IR 05000391/2011609
| ML11350A229 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 12/16/2011 |
| From: | Haag R NRC/RGN-II/DCP/CPB3 |
| To: | Skaggs M Tennessee Valley Authority |
| Haag R | |
| References | |
| IR-11-609 | |
| Download: ML11350A229 (47) | |
Text
December 16, 2011
SUBJECT:
WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED INSPECTION REPORT 05000391/2011609
Dear Mr. Skaggs:
On November 19, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of construction activities at your Watts Bar Unit 2 reactor facility. The enclosed integrated inspection report documents the inspection results, which were discussed on December 2, 2011, with Mr. David Stinson and other members of your staff.
This inspection examined activities conducted under your Unit 2 construction permit as they relate to safety and compliance with the Commissions rules and regulations, with the conditions of your construction permit, and with fulfillment of Unit 2 regulatory framework commitments.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, the enclosed report documents one NRC-identified finding which was determined to involve a violation of NRC requirements. However, because this finding was a Severity Level IV violation and was entered into your corrective action program, the NRC is treating it as a non-cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the non-cited violation in the enclosed report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTENTION: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at the Watts Bar Unit 2 Nuclear Plant.In accordance with 10 CFR 2.390 of the NRCs 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 NRCs 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).
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257
Should you have questions concerning this letter, please contact us.
Sincerely,
/RA by David Gamberoni Acting For/
Robert C. Haag, Chief
Construction Projects Branch 3
Division of Construction Projects
Docket No. 50-391 Construction Permit No: CPPR-92
Enclosure:
Inspection Report 05000391/2011609 w/Attachment
REGION II==
Docket No.:
50-391
Construction Permit No.:
CPPR-92
Report No.:
Applicant:
Tennessee Valley Authority (TVA)
Facility:
Watts Bar Nuclear Plant, Unit 2
Location:
1260 Nuclear Plant Rd
Spring City TN 37381
Dates:
October 2 - November 19, 2011
Inspectors:
T. Nazario, Senior Resident Inspector, Construction Projects Branch (CPB) 3, Division of Construction Projects (DCP)
Region II (RII)
W. Lewis, Resident Inspector, CPB3, DCP, RII C. Fong, Resident Inspector, CPB3, DCP, RII J. Lizardi, Resident Inspector, CPB3, DCP, RII C. Huffman, Project Inspector, CPB4, DCP, RII M. Speck, Senior Emergency Preparedness Inspector, Plant Support Branch 1, Division of Reactor Safety, RII, Sections OA.1.2, OA.1.9, and OA.1.10 J. Seat, Construction Inspector, Construction Inspection Branch 2, Division of Construction Inspection, RII, Section OA.1.1
Approved by:
Robert C. Haag, Chief
Construction Projects Branch 3
Division of Construction Projects
EXECUTIVE SUMMARY
Watts Bar Nuclear Plant, Unit 2
This integrated inspection included aspects of engineering and construction activities performed by TVA associated with the Watts Bar Nuclear (WBN) Plant Unit 2 construction project. This report covered a seven-week period of inspections in the areas of quality assurance, identification and resolution of construction problems, construction activities, and follow-up of other activities. The inspection program for Unit 2 construction activities is described in NRC Inspection Manual Chapter 2517. Information regarding the WBN Unit 2 Construction Project and NRC inspections can be found at http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html.
Inspection Results
- A Severity Level (SL) IV NCV of 10 CFR 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, was identified by the inspectors for failure to perform layup and preventative maintenance (LUPM) activities on the 2A-A and 2B-B containment spray pumps in accordance with site procedures. (Section C.1.6)
- The inspectors concluded that concerns pertaining to several open items, including Temporary Instructions (TIs) and construction deficiency reports (CDRs), have been appropriately addressed for WBN Unit 2. These items are closed.
- Other areas inspected were adequate with no findings of significance identified. These areas included various Unit 2 Corrective Action Programs (CAPs)/Special Programs (SPs); electrical systems and components; mechanical systems and components; fire protection; nuclear welding; nondestructive examination (NDE), commercial grade dedication activities; and refurbishment.
Table of Contents I. QUALITY ASSURANCE (QA) PROGRAM......................................................................... 4 Q.1 QA Oversight Activities................................................................................................. 4 Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure (IP) 35007).......................................................................................................... 4 Q.1.2 Safety Conscious Work Environment (IP 35007)................................................. 5 II.
MANAGEMENT OVERSIGHT AND CONTROLS............................................................ 5 C.1 Construction Activities.................................................................................................. 5 C.1.1 Unit 1 and Unit 2 Construction Activity Interface Controls.................................... 5 C.1.2 Electrical Components - Work Observation and Construction Refurbishment Process (IPs 51053 and 37002).......................................................................... 6 C.1.3 Pipe Support and Restraint Systems (IP 50090, 35020 and TI 2512/023)........... 7 C.1.4 Piping - Work Observation (IPs 49063 and 37002)........................................... 11 C.1.5 Electrical Cable - Work Observation (IPs 51063 and 37002)............................ 12 C.1.6 Mechanical Components - Work Observation (IP 50073).................................. 13 C.1.7 Coatings (IP 37002)........................................................................................... 15 C.1.8 (Closed) Concrete Expansion Anchors (IP 46071 and TI 2512/023).................. 16 T.1 Training and Qualification of Plant Personnel........................................................... 18 T.1.1 Engineering Organization Training (TI 2512/022).............................................. 18 III. OPERATIONAL READINESS ACTIVITIES................................................................... 18 F.1 Fire Protection.............................................................................................................. 18 F.1.1 Fire Protection (IP 64051).................................................................................. 18 IV. OTHER ACTIVITIES...................................................................................................... 19 OA.1.1 (Discussed) Construction Deficiency Report (CDR) 391/85-26: Failure of Coatings on Containment Vessel Interior (IP 37002)......................................... 19 OA.1.2 (Discussed) Emergency Preparedness Confirmatory Item #41 (IP 71114.01)... 20 OA.1.3 (Closed) Browns Ferry Lessons Learned (IP 35007)......................................... 22 OA.1.4 (Closed) NCV 0500391/2011604-01, Failure to Correct a Nonconformance...... 23 OA.1.5 (Closed) NCV 05000391/2010603-05: Inadequate Corrective Actions for Non-Conforming Safety-Related Concrete................................................................ 24 OA.1.6 (Closed) NCV 2010603-04: Undersized Pipe Support Welds............................ 24 OA.1.7 (Closed) Unresolved Item (URI) 391/87-13-02: Supports Installed on Non-Load-Bearing Wall...................................................................................................... 25 OA.1.8 (Closed) Safety-Related Piping - QA Review (IP 49061)................................... 25 OA.1.9 (Closed) Emergency Preparedness Confirmatory Item #39 (IP 71114.01)......... 28 OA.1.10 (Closed) Emergency Preparedness Confirmatory Item #42 (IP 71114.01)......... 29 OA.1.11 (Closed) CDR 391/83-47: Lugs Welded to Spiral Welded Pipe (IP 50100)........ 31 V. MANAGEMENT MEETINGS............................................................................................ 31 X.1 Exit Meeting Summary...................................................................................... 31
REPORT DETAILS
Summary of Plant Status
During the inspection period covered by this report, TVA performed construction completion activities on safety-related systems and continued engineering design activities of the Watts Bar Nuclear (WBN) Plant, Unit 2.
I. QUALITY ASSURANCE (QA) PROGRAM
Q.1 QA Oversight Activities
Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure (IP)35007)
a. Inspection Scope
During this inspection period, the inspectors continued to review problem evaluation reports (PERs), as part of the applicants corrective action program to verify that issues being identified under the corrective action program were being properly identified, addressed, and resolved by the applicant. The inspectors also reviewed quality assurance (QA) surveillance reports to ensure conformance with quality requirements, as discussed in other sections of this report.
b. Observations and Findings
No findings of significance were identified. During both independent NRC reviews and observation of management review committee meetings of PERs, the inspectors noted examples where PERs lacked detail in both the description of the issues and the corrective actions.
