ML12114A060

Cover Letter - Revision to the Sequoyah Unit 2 Steam Generator Replacement Rigging and Heavy Load Handling Technical Report, SQN2-SGR-TR1, Submitted in Tva'S Heavy Load Lifts and UHS One Time Change in Support of Unit 2 SGRP (TAC No. ME7225

ML12114A060
Person / Time
Site:	Sequoyah
Issue date:	04/05/2012
From:	Carlin J T Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME7225
Download: ML12114A060 (4)

Text

Tennessee Valley Authority, Post Office Box 2000, Soddy Daisy, Tennessee 37384-2000April 5, 201210 CFR 50.410 CFR 50.90ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001Sequoyah Nuclear Plant, Unit 1Facility Operating License No. DPR-77Docket No. 50-327

Reference:

Revision to the Sequoyah Unit 2 Steam Generator ReplacementRigging and Heavy Load Handling Technical Report,SQN2-SGR-TRI, Submitted in TVA's Heavy Load Lifts and UHSOne Time Change in Support of Unit 2 SGRP (TAC NO. ME7225)1. Letter from TVA to NRC, "Application to Revise Sequoyah NuclearPlant, Unit 1, Operating License and Technical Specification 3.7.5,"Ultimate Heat Sink," to Support Sequoyah Nuclear Plant, Unit 2,Steam Generator Replacement Project (TS-SQN-2011-05)," datedSeptember 29, 20112. Electronic Mail from NRC to TVA, "Sequoyah, Unit 1 LAR -HeavyLoad Lifts and UHS One Time Change in Support of Unit 2 SGRP(TAC NO. ME7225)," dated January 13, 20123. Letter from TVA to NRC, "Response to NRC Request forAdditional Information Regarding the Heavy Load Lifts and UHSOne Time Change in Support of Unit 2 SGRP (TAC NO.ME7225)," dated February 10, 20124. Electronic Mail from NRC to TVA, "Sequoyah, Unit 1 LAR -HeavyLoad Lifts and UHS One Time Change in Support of Unit 2 SGRP(TAC NO. ME7225)," dated February 2, 20125. Letter from TVA to NRC, "Response to Second NRC Request forAdditional Information Regarding the Heavy Load Lifts and UHSOne Time Change in Support of Unit 2 SGRP (TAC NO.ME7225)," dated March 5, 2012 U.S. Nuclear Regulatory CommissionPage 2April 5, 2012The purpose of this letter is to submit Revision 3 of the Sequoyah Unit 2 SteamGenerator Replacement Rigging and Heavy Load Handling Technical Report,SQN2-SGR-TR1.By letter dated September 29, 2011 (Reference 1), the Tennessee Valley Authority(TVA) submitted a one-time request for amendment to the Operating License (OL)for Sequoyah Nuclear Plant (SQN), Unit 1. The amendment request proposed toadd a one-time license condition to the SQN, Unit 1, OL for the conduct of heavyload lifts associated with the SQN, Unit 2, Steam Generator Replacement Project(SGRP). The one-time license condition establishes special provisions andrequirements for the safe operation of SQN, Unit 1, while large heavy load lifts areperformed on SQN, Unit 2. In addition, a one-time change to SQN, Unit 1, TechnicalSpecification (TS) 3.7.5, "Ultimate Heat Sink," is also proposed to implementadditional restrictions with respect to maximum average Essential Raw CoolingWater System supply header water temperature during large heavy load liftsperformed to support the SQN, Unit 2, SGRP.By electronic mail dated January 13, 2012, (Reference 2), the NRC forwarded arequest for additional information (RAI) regarding the proposed changes establishingthe special provisions and requirements for large heavy load lifts on SQN, Unit 2.TVA responded to this first RAI by letter dated February 10, 2012 (Reference 3).Subsequently, by electronic mail dated February 2, 2012, the NRC forwarded asecond RAI. TVA responded to the second RAI by letter dated March 5, 2012(Reference 5).Since submittal of the Reference 5 response to the second RAI, an alternateinterfacing lift point for removal of the old steam generators (OSGs) has beenidentified. In Enclosure 2 to Reference 1, TVA provided the Sequoyah Unit 2 SteamGenerator Replacement Rigging and Heavy Load Handling Technical Report,SQN2-SGR-TR1, Revision 2. This Technical Report documents the provisions madeto ensure that heavy load handling activities associated with the Unit 2 SGRPOutage can be accomplished without impacting the safe operation of Unit 1. Section5.1, "Description of Cranes and Heavy Loads, Outside Lift System," of Revision 2 ofthe Technical Report describes using a lifting lug welded to the Main Steam nozzleas the interfacing lift point for removal of the OSGs. The alternate OSG interfacinglift point revises the interfacing lift point from the lifting lug to the secondary sidemanways, which will be fitted with keeper plates to enable slings to be utilized to rigout the OSGs. The secondary side manway lift point is described in Section 5.1 ofRevision 3 of the Technical Report provided in Enclosure 1 to this letter.

