ML25352A033
| ML25352A033 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry |
| Issue date: | 12/18/2025 |
| From: | Komm D Tennessee Valley Authority |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML25352A033 (0) | |
Text
Post Office Box 2000, Decatur, Alabama 35609-2000 December 18, 2025 10 CFR 50.4 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:
Boiling Water Reactor Vessel Internals Project (BWRVIP) - Notification of Deviation from BWRVIP-190, Revision 2, BWR Water Chemistry Guidelines
- Mandatory, Needed, and Good Practice Guidance
Reference:
Letter from Boiling Water Reactor Vessel and Internals Project (BWRVIP) to the Nuclear Regulatory Commission dated October 30, 1997, BWRVIP Utility Commitments to the BWRVIP The Tennessee Valley Authority (TVA) is providing notification that the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, will not fully implement the subject guidance of BWRVIP-190, Revision 2, BWR Water Chemistry Guidelines - Mandatory, Needed, and Good Practice Guidance. In accordance with a prior agreement with the NRC and BWR utilities that are part of the Boiling Water Reactor Vessel and Internals Project (BWRVIP), participating licensees are required to provide timely notification to the NRC of a decision, by the licensee, to not fully implement the applicable BWRVIP product.
A deviation disposition (DD) has been prepared, reviewed, and approved in accordance with BWRVIP-94NP, Revision 4, BWR Vessel and Internals Project Program Implementation Guide, and TVA internal procedures. This DD provides assurance that there are no safety implications or reliability concerns with the deviation.
The BFN, Units 1, 2, and 3 deviation concerns one item. BFN, Units 1, 2, and 3, are not meeting the requirement for a continuous measurement frequency for condensate and feedwater dissolved oxygen (DO) in accordance with BWRVIP-190 Revision 2, The sample may be obtained from either the condensate pump discharge or condensate polisher outlet. This measurement is considered a Control Parameter with a monitoring frequency of "Needed" during Power Operation: greater than 10 percent power. "Needed" elements in accordance with BWRVIP-190 is defined as "to be implemented whenever possible but alternative approaches are acceptable." Dissolved oxygen is one of the primary factors that affect the rate of flow accelerated corrosion (FAC) in condensate and feedwater piping of a boiling water
U.S. Nuclear Regulatory Commission Page 2 December 18, 2025 reactor. The lower limit of 40 ppb DO is maintained to provide a protective oxide film on the carbon steel piping which is highly susceptible to FAC. BFN maintains this concentration through injection of oxygen into the suction of the condensate pumps.
BFN does not have on-line DO analyzers installed at either the condensate pump discharge or condensate demineralizer effluent (condensate polisher outlet). Instead, BFN utilizes a portable DO analyzer (Hach - Orbisphere 510) to monitor DO from the condensate demineralizer effluent on a twice daily basis. Additionally, BFN has an online DO analyzer which monitors reactor feedwater.
This deviation is considered permanent and will remain in effect throughout the life of the plant.
This notification is being transmitted for information only. TVA is not requesting any specific action from the NRC.
There are no new regulatory commitments contained in this letter. Should you have any questions concerning this submittal, please contact David J. Renn, Site Regulatory Compliance Manager, at (256) 729-2636.
Respectfully, Daniel Komm BFN Site Vice President cc:
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant