IR 05000391/2013608

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IR 05000391-13-608, on 08/18/2013 - 09/28/2013, Watts Bar Nuclear Plant, Unit 2, NRC Integrated Inspection Report
ML13316A776
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 11/08/2013
From: Haag R
NRC/RGN-II/DCP/CPB3
To: Skaggs M
Tennessee Valley Authority
Michelle Adams
References
IR-13-608
Download: ML13316A776 (54)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 8, 2013

SUBJECT:

WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED INSPECTION REPORT 05000391/2013608

Dear Mr. Skaggs:

On September 28, 2013, 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 October 10, 2013 with you 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.

No findings were identified during this inspection.

In accordance with 10 Code of Federal Regulations (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). Should you have questions concerning this letter, please contact us.

Sincerely,

/RA/

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

Enclosure:

Inspection Report 05000391/2013608 w/Attachment

REGION II==

Docket No.: 50-391 Construction Permit No.: CPPR-92 Report No.: 05000391/2013608 Applicant: Tennessee Valley Authority (TVA)

Facility: Watts Bar Nuclear Plant, Unit 2 Location: Spring City, TN 37381 Dates: August 18 - September 28, 2013 Inspectors: T. Nazario, Senior Resident Inspector, Construction Projects Branch (CPB) 3, Division of Construction Projects (DCP)

Region II (RII)

R. Lewis, Resident Inspector, CPB3, DCP, RII E. Patterson, Resident Inspector, CPB3, DCP, RII A. Matos, Construction Inspector, Construction Inspection Branch (CIB1), Division of Construction Inspection (DCI), RII, Section OA.1.12 C. Even, Senior Project Inspector, CPB3, DCP, Section P.1.2 J. Baptist, Senior Project Inspector, CPB3, DCP, Sections OA.1.9, OA.1.10 K. VanDoorn, Senior Project Inspector, CPB3, DCP, Sections C.1.5, OA.1.3, OA.1.8 C. Jones, Senior Construction Inspector, CIB1, DCI, RII, Sections OA.1.7, OA.1.11, OA.1.12 S. Temple, Construction Inspector, CIB2, DCI, RII, Sections C.1.9, OA.1.1 J. Lizardi, Construction Inspector, CIB2, DCI, RII, Sections OA.1.4, OA.1.5, OA.1.6 J. Bartleman, Senior Construction Inspector, CIB3, DCI, RII, Section OA.1.2 Approved by: Robert C. Haag, 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 six-week period of inspections in the areas of quality assurance (QA),

identification and resolution of construction problems, construction activities, pre-operational testing, 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 inspectors concluded that concerns pertaining to several open items, including two construction deficiency reports (CDRs), one unresolved item (URI), two inspection procedures (IPs), one Three Mile Island (TMI) action item (AI), and one NRC bulletin (BL), have been appropriately addressed for WBN Unit 2. These items are closed.
  • Other areas inspected were adequate with no findings identified. These areas included QA; piping; mechanical systems and components; electrical systems and components; fire protection; pre-operational testing activities; various NRC inspection procedures; the Q-list corrective action program; as-built verifications; and refurbishment activities.

