IR 05000390/2011611

Download: ML111810632

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June 28, 2011

Mr. AshokSenior Vice President Nuclear Generation Development and Construction Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT: WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000391/2011611

Dear Mr. Bhatnagar:

On May 20, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of construction activities at your Watts Bar Unit 2 reactor facility. The enclosed inspection report documents the inspection results, which were discussed on May 20, 2011, with Mr. Ed Freeman and other members of your staff. This inspection examined activities conducted under your Unit 2 construction permit as they relate to identification and resolution of problems, compliance with the Commission's rules and regulations, and with the conditions of your construction permit. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. On the basis of the sample selected for review, there were no findings of significance identified during the inspection. The team concluded, in general, that problems were properly identified, evaluated, and corrected within the problem identification and resolution program (PI&R). Based on the corrective action program being deemed effective, the NRC will no longer perform follow-up inspections on all non-cited violations (NCVs) in accordance with Inspection Manual Chapter 2517, "Watts Bar Unit 2 Construction Inspection Program." NCVs will now be closed based on you entering them into your corrective action program, and follow-up inspections will occur on a sampling basis. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of

TVA 2 NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/

Robert C. Haag, Chief Construction Projects Branch 3 Division of Construction Projects Docket No. 50-391 Construction Permit No: CPPR-92

Enclosure:

Inspection Report 05000391/2011611 w/attachment cc w/encl: (See next page)

TVA 2 NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Robert C. Haag, Chief Construction Projects Branch 3 Division of Construction Projects Docket No. 50-391 Construction Permit No: CPPR-92

Enclosure:

Inspection Report 05000391/2011611 w/attachment cc w/encl: (See next page) PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE NON-SENSITIVE ADAMS: G Yes ACCESSION NUMBER: ML111810632 G SUNSI REVIEW COMPLETE G FORM 665 ATTACHED OFFICE RII: DRP RII:DCP RII:DCI RII:DCI RII:DCP SIGNATURE Via Email Via Email Via Email Via Email GAH2 for NAME AHutto PVan Doorn CJulian RLewis EHeher DATE 6/27/2011 6/27/2011 6/28/2011 6/23/2011 6/27/2011 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME: G:\CCI\INSPECTION REPORTS\WATTS BAR\PIR IR 05000391-2011611.DOCX TVA 3 cc w/encl: Mr. Gordon P. Arent Manager New Generation Licensing Nuclear Generation Development and Construction WBN Nuclear Plant P.O. Box 2000 Spring City, Tennessee 37381 Mr. David Stinson Vice President WBN Unit Two WBN Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381 Mr. C.J. Riedl, Manager Licensing and Industry Affairs WBN Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381 Mr. Preston D. Swafford Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Place Chattanooga, Tennessee 37402-2801 County Executive 375 Church Street Suite 215 Dayton, Tennessee 37321 Mr. W. D. Crouch, Manager WBN Unit 2 Licensing Watts Bar Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381 Mr. Gregory A. Boerschig Plant Manager, WBN Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381 Mr. T. J. Neissen General Manager Quality Assurance Nuclear Generation and Development and Construction 1101 Market Street Blue Ridge 3A Chattanooga, Tennessee 37402-2801 Mr. R. M. Krich Vice President Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Mr. E. J. Vigluicci Assistant General Counsel Tennessee Valley Authority 6A West Tower 400 West Summit Hill Drive Knoxville, Tennessee 37402 Mr. Lawrence E. Nanney, Director Tennessee Department of Environmental Health & Conservation Division of Radiological Health 3rd Floor, L&C Annex 401 Church Street Nashville, TN 37243-1532 Mr. D. E. Grissette Site Vice President WBN Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381 County Mayor P.O. Box 156 Decatur, Tennessee 37322 Tomy Nazario WB Nuclear Plant U.S. NRC 1260 Nuclear Plant Road Spring City, Tennessee 37381 TVA 4 cc email distribution w/encl: Greg Scott Tennessee Valley Authority Electronic Mail Distribution Watts Bar 2 Licensing Tennessee Valley Authority Electronic Mail Distribution

Letter to Ashokfrom Robert C. Haag dated June 28, 2011.

