IR 05000391/2012609
| ML12356A073 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 12/20/2012 |
| From: | Eric Michel NRC/RGN-II/DCP/CPB3 |
| To: | Skaggs M Tennessee Valley Authority |
| Michelle Adams | |
| References | |
| IR-12-609 | |
| Download: ML12356A073 (34) | |
Text
UNITED STATES cember 20, 2012
SUBJECT:
WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED INSPECTION REPORT 05000391/2012609
Dear Mr. Skaggs:
On November 17, 2012, 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 November 30, 2012, with Mr. Hruby, General Manager, 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, the conditions of your construction permit, and 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 the finding was a Severity Level IV violation and was entered into your Corrective Action Program, the NRC is treating this as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy.
If you contest the NCV 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).
TVA 2 Should you have questions concerning this letter, please contact us.
Sincerely,
/RA/
Eric Michel, Acting Chief Construction Projects Branch 3 Division of Construction Projects Docket No. 50-391 Construction Permit No: CPPR-92
Enclosure:
Inspection Report 05000391/2012609 w/Attachment
REGION II==
Docket No.: 50-391 Construction Permit No.: CPPR-92 Report No.: 05000391/2012609 Applicant: Tennessee Valley Authority (TVA)
Facility: Watts Bar Nuclear Plant, Unit 2 Location: Spring City, TN 37381 Dates: October 1 - November 17, 2012 Inspectors: T. Nazario, Senior Resident Inspector, Construction Projects Branch (CPB) 3, Division of Construction Projects (DCP)
Region II (RII)
D. Failla, Resident Inspector, CPB3, DCP, RII E. Patterson, Resident Inspector, CPB3, DCP, RII C. Jones, Senior Construction Inspector, Construction Inspection Branch (CIB) 1, Division of Construction Inspection, RII, Section E.1.1 G. Crespo, Senior Construction Inspector, CIB1, DCI, RII Sections C.1.7, OA.1.2, OA.1.5 J. Bartleman, Senior Construction Inspector, CIB3, DCI, RII, Section OA.1.6 E. Heher, Construction Inspector, CIB2, DCI, RII Section E.1.1 D. Jackson, Construction Inspector, CPB2, DCP, RII Section E.1.1 S. Alexander, Construction Inspector, CIB2, DCI, RII, Section OA.1.5 Approved by: Eric Michel, Acting Chief Construction Projects Branch 3 Division of Construction Projects Enclosure
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, Watts Bar Unit 2 Construction Inspection Program.
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
- The NRC identified a Severity Level (SL) IV non-cited violation (NCV) of 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion XVII, "Quality Assurance Records," for the failure to sufficiently record and furnish evidence of activities affecting quality.
Specifically, quality records for a field change request (FCR), drawing revision authorization (DRA), and engineering document construction release (EDCR) were closed and authenticated as correctly documenting the installation of wiring for the safety injection accumulator tank nitrogen valve position control indications. However, a field walkdown of the completed configuration by the inspectors identified a jumper wire was not installed on terminal from point 3 to 7 as certified by EDCR 52363-A and DRA 52363-14. (Section E.1.1)
- The inspectors concluded that five open items, including two Temporary Instructions (TIs) and three Construction Deficiency Reports (CDR) 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 electrical systems and components; mechanical systems and components; Temporary Instructions (TIs); NRC inspection procedures (IPs); CDRs; and refurbishment.