Table of Contents I. QUALITY ASSURANCE PROGRAM .................................................................................... 5 Q.1 Quality Assurance Oversight Activities ......................................................................... 5 Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure 35007) ................................................................................................................... 5 Q.1.2 Safety Conscious Work Environment (Inspection Procedure 35007 and Temporary Instruction 2512/015) .......................................................................... 5 II. MANAGEMENT OVERSIGHT AND CONTROLS ................................................................. 6 C.1 Construction Activities .................................................................................................... 6 C.1.1 Unit 1 and Unit 2 Construction Activity Interface Controls ..................................... 6 C.1.2 (Discussed) Pipe Support and Restraint Systems (Inspection Procedure 50090) 7 C.1.3 (Discussed) Reactor Coolant Pressure Boundary Piping Work Observations (Inspection Procedure 49053) ............................................................................... 7 C.1.4 (Discussed) Reactor Vessel and Internals Work Observation (Inspection Procedure 50053) .................................................................................................. 8 C.1.5 (Discussed) Verification of As-Builts (Inspection Procedures 37051,50073, and 50075) ................................................................................................................... 9 C.1.6 (Discussed) Electrical Components and Systems - Work Observation (Inspection Procedures 51053 and 37002) ............................................................................ 10 C.1.7 (Discussed) Electrical Cable - Work Observation (Inspection Procedures 51063 and 37002) .......................................................................................................... 10 C.1.8 (Closed) Reactor Coolant Pressure Boundary Piping Record Review (Inspection Procedure 49055) ................................................................................................ 12 C.1.9 (Closed) Structural Steel and Supports Record Review (Inspection Procedure 48055) ................................................................................................................ 13 F.1 Fire Protection ................................................................................................................ 15 F.1.1 Fire Protection (Inspection Procedure 64051) ..................................................... 15 P.1 Pre-Operational Activities ............................................................................................. 16 P.1.1 Preoperational Test Program Implementation Verification (Inspection Procedure 71302) ................................................................................................................. 16 P.1.2 (Discussed) Preoperational Test Procedure Review (Inspection Procedures 70300 and 70343) ............................................................................................... 17 P.1.3 (Discussed) Preoperational Test Witnessing (Inspection Procedures 70312 and 70443) ................................................................................................................. 18 IV. OTHER ACTIVITES ........................................................................................................... 19 OA.1.1 (Discussed) Q-List Corrective Action Program (Temporary Instruction 2512/029)

............................................................................................................................ 19 OA.1.2 (Discussed) Generic Letter 89-10: Safety-Related Motor-Operated Valve Testing and Surveillance (Inspection Procedures 50073 and 50075, Temporary Instruction 2512/109) .......................................................................................... 21 OA 1.3 (Discussed) Unresolved Safety Issue A-47, Safety Implication of Control Systems in LWR Nuclear Power Plants (Inspection Procedure 92701) ............................. 22

OA.1.4 (Discussed) Construction Deficiency Report 391/87-18: Deficiencies in installation of electrical conduit and conduit supports (Inspection Procedure 51055) ................................................................................................................ 24 OA.1.5 (Discussed) Construction Deficiency Report 391/86-59: Qualification of ASCO solenoid valve conduit connector configuration (Inspection Procedure 51055) . 24 OA.1.6 (Discussed) Violation (VIO) 391/86-21-02: Instrument valves, Foxboro transmitters, and instrument panels not seismically qualified (Inspection Procedure 51055) ............................................................................................... 26 OA.1.7 (Discussed) Quality Assurance Records Corrective Action Program (Temporary Instruction 2512/028) .......................................................................................... 27 OA.1.8 (Closed) Unresolved Item 05000391/2013613-01, Potential Inadequate Corrective Actions for Piping Misalignment (Inspection Procedure 92701)......... 28 OA.1.9 (Closed) TMI Action Item II.K.3.5: Automatic Trip of Reactor Coolant Pumps During Loss-Of-Coolant Accident (LOCA) (Inspection Procedure 92701) .......... 29 OA.1.10 (Closed) Construction Deficiency Report 391/89-05: Failure of Auxiliary Feedwater Steam Generator Level Controllers (Inspection Procedure 92701)... 30 OA.1.11 (Closed) IE Bulletin 79-27: Loss of Non-Class 1E Instrumentation and Control Power System Bus during Operation (IP 35007) ................................................ 32 OA.1.12 (Closed) CDR 391/86-21: Non-Quality Assurance Data Used in Calculations for Cable Tray and Conduit Loading (IP 35007) ...................................................... 33 V. MANAGEMENT MEETINGS .............................................................................................. 33 X1 Exit Meeting Summary ................................................................................................... 33

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) and service requests (SRs), 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 reviewed actions associated with the following PERs:

  • PER 781296, Inadvertent 1A component cooling water system (CCS) pump start due to startup group maintenance activity
  • SR 685106, Reactor pressure vessel mirror insulation non-conformance Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The issues identified in the PERs reviewed were adequately identified, addressed, and resolved.