Also, during the Piping Support and Anchor Bolt inspections discussed in sections C.1.3 and OA.1.3 of this report, the inspectors noted that an effectiveness review for PER 297689, Trend PER for QC reject rate, took approximately nine months (since December 2010) to complete. Meanwhile, issues similar to those discussed in the original PER continued to exist during that time period. The missed effectiveness review was self-identified by the applicant in PERs 431856 and PER 452524. The inspectors also observed that the apparent cause, craft not self-checking, in PER 297689 appeared to be inadequate in that after further inspection and interviews with the craft, the inspectors discovered that training and work instruction gaps may have led to the increased reject rates and non-conforming conditions since December of 2010. The applicant took immediate corrective action which included retraining of personnel and enhanced work instructions. Because the missed effectiveness review was self-identified and because the anchor bolt installation activities observed were considered work in progress, the inspectors noted this as an observation which was shared with the applicant and documented in PERs 454859 and 452512.
c. Conclusions
Observations were shared with the applicant regarding the level of detail in PER descriptions, timeliness of corrective actions, and a weakness in a cause evaluation.
With the exception of those PERs noted above, the inspectors found that generally the PERs and QA surveillances reviewed were properly identified, addressed, and resolved.
Q.1.2 Safety Conscious Work Environment (IP 35007)
a. Inspection Scope
The inspectors reviewed existing program requirements and recent safety-related concerns identified by the applicants and contractors employee concerns program (ECP). The inspectors verified that significant problems were documented under the corrective action program and were being properly identified, addressed, and resolved by TVA.
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
The inspectors did not identify any issues or concerns regarding the ability of the applicant to provide a safety-conscience work environment.
II. MANAGEMENT OVERSIGHT AND CONTROLS
C.1 Construction Activities
C.1.1 Unit 1 and Unit 2 Construction Activity Interface Controls
a. Inspection Scope
During the inspection period, the inspectors independently assessed applicant controls associated with Unit 2 construction work activities that were relied upon to prevent adverse impacts on Unit 1 operational safety. The inspectors attended routine Unit 1/Unit 2 interface meetings to assess the exchange and sharing of information between the two site organizations. Periodic construction and planning meetings were observed to assess the adequacy of the applicants efforts to identify those construction activities that could potentially impact the operating unit. This included the review of selected work activities that the applicant had screened as not affecting Unit 1 to verify the adequacy of that screening effort. Additionally, the inspectors independently assessed selected construction activities to verify that potential impacts on the operating unit had been identified and adequately characterized with appropriate management strategies planned for implementation. Furthermore, the inspectors performed independent walkdowns of selected construction work locations to verify controls that protect the operating unit provided an adequate level of protection and had been properly implemented.
Specific work activities observed included:
- Hydrostatic testing of portions of the component cooling water (CCS) system under the following work orders:
Work order (WO) 111617727, CCH Sys 70 WBN-2-PIPE-070-C Pressure Test 2-070-Hydro-B004 WO 111617876, CCH Sys 70 WBN-2-PIPE-070-C Pressure Test 2-070-Hydro-B005
Safety-related motor control center (MCC) bucket change-out under WO 112704132.
The inspectors also reviewed and inspected activities that the applicant had screened out as not affecting Unit 1. These included, but were not limited to, the following:
- Residual heat removal (RHR) 2A-A pump inlet strainer installation and flange repair under WO 112309656
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
Adequate management oversight and controls were in place to identify construction activities which could potentially impact the operating unit, and an adequate level of protection had been implemented.
C.1.2 Electrical Components - Work Observation and Construction Refurbishment Process (IPs 51053 and 37002)
a. Inspection Scope
The inspectors observed vendor (Qualtech) performed work activities associated with the construction refurbishment of safety-related motor control center retrofit replacement breakers under WO 112704132. In particular, the inspectors observed vendor onsite replacement of the defective transformers. Documents reviewed are listed in the attachment.
Specifically, the inspectors also observed the following activities:
- Storage, handling and protection; and
- Installation which included verification that tolerances/clearances were met; appropriate drawings and work procedures were available; and holdpoints were observed.
The following samples were inspected:
- 51053, 02.02.b, c, d, e - 1 sample
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
Field refurbishment of safety-related electrical components was performed per the approved refurbishment program and procedures. Vendor oversight was adequate for the activities observed.
C.1.3 Pipe Support and Restraint Systems (IP 50090, 35020 and TI 2512/023)
a. Inspection Scope
The purpose of IP 50090 was to confirm adequate installation of pipe supports and restraints through procedure reviews, observation of work, and record reviews. This IP includes review of QA and work procedures, installation records, nonconformance reports, personnel qualifications, audit reports, interviews with applicant personnel, and observation of work activities. Integrated Inspection Report (IIR) 05000391/2009602 (ML091210420), Attachment 2, documented reconstitution results and a review of all the previous NRC inspection reports to determine the status of partial completion of IP 50090 requirements. This reconstitution review concluded that inspection requirements for this IP were not fully met, because additional inspection efforts for IP Sections 2.03.b, 2.03.c, 2.03.d, 2.03.e, and 2.03.f were required. Specifically, the reconstitution recommended inspecting a number of samples representative to about 50 percent of the total required samples contained in Sections 02.03.b thru 02.03.f. All sections contained within this IP were recently inspected to ensure that the IP requirements were met and recent changes to programs or procedures for new work would not invalidate commitments and previous inspection efforts performed during initial construction stages.
The following table lists the associated inspection reports and the completion status for each IP section (a table listing specific supports inspected, and a list of documents reviewed are included in the Attachment):
IP Section Inspection Reports Description of inspection effort since construction resumed in 2008 (05000391/2011609)
Section 2.01, Review of QA Implementing Procedures Section 02.01 05000391/2009602 05000391/2009603 05000391/2011607
- Reviewed a sample of procedures for audits, assessments, and surveillances
- Reviewed the existing auditor qualification procedures, audit reports, and organizational charts to ensure that auditors did not have direct responsibility in the areas being audited.
- Reviewed a sample of design and procurement documents to ensure that these technical requirements were appropriately implemented.
- Reviewed a sample of design and field change procedures applicable to pipe support and restraint systems
- Reviewed procedures and verified that provisions had been established to ensure that quality requirements were met. These included installation procedures, datasheets, and corrective action program procedures. In addition, IIR 05000391/2009602, 3 and IIR 05000391/2011611 documented a review of QA program documents and the corrective action program, respectively.
- Reviewed craft and inspection personnel qualification and training requirements included in QA procedures. In addition, IIR 05000391/2010603 documented a review of welding and welder qualification procedures.
Section 2.02, Review of Work Procedures Section 02.02 05000391/2009602 05000391/2009603 05000391/2009604 05000391/2010603 05000391/2011604 05000391/2011607
Reviewed a sample of construction documents that were produced as part of the construction process of installing three pipe supports. Specific design inputs, design changes, drawings, calculations, and implemented procedures pertaining to pipe supports and restraints were among the documents reviewed to ensure they complied with approved drawings and specifications.
Field Check-lists and procurement documents were also reviewed to ensure pre-installation and in-process inspections were performed accordingly.
Section 2.03, Observation of Work and Work Activities Section 02.03.a 05000391/2010603 05000391/2010604 05000391/2010605 05000391/2011605 05000391/2011607 Recent inspection efforts documented at least ten samples of interviews related to fixed pipe supports; however, during these recent inspection efforts no personnel engaged in the installation and testing of dynamic supports were interviewed. Installation of modified or new dynamic supports had not yet been completed.
This section will remain open for future inspection.
Section 02.03.b 05000391/2010603 05000391/2010605 05000391/2011603 05000391/2011604 05000391/2011605 05000391/2011607 05000391/2011608 Recent inspection efforts documented additional inspections of at least fifteen pipe support systems and portions of the installation and testing of concrete anchor bolts for fifteen component support elements. These recent inspection efforts were sufficient to satisfy the minimum original sampling requirements from this IP section.
Section 02.03.c 05000391/2011603 Recent inspection efforts documented additional inspections of at least two dynamic supports. These recent inspection efforts were not sufficient to satisfy the minimum original sampling requirements from this IP section. This section will remain open for future inspection, because sufficient samples have not been inspected due to remaining work involving installation of modified or new dynamic supports.