Table of Contents I. QUALITY ASSURANCE PROGRAM .................................................................................... 4 Q.1 Quality Assurance Oversight Activities ......................................................................... 4 Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure 35007) ................................................................................................................... 4 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 Mechanical Components - Work Observation and Construction Refurbishment Process (Inspection Procedures 50073 and 37002) ............................................. 6 C.1.3 Nondestructive Examination Procedure Radiographic Examination Procedure Review/Work Observation/Record Review (Inspection Procedure 57090 and 37002) ................................................................................................................... 6 C.1.4 Piping - Work Observation (Inspection Procedure 49063 and 37002) ................. 7 C.1.5 Reactor Vessel and Internals Construction Refurbishment Process (Inspection Procedure 50053) .................................................................................................. 8 C.1.6 (Discussed) Electrical Components and Systems - Work Observation (Inspection Procedure 51053) .................................................................................................. 8 E.1 Engineering Activities ..................................................................................................... 9 E.1.1 Onsite Design Activities (Inspection Procedure 37055) ........................................ 9 IV. OTHER ACTIVITES ........................................................................................................... 12 OA.1.1 (Discussed) NRC Bulletin 88-05: Nonconforming Materials Supplied by Piping Supplies, Inc., at Folsom, New Jersey and West Jersey Manufacturing Company at Williamstown, New Jersey (Inspection Procedure 92717) .............................. 12 OA.1.2 (Discussed) Hydrogen Igniter Backup Power -Generic Safety Issue-189 (Inspection Procedure 35007) ............................................................................. 13 OA.1.3 (Closed) Temporary Instruction 2515/028, Inspection Requirements to Review Licensee Actions Taken in Response to Bulletin 79-02, Rev. 1 (Inspection Procedure 46071) ................................................................................................ 14 OA.1.4 (Closed) Temporary Instruction 2515/029, Inspection Requirements for Bulletin 79-14 (Inspection Procedure 50090 and Temporary Instruction 2515/023) ........ 14 OA.1.5 (Closed) Construction Deficiency Report 391/87-11, Failure to Coordinate Solenoid Valve Replacement Documents (Inspection Procedure 35007 and 51053) ................................................................................................................. 15 OA.1.6 (Closed) Construction Deficiency Report 391/87-23: Failed Motor Pinion Keys &
Motor Shaft in Limitorque Operator (Inspection Procedure 50075) ..................... 16 OA.1.7 (Closed) Construction Deficiency Report 391/91-12: Undersized Component Cooling System Instrumentation for Reactor Coolant Pump Thermal Barriers (Inspection Procedure 35007) ............................................................................. 17 V. MANAGEMENT MEETINGS .............................................................................................. 18 V.1 Exit Meeting Summary ................................................................................................... 18
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 PROGRAM Q.1 Quality Assurance Oversight Activities Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure 35007)
a. Inspection Scope
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.
During this inspection period, the inspectors observed a training session on safety conscious work environment and 10 Code of Federal Regulations (CFR) 50.9 to determine whether the training met regulatory requirements of Confirmatory Order 2012-0171, issued for enforcement action EA-12-021 (ML12173A020). The training addressed actions to prevent recurrence outlined in Confirmatory Order 2012-0171, Section 3.d. Specifically, TVA would provide 10 CFR 50.9 training (both manager/supervisor as well as craft-level) to employees, including contractor and subcontractor employees, at all Nuclear Construction (Watts Bar Unit 2 and Bellefonte)locations by December 21, 2012. The training consisted of multiple sessions provided to supervisors and non-supervisory personnel at the site. The observed training was part of the corrective action plan for PER 533342 which addressed the confirmatory order.
b. Observations and Findings
No findings were identified.
c. Conclusions
The observed training satisfied the requirements in Confirmatory Order 2012-0171, Section 3.d, and the corrective actions in PER 533342 for this training.
II. MANAGEMENT OVERSIGHT AND CONTROLS C.1 Construction Activities C.1.1 Unit 1 and Unit 2 Construction Activity Interface Controls
a. Inspection Scope
The inspectors independently assessed applicant controls associated with Unit 2 construction work activities to prevent adverse impact 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 which 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 select construction work locations to verify that controls to protect the operating unit provided an adequate level of protection and had been properly implemented.
Specific activities observed included work associated with:
- Work order (WO) 112833358, Essential Raw Cooling Water (ERCW) Leak Observed Downstream of 1-FCV-67-146, 10/15/2012
- WO 111117679, Remove and Reinstall Check Valve 2-CKV-062-0928, 10/02/2012
- WO 113595125, Remove and Reinstall Check Valve 2-CKV-062-0928, 11/07/2012
- WO 113866338, Conduit 2VC9697A from system 292 Auxiliary Building Conduit
& Cable Tray System, 09/12/2012
- WO 113280423, Conduit 2CR4683A from system 292 Auxiliary Building Conduit
& Cable Tray System, 10/05/2012
b. Observations and Findings
No findings were identified.
c. Conclusions
Adequate management oversight and controls were in place for observed construction activities that could potentially impact the operating unit, and an adequate level of protection had been implemented.
C.1.2 Mechanical Components - Work Observation and Construction Refurbishment Process (Inspection Procedures 50073 and 37002)
a. Inspection Scope
The inspectors observed repairs to the cladding in the bowls and hot leg portions of steam generators 1 and 4 to verify welding was in accordance with procedures and ASME B&PV Code 2007 edition. The inspectors reviewed welding procedure specifications and supporting procedure qualification records to determine whether the qualified procedures met the requirements of ASME B&PV Code 2007 edition.
The inspectors reviewed Westinghouse design specification 425A55, Rev.2, to determine whether the specification met regulatory commitments. The inspectors reviewed pre-heat and post-weld soak procedures to determine whether the requirements of ASME B&PV Code 2007 edition were met.
