ML14260A364

Browns Ferry Nuclear Plant (Bfn), Units 1, 2, and 3 - Response to Generic Letter (GL) 89-13 - Correction to BFN Response to GL 89-13 Actions Ii and Iii

ML14260A364
Person / Time
Site:
Issue date:	09/15/2014
From:	Polson K J Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-89-013
Download: ML14260A364 (3)

Text

Tennessee Valley Authority, Post Office Box 2000, Decatur, Alabama 35609-2000 September 15, 201410 CFR 50.54 (f)ATTN: Document Control DeskU.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68NRC Docket Nos. 50-259, 50-260, and 50-296

Subject:

Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3 -Response to GenericLetter (GL) 89-13 -Correction to BFN Response to GL 89-13 Actions I1 and III

References:

1. Tennessee Valley Authority (IVA) Letter to the NRC, "Browns Ferry NuclearPlant (BFN) -Response to Generic Letter (GL) 89-13 Service Water SystemProblems Affecting Safety-Related Equipment,"

dated March 16, 19902. NRC Letter to TVA, "Issuance of Renewed Facility Operating License Nos.DPR-33, DPR-52, and DPR-68 for Browns Ferry Nuclear Plant, Units 1, 2,and 3 (TAC Nos. MC1704, MC1705, and MC1706),"

dated May 4, 20063. Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety-Related Equipment (Generic Letter 89-13),"

dated July 18, 1989The purpose of this letter is to notify the NRC of changes to information previously provided inBFN's original response to Generic Letter (GL) 89-13 (Reference

1) and contained in the NRC'sSafety Evaluation for the Issuance of Renewed Facility Operating License Nos. DPR-33,DPR-52, and DPR-68 for Browns Ferry Nuclear Plant, Units 1, 2, and 3 (Reference 2). Thesechanges pertain to BFN's original response to Items II and III of GL 89-13 (Reference 1).GL 89-13 (Reference

3) requested in Item II, in part, that the licensees and applicants conduct atest program to verify the heat transfer capability of all safety-related heat exchangers cooled byservice water. The total test program should consist of an initial test program and periodicretest program.

Both the initial test program and the periodic retest program should include theheat exchangers connected to or cooled by one or more open-cycle systems.On March 16, 1990, the Tennessee Valley Authority (TVA) responded to GL 89-13 Item II(Reference

1) by stating that BFN's current program of regular testing and cleaning of heatA0 05 U. S. Nuclear Regulatory Commission Page 2September 15, 2014exchangers will be revised to become an equally effective alternative to the NRC recommended test program and satisfies the intent of the generic letter.The purpose of the recommended test program is to verify the heat transfer capability ofsafety-related heat exchangers.

Upon poor test results, the affected heat exchanger would beinspected and cleaned.The BFN inspection program contains, in part, the heat exchanger for the Unit 1/2 Emergency Chiller.

As part of the action discussed in the GL 89-13 response, TVA stated that it wouldinspect and clean the cooling water side of the Unit 1/2 Emergency Chiller annually.

In 2007, the Unit 1/2 Emergency Chiller was removed from ASME OM Code testing as a resultof the code boundary being moved. Since the Unit 1/2 Emergency Chiller is not safety relatedand is not credited with a safety function to remove heat to the Ultimate Heat Sink. Therfore, the Unit 1/2 Emergency Chiller is no longer required to be within the scope of GL 89-13.GL 89-13 (Reference

3) requested in Item Ill, that licensees and applicants establishing aroutine inspection and maintenance program for open-cycle service water system piping andcomponents, that corrosion,

erosion, protective coating failure,

silting, and biofouling cannotdegrade the performance of the safety-related systems supplied by service water. The programshould have at least the following purposes:

A. To remove excessive accumulations of biofouling agents, corrosion

products, andsilt;B. To repair defective protective coatings and corroded service water system piping andcomponents that could adversely affect performance of their intended safetyfunctions.

TVA responded to GL 89-13 Item Ill, by stating that since the Residual Heat Removal ServiceWater (RHRSW) and Emergency Equipment Cooling Water (EECW) piping systems are notinternally coated, no inspections for paint integrity are made. Since the initial response, it hasbeen determined that the response to GL 89-13 was silent on the heat exchanger cooled by theRHRSW and EECW systems.

Furthermore, it was determined that some heat exchangers cooled by the RHRSW and EECW systems have been determined to contain protective coatings.

This discrepancy has been documented in the TVA's Corrective Action Program.

Theexisting program documents require inspection of the heat exchanger coating.Additionally, in the Safety Evaluation for the issuance of the Renewed Facility Operating Licenses for Browns Ferry Nuclear Plant, Units 1, 2, and 3 (Reference 2), the NRC states,under the Aging Management Programs (Section 3.0.3.2.11),

the following:

"The OCCW[Open-Cycle Cooling Water] System Program relies on implementation ofthe recommendations of GL 89-13 to ensure that the effects of aging on the OCCWsystem will be managed for the extended period of operation.

The program includes U. S. Nuclear Regulatory Commission Page 3September 15, 2014surveillance and control techniques to manage aging effects caused by biofouling, corrosion,

erosion, protective coating failures, and silting in the OCCW system orstructures and components serviced by the OCCW system.Implementation of GL 89-13 activities provides for management of aging effects due toloss of material, fouling due to micro- or macro-organisms, and heat transfer agingeffects in raw water cooling water systems.

The applicant does not utilize protective coatings in any raw water systems, as addressed in IN 85-24. Therefore, protective coating failures do not apply to BFN."TVA is hereby notifying the NRC that the implementation program for GL 89-13 does not requireflow testing of the Unit 1/2 Emergency Chiller as currently listed in the response to GL 89-13Item II. Additionally, TVA is hereby notifying the NRC that the implementation program forGL 89-13 requires an inspection for paint integrity on open-cycle service water systemscomponents (i.e., heat exchangers).

There are no new regulatory commitments contained in these letter. Please address anyquestions concerning this matter to Jamie Paul at (256) 729-2636.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this the15th day of September 2014.Respectfully, K. J. PoisonVice President, Browns Ferry Nuclear Plantcc:NRC Regional Administrator

-Region IINRC Senior Resident Inspector

-Browns Ferry Nuclear PlantNRC Project Manager -Browns Ferry Nuclear PlantNRC Branch Chief -Region IIState Health Officer, Alabama State Department of Health