SUBJECT: WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000391/2011611 Distribution w/encl: L. Raghavan, NRR S. Campbell, NRR P. Milano, NRR C. Evans, RII L. Douglas, RII EICS E. Guthrie, RII DRP R. Monk, RII WBN Unit 1 SRI OE Mail (email address if applicable) PUBLIC Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No: 50-391 Construction Permit No: CPPR-92 Report No.: 05000391/2011611 Applicant: Tennessee Valley Authority (TVA)

Facility: Watts Bar Nuclear Plant, Unit 2 Location: 1260 Nuclear Plant Rd Spring City TN 37381 Inspection Dates: May 16 through May 20, 2011 Inspectors: A. Hutto, (Lead) Senior (Sr.) Resident Inspector, Reactor Projects Branch 1, Division of Reactor Project, Region II (RII) C. Julian, Construction Inspector, Construction Inspection Branch (CIB) 1, Division of Construction Inspection (DCI), RII P. Van Doorn, Construction Projects Branch 3, (CPB) 3, Division of Construction Projects (DCP), RII E. Heher, Construction Inspector, CIB2, DCI, RII R. Lewis, Resident Inspector, CPB3, DCP, RII Accompanying Personnel: L. Dumont, Construction Inspector (In Training), CIB1, DCI, RII Approved By: Robert C. Haag, Chief Construction Projects Branch 3 Division of Construction Projects

EXECUTIVE

SUMMARY

Watts Bar Nuclear Plant, Unit

NRC Inspection Report 05000391/2011611 Introduction This inspection assessed implementation of the corrective action program for the Watts Bar Unit construction completion project. The inspection program for Unit construction activities is described in NRC Inspection Manual Chapter 2517. Information regarding the Watts Bar Unit Construction Project and NRC inspections can be found at http://www.nrc.gov/reactors/plant-specific-items/watts-bar.html.

Inspection Results

• The inspectors determined that implementation of the corrective action program (CAP) for the Watts Bar Unit construction completion project was effective. In general, the threshold for initiating problem evaluation reports (PERs) was low, PERs were appropriately categorized, and problem evaluations were effective in identifying corrective actions that addressed the problem (Section Q.1.1).

• The inspectors determined that adequate measures have been established to evaluate and incorporate applicable operating experience into the corrective action program (Section Q.1.1).

• The inspectors determined that TVA and Bechtel have established an acceptable program and environment for allowing employees to identify quality or safety-related concerns. (Section Q.1.1)

REPORT DETAILS

I. Quality Assurance Program Q.1 Quality Assurance Program Implementation Q.1.1 Implementation of Corrective Action Program During Construction (IP 35007)

a. Inspection Scope

The inspectors assessed the adequacy of the Tennessee Valley Authority (TVA) and Bechtel program for identification, evaluation, and corrective action of conditions adverse to quality during the period since the previous problem identification and resolution inspection in August 2010. This was accomplished by evaluating the thresholds for problem identification, the effectiveness of immediate and preventive corrective actions, the accuracy and thoroughness of problem documentation, and the adequacy of corrective actions for previously identified compliance issues. The inspectors conducted reviews to evaluate management/quality assurance oversight of the corrective action process. The inspectors reviewed a sample of over 85 PERs and Service Requests (SRs) selected from reports of plant problems at Watts Bar Unit 2. The sample included problems addressed by a diverse selection of plant departments and problems classified under all of the significance levels. The sample also covered a diverse selection of sources, including problems identified in audits and assessments, nonconforming results from inspections and tests, findings from NRC inspections, concerns from anonymous sources, and concerns identified as adverse trends. Most PERs were reviewed after corrective actions had been implemented; however, some were reviewed after the corrective action plan was developed but prior to implementation. The inspectors also reviewed the applicant's alternate issue tracking systems which address issues that were not classified as conditions adverse to quality. This review targeted verification of appropriate characterization and closure of issues managed outside the corrective action program. The TVA Over, Short, Damaged, and Discrepant (OSDD) report was reviewed to verify that items in the report were appropriately evaluated for potential inclusion in the corrective action program. The OSDD report documents unsatisfactory, overage, shortage and damage (UOS&D) deficiencies during material receiving process. The inspectors reviewed applicable portions of the applicant's Quality Assurance Program (QAP) implementing procedures in order to ensure that commitments for the identification, evaluation, and resolution of conditions adverse to quality had been adequately addressed. The inspectors review evaluated the applicant's consideration for extent of condition, generic implications, common cause and previous occurrences (trending), including the identification of root and contributing causes along with actions to prevent recurrence for significant conditions adverse to quality. The inspectors reviewed TVA's and Bechtel's respective programs for resolving employee concerns. This review covered documents and reports, some of which were documented in previous NRC inspection reports. The inspectors interviewed TVA and the major contractor's (Bechtel) employee concern representatives, reviewed a listing of new employee concerns, and reviewed corrective actions for selected concern files. The inspectors reviewed and evaluated the adequacy of the programs which provide employees with an alternate method to identify quality or safety-related concerns. The inspectors also reviewed the provisions provided for workers to report conditions that may be adverse to quality. The inspectors reviewed several anonymous PERs to determine if they had been adequately captured and addressed.