Documents reviewed are listed in the attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
The observed refurbishment activities on steam generators 1 and 4 were conducted in accordance with procedures and ASME B&PV Code 2007 edition. The documents reviewed as a result of the inspection were in compliance with the requirements of ASME B&PV Code 2007 edition.
C.1.3 Nondestructive Examination Procedure Radiographic Examination Procedure Review/Work Observation/Record Review (Inspection Procedure 57090 and 37002)
a. Inspection Scope
The inspectors observed radiographic examination (RT) of refueling water storage tank (RWST) welds 2-063B-T288-1H10 and 2-063Y-PDMT-0F-1 to determine whether procedure and American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code 1971 edition 1973 addenda requirements were met. Specifically, the inspectors reviewed the material to be radiographed, material thickness, radiation source, film brand, minimum source to film distance, exposure conditions, film density limits, radiograph identification, location markers, geometrical unsharpness limits, penetrameter selection, and radiographic technique to determine whether procedure and ASME requirements were met.
The inspectors observed RT of the RWST to determine whether applicable work instructions clearly specified the examination procedure to be used and that a copy of the procedure was available in the area during examination. Radiographic examination of the RWST was also observed to determine whether the specific areas to be examined were clearly defined and the required equipment and materials were available at the work location.
The inspectors observed processing of radiographic film to determine whether the film was being processed in accordance with procedure requirements and that the film was free of chemical and mechanical blemishes.
The inspectors reviewed radiographic personnel certifications to determine whether the personnel performing RT met procedure and American Society for Nondestructive Testing SNT-TC-1A requirements.
The following samples were inspected:
- IP 57090 Section 02.02 - two samples Documents reviewed are listed in the attachment.
b. Observations No findings were identified.
c. Conclusions
The observed radiographic examination of RWST welds met procedure and applicable ASME B&PV Code 1971 edition thru 1973 addenda requirements. The processing of the radiographic film was conducted in accordance with procedure requirements. The radiographic personnel were certified in accordance with procedure and SNT-TC-1A requirements.
C.1.4 Piping - Work Observation (Inspection Procedure 49063 and 37002)
a. Inspection Scope
The inspectors observed installation of pipe spools and fittings in the ERCW system, turbine driven auxiliary feedwater system, and chemical & volume control system to determine whether procedure and ASME B&PV Code 1971 edition thru 1973 addenda requirements were met. The inspectors observed cleanliness control, grinding, supporting, and quality-related inspections for the piping and fittings installed in the systems discussed above to determine whether procedures and specifications were followed. The inspectors reviewed material identification and records related to the piping and fitting installations to determine whether procedure requirements were met.
The following samples were inspected:
- IP 49063 Section 02.01 - 2 samples
- IP 49063 Section 02.02 - 2 samples Documents reviewed are listed in the attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
The observed pipe spool and fitting installations activities were conducted in accordance with procedures, specifications, and ASME B&PV Code 1971 edition thru 1973 addenda.
The cleanliness control, grinding, supporting, and quality-related inspections observed by the inspectors were conducted in accordance with procedures and specifications.
C.1.5 Reactor Vessel and Internals Construction Refurbishment Process (Inspection Procedure 50053)
a. Inspection Scope
The inspectors performed inspection activities associated with the reactor vessel stud hole remediation plan and trial fit to support Westinghouse analysis, performed under WO 112388257. The inspectors observed the trial fit of the reactor vessel studs into the reactor vessel and observed the applicants oversight of the work activities to determine if the work was completed in accordance with the work instructions, if foreign material exclusion control measures were implemented, and if the applicant provided adequate oversight for the work activity.
Documents reviewed are listed in the attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
The reactor vessel stud trial fit activities were performed in accordance with applicable procedures.
C.1.6 (Discussed) Electrical Components and Systems - Work Observation (Inspection Procedure 51053)
a. Inspection Scope
The inspectors observed in-process and completed installation of safety-related raceway components to verify they were in accordance with specification and drawing requirements in the WO package. The inspectors reviewed associated work orders to verify that components were installed in accordance with the latest approved revision of construction drawings, specifications, and procedures. The inspectors reviewed the size and type of installed raceway systems to verify that the drawings and the Integrated Cable and Raceway Design System reports matched the installed components. As part of the installation review, the inspectors reviewed drawings to verify that components were installed in the location shown on the drawings, and that supports and mounting hardware were installed and spaced in accordance with the G-40 specification. The inspectors reviewed the installation to verify that component identification tags and train labeling were in accordance with the G-40 specification. The inspectors examined specification requirements of pull fittings to verify that the pull fittings used were applied at intervals to maintain adequate total bend radius in accordance with the G-40 specification. The inspectors reviewed the installation to verify that conduits and junction boxes maintained specified physical and electrical separation and independence between redundant components. The inspectors reviewed the documentation of quality control inspections of the completed work package to verify the quality control inspection reviewed the appropriate installation aspects of the raceway components.
