ML22343A000

Response to Request for RAI on ASME Operation & Maintenance Code Inservice Testing Program - Request for Approval of Alternative Request V-01 Use of Mechanical Agitation Process for Pressure Isolation Valve 1-SI-241 Seat Leakage Testing

ML22343A000
Person / Time
Site:	Surry
Issue date:	12/09/2022
From:	James Holloway Virginia Electric & Power Co (VEPCO)
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
22-374A
Download: ML22343A000 (1)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 December 9, 2022 10 CFR 50.55a U.S. Nuclear Regulatory Commission Serial No.: 22-374A ATTN: Document Control Desk NRA/GDM: R0 Washington, D.C. 20555-0001 Docket No.: 50-280 License No.: DPR-32 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 ASME OPERATION AND MAINTENANCE (OM) CODE INSERVICE TESTING PROGRAM - REQUEST FOR APPROVAL OF ALTERNATIVE REQUEST V-01 USE OF MECHANICAL AGITATION PROCESS FOR PRESSURE ISOLATION VALVE 1-SI-241 SEAT LEAKAGE TESTING RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION By letter dated December 8, 2022 (ADAMS Accession No. ML22342B248), Virginia Electric and Power Company (Dominion Energy Virginia) submitted Alternative Request V-01 for the use of a mechanical agitation process for pressure isolation valve (PIV) 1-SI-241 seat leakage testing for Surry Unit 1 under 10 CFR 50.55a(z)(2) as a hardship alternative to specific ASME OM Code requirements for PIV 1-SI-241.

Dominion Energy Virginia requested NRC review of Alternative Request V-01 and, if possible, verbal authorization of the proposed alternative by 9:00 am EST on December 9, 2022, to support Surry Unit 1 startup activities.

By email dated December 8, 2022, 1018 hours0.0118 days <br />0.283 hours <br />0.00168 weeks <br />3.87349e-4 months <br />, the NRC Project Manager for SPS provided a request for additional information (RAI) associated with the proposed alternative request for the NRC staff to complete its review. The NRC RAI and the associated Dominion Energy Virginia response are provided in the attachment.

Should you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.

Respectfully, James E. Holloway Vice President - Nuclear Engineering and Fleet Support

Attachment:

Response to NRC Request for Additional Information Associated with IST Alternative Request V-01

Serial No. 22-374A Docket No. 50-280 IST Alternative Request RAI Response Page 2 of 2 Regulatory commitments contained in this correspondence:

1. PIV 1-SI-241 will be internally inspected and repaired or replaced prior to startup from the next SPS Unit 1 RFO (1R32).

2. The mechanical agitation of 1-SI-241 at SPS Unit 1 will implement the process specified in the section Recommendations for Future Application of Mechanical Agitation to Seat Valve 1-SI-241 for Alternative Request V-01.

cc: U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303 Mr. John J. Klos - Surry NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852 Mr. G. Edward Miller - North Anna NRC Senior Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 09 E-3 11555 Rockville Pike Rockville, Maryland 20852 NRC Senior Resident Inspector Surry Power Station

Serial No. 22-374A Docket No. 50-280 Attachment RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH ALTERNATIVE REQUEST V-01 USE OF MECHANICAL AGITATION PROCESS FOR PRESSURE ISOLATION VALVE 1-SI-241 SEAT LEAKAGE TESTING Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Unit 1

Serial No. 22-374A Docket No. 50-280 Proposed IST Alternative Request V-01 RAI Response Attachment RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Alternative Request V-01 for Use of Mechanical Agitation Process on Pressure Isolation Valve 1-SI-241 Seat Leakage Testing NRC Comment At 5:05 pm EST on December 8, 2022, Dominion Energy Virginia (licensee) submitted Alternative Request V-01 for the use of a mechanical agitation process for pressure isolation valve (PIV) 1-SI-241 seat leakage testing for Surry Unit 1 under 10 CFR 50.55a(z)(2) as a hardship alternative to specific ASME OM Code requirements for PIV 1-SI-241. The licensee requested NRC review of Alternative Request V-01 and, if possible, verbal authorization of the proposed alternative by 9:00 am EST on December 9, 2022, to support Surry Unit 1 startup activities.

For the NRC staff to complete its review of Alternative Request V-01 in the requested timeframe, the licensee needs to respond to the following items:

RAI Question No. 1 As indicated in the alternative request, the licensee mechanically agitated 1-SI-241 at Surry Unit 1 in the spring of 2006 (1R20) following the identification of seat leakage greater than 5 gpm. The licensee again agitated 1-SI-241 in the spring of 2021 (1R30) following the identification of seat leakage greater than 25 gpm. As corrective action, the licensee planned to internally inspect and repair 1-SI-241 during the current RFO (1R31), but decided to proceed with startup activities without performing the corrective action. With the degradation indicated by the increasing leakage of 1-SI-241 over time and the performance of multiple instances of mechanical agitation of 1-SI-241, please specify that 1-SI-241 will be internally inspected and repaired prior to startup from the next RFO (1R32).

Dominion Energy Virginia Response Dominion Energy Virginia confirms that PIV 1-SI-241 will be internally inspected and repaired or replaced prior to startup from the next SPS Unit 1 RFO (1R32).

RAI Question No. 2 In the first sentence of Section 6.B of the alternative request, the licensee states that it has performed an engineering evaluation similar to the TVA precedent. Please confirm that the results of your engineering evaluation demonstrate that the mechanical agitation will not damage 1-SI-241.

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Serial No. 22-374A Docket No. 50-280 Proposed IST Alternative Request V-01 RAI Response Attachment Dominion Energy Virginia Response The Dominion Energy Virginia engineering evaluation documents that 1-SI-241 is the same make/model as the 6 check valve evaluated by TVA (same thickness, same material) and that the results from the TVA analysis therefore apply to 1-SI-241 assuming mechanical agitation is performed applying the same approach, which is required by the proposed alternative. Therefore, Dominion Energy Virginia confirms that the results of our engineering evaluation demonstrate that mechanical agitation will not damage 1-SI-241.

RAI Question No. 3 In Attachment 2 to Surry Alternative Request V-01, the licensee includes a section titled where the licensee lists guidance for mechanical agitation that has been authorized by the NRC in the precedent referenced in Surry Alternative Request V-01. Please confirm that the mechanical agitation of 1-SI-241 at Surry Unit 1 will implement the process specified in this section of Recommendations for Future Application of Mechanical Agitation to Seat Valve 1-SI-241 for Alternative Request V-01.

Dominion Energy Virginia Response Dominion Energy Virginia confirms that the mechanical agitation of 1-SI-241 at SPS Unit 1 will implement the process specified in the section Recommendations for Future Application of Mechanical Agitation to Seat Valve 1-SI-241 for Alternative Request V-01.

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