth.
[t]his recommendation [referring to a recommendation from ASM Handbook, Volume 13C - Corrosion: Environments and Industries ] for tape-wrap coating only applies the mitigating actions of tape wrap and cathodic protection when all three conditions are met, that is, high chloride concentrations, high sulfate concentrations, and low pH occur in a discreet sample. As shown in Figure 2, Sample Location ID, BROWNS FERRY 7, the in-situ soil has a pH of 5.3, a chlorine (Cl) concentration of 43 ppm [parts per million],
and a sulfate (SO4) concentration of 0 ppm. Thus, the soil does not meet all three characteristics as per the recommendation in the ASM Handbook referenced above.
[c]onsistent with the guidance provided in the GALL, this piping is installed in accordance with NFPA 24 [Standard for the Installation of Private Fire Service Mains and Their Appurtenances] and is monitored in accordance with NFPA 25 [Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems]...According to NUREG-2191, Vol 2, Rev 1, Chapter XI-XI.M41 Mechanical, "... for fire mains installed in accordance with National Fire Protection Association (NFPA) 24, preventive actions beyond those in NFPA 24 need not be provided if (1) the system undergoes either a periodic flow test in accordance with NFPA 25... As described in SLRA B.2.1.27, TVA will monitor the high pressure fire protection system, and the raw service water copper piping fed from the high pressure fire protection system headers, by performing periodic flow tests in accordance with NFPA 25 to identify fire main leakage.
Table 9-4, Soil Corrosivity Index from BPWORKS, of Electric Power Research Institute (EPRI)
Report 3002005294, Soil Sampling and Testing Methods to Evaluate the Corrosivity of the Environment for Buried Piping and Tanks at Nuclear Power Plants, adds at least three soil corrosivity points for copper alloys when pH is 5.5 or less.
GALL-SLR Report Table XI.M41-1, Preventive Actions for Buried and Underground Piping and Tanks, recommends that cathodic protection and external coatings are provided for buried copper alloy piping. In addition, GALL-SLR Report Table XI.M41-2, Inspection of Buried and Underground Piping and Tanks, recommends that periodic direct inspections are performed for buried copper alloy piping.
GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks, states
[a]dditional inspections, beyond those in Table XI.M41-2 may be appropriate if exceptions are taken to program element 2, preventive actions.
Issue:
In general, aging management guidance for buried copper alloy piping provided in GALL-SLR Report AMP XI.M41 relies on the combined approach of preventive actions and direct inspections to provide reasonable assurance that the effects of aging will be adequately managed during the SPEO. In contrast, the aging management strategy at BFN for buried
L. Gibson 10 copper alloy piping does not utilize preventive actions or direct inspections, and the piping is potentially exposed to an aggressive environment. Additional discussion on preventive actions, direct inspections, and the aggressiveness of the environment is provided in the discussion below.
Based on discussions with the applicant during the audit, it is the staffs understanding that the depth of buried copper alloy piping is approximately seven feet. Given that the difference in depth between the 5.3 pH reading and buried copper alloy piping is only four feet, it is unclear to the staff why this reading should not be considered as representative of the conditions at pipe depth. In addition, the staff notes that there is a second pH reading of 5.5 in Figure 2 of the response to RAI B.2.1.27-2, which would result in multiple soil corrosivity points per Table 9-4 of EPRI Report 3002005294. The staff brings up this discussion on low pH to demonstrate that the soil environment is potentially corrosive to copper alloys.
The staff does not agree that all three characteristics from ASM Handbook, Volume 13C - Corrosion: Environments and Industries (i.e., high chloride concentrations, high sulfate concentrations, and low pH) need to be met to consider the use of preventive actions. While the staff agrees that the most corrosive conditions would occur when all three characteristics are present at a discreet location, one characteristic (i.e., high chloride, high sulfate, or low pH) could result in potentially corrosive conditions as well.
This is demonstrated in Table 9-4 of EPRI Report 3002005294 where a single parameter, such as low pH, would result in at least a mildly corrosive environment for copper alloys.
As was mentioned in the response to RAI B.2.1.27-2, GALL-SLR Report AMP XI.M41 states preventive actions beyond those in NFPA 24 need not be provided if the system undergoes a periodic flow test in accordance with NFPA 25. It is the staffs understanding that BFN is interpreting this as meaning that no preventive actions are needed for buried copper alloy piping since it is not explicitly required per NFPA 24.
The staff agrees that cathodic protection would not be required since it is not referenced in NFPA 24; however, NFPA 24 provides general recommendations for buried external coatings in Section 10.8.3.5, Corrosion Resistance, and aboveground external coatings in Section 12.2.4. Allowing for no preventive actions in potentially corrosive environments was not the intent of this GALL-SLR Report AMP XI.M41 recommendation.