Additional documents reviewed are listed in the attachment.
The following samples were inspected:
- IP 51053 Section 02.02.d - 3 samples
- IP 51053 Section 02.02.e - 4 samples
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors concluded that the conduit installation met specification and drawing requirements.
E.1 Engineering Activities E.1.1 Onsite Design Activities (Inspection Procedure 37055)
a. Inspection Scope
The inspectors evaluated the adequacy of design controls as implemented by the applicants contractor for engineering, procurement, and construction (EPC) at the Watts Bar Unit 2 construction completion project. The inspection scope included reviews of documentation for completed field change requests (FCRs), including advance approvals for at-risk changes and red-line changes.
An inspection sample of nine FCRs was selected for review where the lead design discipline was electrical engineering. A sample of five FCRs was selected in the plant design discipline (e.g. supports and stress analysis). An additional six FCRs were selected that affected equipment supports and instrumentation. The inspection scope included evaluations of the following attributes:
- Design change documents, including engineering document construction releases (EDCRs), associated design verification reports (DVRs), associated FCRs, master equipment lists, and associated drawing revision authorizations (DRAs) were reviewed to determine whether the documents were prepared, verified, approved, and controlled in accordance with the TVA Nuclear Quality Assurance Plan, the Bechtel Project Nuclear Quality Assurance Manual, and project procedures
- FCR documentation was reviewed to determine whether the documents identified the reasons or need for the changes
- The FCR changes were evaluated to confirm the changes did not compromise the original design intents and that design input assumptions remained valid
- The inspectors evaluated whether FCR changes were subject to controls commensurate with that provided for the original designs (inspectors considered impact on overall design by reviewing the adequacy of FCR changes, impact on other disciplines, and need to change prior analyses)
- Reviews determined whether design output documents, including drawings were updated to accurately reflect new or changed design configurations
- For the Advance Authorization (AA) changes released for work at-risk without design verification, the reviews determined whether the unverified changes and related construction activities were adequately controlled during the unverified periods
- For changes that had been implemented in the field, the inspectors reviewed a sample of work orders and field implementation data sheets to verify work was completed in accordance with the approved field change request
- Effective performance of activities, including roll-up of red-line changes, was evaluated through interviews with field engineers, design engineers, quality assurance management, and direct field inspections of completed installations The inspectors reviewed QA audits and surveillances conducted in 2011 and 2012 and interviewed responsible managers to evaluate the extent of independent oversight for design activities. The review provided a determination whether the scope and schedule of audits were consistent with activities being performed at the site, whether audit findings were adequately addressed through the corrective action program, whether issues were properly screened for significance and reportability, and if substantive findings were reported to responsible management. The audit results were reviewed to determine whether audit conclusions were consistent with problems being reported in the corrective action program. Three QA audits and five QA surveillances were reviewed.
Documents reviewed for this inspection are listed in the attachment.
The following samples were inspected:
- IP 37055 Section 02.03.b - 20 samples
- IP 37055 Section 02.05.c - 3 samples
- IP 37055 Section 02.06 - 2 samples
b. Observations and Findings
The inspection of the implementation of design controls identified the following Severity Level (SL) IV Non-Cited Violation (NCV):
Introduction:
A SL IV NCV of 10 CFR50, Appendix B, Criterion XVII, "Quality Assurance Records," was identified by the inspectors for the failure to sufficiently record and furnish evidence of activities affecting quality. Specifically, quality records for a FCR, drawing revision authorization, and EDCR were closed and authenticated as correctly documenting the installation of wiring for the safety injection accumulator tank nitrogen valve position control indications. However, a field walkdown of the completed configuration by the inspectors identified a jumper wire was not installed on terminal A1-47 from point 3 to 7 as certified by EDCR 52363-A and DRA 52363-14.
Description:
The inspectors reviewed completed FCR 55144-A, at-risk advance authorization AA-06, and DRA 52363-14. The inspectors interviewed design engineers and reviewed the closure documentation for the controlling EDCR 52363-A. The quality record review and design engineering interviews established that the closure of the EDCR indicated that the installation of the jumper on terminal A1-47 between points 3 and 7 on the safety injection system accumulator nitrogen inlet valve, 2-HS-63-64A, had been completed in accordance with FCR 55144-A, DRA 52363-14, and WO 09-954101-015. In contrast, the inspectors walkdown of the completed wiring for the safety injection system accumulator tank nitrogen header inlet valve, 2-HS-63-64A, control room indications in panel 2-M-6 identified that a jumper necessary for functionality of the control room circuitry was not installed on terminal block A1-47 between terminals 3 and
7. The EDCR was authenticated as complete and correct even though the full work scope
described in an associated field change request was not accomplished. The work order that was issued to install the wiring, WO 09-954101-015, documented that the wiring had not been installed; however, it incorrectly indicated that the work was accomplished under another design control package, EDCR 52453. The inspectors review of EDCR 52453 found that the EDCR did not include instructions to install the missing wire.
