IR 05000390/2013613
| ML13158A115 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 06/07/2013 |
| From: | Haag R C NRC/RGN-II/DCP/CPB3 |
| To: | Skaggs M D Tennessee Valley Authority |
| Michelle Adams | |
| References | |
| IR-13-613 | |
| Download: ML13158A115 (22) | |
Text
June 7, 2013
Mr. MichaelSenior 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 05000391/2013613
Dear Mr. Skaggs:
On April 26, 2013, 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 April 26, 2013, with Mr. Zeringue and other members of your staff. This problem identification and resolution (PI&R) 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.
No findings were identified during this inspection.
In accordance with 10 Code of Federal Regulations (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 the 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).Should you have questions concerning this letter, please contact us.
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 05000391/2013613 w/Attachment
cc w/encl: (See next page)
SUMMARY
Watts Bar Nuclear Plant, Unit
NRC Inspection Report 05000391/2013613 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/info-finder/reactor/wb/watts-bar/construction-insp-info.html. Inspection Results
- In general, the threshold for initiating problem evaluation reports (PERs) was low and PERs were appropriately categorized. For the majority of PERs reviewed, the inspectors determined that problem evaluations were effective in identifying corrective actions that addressed the problem. [Section Q.1.1]
- The inspectors noticed that the corrective action backlog had been greatly reduced since the last PI&R inspection. [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]
Table of Contents I. QUALITY ASSURANCE PROGRAM .....................................................................................
Q.1 Quality Assurance Program Implementation .................................................................
Q.1.1 Implementation of Corrective Action Program During Construction (IP 35007) ...............
IV. OTHER ACTIVITES .............................................................................................................
OA.1.1 (Closed) Non-Cited Violation (NCV) 05000391/2011604-02: Failure to Maintain Adequate Design Specifications.....................................................................................
V. MANAGEMENT MEETINGS ............................................................................................
X.1 Exit Meeting Summary ...................................................................................................
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 March 2012. This was accomplished by reviewing selected PERs, verifying corrective actions were implemented, and attending meetings where PERs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the Corrective Action Program (CAP) at an appropriate threshold.
The inspectors reviewed a sample of PERs and Service Requests (SRs) selected from the applicant's CAP for 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 that 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 alternative issue tracking systems that were sampled included TVA Over, Short, Damaged, and Discrepant items (OSDDs), Test Deficiency Notices (TDNs), and Quality Control (QC) Rejects. These systems were defined as corrective Work Processes approved to track/implement correction, according to TVA's CAP procedure (NC-PP-3, Revision 15). The inspectors reviewed applicable portions of TVA's and Bechtel'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. The inspectors interviewed TVA and the major contractor's (Bechtel) employee concern representatives, reviewed a sample of PERs referred to employee concerns and PERs initiated as a result of employee concerns. The inspectors also reviewed several anonymous PERs to determine if they had been adequately captured and addressed. 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 surveys and assessments of the employee concerns programs. The inspectors reviewed a sample of the applicant's management and quality assessments, audits, and trend reports to verify adverse results were properly evaluated and dispositioned within 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.
The inspectors reviewed the status of actions taken to address multiple problems involving loose bolts and parts. Previous inspection of some interim actions was documented in Report 05000391/2012610 (ADAMS ACCESSION NUMBER ML13035A201), Section Q.1.1. During the previous inspection untimely corrective action was noted, in that, actions to address potential wrongdoing had not been initiated and the extent of condition (EOC) review was not yet developed. The inspectors reviewed the status of corrective actions identified in the two primary PERs associated with this issue (PER 549197 concerning loose flex conduit and PER 584243 which documented a trend of issues involving loose bolts and parts). In addition, the inspectors reviewed a sample of PERs with similar issues identified since the original PERs were documented.
Specific PERs and other documents reviewed are listed in the attachment.
b. Observations and Findings
(i)
Introduction:
The inspectors identified a Unresolved Item (URI) associated with the quality of the piping alignment installation process for numerous components across several safety-related systems. In addition, the inspectors questioned the adequacy and implementation of the procedures associated with piping alignment for static and rotating safety-related equipment.
Description:
The inspectors reviewed a SR and 6 PERs, written between March of 2012 and April of 2013, associated with piping alignment issues. The inspectors noted that the issues identified were generally related to safety-related heat exchangers that had been refurbished during construction. The applicant identified misalignments that were not in accordance with the alignment procedure tolerances between the heat exchanger shell flange and the existing pipe flange. In addition, the inspectors reviewed PER 528852, "Piping misalignment is a major cause of pump and seal reliability problems."