Q.1.2 Safety Conscious Work Environment (Inspection Procedure 35007 and Temporary Instruction 2512/015)

a. Inspection Scope

The inspectors reviewed existing program requirements and recent safety-related concerns identified by the applicants and contractors employee concerns program. The inspectors also met with the employee concerns program coordinator to discuss program and personnel changes.

b. Observations and Findings

No findings 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

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, at least once per week, 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 select 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 select 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 work activities observed included work associated with:

  • Work Order (WO) WO 114825125, Splice ID WBN-SPL-2PP625-1 for System 072 which included overhead work in the Auxiliary Building Elevation 692
  • WO 111307969, 2-PMP-070-0131-A Startup Test and PER 781296, Inadvertent 1A CCS pump start due to startup group maintenance activity
  • PER 783250, Dow Corning silicon foam used on penetration seals Specific work activities that the applicant had screened out as not affecting Unit 1 included, but were not limited to, electrical work activities and refurbishment activities as noted in this inspection report.

b. Observations and Findings

No findings were identified. The inspectors reviewed immediate corrective actions following an inadvertent Unit 1 pump start that occurred on September 12, 2013, as a result of Unit 2 work activities. The inadvertent pump start had no significant adverse effect on nuclear safety. Corrective actions included a stand down with personnel and reinforcement of human error prevention tools.

c. Conclusions

Overall, 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 with the exception of the inadvertent Unit 1 pump start.

C.1.2 (Discussed) Pipe Support and Restraint Systems (Inspection Procedure 50090)

a. Inspection Scope

The inspectors observed one dynamic pipe support (snubber) installation for support 72-2CS-R149, reviewed the associated procedures, and reviewed two snubber installation records for 72-2CS-R149 and 63-2SIS-R276. The inspections were completed to verify that the work activities, relative to dynamic pipe support systems, were completed in accordance with NRC requirements and the applicants approved procedures. The inspectors observed the snubber installation to verify the support was free of damage and corrosion, pre-installation checks were completed, correct materials were used, extension rods and connecting joints were not deformed, the snubber was installed with the correct pin-to-pin and cold setpoints in accordance with the design specifications, and measuring and test equipment (M&TE) was properly controlled and calibrated. Design and installation records were reviewed to verify that the design inputs, to include field changes and vendor specifications, were properly translated to the field installation procedures and that the pipe support installation was completed in accordance with the approved drawing and design specifications.

The following sample was inspected:

  • IP 50090 Section 02.03.c - one sample Documents reviewed are listed in the attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The installations of the dynamic supports (snubbers) were completed in accordance with the approved drawings and procedures.

C.1.3 (Discussed) Reactor Coolant Pressure Boundary Piping Work Observations (Inspection Procedure 49053)

a. Inspection Scope

The inspectors observed the nondestructive examination (NDE) liquid penetrate (PT)examinations for the steam generator (SG) 2 tube sheet plug welds to verify the examinations were completed in accordance with procedure GQP 9.7, Solvent, Removable Liquid Penetrant Examination and Acceptance Standards for Welds, Base Materials, and Cladding, Revision (Rev.) 15. In addition, the inspectors reviewed six PT examination records for SGs 1 and 2 to determine whether the reports, evaluation data, and results, were in accordance with approved procedures and American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) code 1971 edition through 1973 summer addenda.

Documents reviewed are listed in the attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The NDE was completed in accordance with the approved procedures and the records reviewed were in compliance with the ASME B&PV code 1971 edition through 1973 summer addenda.

C.1.4 (Discussed) Reactor Vessel and Internals Work Observation (Inspection Procedure 50053)

a. Inspection Scope

The inspectors conducted inspections of the reactor pressure vessel (RPV) and reactor vessel internals storage, preservation, housekeeping, and protection activities to determine whether requirements, work procedures, and inspection (quality control)procedures were being met. These activities are controlled by procedure 25402-000-GPP-0000-N2102, Housekeeping, Rev. 8. The inspectors observed the use of platforms and scaffolding inside the vessel to verify the scaffolding was treated to prevent the spread of accidental fires. The core barrel and internals were inspected to verify storage locations were adequate and controls were in place to protect from construction damage.

The following samples were inspected:

b. Observations and Findings

No findings were identified.

c. Conclusions

Adequate controls were in place to protect the reactor vessel and internals.