Information recorded in EDCR 52453-A incorrectly indicated the jumper had previously been installed.
The applicants failure to ensure that the QA record of the activity, specifically EDCRs 52363-A and 52453-A were sufficient, as required by 10 CFR50, Appendix B, Criterion XVII, in documenting the as installed configuration of the safety injection system accumulator tank nitrogen header inlet valve is a performance deficiency. The applicant issued PER 628404 to address the issue. This finding is considered more than minor because it is similar to Inspection Manual Chapter 2517, Appendix C, Example 1.a, where the inaccurate quality record could preclude the applicant from being able to take appropriate action on safety-significant matters, or the NRC from objectively or properly assessing, auditing, or otherwise evaluating significant activities. The inspectors determined this finding to be a SL-IV violation, in accordance with Section 6.5 of the Enforcement Policy because the applicant failed to establish, maintain, or implement adequate controls over construction processes that are important to safety. However, this finding did not represent a breakdown in the applicants QA Program for construction related to a single work activity.
No cross-cutting aspects were identified for this finding.
Enforcement:
Appendix B, Criterion XVII, "Quality Assurance Records" of 10 CFR Part 50, states, in part, that: Sufficient records shall be maintained to furnish evidence of activities affecting quality Section 6.3.2 of procedure TVA-NQA-PLN89-A Rev.26, Nuclear Quality Assurance Plan states, Sufficient records and documentation shall be prepared and maintained to provide evidence of the quality of items or activities affecting quality Additionally, Bechtel Engineering Department Procedure Instruction for EDCRs, 25402-3DP-G04G-00081 Rev. 14, section 4.8 states, in part, that: SSCs are considered design complete when the design changes (EDCRs) have been issued and all regulatory requirements and open items have been closed.
Contrary to the above, the quality records failed to provide sufficient evidence that the documented activity affecting quality was consistent with the installed field configuration.
Specifically, EDCRs 52363-A and 52453-A incorrectly indicated that the jumper was installed on terminal A1-47 between points 3 and 7 on the safety injection system accumulator nitrogen inlet valve, 2-HS-63-64A.
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 example supporting the violation was 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. This violation is identified as NCV 05000391/2012609-01, Failure to maintain sufficient quality records of completed construction activities.
c. Conclusion With the exception of the EDCR identified in the non-cited violation, the design changes reviewed for this inspection were completed in accordance with established procedures and the applicants QA program.
IV. OTHER ACTIVITES OA.1.1 (Discussed) NRC Bulletin 88-05: Nonconforming Materials Supplied by Piping Supplies, Inc., at Folsom, New Jersey and West Jersey Manufacturing Company at Williamstown, New Jersey (Inspection Procedure 92717)
a. Inspection Scope
The inspectors observed hardness testing on five flanges associated with Bulletin (BL)88-05 to determine whether the testing was conducted in accordance with procedures, specifications, and manufacturers guidelines. The inspectors observed calibration of the hardness testing equipment to determine whether the calibration was conducted in accordance with procedures and that the equipment met the allowable tolerances. The inspectors reviewed procedure N-GP-24, Hardness Testing, Rev. 6, to determine whether the procedure included manufacturers guidelines and correct hardness conversion tables.
Hardness for the following flanges (identified by weld number) was observed:
- 2-015A-T001-90A, Heat No. 6579
- 2-015A-T001-94A, Heat No. CAO
- 2-015A-T010-95, Heat No. 6579
- 2-015A-T004-95A, Heat No. CAO
- 2-015A-T001-99C, Heat No. CAO
b. Observations and Findings
No findings were identified.
c. Conclusions
The observed hardness testing and equipment calibration was conducted in accordance with procedures, specifications, and manufacturers guidelines. The procedure reviewed incorporated manufacturers guidelines and correct hardness conversion tables.