The inspectors reviewed a sample of 10 management and quality assessments, audits, trend reports, and focused surveillances to verify adverse results were properly evaluated and dispositioned in the corrective action program. The inspectors reviewed the revision history for corrective action program implementing procedures and assessed the integration of industry operating experience into the corrective action process. Direct observations by inspectors included meetings of the Project Review Committee (PRC) and the Construction Completion Management Review Committee (CCMRC) as they screened newly reported problems and reviewed dispositions for selected issues. Specific documents reviewed are listed in the attachment.

b. Observations and Findings

No findings of significance were identified. The following observations were noted: (1) Effectiveness of Identifying, Evaluating, and Correcting Problems Identifying Problems The inspectors determined that the applicant was effective in identifying problems and entering them into the CAP. PERs normally provided complete and accurate characterization of the subject issues. In general, the threshold for initiating PERs was low as evidenced by the continued large number of PERs entered annually into the CAP.

Employees were encouraged by management to initiate PERs. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. The inspectors' independent review did not identify any significant adverse conditions which were not in the CAP for resolution. Evaluating Problems The inspectors found no significant issues with the evaluations provided for individual PERs and determined that the applicant had adequately prioritized issues entered into the CAP consistent with established procedures. This was confirmed through the review of audits conducted by the applicant and the assessment conducted by the inspection team during the on-site period. Generally, the applicant performed evaluations that were technically accurate and of sufficient depth. The inspectors determined that site trend reports were thorough and that a low threshold was established for evaluation of potential trends. Use of trending at the site was comprehensive and effective in identifying areas for improvement.

The team determined that the applicant conducted an adequate number of root cause analyses based on the overall number and significance of issues entered into the CAP. The classifications were consistent with established procedures. A variety of causal analysis techniques were used depending on the type and complexity of the issue. For root causes that were identified, the applicant appropriately developed corrective actions to prevent recurrence (CAPR).

The team did identify one example (PER 247196) where the completion of the root cause analysis did not meet the applicant's timeliness requirements; however, immediate corrective actions and the extent of condition that was performed was sufficient such that there were no adverse consequences from the late root cause.

The inspectors also identified one example (PER 268797) where the development of the corrective action plan had not been completed within the assigned due date and no extensions had been initiated. The inspectors found three examples of C Level PERS (287646, 323361, and 356557) that identified corrective actions to address the identified issue, but did not evaluate potential underlying process weakness that could have contributed to the issue. For C Level PERs, this type of review is not required; however, the inspectors noted these PERs represented opportunities to better understand process weaknesses. Correcting Problems Based on a review of numerous PER corrective actions and their implementation, the team found, for the most part, that the applicant=s corrective actions developed and implemented for problems were timely, effective, and commensurate with the safety significance of the issues. Effectiveness reviews for CAPRs and audits were generally of good depth and correctly identified issues.

The inspectors did find several examples where the documentation of corrective actions were incomplete or inaccurate. One example (PER 262178) failed to document the completion of an effectiveness review that was completed two months previously and the open corrective action status was a month past due. Two examples were identified (PERs 326539 and 335991) where corrective action status was incorrect. One PER (321209) closed out a corrective action plan to an email that contained little documentation as to what was done, and the associated corrective action within the PER remained open. The applicant corrected these issues at the time of the inspection. (2) Use of Operating Experience The inspectors found that the applicant's measures to evaluate and incorporate applicable operating experience into the corrective action program contained processes for including vendor recommendations and internally generated lessons learned. The industry and operating experience (I&OE) information was collected, evaluated, and communicated to affected internal stakeholders as specified in TVA procedures, and appropriate corrective actions were developed for issues applicable to the Watts Bar Unit 2 Construction Completion Project.