Section 02.03.d 05000391/2010603 05000391/2011603 05000391/2011604 05000391/2011605 05000391/2011607 Recent inspection efforts documented additional inspections of at least eighteen installed spring hanger assemblies, ninety-three installed pipe support systems of different sizes, and twenty-five small-bore or instrumentation line supports. These recent inspection efforts were sufficient to satisfy the minimum original sampling requirements for this IP section.
Section 02.03.e 05000391/2009603 05000391/2009604 05000391/2011603 05000391/2011604 05000391/2011605 05000391/2011607
During this inspection, component and multiple pipe supports previously accepted by quality control (QC) were sampled to verify their compliance with NRC requirements and applicant commitments. The inspectors conducted walkdowns of several installed safety-related pipe supports. Specifically, the inspectors performed a visual inspection to verify adequate support clearances and installation, and the absence of deformation and corrosion. Independent measurements were also performed to determine whether the installed configuration of pipe supports was consistent with final as-built drawings, and weld surfaces met the applicable codes and standards. Recent inspection efforts documented additional inspections on at least nine components and one multiple pipe support. Additionally, during this inspection, eight components and five multiple pipe supports were examined. These recent inspection efforts were sufficient to satisfy the minimum original sampling requirements from this IP section.
Section 02.03.f 05000391/2009602 05000391/2009603 05000391/2009604 05000391/2010603 05000391/2011603 05000391/2011604 05000391/2011605 05000391/2011607 Recent inspection efforts documented additional inspections of at least 122 as-built/final design pipe supports and 200 pipe anchor locations. These recent inspection efforts were sufficient to satisfy the minimum original sampling requirements from this IP section.
Section 2.04, Review of Records Section 02.04.a 05000391/2009603 05000391/2009604
-Reviewed records and documentation associated with the installation of three fixed pipe supports to determine the following:
- The type and classification of pipe support or restraints complied with appropriate drawings and specifications
- The location, spacing and critical clearances met the applicants specifications and was verified by QA/QC inspection
- The required scope of QA/QC was met
- The weld identification/location conformed to the respective weld card, drawing, work order or other welding documentation
- The welding material used corresponded to the material specified on the work order
- Welders were qualified to the welding procedures used and welding procedures were in accordance with code requirements
Recent inspection efforts documented additional inspections of at least thirty fixed pipe supports; however, these recent inspection efforts were not sufficient to satisfy the minimum original sampling requirements for dynamic supports. This section will remain open for future inspection, because sufficient samples have not been inspected due to remaining work involving installation of modified or new dynamic supports.
Section 02.04.b 05000391/2011608
Reviewed three problem evaluation reports (PERs) associated with pipe supports and restraints to determine the following:
- The records adequately document current status of nonconformances and deviations.
- The records are legible, complete, and indicate that reports are promptly reviewed by qualified personnel for evaluation and disposition.
- The records are routinely being processed through established channels for resolution of the immediate problem as well as for generic implications.
- The records are being properly identified, stored, and can be retrieved in a reasonable time.
- Nonconformance reports include the status of corrective action or resolution.
- Resolution of nonconformances is appropriate and demonstrates good engineering practice.
IIR 05000391/2011611 documented a review of the corrective action program. Inspectors reviewed PERs in all areas, including pipe supports, as part of their routine review of the corrective action program as documented in previous inspection reports.
Additional inspection efforts will be performed in this area to evaluate the resolution of recently identified non-conformances including those for dynamic supports.
Section 02.04.c 05000391/2011605
Twenty-one qualification and training records of engineering, craft, and inspection personnel (four engineering, three craft, two inspection, and ten audit personnel) from TVA, Bechtel, and subcontractors performing activities associated with pipe support and restraint installation work were reviewed to determine if these persons were qualified to conduct the work they were performing.
Section 02.04.d
During this inspection, three audit reports, five surveillance reports, one assessment report, and two quality assurance oversight reports relevant to the installation of pipe supports and restraints were reviewed to ensure that audits reported sufficient detail, were performed in the required functional areas, and were performed in accordance with the schedule and stated requirements.
From the audit reports, three PERs were reviewed and compared to the audit report findings that referenced them to determine if the audit findings were reported in sufficient detail to permit a meaningful assessment by those responsible for corrective action, final disposition, and trending. Corrective actions were completed for the PERs, and they were reviewed to determine that proper follow-up actions were taken.
The following samples were inspected during this inspection period:
- IP 50090 Section 02.01 - 1 sample
- IP 50090 Section 02.02 - 4 samples
- IP 50090 Section 02.03.e - 13 samples
- IP 50090 Section 02.04.a - 3 samples
- IP 50090 Section 02.04.b - 3 samples
- IP 50090 Section 02.04.c - 21 samples
- IP 50090 Section 02.04.d - 11 samples
- IP 35020 Section 02.01 - 1 sample
b. Observations and Findings
No findings of significance were identified.
The following table summarizes the completion status for each IP section:
IP Section Completion Status Section 02.01 Closed Section 02.02 Closed Section 02.03.a Open This section will remain open for further inspection. The inspectors were not able to interview applicant personnel engaged in the installation of hydraulic units, because installation of modified or new dynamic supports had not yet been completed.
Section 02.03.b Closed Section 02.03.c Open This section will remain open for further inspection. The minimum required samples were not met, because installation of modified or new dynamic supports had not yet been completed.
Section 02.03.d Closed Section 02.03.e Closed Section 02.03.f Closed Section 02.04.a Open This section will remain open for further inspection. The minimum required samples were not met, because installation of modified or new dynamic supports had not yet been completed.
Section 02.04.b Open This section will remain open for further inspection. Additional inspection efforts will be performed on this area to evaluate the resolution of recent identified non-conformances, including those associated with dynamic pipe supports.
Section 02.04.c Closed Section 02.04.d Closed
c. Conclusions
The procedures and records reviewed during this inspection period, associated with pipe support and restraint systems were found to conform to the applicable regulatory requirements. The requirements of this IP were not fully met for several IP sections; however the majority of the sections from this IP were considered to be complete. This determination was made based on initial construction inspections and recent inspection efforts for new work; therefore, for those sections that are not complete additional inspections will be performed and these sections will remain open until the sampling requirements are met. In addition, if major changes to the applicants instructions and procedures are identified through observation of future work activities associated with pipe support and restraint systems; the inspectors will inspect those as necessary to satisfy the requirements in this procedure.
C.1.4 Piping - Work Observation (IPs 49063 and 37002)
a. Inspection Scope
The inspectors observed work activities associated with the construction refurbishment and acceptance of safety-related piping systems and passive components within the component cooling water (CCS) system and residual heat removal (RHR) system. The inspectors reviewed work instructions and procedures to verify that they identified requirements and provisions for ensuring that the material condition of accessible portions of piping systems was evaluated and documented prior to final assembly of associated components. The inspectors also reviewed actions associated with Information Notice 85-96, Temporary strainers left installed in pump suction piping and observed the existence of a physical tab that protruded from the flanged fitting to identify its presence. The inspectors also reviewed personnel qualifications to verify that they were qualified for the roles they performed, that procedures detailed necessary actions and were followed by the craft. The inspectors also reviewed corrective action documents to verify that work activities promptly identified any failures, malfunctions, deficiencies, deviations, defective materials and equipment, and non-conformances in safety or quality-related structures, systems, or components (SSCs), and that material identification and control measures were in place and appropriately implemented.
Documents reviewed are listed in the attachment.
The following areas were inspected:
- Hydrostatic testing of Unit 2 portions of the CCS system
The following samples were inspected:
- IP 49063 Section 02.02 - 2 samples
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
Hydrostatic testing was performed per the associated WO and test package instructions and adequate controls were in place to support an adequate repair of the flange seating face while protecting the pipe surface and internals. With respect to pump inlet strainers, the applicant has adequately implemented controls to ensure that temporary construction devices do not affect operational activities.