OA.1.2 (Discussed) Hydrogen Igniter Backup Power -Generic Safety Issue-189 (Inspection Procedure 35007)
a. Inspection Scope
Background: An evaluation was performed for the potential of early failure of containment during very low probability events involving damage to the reactor core as discussed in NUREG/CR-6427, Assessment of the Direct Containment Heat Issue for Plants with Ice Condenser Containments. The results of the evaluation revealed an early containment failure probability of ice condenser containments, dominated by hydrogen combustion following core damage events. Plants with these containment designs use hydrogen igniters to control the buildup of hydrogen. The existing hydrogen igniters rely on the plant AC power distribution system for power, and AC power may not be available for certain events with the potential to result in severe core damage.
Therefore, for the hydrogen igniters to be effective in preserving containment integrity, the igniters must have power before a buildup of hydrogen has developed (i.e., before severe core damage has occurred).
To resolve GSI-189, Susceptibility of Ice Condenser and Mark III Containments to Early Failure from Hydrogen Combustion during a Severe Accident, the staff recommended the addition of a backup power supply for the hydrogen igniters for plants with ice condenser containments. A regulatory analysis indicated the backup power modification may provide a substantial safety benefit at a justifiable cost for the PWRs with ice-condenser containments, and voluntary measures proposed by the licensees for these facilities provided the majority of the benefit. The capability to provide backup power to the igniters for events involving severe core damage coincident with a station blackout is beyond the current design basis of affected facilities. The changes at these units involve development of procedures and training to support connection of an existing large, mobile diesel generator to the electrical distribution system in a manner that provides power to at least one train of igniters through temporary connections.
Inspection Activities:
The inspectors reviewed the applicants documentation on equipment arrangement for the portable diesel generator, the associated dry type transformer, and the temporary service for the battery charger inside the portable diesel generator to verify component capacity and service ratings. The inspectors reviewed wiring diagram drawings to determine the adequacy of the design. The inspectors reviewed calculations to verify that the generator load was within the manufacturers rating with the addition of the hydrogen igniters load on the generator. The inspectors reviewed portable diesel generator load testing records to verify actual test loads applied and test duration adequacy. The inspectors performed a walkdown of the procured equipment staged at the site to confirm that the equipment characteristics and nameplate data were consistent with the drawings.
b. Observations and Findings
No findings were identified.
c. Conclusions
Based on the review, the applicants documentation of the backup power system capacity was adequate. This item will remain open and require further inspection of the final system configuration.
OA.1.3 (Closed) Temporary Instruction 2515/028, Inspection Requirements to Review Licensee Actions Taken in Response to Bulletin 79-02, Rev. 1 (Inspection Procedure 46071)
a. Inspection Scope
Background: Temporary Instruction (TI) 2515/028 was issued on July 1, 1979, to verify that TVA had taken actions on the issues required by BL 79-02, Rev. 1. Inspection Procedure 46071, Concrete Expansion Anchors, was issued on December 17, 1986, with the objective to confirm concrete expansion anchors were properly installed and that the applicants response was consistent with commitments made in response to BL 79-02. Inspection Procedure 46071 was closed in NRC Integrated Inspection Report (IIR) 05000391/2011609, Section C.1.8. This report documented the inspection of field work and review of procedures and records associated with concrete expansion anchors for Unit 2. BL 79-02 was later inspected, documented, and closed in IIR 05000391/2012608 for Unit 2, Section OA.1.10. These combined inspection efforts documented in the inspection report were conducted following guidance contained inspection procedure 46071 and TI 2515/028.
Inspection Activities: The inspectors reviewed the above IIR associated with BL 79-02 to determine if sufficient NRC inspection activities had been performed to adequately address TI 2515/028.
b. Observations and Findings
No findings were identified.
c. Conclusions
Based on the inspection reports reviewed, the inspectors concluded that the previous inspection documented under BL 79-02 adequately addressed TI 2515/028. TI 2515/028 is closed.
OA.1.4 (Closed) Temporary Instruction 2515/029, Inspection Requirements for Bulletin 79-14 (Inspection Procedure 50090 and Temporary Instruction 2515/023)
a. Inspection Scope
Background: TI 2515/029 was issued on September 14, 1979. The objective of this TI was to provide guidance for inspection and review of licensees actions and written responses to BL 79-14. Inspection Procedure 50090 also covered aspects of BL 79-14 which requested that licensees assure that seismic analyses of safety-related piping systems accurately reflected the as-built configuration of the plant.
BL 79-14 was inspected, documented, and closed in inspection report 05000391/2012608, Section OA.1.11 for Unit 2. The combined inspection efforts documented in the inspection report were conducted following guidance contained IP 50090 and TI 2515/028.
Inspection Activities: The inspectors reviewed IIR 05000391/2012608 (ADAMS Accession Number ML11311A082) associated with BL 79-14 to determine if sufficient inspection activities had been performed to verify TI-2515/029 was adequately addressed.
b. Observations and Findings
No findings were identified.
c. Conclusions
Based on the activities reviewed in IIR 05000391/2012608, the inspectors concluded that TI 2515/029 is closed.