(3) Safety Conscious Work Environment (SCWE) The inspectors determined that TVA's and Bechtel's employee concern programs were adequate with significant improvement noted for the Bechtel program, in that the program procedure had undergone significant improvement and use of employee surveys had resulted in improvement initiatives. Employees interviewed expressed knowledge of the employee concerns program and the ability to raise safety related concerns through various available means. Generally, there appeared to be a low threshold for initiating PERs with strong management support for the program evident.

(4) Corrective Action Program Performance Insights The sample of audits, assessments, and surveillances reviewed by the inspectors confirmed that management and quality personnel actively conducted observations and effectiveness reviews of the corrective action program. These program assessments concluded that overall, the corrective action program was effectively implemented which was consistent with the inspectors' observations and assessments during this inspection. The sample of reported problems reviewed by the inspectors, interviews with responsible personnel, observations of program activities, and evaluation of program trends identified the following insights:

• The corrective action plan and corrective action (CA) backlog was relatively high due to extensions and late actions as identified by Bechtel trending in these areas. As a result, an action plan has been developed to complete development of overdue and extended corrective action plans and to schedule realistic completion dates for CAs tied to system schedule milestones.

• The CCMRC provided an appropriate level of management focus and input to the CAP. Committee members were engaged and their review of PER categorization and corrective actions was critical and probing. This level of management involvement in the PER review process provided added value and illustrated management's commitment to improving the CAP at Watts Bar Unit 2.

• There were opportunities to perform an increased number of apparent cause evaluations for Level C PERs. The inspectors noted several examples were Level C PER corrective action plans only addressed the problem identified but did not address potential process breakdowns that led to the problem. Only 16 Level C PERs written since the last PI&R inspection were determined to require apparent cause evaluations and this potentially represents missed opportunities for additional improvements that could be realized from the CAP.

• PER 247196 was a Level A PER associated with potential falsification of quality records involving electrical cable determinations and measurements. This PER was initiated on August 31, 2010. The inspector noted that the Root Cause evaluation was not completed until March 31, 2011. The applicant indicated that one of the delays was because the potential personnel issues required special investigation. The inspector was concerned that technical aspects of the problem may not have been addressed in a timely manner. Further inspector review showed that sufficient actions had been taken to address the technical issued in a reasonable time before the Root Cause was completed. These included an extent of condition review which consisted of reviewing all work performed by the individuals and evaluating whether any other problems existed. None were found. In addition, the applicant held briefings with the affected department personnel. Additional training was implemented after the Root Cause was completed. While the applicant did not meet the timeliness requirements of the applicable procedure, management had made a decision to delay the final evaluation so as not to prejudice the investigation, and sufficient intermediate actions were taken to address prevention of similar problems and evaluate if any others existed. (5) Corrective Action Program Effectiveness As discussed above, the inspectors found that the applicant had conducted program assessments and focused assessments which addressed effectiveness. The inspectors determined the implementation of the CAP since the last NRC 2010 PI&R inspection (August 2010) has improved. Problem areas identified in the 2010 report associated with the identification and corrective action components of the program were not observed to the same extent and significance during this inspection. The CAP improvement appears to be a result of increased management attention and resources to the program and the communication of program expectations to the staff and contractors.

c. Conclusions

As documented above, the inspectors determined that implementation of the CAP for the Watts Bar Unit 2 construction completion project was effective. The threshold for initiating PERs was appropriate, PERs were categorized in accordance with their significance, and problem evaluations were effective in identifying appropriate corrective actions. The inspectors determined that adequate measures had been established to evaluate and incorporate applicable operating experience into the corrective action program.

In regards to maintaining a Safety Conscious Work Environment, the inspectors determined that TVA and Bechtel had established an acceptable program and environment for allowing employees to identify quality or safety-related concerns.

Inspection Manual Chapter (IMC), 2517, Section 10.03 contained a provision to stop the NRC's practice of performing follow-up inspections for all non-cited violations when the applicant's corrective action program is deemed to be effective. Based on the results of this PI&R inspection, the NRC will not be required to perform follow-up inspections for all non-cited violations. Corrective actions for future non-cited violations will be assessed on a sampling basis by NRC inspections, including PI&R inspections. V. Management Meetings X.1 Exit Meeting Summary On May 20, 2011, the inspectors presented the inspection results to Mr. Ed Freeman and other members of his staff. Proprietary information reviewed during the inspection was returned and no proprietary information was included in this inspection report.