C.1.5 (Discussed) Verification of As-Builts (Inspection Procedures 37051, 50073, and 50075)

a. Inspection Scope

The inspectors performed an as-built inspection of the flood mode boration system, System 084, to verify that construction drawings and specifications correctly reflected the as-built condition of the plant. The flood mode boration system, as described in the system description document, WBN2-84-4001, Rev. 2, is considered an essential system designed to perform a primary safety function by providing borated makeup water for the reactor coolant system (RCS) when the plant experiences a design basis flood. The inspectors reviewed applicant procedures to verify administrative controls were in place to ensure completion of as-built design documents, drawings, specifications, calculations, and critical documents required by operators. In addition, inspectors verified the applicants use of appropriate mark-up documents until the final documents are updated. This review included verification of the following:

  • Schedule for completion of as-built design documents has been established.
  • Procedures governing generation and completion of as-built design documents including design modifications, were adequate (i.e., drawings, specifications, and incomplete calculations).
  • Administrative controls and responsibilities have been clearly established.
  • Status of reviewed, approved, and revised changes that had not yet been incorporated in to the as-built design Inspectors also performed field inspections to verify location, configuration, and component identification for pipe supports, pipe welds, and piping to determine whether the design drawings and specifications reflected as-built conditions, for a sample of sections of system 084, which had been modified in support of Unit 2 construction activities. The inspectors walked down the as-built installation of the flood mode boration system auxiliary charging pumps 2A and 2B, reviewed the as-built drawings, and installation WOs to verify that the as-built final design drawings matched the actual installation. In addition, the inspectors reviewed the NRC-identified nonconformance report, PER 781247, which documented the failure of the applicant to provide adequate acceptance criteria from the vendor manual in the installation instructions for the 2A and 2B auxiliary charging pumps. The nonconformance record review was conducted to verify that the corrective actions were properly documented, were completely processed through the established corrective action program, and that the records were stored appropriately in the approved electronic database.

The following samples were inspected:

  • IP 37051 Section 02.01.b.1 - one sample (Piping Systems-Flood Mode Boration, System 084)
  • IP 50075 Section 02.03.b - one sample Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The as-built piping, supports, and components for selected modified sections of System 084 were in accordance with available drawings, field changes, specifications, and procedures. The nonconformance issue documented in PER 781247 was adequately documented and processed.

C.1.6 (Discussed) Electrical Components and Systems - Work Observation (Inspection Procedures 51053 and 37002)

a. Inspection Scope

The inspectors observed general electrical testing of 2-FCV-070-0100-A under WO 111480829, Perform GTE-11. The inspectors reviewed the latest revision of the applicable test procedures, drawings, and vendor documents to verify they were available as required and used by personnel performing the testing. Test apparatuses were reviewed to verify calibration and the inspectors confirmed that all equipment and components utilized could achieve the necessary levels of accuracy and tolerance to adequately document testing results. The inspectors observed test personnel documenting test results as testing was performed and reviewed personnel qualifications to verify applicant staff were properly trained and qualified for the duties they were performing. The inspectors reviewed testing discrepancies to verify they were properly identified and recorded for resolution.

The following sample was inspected:

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors determined that adequate measures were in place to ensure the applicant was performing construction testing in accordance with applicable regulatory requirements, standards, and site procedures.

C.1.7 (Discussed) Electrical Cable - Work Observation (Inspection Procedures 51063 and 37002)

a. Inspection Scope

The inspectors observed and inspected applicant personnel performing medium voltage power cable terminations and splices involving application of stress cones for dielectric stress control. The inspectors reviewed work packages to verify that the latest approved revision of applicable construction specifications, drawings, and procedures were available and used by the installers, as well as relevant vendor instructions as referenced by site procedures. The inspectors reviewed materials and their associated records to verify that they were as specified. Crimping tools were inspected to verify that they were in proper working order and properly calibrated and controlled. Cable marking was observed to verify that it matched installation and in-process records and that cable identification was preserved through the splice or termination process. Activities were observed to verify that the cable was physically protected from insulation or jacket damage, bending radius violations, and moisture or environmental contamination. The inspectors witnessed quality control (QC) personnel verification of dimensions and attributes throughout the termination or splice application and independently verified certain measurements and cable attributes. Qualifications and training of craft and QC personnel was reviewed to verify that all licensee requirements for this work had been met by those involved. The terminations or splices were inspected to verify that the terminations were of the correct type, properly located, and appropriately tight for the application. The inspectors reviewed in-process records to verify that installation and inspection activities were being documented throughout and that non-conformances were identified, dispositioned, and addressed in accordance with site procedures.