As was mentioned in the response to RAI B.2.1.27-2, GALL-SLR Report AMP XI.M41 allows for performing periodic flow tests in accordance with NFPA 25 as an alternative to direct inspections. However, as noted in the background section above, the staff has discretion with respect to the applicants proposed inspections based on any exceptions being taken to the preventive actions program element. Although not classified as an exception by the applicant, the staff considers the lack of external coatings for buried copper alloy piping as a staff-identified difference between the applicants program and GALL-SLR Report AMP XI.M41. Based on this staff-identified difference, it is unclear to the staff why direct inspections should not be performed in addition to periodic flow tests.
L. Gibson 11 Request:
Provide additional information to justify why external coatings and direct inspections are not necessary for buried copper alloy piping (e.g., results of any direct inspections that have been performed).
References:
ASM Handbook, Volume 13C - Corrosion: Environments and Industries. ASM International. 2006.
EPRI Report 3002005294, Soil Sampling and Testing Methods to Evaluate the Corrosivity of the Environment for Buried Piping and Tanks at Nuclear Power Plants.
Palo Alto, California: Electric Power Research Institute. November 6, 2015.
NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances. Quincy, Massachusetts: National Fire Protection Association. 2010.
NFPA 25, Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. Quincy, Massachusetts: National Fire Protection Association. 2011.
RAI B.2.1.28-1 Regulatory Basis:
10 CFR 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.
Background:
GALL-SLR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, provides guidance for monitoring the condition of internal coatings/linings of in-scope components where loss of coating or lining integrity could prevent satisfactory accomplishment of the components or downstream components current licensing basis intended functions.
GALL-SLR Report AMP XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks, provides guidance for managing the aging effects of loss of material and cracking on the outside and inside surfaces of metallic aboveground tanks constructed on concrete and soil. This program may also be used to manage the aging effects for coatings/linings that are applied to
L. Gibson 12 the internal surfaces of components included in the scope of this program as long as the following are met:
The recommendations of GALL-SLR Report AMP XI.M42 are incorporated into this AMP.
Exceptions or enhancements associated with the recommendations in GALL-SLR Report AMP XI.M42 are included in this AMP.
The FSAR supplement for GALL-SLR Report AMP XI.M42, as shown in Table XI-01, FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs, is included in the application with a reference to this AMP.
Issue:
Table 3.4.1, Summary of Aging Management Evaluations for the Steam and Power Conversion Systems, of the Browns Ferry SLRA specifies that for AMR item 3.4-1, 066, the applicants Outdoor and Large Atmospheric Metallic Storage Tanks program (stated to be consistent with GALL-SLR AMP XI.M29 with one exception) has been substituted for the applicants Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program (stated to be consistent with GALL-SLR AMP XI.M42) to manage loss of coating integrity of carbon steel tanks with internal coating exposed to treated water in the condensate/demineralizer water system. NRC staff note the following issues with the applicants proposed AMP substitution:
a)
Table 3.4.2-2, Condensate/Demineralized Water System - Summary of Aging Management Evaluation, of the Browns Ferry SLRA does not list any internally coated carbon steel tanks for which the loss of coating integrity is to be managed by any SLRA AMP.
b)
Contrary to the scope of GALL-SLR Report AMP XI.M29, the SLRAs Outdoor and Large Atmospheric Metallic Storage Tanks program does not contain the recommendations of GALL-SLR Report AMP XI.M42 (including exceptions and enhancements if applicable).
c)
Contrary to the scope of GALL-SLR Report AMP XI.M29, the FSAR supplement for the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program does not include a reference to the Outdoor and Large Atmospheric Metallic Storage Tanks program.
Request:
a)
Identify any internally coated carbon steel tanks for which loss of coating integrity is to be managed by an SLRA AMP.
b)
For any internally coated carbon steel tanks identified in response (a) above, specify which SLRA AMP will be used to manage for loss of coating integrity.
c)
For any internally coated carbon steel tanks using the SLRA AMP for Outdoor and Large Atmospheric Metallic Storage Tanks to manage for loss of coating integrity,
L. Gibson 13 explain how the recommendations of GALL-SLR Report AMP XI.M42 (including exceptions and enhancements if applicable) are incorporated into the SLRA AMP.
d)
If internally coated carbon steel tanks are being managed for loss of coating integrity using the Outdoor and Large Atmospheric Metallic Storage Tanks program, amend the FSAR supplement for the Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program to reference the Outdoor and Large Atmospheric Metallic Storage Tanks program.