IR 05000390/2015613
| ML15142A663 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 05/22/2015 |
| From: | Haag R C NRC/RGN-II/DCP/CPB3 |
| To: | Skaggs M D Tennessee Valley Authority |
| References | |
| IR 2015613 | |
| Download: ML15142A663 (21) | |
Text
May 22, 2015
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 05000391/2015613
Dear Mr. Skaggs:
On April 10, 2015, 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 10, 2015, 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 05000391/2015613 w/Attachment
cc w/encl: (See next page)
SUMMARY
Watts Bar Nuclear Plant, Unit
NRC Inspection Report 05000391/2015613 This inspection assessed implementation of the corrective action program (CAP) for the Watts Bar Unit construction completion project and ongoing CAP transitional activities to merge Unit into the Watts Bar site wide CAP. 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 determined that adequate measures have been established to evaluate and incorporate applicable operating experience into the CAP. [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]
- The inspectors determined that TVA and Bechtel have established an acceptable transition process that will integrate the Unit CAP into the CAP that Unit is under. [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 Status of PERs Issued in Response to Previous NRC Unresolved Items and Violations ........................................................................................................................
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 (CAQs) during the period since the previous problem identification and resolution inspection in April 2014. This was accomplished by reviewing selected problem evaluation reports (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 issues 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 CAQs. This review targeted verification of appropriate characterization and closure of issues managed outside the CAP. The alternative issue tracking systems that were sampled included Test Deficiency Notices (TDNs), Quality Control (QC) Rejects, and Over/Short/Damaged/and Discrepant (OSD&D) receipt inspection items. These systems were defined as corrective Work Processes approved to track/implement correction, according to TVA's CAP procedure (NC-PP-3, Revision 16). The inspectors reviewed the current CAP procedures to assess the adequacy of the CAP instructions for the identification, evaluation, and corrective action of CAQs. The inspectors assessed the process utilized to screen PERs for applicability to Unit 1. It was identified that designated staff from Unit 1 routinely reviewed all PERs to determine applicability of PERs and risk significance. For PERs that were determined to have impact on Unit 1, a separate PER was created under the CAP program for Unit 1 and all associated procedures such as root cause guidance and trend guidance would be utilized to resolve the issue. 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 CAQs.
The inspectors reviewed the plans to transition the Unit 2 CAP into the TVA Nuclear Power Group (NPG) CAP that is currently in place for Watts Bar Unit 1. The inspectors interviewed staff from both Unit 1 and Unit 2 who were directly involved in developing these transition plans. The inspectors also reviewed relevant procedures, discussed staffing levels, and required training to fully support a dual-unit Watts Bar CAP. The inspectors reviewed TVA's and the major contractor's (Bechtel) programs for resolving employee concerns. The inspectors interviewed TVA's and Bechtel's employee concerns representatives, reviewed a sample of PERs related 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 CAP. The inspectors reviewed the revision history for CAP 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 PERs and other documents reviewed are listed in the attachment.
b. Observations and Findings
No findings were identified.
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. The inspectors' independent review did not identify any significant adverse conditions which were not in the CAP for resolution. The use of trending at the site was comprehensive and effective in identifying areas for improvement.
Evaluating Problems Through the attendance of CAP meetings, including the PRC and CCMRC, the inspectors determined that the applicant adequately prioritized issues that were entered into the CAP. Service requests that were discussed during the meetings were appropriately dispositioned.The inspectors determined that the threshold for closing items as SRs, closing items to a WO, and creating a PER when necessary were determined to be adequate. The inspectors observed a few 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. The inspectors did not identify any technical issues associated with delays the inspectors noted for some procedure changes and revisions.
(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 CAP 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 implemented 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 and construction workers out in the field for 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 construction workers that were interviewed were also knowledgeable of the employee concerns program and were comfortable raising nuclear safety concerns. 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 is aware of the employee concerns programs and know how to raise concerns if necessary.
(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 CAP. These program assessments concluded that overall, the CAP 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. The inspectors reviewed the implementation of trending for adverse conditions identified in PERs, Service Requests, and Test Deficiency Notices. The review was performed to determine whether reported information provided an assessment of the health of the Corrective Action Program, and if the information compared the program performance against the program metrics. The inspectors determined that the trends showed that CAQs were being identified, and were being evaluated and dispositioned in a timely manner. No excessive backlogs or adverse trends were depicted.
(5) Corrective Action Program Effectiveness The inspectors did observe where some PERs were lacking details which required additional questioning by the inspectors to fully understand how the PERs were dispositioned. The inspectors determined that the applicant has maintained implementation of the CAP at an effective level since the last NRC Problem Identification and Resolution inspection (April 2014).
(6) Corrective Action Program Transition Plans Based on interviews and procedure reviews, the inspectors determined the transition of the Unit 2 CAP to the NPG CAP and associated closure activities are expected to start when hot functional testing is finished and will be completed before Unit 2 fuel load. In preparation for the transition, the licensee plans to evaluate all open Unit 2 CAP items for closure or initiation of a new item within the NPG CAP. This evaluation will include all open SRs and PERs, Watts Bar Integrated Task and Equipment List (WITEL) open items, and corrective work processes other than PERs for some non-significant CAQs.
These processes would include WOs, FCRs, QC rejects, and TDNs. The applicant stated as Unit 2 testing activities increase, there will be a greater potential for activities to impact both units. If needed, a joint Corrective Action Review Board (CARB)/CCMRC may be established.
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. 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 Status of PERs Issued in Response to Previous NRC Unresolved Items and Violations
a. Inspection Scope
The inspectors evaluated corrective action PERs issued in response to previously identified NRC unresolved items and violations to determine whether the adverse condition identified by the inspectors had been addressed, evaluated, and dispositioned commensurate with their safety significance. Responses to the following regulatory issues were reviewed: Unresolved Issue (URI) 87 06, "Review of Cable Separation of Non-Safety Related Cables in Close Proximity to Safety Related Cables in Electrical Panels." Non Cited Violation (NCV) 2014605-01, "Failure to Accomplish Installation in Accordance with Instructions, Procedures, or Drawings." NCV 2014608-02, "Inadequate Storage of Safety-Related Equipment."
NCV 2014608-03, "Failure to Prescribe Accurate Instructions in WO 115834758." In each case, the inspectors determined the PERs for the NRC issues had been closed and archived; however, corrective actions which are contained in WOs have not been implemented yet. The inspectors assessed whether the applicant had followed their CAP procedures for closing out PERs when the corrective action has not been completed.
b. Observations and Findings
No findings of significance were identified
c. Conclusions
Based on the regulatory issues reviewed above, the inspectors concluded that the proposed corrective actions were adequate to address the identified problems. The CAP process was followed for closing PERs with the corrective actions not yet performed. V. Management Meetings X.1 Exit Meeting Summary On April 10, 2015, 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.