The PER identified that the construction personnel assigned to align rotating equipment were not following the requirements of the procedures with regards to alignment tolerances. The PER details identified an issue with construction personnel that were potentially transmitting stresses to the pump through the misaligned pipe to pump flange.
The PER details identified three safety-related pumps, the turbine driven auxiliary feed water pump, and the two containment spray pumps, as having potential misalignment issues. The PER Corrective Action Plan initiated walkdowns of the safety-related pumps and identified an additional issue with the misalignment of the two safety injection pumps. The majority of the safety related pumps were removed, refurbished, and reinstalled during construction. During the reinstallation of the piping to the pumps the misalignment issues were identified.
The applicant initiated WOs to investigate the pump alignment issues and closed the PER. Approximately three months after the implementation of the corrective actions for PER 528852 to investigate the pump alignment issues, additional piping alignment process issues were observed by the inspectors. The inspectors identified that the total population of safety related pumps that had misalignment issues had increased from the five, noted in PER 528852, to eleven safety-related pumps which included the addition of the two charging pumps, two motor driven auxiliary feed water pumps, and the two thermal barrier booster pumps. During field observations of the piping alignment for the pumps, the inspectors noted several discrepancies with the adequacy of the procedures governing the pump piping alignment which was noted by the applicant in the request for information (RFI) No. 412, 4/15/2013, and RFI 1410, 4/10/2013. In addition, during interviews with the applicant's engineering and construction personnel, the inspectors noted that the applicant considered the misalignment issues as being part of the construction process, and at the time of the inspection, the applicant had not completed an engineering evaluation of the historical or in process conditions related to the equipment piping misalignments.
The above observations indicated a potential weakness in the quality process for the static and rotating equipment piping alignment. The inspectors questioned the adequacy of the piping alignment procedures for both static and rotating equipment; and questioned if the corrective action program had properly identified and corrected the piping misalignment issues. The applicant created PER 719796 to address the URI.
Further review is needed to address the issue of concern as defined by NRC Manual Chapter 0612, "A well-defined observation or collection of observations that may have a bearing on safety which may warrant further inspection, screening, evaluation, or regulatory action," related to the equipment piping alignment. The following items will be reviewed to address the URI:
1. Evaluate the applicant's review of the adequacy of the piping alignment procedures to include static and rotating equipment 2. Inspect the interim actions put in place by the applicant 3. Review actions associated with PER 719796
4. Review/observe additional field work as necessary This unresolved item is identified as URI 05000391/2013613-01, Potential Inadequate Corrective Actions for Piping Misalignment.
In addition, the inspectors made the following observations as a result of their inspections:
(1) Effectiveness of Identifying, Evaluating, and Correcting Problems Identifying Problems The inspectors determined that, for the most part, the applicant was effective in identifying problems and entering them into the CAP. PERs normally provided complete and accurate characterization of the subject issues. Employees were encouraged by management to initiate PERs. However, the inspectors did identify some instances where the applicant was correcting issues outside of their CAP when a PER should have been developed. The URI in this report is one example of this. None of the issues identified by the inspectors resulted in more than minor considerations with the possible exception of the URI.
Evaluating Problems The inspectors attended several meetings throughout the week, including the PRC and the CCMRC. It was determined that the applicant had adequately prioritized issues entered into the CAP consistent with established procedures. Service requests that were being initiated and discussed during the meetings were being appropriately dispositioned. The threshold of closing items as SRs, closing items to a WO, and creating a PER when necessary was determined to be adequate. The inspectors did notice a few examples of PERs where documentation was lacking, however, appropriate corrective actions were being taken for each example.
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 commensurate with the safety significance of the issues.
Based on discussions with staff and PER reviews, the inspectors noted that corrective actions related to procedure changes, in some cases, were taking a long time to implement. The inspectors did not find any technical issues with delays of procedures changes, however, it was discussed with the applicant as something that could become an issue in the future. For the loose parts issues, the applicant appropriately initiated evaluation of potential wrongdoing and has considered EOC. The EOC for flex conduit resulted in an action to inspect 100% of those that are accessible. For those that are not accessible, an engineering evaluation was planned. In addition, PERs were being initiated for individual issues in this area.