OA.1.5 (Closed) Construction Deficiency Report 391/87-11, Failure to Coordinate Solenoid Valve Replacement Documents (Inspection Procedure 35007 and 51053)
a. Inspection Scope
Background: The subject deficiency was initially reported to the NRC for Unit 2 on March 24, 1987 in accordance with 10 CFR 50.55(e). After review, the NRC determined this deficiency was associated with notice of violation 50-391/86-18-01 issued previously as part of NRC Inspection Report 50-390/86-18 and 50-391/86-18.
The notice of violation concerned TVAs failure to translate design requirements, including vendor specifications, into specifications, drawings, procedures, or instructions as required by 10 CFR Part 50, Appendix B, Criterion III. The following two specific examples were cited.
- The American Switch Company (ASCO) Solenoid Valves Manual NP-1 requirements to orient solenoid valves, model 206.381, vertical and upright, were not translated into installation instructions. This failure resulted in installed equipment not meeting vendor requirements.
- Seismic requirements of IEEE 344-1975, which requires the effects of electrical connections, conduit, and sensing lines, etc., to be considered, were not translated into installation instructions. This failure resulted in inadequately installed equipment, as referenced in construction Deficiency Report (CDR) WBRD 50-390/86-59.
CDR 391/87-11 addressed only the first example. The second example was documented in CDR 391/86-59.
As a result of several EDCRs, the applicant intended to remove and replace all ASCO solenoid valves for Unit 2. NCO080008030 was written to track this issue. This package was reviewed as part of the closure for BL 75-03, and was documented in NRC Inspection Report 05000391/2012602. When the initial engineering change notice (ECN) was issued for this package, it did not include civil or mechanical disciplines in the review. The root cause of this deficiency was the failure to perform appropriate inter-discipline reviews of the ECN before implementation, which was addressed by CDR 391/87-11.
The seismic adequacy of the solenoid valve installation was subject to evaluation because a change in configuration and/or mass of the solenoid valves could render the seismic qualification invalid. Vendor drawings indicated that the installation of ASCO solenoid valves must be upright within 45 degrees of vertical to ensure operation. If the configuration of the installations was different than specified by the vendor, operation of the solenoid valves could not be ensured.
Inspection Activities: The inspectors reviewed calculation WCG-ACQ-0125, Seismic Evaluation of Control Valves/Dampers Due to the Replacement of Solenoid Valves, which included assessments of the weight differential for each solenoid valve and the effect of the weight variation of the assembly on the dampers to verify the seismic evaluation was not compromised by replacement solenoid valves. The inspectors reviewed several design change procedures within the WO package to ensure appropriate inter-discipline reviews were required for design changes. The inspectors reviewed work orders for the installation of auxiliary feedwater pump flow control valves 2-FCV-003-355A and 2-FCV-003-359B to verify the implementation of work packages.
Inspectors interviewed responsible engineering staff involved with the seismic calculations and the installation instructions contained within the WO package to verify adequacy of seismic design margins, solenoid valve weights, and installation requirements for proper alignment of solenoid valves. The inspectors observed the physical installation of the solenoid valves listed above inside the Auxiliary Building at elevation 713 column line A12S and verified the valves were installed in the upright position in accordance with manufacturers instructions.
Documents reviewed are listed in the attachment.
b. Observations and Findings
No findings were identified.
c. Conclusion Based on reviews of the applicants final completion package, calculations, and revised installation instructions, the inspectors determined the applicant has adequately addressed the issues identified in the CDR. CDR 391/87-11 is considered closed.
OA.1.6 (Closed) Construction Deficiency Report 391/87-23: Failed Motor Pinion Keys &
Motor Shaft in Limitorque Operator (Inspection Procedure 50075)
a. Inspection Scope
Background: The applicant identified multiple motor-operated valves (MOVs) with failed motor pinion keys and motor shafts in Limitorque electric actuators. Limitorque was the original equipment manufacturer that supplied the MOV electric actuators for WBN Unit 2. These failures consisted primarily of circumstances resulting from high impact loading on components inside of high speed MOV actuators that had valve stem speeds greater than 50 inches/minute. The applicant implemented modifications to these high speed Limitorque actuators that experienced rapid impact overloading. The modifications consisted of slowing down many of these MOV actuators so they would have valve stem speeds of less than 50 inches/minute, and had the motor shaft and motor pinion gear key fabricated from higher strength American Iron and Steel Institute (AISI) 4140 material.
