CNL-22-104, Correction to Response to Request for Additional Information Regarding Sequoyah Nuclear Plant, Units 1 and 2, American Society of Mechanical Engineers Operation and Maintenance Code, Request for Alternative RV-02

Correction to Response to Request for Additional Information Regarding Sequoyah Nuclear Plant, Units 1 and 2, American Society of Mechanical Engineers Operation and Maintenance Code, Request for Alternative RV-02

ML22304A146
Person / Time
Site:	Sequoyah
Issue date:	10/31/2022
From:	Rymer S Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
CNL-22-104, EPID L-2022-LLR-0034
Download: ML22304A146 (1)

Text

1101 Market Street, Chattanooga, Tennessee 37402 CNL-22-104 October 31, 2022 10 CFR 50.55a ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

Subject:

Correction to Response to Request for Additional Information Regarding Sequoyah Nuclear Plant, Units 1 and 2, American Society of Mechanical Engineers Operation and Maintenance Code, Request for Alternative RV-02 (EPID L-2022-LLR-0034)

References:

1. TVA letter to NRC, CNL-22-024, Sequoyah Nuclear Plant, Units 1 and 2, American Society of Mechanical Engineers Operation and Maintenance Code, Request for Alternative RV-02, dated March 15, 2022 (ML22074A315)

2. TVA letter to NRC, CNL-22-062, Response to Request for Additional Information Regarding Sequoyah Nuclear Plant, Units 1 and 2, American Society of Mechanical Engineers Operation and Maintenance Code, Request for Alternative RV-02 (EPID L 2022-LLR-0034), dated June 28, 2022 (ML22179A357)

3. NRC letter to TVA, Sequoyah Nuclear Plant, Units 1 and 2 Authorization of Alternative Request RV-02 for Pressure Isolation Valve Seat Leakage (EPID L-2022-LLR-0034), dated September 29, 2022 (ML22263A375)

4. NRC letter to TVA, Sequoyah Nuclear Plant, Units 1 and 2 Summary of Regulatory Audit for Alternative Request RV-02 (EPID L-2022-LLR-0034),

dated September 28, 2022 (ML22263A008)

In Reference 1, Tennessee Valley Authority (TVA) requested Nuclear Regulatory Commission (NRC) approval of inservice testing (IST) alternative request RV-02, for the Sequoyah Nuclear Plant (SQN), Units 1 and 2, pressure isolation valves (PIV) listed in the enclosure to Reference 1, to allow mechanical agitation as a means to achieve acceptable valve seat leakage. In Reference 2, TVA responded to an NRC request for additional information (RAI). In Reference 3, the NRC approved the alternative request.

U.S. Nuclear Regulatory Commission CNL-22-104 Page 2 October 31, 2022 The purpose of this letter is to inform the NRC of an error that TVA recently discovered in the Reference 2 RAI response. Specifically, in the Introduction Section of the enclosure to Reference 2, TVA stated:

Mechanical agitation of six-inch, eight-inch, and ten-inch check valves may be performed by tapping the valve body using a 15-pound (maximum) soft-faced dead blow mallet, rubber mallet, or against a block of wood with a ten-pound (maximum) steel mallet, swung approximately 120 degrees about the elbow, without excessive use of the body to accelerate the hammer head.

The above paragraph should have stated or against a block of wood with a 15-pound (maximum) steel mallet.

The incorrect quoted information from Reference 2 was repeated by the NRC in References 3 and 4. However, the correct information [i.e., 15-pound (maximum) steel mallet] was provided in the TVA Engineering Work Request (EWR) No. 22-DEC-063-050 that was audited by the NRC in Reference 4. Reference 4 correctly states, The EWR specifies that a 15-lb maximum soft-faced dead blow mallet or rubber mallet, or a 15-lb max steel mallet against block of wood, will be used to mechanically agitate the 6-inch, 8-inch and 10-inch check valves." Therefore, the EWR properly evaluated the use of the 15-pound (maximum) steel mallet.

The incorrect statement regarding the ten-pound (maximum) steel mallet was derived from an earlier draft of EWR 22-DEC-063-050. The EWR was later revised to correct the statement to a 15-pound (maximum) steel mallet, but TVA GLGQRWidentify this change in the development of Reference 2.

TVA requests NRC revise Reference 3 to correct the statement regarding the ten-pound (maximum) steel mallet to a 15-pound (maximum) steel mallet. TVA has entered this error into the TVA corrective action program.

There are no new regulatory commitments associated with this submittal. Please address any questions regarding this request to Stuart L. Rymer at slrymer@tva.gov.

Respectfully, Digitally signed by Rymer, Stuart Loveridge Date: 2022.10.31 08:43:11 -04'00' Stuart L. Rymer Director (Acting), Nuclear Regulatory Affairs cc:

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Project Manager - Sequoyah Nuclear Plant