C.1.5 Electrical Cable - Work Observation (IPs 51063 and 37002)
a. Inspection Scope
The inspectors assessed whether activities relative to safety-related electric cable systems were controlled and accomplished in accordance with NRC requirements, safety analysis report commitments, and applicant procedures. This was accomplished by inspecting supervision, independent evaluation of work performance, work in progress, and completed work. The inspectors reviewed a portion of cable pull activities associated with WO10-951137-003; specifically, a replacement of pull-by cable, 2V4433A, to determine whether:
- Latest approved revisions were utilized
- Specifications were complete
- Cable tensions were within limits
- Conduit/raceway was acceptable for use
- Cable protection was adequate
- Segregation was maintained
- Cable identification was preserved
- Bending radius was maintained within limits
- Boundary conditions were specified and appropriate
- QC inspectors were present and performing their assigned tasks
- Installation and inspection activities were being documented during the activity
The following sample was inspected:
- IP 51063 2.02.c - 1 sample
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
The inspectors determined that adequate measures were in place to ensure the applicant was prepared for the cable pull/push and that procedures were adequate and followed during the pull/push operations, with appropriate QC oversight.
C.1.6 Mechanical Components - Work Observation (IP 50073)
a. Inspection Scope
The inspectors observed work in progress and reviewed documentation to determine whether activities affecting safety-related mechanical components were accomplished in accordance with NRC requirements and applicant commitments.
Specifically, the inspectors verified that work instructions and procedures identified requirements and provisions for ensuring adequate receipt inspection and proper location, placement, orientation, alignment, mounting, flow direction, tolerances, and expansion clearance for safety-related mechanical components. The inspectors verified that these instructions were followed during component receipt and installation and that appropriate QC hold points were observed. Additionally, the inspectors reviewed WOs and associated documentation to determine whether special requirements for long-term storage had been met. The following components were inspected:
- 2A-A containment spray pump
- 2B-B containment spray pump
- 2B-B containment spray pump motor
- 2B-B containment spray heat exchanger
- Unit 2 AFW pump turbine
The following samples were inspected:
- IP 50073 Section 02.02.a - 1 sample
- IP 50073 Section 02.02.c - 3 samples
- IP 50073 Section 02.03.d - 5 samples
b. Observations and Findings
The inspectors identified the following non-cited violation (NCV):
Introduction:
A Severity Level (SL) IV NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for failure to perform layup and preventative maintenance (LUPM) activities on the 2A-A and 2B-B containment spray pumps in accordance with site procedures.
Description:
On January 19, 2010, the applicant began on-site refurbishment of the 2A-A and 2B-B containment spray pumps. This work included disassembly and inspection of the pumps and subsequent cleaning or replacement of various piece parts according to their material condition. These refurbishment activities concluded on September 27, 2010, when both pumps were installed in their final locations.
During a review of the two WO packages for the refurbishment, the inspectors noted that the following LUPM activities were delineated by the vendor technical document (VTD)but were not listed as steps in either WO:
- Fill the pump bearing housing with rust inhibiting lubricating turbine oil
- Store the mechanical seal package separately after one year of pump layup
- Coat shaft sleeve and exposed portions of shaft with rust preventative
- Rotate pump shaft every three months to recoat bearings with lubricant
The inspectors also noted that the Bechtel procedure 25402-000-GFP-000-N1304, System/Component Layup, Rev. 1, states that vendor-recommended LUPM activities shall be performed unless justified by an engineering evaluation. On October 5, 2011, the inspectors questioned the applicant as to whether the activities had been performed or whether such an evaluation had been completed.
On October 6, 2011, the applicant initiated PER 444516 to evaluate the conditions identified by the inspectors. The applicant concluded that neither the vendor-recommended LUPM activities nor an engineering evaluation had been performed for the Unit 2 containment spray pumps although the pumps had been installed and idle since September 27, 2010.
This finding was determined to be more than minor because it represented an improper work practice (failure to perform LUPM) that can impact safety by adversely affecting the material condition of the safety-related Unit 2 containment spray pumps. The finding is of low safety significance because the work practice was not indicative of a breakdown in the applicants QA program for construction; and was not the result of multiple and recurring significant deficiencies associated with a construction activity.
This finding is related to the work control component of the Human Performance cross-cutting area, as defined in Inspection Manual Chapter (IMC) 0310, because the applicant failed to incorporate actions to address the need for work groups to communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance H.3(b). Specifically, the applicants work control processes failed to address the need for construction personnel to promptly inform personnel responsible for LUPM when items subject to degradation (e.g., gaskets, bearings) are installed in a component. The lack of this prompt notification led to a condition where the containment spray pumps did not receive vendor-recommended maintenance for over one year.
Enforcement:
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings requires, in part, that activities affecting quality shall be accomplished in accordance with instructions, procedures, or drawings.
Section 6.19 of Bechtel Procedure 25402-000-GPP-0000-N1304, System / Component Layup, Rev.1, states that vendor-recommended LUPM activities shall be performed for items in long term storage unless justified by an engineering evaluation.
Contrary to the above, activities affecting quality were not performed in accordance with applicable instructions and procedures. Specifically, vendor-recommended LUPM activities for both Unit 2 containment spray pumps were not performed and an engineering evaluation to justify the lack of LUPM was not completed.
This finding was determined to be a SL IV violation using Section 6.5 of the Enforcement Policy. Because this was a SL IV violation and the examples supporting the violation were entered into the applicants corrective action program, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000391/2011609-01, Failure to Perform Layup and Preventative Maintenance on Safety-Related Components.
c. Conclusions
The inspected activities associated with LUPM activities were not performed in accordance with applicant procedures and NRC regulations as discussed above in NCV 05000391/2011609-01; however, other activities observed were performed in accordance with applicable procedures and regulations.
a. Inspection Scope
The inspectors observed work activities associated with the construction inspection and refurbishment of service level (CSL)-1 coating in upper containment inside the reactor building. The inspectors verified proper qualification, storage, handling, and control of safety-related coating materials/systems. The inspectors assessed whether personnel were adequately qualified for the roles they performed. The inspectors assessed whether existing CSL-1 coatings were inspected and repaired or maintained in accordance with applicable procedures and specifications. The inspectors also observed the preparation and application of coatings in CSL-1 areas associated with WO 112257658 to verify that they were adequately documented per the applicable procedures. Documents reviewed are listed in the attachment.
The following sample was inspected:
- IP 37002 Section 02.02.d - one sample
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
Inspected refurbishment activities associated with coatings in CSL-1 areas in containment were adequate.
C.1.8 (Closed) Concrete Expansion Anchors (IP 46071 and TI 2512/023)
a. Inspection Scope
The purpose of this IP was to confirm concrete expansion anchors were properly installed and that the applicants response was consistent with commitments made in response to Bulletin (BL) 79-02, Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts. The inspectors observed control of specific materials, control of specific processes and activities, and reviewed as-built installations. IIR 05000391/2009602 (ML091210420), Attachment 2, contained a review of all the previous NRC inspection reports to determine the status of completion of IP 46071 requirements.
This review (or reconstitution) concluded that inspection requirements for this IP had not been fully met, because additional inspection activities for IP Sections 02.02 and 02.03 were required. Specifically, the reconstitution recommended inspection of 172 samples for Section 02.02 and 100 samples for Section 02.03.
Section 2.01, Review of QA program, required a review to determine the adequacy of established QA procedures, plans, and instructions involving concrete expansion anchors as well as the applicants response to BL 79-02. Previous inspections results in this area were documented in inspection reports 05000391/2009602, 05000391/2009603, and 05000391/2011603
The inspectors reviewed NRC letter to TVA dated February 11, 2009 (ML090210107)which described the staffs review of TVAs description of the Hanger Analysis and Update Program (HAAUP). This letter acknowledged that the HAAUP would be implemented in a manner similar to Unit 1 and would incorporate corrective actions identified during the Unit 1 implementation of the HAAUP and response to BL 79-02.
The inspectors reviewed TVAs closure report for Bulletin 79-02 for Watts Bar Unit 1, which is described in a letter to the NRC dated August 21, 1985. This report was applicable to Unit 2 because it addresses anchor bolts that were acquired from common lots during the time construction was ongoing for both units.
The inspectors also reviewed NUREG-0847, Supplement 8, dated January 1992, and confirmed that NRC staff had approved the methodology discussed above and that the same methodology used on Unit 1 to address BL 79-02 was being followed for Unit 2.