U.S. Nuclear Regulatory CommissionPage 3April 5, 2012Utilizing the secondary side manways as the OSG interfacing lift point eliminates theignition sources in the Containment Building associated with welding the lifting lug tothe Main Steam nozzle, including the post-weld heat treatment processes.Eliminating the ignition sources improves the safety of personnel working in theContainment Building during the welding processes. In addition, using thesecondary side manways is considered a more efficient method for removal of theOSGs which reduces the likelihood of human error by reducing complexity.Furthermore, since the OSG removal task activity duration will be reduced, there willbe a corresponding reduction in personnel radiation exposure.Revision 3 of the Technical Report in Enclosure 1 to this letter supersedes in itsentirety, Revision 2 of the Technical Report previously submitted in Enclosure 2 ofReference 1. In addition to the interfacing lift point revision described above, thefollowing changes are also included in Revision 3 to the Technical Report:* Added valve numbers to Figures 6-1 and 8-2 as addressed in the response toRAI Question 2 of the enclosure to Reference 5;* Corrected the test weight;* Changed Figure 5-3 to illustrate raising the Outside Lift System foundation by6 inches;* Changed the reference to "Liebherr 1400/1" crane to be "Liebherr 1400/1 orLiebherr 1400/2" to permit use of either crane; and,* Made changes to reflect the updated Replacement Steam Generator riggingweight.The changes are identified by revision bars in the Technical Report provided inEnclosure 1 to this letter. Enclosure 2 to this letter provides an affected page listingof each of the changes included in Revision 3 of the Technical Report.TVA has evaluated the revision to the OSG interfacing lift point and the otherchanges made in Revision 3 of the Technical Report and determined that there is noimpact on the no significant hazards considerations associated with the OL and TSamendment request submitted in Reference 1. TVA has further determined that theproposed amendment still qualifies for a categorical exclusion from environmentalreview pursuant to the provision of 10 CFR 510.22(c)(9). In addition, TVA hasconcluded that there is no change to the Probabilistic Risk Assessment (PRA)Insights as documented in Section 9.0 of the Technical Report. In accordance with10 CFR 50.91 (b)(1), TVA is sending a copy of this letter and enclosures to theTennessee State Department of Environment and Conservation.

U.S. Nuclear Regulatory CommissionPage 4April 5, 2012There are no regulatory commitments included in this submittal. If you have anyquestions, please contact Clyde Mackaman at (423) 751-2834.I declare under penalty of perjury that the foregoing is true and correct. Executed onthe 9" day of April 2012.Resp~vc~tfully,Vice PresidentSequoyah Nuclear Plant

Enclosures:

1. Sequoyah Unit 2 Steam Generator Replacement Rigging and HeavyLoad Handling Technical Report, SQN2-SGR-TR1, Revision 32. SQN2-SGR-TR1 Revision 3 Affected Page Listcc: (Enclosures):NRC Regional Administrator -Region IINRC Senior Resident Inspector -Sequoyah Nuclear PlantDirector, Division of Radiological Health, Tennessee State Department ofEnvironment and Conservation