Specific work activities observed included work associated with:

  • WO 114825125, EDCR (Engineering Document Construction Release) 55121 PER 595694 SR 776079 Field Change Request (FCR) 61651 SYS 072 211 BC CABLE TERMINATIONS, Splice ID WBN-SPL-2PP625-1 affecting WBN-2-MTR-072-027-A
  • WO 113228892, SR 777972, 778560, 780718 SYS 072 EDCR 55121 FCR 57130, 56071 affecting WBN-2-MTR-072-010-B
  • WO 114565720, EDCR 55121 SYS 074, 211,292 CABLE TERMINATIONS, affecting WBN-2-MTR-074-020-B termination at 2-BD-211-B/14-B
  • WO 114565720, EDCR 55121 SYS 074, 211,292 CABLE TERMINATIONS, Splice ID WBN-SPL-2PP587 affecting WBN-2-MTR-074-020-B Additionally, inspectors followed up on licensee disposition and corrective actions associated with NRC identified PER 782452 (September 19, 2013), Verification of Dimensions IAW Vendor Instructions, to verify that the licensee adequately captured the concern and implemented corrective actions commensurate with the apparent inadequacies.

The following samples were inspected:

  • IP 51063 02.02.c (in-process installation) - four samples

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors determined that adequate measures were generally in place to ensure the applicant was prepared for splices/terminations and that procedures were adequate and appropriately followed during the splicing and terminating operations, with appropriate QC oversight.

C.1.8 (Closed) Reactor Coolant Pressure Boundary Piping Record Review (Inspection Procedure 49055)

a. Inspection Scope

Background: As described in Inspection Manual Chapter (IMC) 2517 (Agencywide Documents Access and Management System (ADAMS) Accession Number [No.]

ML13136A301), TVA addressed WBN Unit 1 construction quality issues as part of the implementation of its nuclear performance plan (NPP). The results of the NRC inspection program were published in NUREG-1528, Reconstitution of the IMC 2512 Construction Inspection Program for Watts Bar Unit 1 (ADAMS Accession No.

ML073450842. In 1985, construction on Watts Bar Unit 1 and Watts Bar Unit 2 was stopped due to the identification of multiple construction QA issues. TVA completed Unit 1 in 1995 but had conducted very little Unit 2-specific work since 1985. In 2007, TVA decided to finish the Unit 2 plant. As part of confirming that all issues and inspection requirements will be completed for Unit 2, a review of all NRC inspection reports was initiated to determine the status of the required IPs, contained in NRC IMC 2512, in effect at the time construction was stopped. This effort was called the reconstitution process. The NRC used the results of the reconstitution process to identify areas which require additional inspections. NRC integrated inspection report (IIR) 05000391/2009602 (ADAMS Accession No. ML091210420), Attachment 2, documented the reconstitution results for IP 49055 and determined that the requirements of the IP were met for Unit 2.

In addition, new reactor pressure boundary piping work or activities performed in areas covered by IP 49055 would be inspected. The majority of the reactor coolant pressure boundary piping work activities were completed and inspected prior to Unit 2 construction reactivation in 2007. The inspection scope, for new work, included a sample of weld repairs, cleanliness, sensing line, and instrument line work activities.

Inspection Activities: The purpose of this IP was to review a sample of reactor coolant pressure boundary piping records to determine if the applicants system for preparing, reviewing, and maintaining records met the applicable requirements to include NRC requirements and Safety Analysis Report (SAR) commitments. The following table lists the inspections that were performed under this IP.

IP Section Inspection Report 02.01 Receipt and Installation Records 05000391/2010602 (ADAMS Accession No.

ML101230144)05000391/2013605 (ADAMS Accession No.

ML13220A640 02.02 Non-Conforming Reports (NCRs) 05000391/2010602 05000391/2010603 (ADAMS Accession No.

ML101230144 02.03 Personnel Qualification Records 05000391/2010602 05000391/2013605 02.04 Audit and Surveillance Records 05000391/2010602 Section 02.05 required an expansion of the sample size as appropriate. At this time the additional sampling sections are not required.

b. Observations and Findings

No findings were identified.

Below is a summary of each section of IP 49055:

  • Section 02.01 - Complete
  • Section 02.02 - Complete
  • Section 02.03 - Complete
  • Section 02.04 - Complete
  • Section 02.05 - Inspection not required c. Conclusion The inspectors determined that the records associated with the reactor coolant pressure boundary piping met the applicable requirements. IP 49055 is considered closed; however, if additional reactor coolant pressure boundary piping activities are performed, inspections may be performed at the NRCs discretion.