Finally, the inspectors reviewed Bechtel procedure 25402-000-GPP-0000-N3212, Drilled-In Anchors and Core Drilling Operations, to ensure no significant changes were made since the initial review that would invalidate previous inspection results.
Section 2.02, Observation of Work, required, in general, direct observation of work performance, work in progress, and completed work, to determine whether concrete expansion anchor activities were accomplished in accordance with applicant commitments. The requirements of this IP section were partially completed and documented in IIR 0500039/2009602, which required a minimum sample of 172 anchor bolts.
Section 02.02.a of this IP addressed control of specific materials while Section 02.02.b addressed the control of specific processes or activities. To satisfy the requirements of the IP, the inspectors typically looked at both control of materials and control of processes during an inspection of a work activity; therefore, the intent of 02.02 was met when inspecting one or both of these attributes. In summary, eventhough the following recent inspection reports may only specify 02.02.a or 02.02.b or 02.02, the observation of ongoing work was accomplished and the intent of 02.02 was met for the overall control of materials and processes:
These recent inspection efforts documented inspections of at least 200 concrete anchor bolt installations which were sufficient to satisfy the minimum sampling requirements from this IP section.
Section 02.03, Review of As-Built Portions, required, in general, independent as-built verification and visual examination of at least 200 installed or quality-control-accepted concrete anchors of various bolt diameters. This requirement was to ensure that construction was consistent with NRC requirements and applicant commitments.
Recent inspection efforts documented additional inspections of at least 200 concrete anchors in the following inspection reports:
These recent inspection efforts were sufficient to satisfy the minimum original sampling requirements from this IP section.
b. Observations and Findings
No findings of significance were identified.
Below is a summary of each section of IP 46071:
Section 02.01-Closed Section 02.02 - Closed Section 02.03 - Closed
c. Conclusions
The procedures and records reviewed during this inspection period associated with concrete expansion anchors were found to conform to the applicable regulatory requirements. Based on initial construction inspections and recent inspection efforts, IP 46071 is considered closed; however, implementation, final review, and closure of actions for BL 79-02 will be reviewed once the applicant finalizes the HAAUP CAP closure report for Unit 2. In addition, if major changes to the applicants instructions and procedures are identified through observation of future work activities associated with concrete expansion anchors, the inspectors will inspect those as necessary to satisfy the requirements in this procedure
T.1 Training and Qualification of Plant Personnel
T.1.1 Engineering Organization Training (TI 2512/022)
a. Inspection Scope
The inspectors observed a classroom training session for engineering personnel that covered the walkdown, design, and drawing creation guidelines to be utilized in the installation of Thermo-Lag electrical raceway fire barriers (ERFBs). The training session was intended to be an introduction on the use of TVA contractors Field Manual.
Training was also provided for the application of TVA General Engineering Specification G-98, Installation, Modification and Maintenance of Electrical Raceway Fire Barrier Systems, Rev. 5, dated December 17, 1997. The training emphasized the requirements of Appendix 7.1, Special Requirements and Application of Thermo-Lag 330-1 One-Hour Rated Electrical Raceway Fire Barrier Systems. At the end of the training session the instructor administered a written exam which all attendees completed and passed.
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
TVAs program for training of contractor personnel associated with fire barrier systems was adequate.
III.
OPERATIONAL READINESS ACTIVITIES
F.1 Fire Protection
F.1.1 Fire Protection (IP 64051)
a. Inspection Scope
The inspectors observed hot work, control of flammable material, and control of ignition sources in both the Unit 2 and shared U1/U2 areas. The inspectors verified that TVA inspected the fire suppression devices per site procedural requirements at the prescribed intervals. The inspectors verified the availability of auxiliary equipment necessary to meet procedural guidance. Additionally, the inspectors interviewed the fire watches who were responsible for overseeing hot work activities occurring in the auxiliary building, valve vault room, and Unit 2 containment. The inspectors also interviewed continuous and roving fire watch personnel. The inspectors reviewed hot work procedures to verify their adequacy related to fire suppression during construction activities taking into account the impact on the operating unit and attended the hot work training course (TRN-32) that is required for fire watch personnel. Documents reviewed are listed in the attachment.
The inspectors observed the following hot work activities involving welding and/or grinding:
- WO 110805640, CCI EDCR 253622, Sys 062 2-RTV-062-0365A
- WO 111141416, CCM EDCR 52475C, Sys 062, WB2-2-HGR-062-AB
- WO 112212599, CCM EDCR 56966B, Sys 062, WBN-2-HGR-062-AB
The following samples were inspected:
- IP 64051 Sections 02.01 - 1 sample
- IP 64051 Sections 02.04 - 1 sample
- IP 64051 Sections 02.06 - 1 sample
- IP 64051 Sections 02.07 - 10 samples
- IP 64051 Sections 02.08 - 3 samples
b. Observations and Findings
No findings of significance were identified; however, the inspectors observed, through training attendance and field observations, a discrepancy in fire watch duty expectations.
Specifically, the training course TRN-32 instructed personnel that, if they are on fire watch, they should have no other job; however, procedure NPG-SPP-18.4.8, Control of Ignition Sources (Hot Work), does not prevent hot work personnel from performing other tasks as long as they are capable of providing continuous fire watch. PER 461395 was initiated to address this observation along with additional observations that the inspectors identified during hot work activities. Immediate corrective actions included a stand-down to reinforce the requirements and expectations for hot work activities.
c. Conclusion
The inspectors concluded that, overall, the level of fire protection provided was adequate for the current level of construction activities being performed. TVA implemented adequate fire protection measures and controls to support Unit 2 construction activities and minimize impact on Unit 1 operation activities.
IV.
OTHER ACTIVITIES
OA.1.1 (Discussed) Construction Deficiency Report (CDR) 391/85-26: Failure of Coatings on Containment Vessel Interior (IP 37002)
a. Inspection Scope
Background: In July 1985, the applicant notified the NRC of failing inorganic zinc primer coatings on the interior of the steel containment vessel. The deficient coatings were present from elevation 819 to 830, on the entire circumference of the vessel. The applicant submitted a closure report to the NRC on August 21, 1985 stating the apparent cause of the failure was improper application of a second coat of zinc primer. The applicant also stated that the deficient coatings were removed and replaced, and all individuals who applied protective coatings were recertified in order to prevent recurrence. This deficiency was originally identified in historical Nonconformance Report (NCR) WBN 6144.
Inspection Activities: The inspectors performed the following:
-
Reviewed PER 172633 which was issued to track required Unit 2 actions for historical NCR WBN 6144.
-
Reviewed PER 227383 which was issued to address numerous historic coatings issues inside containment, including those associated with NCR WBN 6144
-
Reviewed WO110921696, Visual Examination of the U2 Primary Containment Interior, which was issued to identify deficiencies associated with PER 227383
-
Reviewed the final report for Failure of Coating on Containment Vessel Interior-WBRD-50-391/85-26, dated August 21, 1985, to verify that corrective action documents adequately captured the original construction deficiency.
-
Reviewed General Engineering Specification G-55, Technical and Programmatic Requirements for the Protective Coating Program for TVA Nuclear Plants; TVA Watts Bar Nuclear Unit 2 Construction Completion Project Procedure 25402-000-GPP-000-N3222, Field Painting and Coating; and Watts Bar Nuclear Unit 0 Modification/Addition Instruction MAI-5.3, Protective Coatings; to verify they contained adequate protective coatings applicator certification requirements.
-
Reviewed calculation ALION-CAL-TVA-2739-03 Revision 4, Watts Bar Reactor Building GSI-191 Debris Generation Calculation, to verify that assumptions and conditions stated in the calculation enveloped the condition of the protective coatings.
b. Observations and Findings
No findings of significance were identified. Sufficient documentation was not available at the time of the inspection to verify the extent and adequacy of the repairs performed.
c. Conclusion
The inspectors determined that further inspection will be required to verify resolution of the original construction deficiency.
OA.1.2 (Discussed) Emergency Preparedness Confirmatory Item #41 (IP 71114.01)
a. Inspection Scope
Background: The confirmatory item discussed below is identified in NUREG-0847, Safety Evaluation Report Related to the Operation of Watts Bar Nuclear Plant, Unit 2, Supplemental Safety Evaluation Report No. 22, Section 13.3.2.9, Emergency Communications.