Additional actions included craft training, procedural improvements, establishing a match mark process for marking components after these have been tightened, initiation of a process for enhanced field monitoring for tightness, and confirming that walkdown processes are in place to inspect these types of issues. The primary walkdown process for loose, damaged and missing parts had not yet begun and associated craft training had not been completed at the time of this inspection. Further NRC inspections are planned in this area. The applicant's current actions are considered acceptable and planned actions should identify and correct/evaluate other problems, if properly implemented.
(2) Use of Operating Experience The inspectors determined that the applicant's measures used to identify, evaluate and incorporate applicable industry and operating experience (I&OE) information into the corrective action program contained processes for including vendor recommendations and internally generated lessons learned. The I&OE information was collected, evaluated, and communicated to the affected internal stakeholders as specified in TVA and Bechtel procedures. The inspectors determined that appropriate corrective actions were developed and taken for the sample of I&OE problem evaluation reports reviewed for the Watts Bar Unit 2 Construction Completion Project.
(3) Safety Conscious Work Environment (SCWE)
The inspectors reviewed several anonymous PERs and PERs that either referred to the employee concerns program or PERs generated as a result of employee concerns. The inspectors also interviewed senior employee concerns coordinators from both TVA and Bechtel. The inspectors determined that TVA's and Bechtel's employee concern programs were adequate. The senior employee concerns coordinators expressed knowledge of the employee concerns program and the ability to raise safety related concerns through various available means. The inspectors noted that the employee concerns program staff provide several training sessions they provide employee concerns program information in newsletters, and they also walk around the site frequently, talk daily to staff, and attend several meetings to ensure that staff are aware of the employee concerns programs and know how to raise concerns if necessary. Also, there appeared to be strong management support for both employee concerns programs.
(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. The applicant continues to track and trend issues, run summary reports on the trend data, and present results to management in several meetings, such as the site status meeting, CCMRC, etc. Also, management showed support for this process and the inspectors noted that the corrective action backlog had been greatly reduced since the last PI&R inspection.
(5) Corrective Action Program Effectiveness As discussed above, in general, the applicant's CAP was effective and adequate. The inspectors did observe where some PERs were lacking detail. The inspectors also observed that in some cases it took too long to make procedure revisions. However, the inspectors did not find any significant technical issues with the CAP effectiveness, and none of the examples the inspectors observed resulted in more than minor considerations. Also, during the assessment period, inspectors identified examples where PERs were not initiated for issues involving work that was still in progress or that did not involve specific hardware issues. Although no significant problems were noted, this observation is indicative of a vulnerability that may preclude the applicant from entering issues into the corrective action program and addressing broader non-hardware issues that may warrant corrective actions such as procedure, training, or process deficiencies. The URI identified in this report is one example of this issue.
c. Conclusions
As documented above, the inspectors determined that implementation of the CAP for the Watts Bar Unit 2 construction completion project was generally adequate, with exceptions to the areas previously discussed. 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.
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. IV. OTHER ACTIVITES OA.1.1 (Closed) Non-Cited Violation (NCV) 05000391/2011604-02: Failure to Maintain Adequate Design Specifications
a. Inspection Scope
Background: This issue involved the inappropriate use of Type 410 stainless steel for check valve internal parts highlighted in NRC Bulletin 89-02. This issue was documented in PER 356559. The applicant failed to preclude use of this type material in the design specifications. Inspection Activities: The inspectors reviewed the applicant's corrective action documented in PER 356559 to determine if the applicant appropriately resolved the concern in a timely manner. The applicant's actions included correction of the specifications and conducting an extent of condition review of check valves to confirm the wrong material was not used. Further NRC inspections later identified that additional documents needed correction which was documented as NCV 05000391/2012608-02 (ADAMS Accession Number ML12319A368), Failure to Take Adequate Corrective Action Associated with NCV 391/2011604-02 (ADAMS Accession Number ML12167A212). The applicant's actions for this problem included correction of the additional documents to preclude use of the wrong material. These actions were documented in PERs 605338 and 686961. The inspectors reviewed the applicant's actions and confirmed these were completed.
b. Observations and Findings
No findings of significance were identified. The applicant has taken appropriate corrective actions to address both NCVs.
c. Conclusions
Based on the activities reviewed, the inspectors concluded that the NCV can be closed.
V. Management Meetings X.1 Exit Meeting Summary On April 26, 2013, the inspectors presented the inspection results to Mr. Zeringue and other members of his staff. Proprietary information reviewed during the inspection was returned and no proprietary information was included in this inspection report.