ML16237A400
| ML16237A400 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 08/24/2016 |
| From: | Simmons P Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML16237A400 (4) | |
Text
Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 August 24,2016 10 cFR 50 4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 Facility Operating License No. NPF-96 NRC Docket No. 50-391
Subject:
Watts Bar Nuclear Plant, Unit 2 - American Society of Mechanical Engineers Boiler and Pressure Vessel Gode Section XI, lnitial Inservice
!nspection Report - Revised Commitment
Reference:
TVA letter to NRC, "Watts Bar Nuclear Plant WBN) Unit 2 - American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Transition - Revised Commitment," dated September 1,2011 (M1113064022) ln the referenced letter, the Tennessee Valley Authority (TVA) committed to the following action:
"The initial inservice inspection report shall be issued within 90 days following initial Unit 2 Turbine Generator synchronization following criticality for those repairs or replacements, if any, which were performed under Section Xl on Unit 2."
ln accordance with the WA process for managing Nuclear Regulatory Commission (NRC) commitments (NPG-SPP-O3.3), TVA is hereby informing the NRC that the above commitment is being revised as follows:
The initial inservice inspection report shall be submitted to the NRC within 90 days following Unit 2 commercial operation for those repairs or replacements, if any, which were performed under Section Xl on Unit 2 between the initial code stamp up to commercial operations.
As noted in the referenced letter, the basis for the original commitment was:
"ASME Section Xl, Subparagraph IWA-6240(b) requires the inservice inspection summary report to be submitted within 90 calendar days of the completion of each refueling outage. This requirement related to completion of a refueling outage does
U. S. Nuclear Regulatory Commission Page2 August 24,2016 not provide clear guidance for initial startup of a new plant; therefore, TVA provides the following interpretation. For operating plants, TVA defines completion of a refueling outage as Turbine Generator synchronization; therefore, for the purpose of ASME inspections of an initial cycle, TVA will define completion of Unit 2 as initial Turbine Generator synchronization following criticality."
Thus, the intent of the original commitment was to provide the NRC with the Watts Bar Nuclear Plant (WBN) Unit 2 Owners Activity Report (OAR) for repair/replacement work performed between the time the hardware is transitioned from ASME Section lll to Section Xl and the time of initial turbine generator synchronization following criticality.
As discussed in the referenced letter, TVA noted that the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code Section Xl does not address the period of time between turbine generator synchronization and commercial operations. As stated in the referenced letter:
"For WBN Unit 2, the use of initial Turbine Generator synchronization following criticality' as the ending boundary for the initial inservice inspection report and preservice test period, and commercial operation as the beginning of the IWA-2430(b) inservice inspection and ISTA-3120(b) inservice test intervals, will minimize the undefined timeframe."
Turbine generator synchronization for WBN Unit 2 occurred on June 3, 2016. Commercial operation is not intended to commence until after September 1,2016. Thus, there could be as much or more than a three-month period between turbine generator synchronization and commercial operations.
The revised commitment will enable TVA to address all repair replacement activities done between the initial code stamp up to commercial operations, which will include the undefined period not addressed in ASME Section Xl (i.e., turbine generator synchronization to commercial operations).
The information to be submitted to the NRC in the revised commitment will be in accordance with ASME B&PV Code Section Xl, Division 1, Subsub Article IWA-6210 and ASME Code Case N-532-5, "Repair/Replacement Activity Documentation Requirements and lnservice lnspection Summary Report Preparation and Submission Section Xl, Division 1."
TVA notes that the commitment to submit the initial inservice inspection report within 90 days following initial WBN Unit 2 turbine generator synchronization following criticality was not credited in the Safety Evaluation Report related to the operation of WBN Unit 2 (NUREG-0847) nor its supplements.
TVA has discussed this revised commitment with the NRC and received alignment.
U. S. Nuclear Regulatory Commission Page 3 August 24,2016 The enclosure to this letter lists the revised regulatory commitment associated with this submittal. lf you have questions regarding this letter, please contact Gordon Arent at (423) 365-2004.
Respectfully, /
Paul Simmons Site Vice President Watts Bar Nuclear Plant
Enclosure:
Revised Regulatory Commitment cc (Enclosure):
NRC Regional Administrator - Region ll NRC Senior Resident lnspector - Watts Bar Nuclear Plant NRC Project Manager - Watts Bar Nuclear Plant
Enclosure Revised Regulatory Commitment The initial inservice inspection report shall be submitted to the NRC within 90 days following Unit 2 commercial operation for those repairs or replacements, if any, which were performed under Section Xl on Unit 2 between the initial code stamp up to commercial operations.
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