TVA committed to
- (1) update plant data displays as necessary to include Unit 2, and
- (2) to update dose assessment models to provide capabilities for assessing releases from both WBN units. The NRC staff will confirm the adequacy of these items prior to the issuance of the Unit 2 OL.
The scope of the present review is based on the Section 13.3, Emergency Preparedness, of the Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR [Light-Water Reactor] Edition, NUREG-0800. The SRP provides:
In general, if an application is for an additional reactor at an operating reactor site, and the application proposes to incorporate and extend elements of the existing emergency planning program to the new reactor (included by reference), those existing elements should be considered acceptable and adequate.
This protocol applies to this inspection in that the Watts Bar Radiological Emergency Plan (WBN REP) was written as a site-wide plan and that TVA proposed, and the Commission accepted, a regulatory framework in which TVA would align the Unit 1 and Unit 2 licensing and design basis to ensure design and operational fidelity between the two units. The adequacy of the WBN REP has been confirmed by the routine NRC inspection oversight, and TVAs performance in biennial exercises conducted since the licensing of Unit 1 in 1996.
This Confirmatory item was generated in response to an applicant response to a staff request for additional information regarding the capability of the WBN emergency response facilities (ERFs) to simultaneously handle an emergency event affecting both WBN Unit 1 and Unit 2 (e.g., events initiated by loss of power, earthquake, tornado, flooding, or hostile actions).
Inspection Activities: The inspector evaluated the status of the plant data display updates to include Unit 2.
b. Observations and Findings
No findings of significance were identified. The instrumentation displays in the MCR are specific to each unit and independent of each other. The data displays in the WBN ERFs are driven by the Plant Engineering Data System (PEDS), which serves as an interface to the plant data on the plants Integrated Computer System (ICS). The data is displayed on personal computers (PCs) through user-selectable menu options. As such, any PC can access data from Unit 1, Unit 2, or the simulator. The Technical Support Center (TSC) has several PCs that have access to the data, by menu and icon selection, necessary for the individual workstations and functional areas (i.e., emergency response officer (ERO) positions). In addition, there are wall mounted large LCD screens that clone the display on the individual attached PCs. A similar configuration exists in the Onsite Support Center (OSC) with fewer displays and PCs. ICS and PEDS displays are also available within the MCR.
The licensee EP staff demonstrated the PEDS data displays for Unit 2 in the TSC. All of the data screens available for Unit 1 were available for Unit 2 and were online and active. Critical Safety Function Status Tree display screens were also active. Not all planned parameters were active since many plant systems have not been turned over from construction to operations; however, as various plant systems are turned over from construction to operations, the parameters will become active. Some in-service parameters correctly showed inaccurate data as the associated plant system was not in service (e.g., RVLIS data was inaccurate because the reactor vessel is still dry). In the Unit 2 MCR, the unit supervisor demonstrated that he was using the data displays to monitor current plant system status (e.g., he was monitoring main condenser hotwell level trends in order to control levels due to system test water collecting in the hotwell).
Licensee personnel informed the inspectors that TVA is in the process of obtaining the commercially obtainable MIDAS' (Meteorological Information and Dose Assessment System) specifically configured for all of the TVA nuclear units. This system will replace the current system that was previously found to be acceptable to the NRC.
In addition to the communications capabilities observed at the WBN site, the inspectors observed the October 19, 2011, WBN Unit 1 exercise from the Central Emergency Control Center (CECC). This facility currently serves all TVA Nuclear sites and was previously found to be acceptable by the NRC. The CECC has seven display screens projected onto a large projection screen in the central CECC area. As with the configuration in the TSC and OSC, these screens are driven by individual PCs. These display screens are selectable as menu options on the associated PC and included PEDS, radiological assessment team and plant assessment team status summaries, a protective action plot, and selected WebEOC' pages. The majority of the PCs in the CECC had dual monitors allowing multiple displays. Although no Unit 2 screens were displayed during the exercise, the capability would have been available given the PEDS configuration.
c. Conclusions
Although all the planned parameters are not currently able to be displayed, the structure of the individual Unit 2 display screens, the number of active parameters displayed on the screens, and the fact that the Unit 2 MCR is currently using these displays, provides reasonable assurance that the data displays will be capable of adequately supporting an emergency response for Unit 2. However, this confirmatory item will remain open since Part 2 of this item, updated dose assessment models, is not yet available for review.
OA.1.3 (Closed) Browns Ferry Lessons Learned (IP 35007)
a. Inspection Scope
In 2002, TVA endeavored to restart its Browns Ferry Unit 1 under a five-year contract award to Bechtel. In 2007, the project culminated with the restart of Unit 1, a project endeavor and restart which presented several challenges related to construction and constructability. Some of these challenges resulted in lessons learned which were carried over to the Watts Bar project oversight.
The inspectors reviewed the set of issues which the applicant identified as having occurred at Browns Ferry and for which Watts Bar was likewise potentially vulnerable.
The inspectors assessed actions taken to address these issues for adequacy and overall effectiveness to date. The inspectors reviewed the underlying root and apparent cause analyses to determine whether they were of appropriate scope and detail. The inspectors sampled across the spectrum of required responses, whether programmatic, cultural, or technical to evaluate actions planned and taken. Documents reviewed are listed in the attachment.
b. Observations and Findings
No findings of significance were identified. The applicants choice to limit the scope of consideration to those issues which were categorized as level A or level B PERs (or only those requiring apparent or root causes) perhaps limited their perspective of issues of regulatory significance, as many findings identified as being of very low safety significance are routinely classified as level C PERs.
For example, had the applicant considered regulatory findings associated with Browns Ferry 1, lessons learned from NCV 05000259/2006-09-04 (T Drain on Limitorque Operator Has Been Plugged with Paint) may have led to enhanced painter training materials and could have prevented a similar issue at WB2 where a RHR 2B-B pump room cooler temperate switch was painted, resulting in its failure to calibrate properly.
c. Conclusions
Applicant actions, to the extent that they were initiated, appeared sufficient to address underlying programmatic, cultural, and technical challenges which occurred in conjunction with the licensees recovery of Browns Ferry Unit 1.
OA.1.4 (Closed) NCV 0500391/2011604-01, Failure to Correct a Nonconformance
a. Inspection Scope
The inspectors reviewed the corrective actions associated with NCV 05000391/2010604-01, Failure to Correct a Nonconformance, and documented in PER 364388. This issue involved the inappropriate closure of PER 229082, Anchor Bolt Spacing Violation, where the applicant did not address and correct the anchor bolt spacing violation identified in PER 229082. The inspectors performed the following actions:
- Reviewed immediate actions and discussed them, along with PER closure, with corrective action program coordinator and other applicable personnel
- Reviewed the engineering evaluation and reanalysis used to accept the spacing
- Reviewed impacted documents such as drawings and design change documents to verify that applicable changes were incorporated
Documents reviewed are listed in the attachment.
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
The inspectors determined that, based on the review of documentation and interviews with personnel, there is reasonable assurance that the issues associated with this NCV were adequately addressed to close this item. Based on the inspection of these items, NCV 0500391/2011604-01, Failure to Correct a Nonconformance, is closed.
OA.1.5 (Closed) NCV 05000391/2010603-05: Inadequate Corrective Actions for Non-Conforming Safety-Related Concrete
a. Inspection Scope
The inspectors reviewed the corrective actions associated with NCV 05000391/2010603-05, Inadequate Corrective Actions for Non-Conforming Safety-Related Concrete as documented by PER 237820. This issue involved the inappropriate closure of PER 238011, Concrete Mixing and Placement Violation, where the applicant did not appropriately evaluate the installed non-conforming concrete batch as part of the corrective actions stated in PER 230811. The inspectors performed the following actions:
- Discussed details of immediate actions taken with corrective action program coordinator
- Observed concrete rework and placement associated with WO 09-954333-011 as documented in IIR 05000391/2010604, Section C.1.5, Structural Concrete - Work Observation
- Reviewed the engineering evaluation of the concrete placement
- Reviewed associated documentation including QC datasheets documenting engineerings disposition to rework the area to verify that applicable requirements were met where the non-conforming concrete was placed
Documents reviewed are listed in the attachment.