Inspection Activities: The inspectors reviewed the applicants complete EDCR closure packages, purchase order, specification, corrective actions, and WOs to ensure that proposed actions satisfied the concerns identified in CDR 391/87-23. The inspectors reviewed several corrective action documents to verify proper actions were implemented by the applicant that addressed and corrected these failures and prevented recurrence.
The inspectors reviewed TVA WOs and maintenance instructions to ensure that adequate requirements existed in the instructions for the maintenance of MOV actuators.
Additionally, the inspectors reviewed several TVA Maintenance Instructions used for performing maintenance on various sizes and types of Limitorque actuators to ensure that proper motor pinion gear key material was specified to prevent inadvertent installation of the wrong key material. The inspectors reviewed the PO and design specification used to purchase the replacement safety-related electrical MOV actuators to verify these documents contained requirements to obtain the new higher strength AISI 4140 material for the motor shafts and motor pinion gear keys.
Documents reviewed are listed in the attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
Based upon the review of the applicants completed engineering complete package, EDCRs, WOs, and additional documentation, the inspectors concluded that the scope and effectiveness of the applicants corrective actions were the same as Unit 1, are in compliance with all applicable requirements, and are adequate to address this sub-issue/CDR. Based on these actions, CDR 391/87-23 is closed.
OA.1.7 (Closed) Construction Deficiency Report 391/91-12: Undersized Component Cooling System Instrumentation for Reactor Coolant Pump Thermal Barriers (Inspection Procedure 35007)
This item was previously closed in IIR 2012608, Section OA.1.19, as CDR 390/91-12.
The item identifier should have been documented as CDR 391/91-12. The number 390 refers to the docket number for Watts Bar Unit 1, while the number 391 refers to the docket number for Unit 2. This section documents the change to Section OA.1.19 in IIR 2012608 to CDR 391/91-12. This was a typographical error, and no changes to the inspection activities or inspection conclusions were necessary.
V. MANAGEMENT MEETINGS V.1
Exit Meeting Summary
An exit meeting was conducted on November 30, 2012 to present inspection results to Mr. Hruby, General Manager, and other members of his staff. The inspectors identified that no proprietary information had been received during the inspection and none would be used in the inspection report. The areas inspected were described, inspection activities, and discussed the inspection results. The applicant acknowledged the observations provided with no dissenting comments.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Applicant personnel
- A. Bangalore, Bechtel - Electrical Design
- D. Beckley, Bechtel - Electrical Engineer
- M. McGrath, TVA - Licensing
- A. Hart, Construction Supervisor
- T. Das, Civil Engineer
- M. Usman Quraishi, Electrical Engineer
- J. Mills, Valve Design Engineer
- R. Phipps, Electrical Foreman
- B. Pittman, MOV Test Engineer
INSPECTION PROCEDURES USED
IP 35007 Quality Assurance Program Implementation During Construction
IP 37002 Construction Refurbishment Process - Watts Bar Unit 2
IP 46071 Concrete Expansion Anchors
IP 50073 Mechanical Components - Work Observation
IP 50053 Reactor Vessel and Internals Work Observation
IP 57090 Pipe Support and Restraint Systems
IP 50075 Safety-Related Components - Records Review
IP 50090 Pipe Support and Restrain Systems
IP 51053 Reactor Vessel and Internals Work Observation
IP 49063 Piping - Work Observation
IP 37055 Onsite Design Activities
IP 92717 IE Bulletins for Information and IE Information Notice Follow-up
TI 2512/028 Inspection Requirements to Review Licensee Actions Taken in
Response to IE Bulletin 79-02, Revision No. 1
TI 2515/029 Inspection Requirements for IEB 79-14
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Open and
Closed
391/2012608-01 NCV Failure to maintain sufficient quality records of completed construction activities (Section E.1.1)
Closed
2515/028 TI Inspection Requirements to Review Licensee Actions Taken in Response to Bulletin 79-02, Rev. 1 (Section OA.1.3)
2515/029 TI Inspection Requirements for Bulletin 79-14 (Section OA.1.4)
391/87-11 CDR Failure to Coordinate Solenoid Valve Replacement Documents (Section OA.1.5)
391/87-23 CDR Failed Motor Pinion Keys & Motor Shaft in Limitorque Operator (Section OA.1.6)
391/91-12 CDR Undersized Component Cooling System Instrumentation for Reactor Coolant Pump Thermal Barriers (Section OA.1.7)
Discussed
88-05 BL Nonconforming Materials Supplied by Piping Supplies, Inc., at Folsom, New Jersey and West Jersey Manufacturing Company at Williamstown, New Jersey (Section OA.1.1)
189 GSI Hydrogen Igniter Backup Power (Section OA.1.2)