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
The inspectors determined that, based on observation of rework activities, review of documentation, and interviews with personnel, there is reasonable assurance that the issues associated with this NCV have been adequately addressed. Therefore, NCV 05000391/2010603-05, Inadequate Corrective Actions for Non-Conforming Safety-Related Concrete, is closed.
OA.1.6 (Closed) NCV 2010603-04: Undersized Pipe Support Welds
a. Inspection Scope
The inspectors reviewed corrective actions associated with PERs 219205 and 308404.
These PERs addressed NCV 05000391/2010603-04, Undersized Pipe Support Welds, which involved an undersized weld on a safety-related pipe support. The inspectors reviewed the PER corrective actions to determine that the applicant adequately identified the apparent cause of the undersized weld and implemented corrective actions, including a revised training program, independent assessment of QC performance, and re-inspection of 1,173 welds that had been previously accepted by QC inspectors. The inspectors also reviewed a sample of the re-inspected welds to verify that the applicant had appropriately characterized them. Documents reviewed are listed in the attachment.
b. Observations and findings
No findings of significance were identified.
c. Conclusion
The inspectors determined that the issues associated with NCV 05000391/2010603-04 were effectively tracked in the applicants corrective action program and that the corrective actions implemented were adequate. Based on the inspection of these items, this NCV is closed.
OA.1.7 (Closed) Unresolved Item (URI) 391/87-13-02: Supports Installed on Non-Load-Bearing Wall
a. Inspection Scope
Background: In NRC Inspection Report Nos. 50-390/87-13 and 50-391/87-13, dated February 24, 1988, the NRC identified concerns with reinforcing steel spacing in relation to the loads being applied to the non-load bearing walls at the location of Charging Pump Room 2C for Unit 2. Hanger support connections were installed on these walls.
The concern was considered unresolved pending the applicants analysis, evaluation and corrective actions and was identified as URI 50-391/87-13-02. The applicants analysis and evaluation identified a worst case section of the non-load bearing walls by performing walk downs of these walls and reviewing design documents. The applicant performed an engineering evaluation of the worst case section to analyze the non-load bearing walls to determine if the walls were adequate for the loads being applied.
Documents reviewed are listed in the attachment.
Inspection Activities: The inspectors walked down a sample of the worst case section from the walkdown package used in the calculation. The inspectors performed the following review of the applicants analysis, evaluation to verify that corrective actions were implemented:
-
Reviewed the applicants open item closure report PER 178014 which was used to track this open item.
-
Inspected the walkdown package for the Concrete Feature Number 41N368-4/45,SW,AB to verify it was consistent with the information obtained in the field
b. Observation and Findings
No findings of significance were identified.
c. Conclusions
Based on these actions the inspectors determined that the applicant had resolved the original construction deficiency. This item is closed.
OA.1.8 (Closed) Safety-Related Piping - QA Review (IP 49061)
a. Inspection Scope
The purpose of this IP was to determine whether technical requirements associated with safety-related piping (outside the reactor coolant system pressure boundary) have been adequately addressed and established in the construction specification, drawings, and work procedures and whether these controls were adequate. IIR 05000391/2009602 (ML091210420), Attachment 3, documented some of these QA program reviews during a readiness inspection. In addition, inspectors performed applicable remaining portions of this IP to ensure that the applicant had adequate procedures in place.
The inspectors interviewed staff and reviewed related procedures to ensure that QA/QC requirements established by the NRC and SAR commitments for safety-related piping have been addressed. This inspection covered procedure review for the following aspects required for safety-related piping: purchase documents, material receipt, storage, handling, installation, field changes, and cleanliness. The applicants plans and schedules for audits were reviewed. Procedure requirements for appropriate training with respect to the assigned duties were also inspected.
Portions of this IP have been previously addressed through inspection samples credited in the following inspection reports including some where IP 49063, Safety-Related Piping Work Observation, was performed:
-
-
-
-
-
-
-
-
-
The intent of this inspection effort was to perform a comprehensive review of applicant procedures in addition to those previously performed such that this IP can be closed.
Section 2.01 of this IP requires the completion of IP 35100, which was completed and documented in IIR 05000391/2009602, Attachment 3.
Section 2.02 of this IP is used to determine if appropriate and adequate procedures are included or referenced in the QA manual to ensure that specific activities pertaining to safety related piping are controlled and performed according to NRC requirements and SAR commitments relating to safety-related piping.
The following table documents the procedures reviewed relating to the criteria for each subsection in Section 2.02.
Section Safety Related Piping Attribute Associated Procedures 2.02.a Purchase Documents NPG-SPP-04.1 NEDP-8 25402-PRO-0002 25402-000-GPP-0000-N3705 25402-000-GPP-0000-N6102 25402-3DP-G06G-00001 2.02.b Receiving Inspection NPG-SPP-04.2 25402-000-GPP-0000-N6104 2.02.c Storage and Issue NPG-SPP-04.3 NPG-SPP-04.4 25402-PRO-0007 25402-000-GPP-0000-N6204 2.02.d Handling NPG-SPP-04.3 2.02.e Installation N3M-868 25402-000-GPP-0000-N3503 25402-000-GPP-0000-N3504 25402-000-GPP-0000-N3506 25402-000-GPP-0000-N3701 25402-000-GPP-0000-N3702 2.02.f Design Changes 25402-3DP-G04-00062 25402-000-GPP-0000-N3105 2.02.g Cleanliness 25402-000-GPP-0000-N3505
Section 02.03 requires the review of the applicants plans and schedules to audit compliance with and effectiveness of the QA/QC requirements associated with safety-related piping, including: design, procurement, receipt/storage, installation, and testing.
The inspectors reviewed audit plans to determine whether the elements needed to satisfy this requirement were scheduled.
Section 02.04 requires determination of whether the applicant management has an established program for ensuring that all personnel involved in the activities mentioned in this IP are suitably proficient, skilled or otherwise qualified by experience or training to perform their assigned duties. The inspectors verified that the applicants training program exists to ensure compliance with the necessary requirements. Furthermore, the individual procedures which meet the requirements of Section 02.02 have explicit requirements for training or qualification necessary for individuals to carry out the respective tasks.
Section 02.05 requires, if deemed appropriate, completion of sections 02.01 and 02.02 for an expanded sample of onsite organizations having QA/QC responsibilities relative to safety-related piping. At this time the additional sampling of sections 02.01 and 02.02 are not required as the procedures and organizations sampled thus far are adequate.
However, should major changes occur to the procedures or responsible organizations then further inspection may be required.
Additional documents reviewed are listed in the Attachment.
b. Observation and Findings
No findings of significance were identified.
Below is a summary of each section of IP 49061:
Section 02.01-Closed Section 02.02 - Closed Section 02.03 - Closed Section 02.04 - Closed Section 02.05 - Closed
c. Conclusions
The inspectors determined that procedures and audit material reviewed associated with safety related piping were adequate and established within quality assurance requirements. Based on initial construction inspections and recent inspection efforts, a sufficient number of samples have been reviewed in order to consider IP 49061 closed.
However, if major changes to the applicants instructions or procedures are identified through observation of future work activities associated with safety-related piping, the inspectors will inspect those as necessary to satisfy the requirements in this procedure.
OA.1.9 (Closed) Emergency Preparedness Confirmatory Item #39 (IP 71114.01)
a. Inspection Scope
Background: The confirmatory item discussed below is identified in NUREG-0847, Safety Evaluation Report Related to the Operation of Watts Bar Nuclear Plant, Unit 2, Supplemental Safety Evaluation Report No. 22, Section 13.3.2.6, Emergency Communications.
The NRC staff will confirm the adequacy of communications capability to support dual unit operations prior to issuance of the Unit 2 OL
The scope of the present review is based on the Section 13.3, Emergency Preparedness, of the Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR [Light-Water Reactor] Edition, NUREG-0800. The SRP provides:
In general, if an application is for an additional reactor at an operating reactor site, and the application proposes to incorporate and extend elements of the existing emergency planning program to the new reactor (included by reference), those existing elements should be considered acceptable and adequate.
This protocol applies to this inspection in that the Watts Bar Radiological Emergency Plan (WBN REP) was written as a site-wide plan and that TVA proposed, and the Commission accepted, a regulatory framework in which TVA would align the Unit 1 and Unit 2 licensing and design basis to ensure design and operational fidelity between the two units. The adequacy of the WBN REP has been confirmed by the routine NRC inspection oversight, and TVAs performance in biennial exercises conducted since the licensing of Unit 1 in 1996.
Inspection Activities: The review of the WBN REP for Unit 2, and this inspection, focused on differences between the two units, and any dual-unit issues that would be created by the licensing of Unit 2. The inspectors toured the main control room (MCR),the TSC, and the OSC with licensee/applicant personnel with a focus on adequacy of communications capability provided for Unit 1 to support a Unit 2 response following startup.
b. Observations and Findings
No findings of significance were identified. For the MCR, Watts Bar has a combined control room with each units controls located at opposite ends of the MCR and a common shift manager station located between these two ends. The emergency response communication equipment is located at the shift managers station. As such, an emergency response for Unit 2 would use the same communication equipment as is currently used by Unit 1, and that were previously found to be acceptable by the NRC.
The TSC and OSC were observed to have the communications capabilities currently used by Unit 1 and that were previously found to be acceptable by the NRC. An emergency response for Unit 2 would use the same facilities and communication equipment as is currently used by Unit 1.
In addition to the communications capabilities observed at the WBN site, the inspectors observed the October 19, 2011, WBN Unit 1 exercise from the CECC. This facility currently serves all TVA Nuclear sites and was previously found to be acceptable by the NRC. In observing the exercise in the CECC the inspectors did not observe any situation that would suggest the current communications capabilities of the CECC could not adequately support an emergency response involving Unit 2.
c. Conclusions
In accordance with the protocol for this inspection, and based on the preceding discussion, the inspectors finds, with reasonable assurance, that the communications capability to support an emergency response at Unit 2 will be adequate. Accordingly, Confirmatory Item #39 can be closed. The communication capability associated with Item #39 will remain subject to routine NRC inspection oversight.
OA.1.10 (Closed) Emergency Preparedness Confirmatory Item #42 (IP 71114.01)
a. Inspection Scope
Background: The confirmatory item discussed below is identified in NUREG-0847, Safety Evaluation Report Related to the Operation of Watts Bar Nuclear Plant, Unit 2, Supplemental Safety Evaluation Report No. 22, Section 13.3.2.9, Emergency Communications.
The NRC staff will confirm the adequacy of the accident assessment capabilities to support dual unit operations prior to the issuance of the Unit 2 OL
The scope of the present review is based on the Section 13.3, Emergency Preparedness, of the Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR [Light-Water Reactor] Edition, NUREG-0800. The SRP provides:
In general, if an application is for an additional reactor at an operating reactor site, and the application proposes to incorporate and extend elements of the existing emergency planning program to the new reactor (included by reference), those existing elements should be considered acceptable and adequate.
This protocol applies to this inspection in that the WBN REP was written as a site-wide plan and that TVA proposed, and the Commission accepted, a regulatory framework in which TVA would align the Unit 1 and Unit 2 licensing and design basis to ensure design and operational fidelity between the two units. The adequacy of the WBN REP has been confirmed by the routine NRC inspection oversight, and TVAs performance in biennial exercises conducted since the licensing of Unit 1 in 1996.
This Confirmatory item was generated in response to an applicant response to a staff request for additional information regarding the capability of the WBN ERFs to simultaneously handle an emergency event affecting both WBN Unit 1 and Unit 2 (e.g.,
events initiated by loss of power, earthquake, tornado, flooding, or hostile actions). This item differs from Confirmatory Item #41 in that the ability for simultaneous response is of interest rather than whether the Unit 2 data are available.
Inspection Activities: The inspectors evaluated the status of the plant data display updates to include Unit 2.
b. Observations and Findings
No findings of significance were identified. The instrumentation displays in the MCR are specific to each unit and independent of each other. The data displays in the WBN ERFs are driven by the Plant Engineering Data System (PEDS), which serves as an interface to the plant data on the plants Integrated Computer System (ICS). The data was displayed on personal computers (PCs) through user-selectable menu options. As such, any PC can access data from Unit 1, Unit 2, or the simulator. The TSC has several PCs that have access to the data, by menu and icon selection, necessary for the individual workstations and functional areas (i.e., ERO positions). In addition, there are wall mounted large LCD screens that clone the display on the individual attached PCs.
A similar configuration exists in the OSC with fewer displays and PCs. ICS and PEDS displays are also available within the MCR. The licensee EP staff demonstrated the PEDS data displays for Unit 2 in the TSC. All of the data screens available for Unit 1 were available for Unit 2 and were online and active.
The CECC has seven display screens projected onto a large projection screen in the central CECC area. As with the configuration in the TSC and OSC, these screens are driven by individual PCs. These display screens are selectable as menu options on the associated PC and included PEDS, radiological assessment team and plant assessment team status summaries, a protective action plot, and selected WebEOC' pages. The majority of the PCs in the CECC had dual monitors allowing multiple displays. Although no Unit 2 screens were displayed during the recent exercise on October 19, 2011, which the inspectors observed, the capability would have been available given the PEDS configuration.
c. Conclusions
Although all planned parameters are not currently able to be displayed, the structure of the individual display screens, the number of display screens available, and the ability of the end user to select which data from which unit are to be displayed, provide reasonable assurance that the data displays will be capable of adequately supporting a emergency response for both Unit 1 and Unit 2 simultaneously. Accordingly, Confirmatory Item #42 can be closed.
OA.1.11 (Closed) CDR 391/83-47: Lugs Welded to Spiral Welded Pipe (IP 50100)
This item was reviewed and closed in IIR 2011608, section OA.1.29; however, the reference number for the CDR was incorrect. This is to document the correct CDR number and proper closure of this item.
V. MANAGEMENT MEETINGS
X.1
Exit Meeting Summary
On December 2, 2011, the resident inspectors presented the inspection results to Mr.
Gordon Arent and other members of his staff. Although some proprietary information may have been reviewed during the inspection, no proprietary information was included in this inspection report.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Applicant personnel
- D. Stinson, Site Vice President, TVA, Unit 2
- C. Stephenson, TVA Licensing
- D. Beckley, Electrical Design, TVA Unit 2
- D. Charlton, Licensing, TVA, Unit 2
INSPECTION PROCEDURES USED
Quality Assurance Program Implementation During Construction
Construction Refurbishment Process - Watts Bar Unit 2
Concrete Expansion Anchors
Safety-Related Piping - QA Review
Piping - Work Observation
Mechanical Components - Work Observation
Pipe Support and Restrain Systems
Electrical Components and Systems - Work Observation
Electric Cable - Work Observation
Procedures - Fire Prevention/Protection
Inspection of Watts Bar Nuclear Plant Fire Protection Corrective Action Program
Plan
Inspection of Watts Bar Nuclear Plant Hanger Update Corrective Action Program
Plan
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
Failure to Perform Layup and Preventative Maintenance on Safety-Related Components (Section C.1.6)
Discussed
391/85-26
Open Item 41
Closed
SSER 22 (App HH)
Failure of Coatings on Containment Vessel Interior (Section OA.1.1)
Review Plant Data Displays and Updated Dose Assessment Models (Section OA.1.2)
46071
IP
Concrete Expansion Anchors (Section C.1.8)
Failure to Correct a Nonconformance (Section OA.1.4)
391/87-13-02
49061
Open Item 39
Open Item 42
391/83-47
IP
SSER 22 (App HH)
SSER 22 (App HH)
Inadequate Corrective Actions for Non-
Conforming Safety-Related Concrete (Section OA.1.5)
Undersized Pipe Support Welds (Section OA.1.6)
Supports Installed on Non-Load-Bearing Wall (Section OA.1.7)
Safety-Related Piping - QA Review (Section OA.1.8)
Communications Capability to Support Dual Unit Operations (Section OA.1.9)
Review Accident Assessment Capabilities to Support Dual Unit Operations (Section OA.1.10)
Lugs Welded to Spiral Welded Pipe (Section OA.1.11)