C.1.9 (Closed) Structural Steel and Supports Record Review (Inspection Procedure 48055)

a. Inspection Scope

Background: The purpose of this IP was to confirm documentation met requirements for approximately half of the activities described in IP 48053 and a small sample of additional activities. This IP includes receipt inspection and material certification, installation inspections, nonconformance/deviation records, training/qualification records, and QA audits. As documented in NRC IIR 05000391/2009602 (ADAMS Accession No. ML091210420), the reconstitution of this IP determined that the requirements for satisfying this IP were accomplished and documented in previous construction inspection reports. New construction work or activities performed in areas covered by this IP were reviewed as part of the rework inspection effort.

Inspection Activities: The inspectors reviewed records for Unit 2 to determine whether:

  • records were legible, complete, reviewed by QC personnel, and readily retrievable;
  • the licensees system for preparing, reviewing, and maintaining records was effectively implemented;
  • records reflected work accomplishment consistent with specifications and procedures; and
  • records indicated any potentially generic problems, management control inadequacies, or other weaknesses that could have safety significance.

The inspectors reviewed documentation generated for a representative sample of the new construction work activities for structural steel and supports reviewed using IP 48053, Structural Steel and Supports Work Observation to determine whether the applicants system for documenting safety-related work was functioning properly.

Receipt inspection and material certification records were reviewed to verify that required performance tests, nondestructive tests, and environmental qualification (EQ)tests were performed; material characteristics and other specification requirements were met; and the records classification system was adequate. The inspectors reviewed closed WO packages to verify records confirmed that components were installed as specified, the required inspections were performed, acceptance criteria were defined, test records quantitatively indicated test results and acceptance criteria, and required protection was provided after installation. The inspectors reviewed a sample of PERs to verify that items status and corrective actions were included, the appropriate structural review was performed, and the structural engineering review ensured that the structures were adequately designed for the as-built loading conditions. The inspectors reviewed a sample of training and qualification records for craft and QC inspectors to verify the records were complete and current, the QC personnel were adequately qualified for their assigned duties and responsibilities, and the craft personnel were trained in their assigned tasks. Although no QA audits were performed for new structural steel work, the inspectors reviewed a sample of surveillance reports and associated documentation to verify that deficiencies identified during surveillances were corrected and that corrective actions were adequate.

The following samples were inspected:

  • IP 48055 Section 02.01.a - seven samples
  • IP 48055 Section 02.02.c - no samples - Audits were not performed on new work and these records were unavailable for inspection.

Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors reviewed the applicants documentation for the new construction work and determined that the documentation requirements were met concerning materials receipt, storage, fabrication, erection, inspection, and testing of steel structures and supports. The inspectors concluded that the applicant has satisfied the intent of the IP.

IP 48055 is considered closed; however, if additional structural steel and support activities are performed, inspections of completed records may be performed at the NRCs discretion.

F.1 Fire Protection F.1.1 Fire Protection (Inspection Procedure 64051)

a. Inspection Scope

The inspectors performed a walkdown of construction areas to determine whether construction activities and areas met procedure requirements for fire protection. The inspectors took a limited set of field-verifiable attributes from preventive maintenance guidance into the field and evaluated 10 fire suppression devices. The inspectors reviewed labeling, accessibility, cartridge weight, extinguisher agent, and material condition of fire extinguishers to verify no evidence of deterioration was present, the extinguisher agent was free of contamination, and cartridge weight met the preventive maintenance specifications. The inspectors reviewed preventive maintenance instructions to determine whether records of these 10 fire suppression devices met procedure inspection requirements.

The inspectors observed one construction activity using ignition sources to determine whether fire prevention procedure requirements were met. This included the handling and use of flammable materials and the use of combustible materials relative to locations of flammable ignition sources. Specifically, the inspectors observed fire watch activities related to:

  • WO 114565720, EDCR 55121 SYS 074, 211,292 CABLE TERMINATIONS, affecting WBN-2-MTR-074-020-B termination at 2-BD-211-B/14-B The following fire suppression devices were observed, and associated records were reviewed:

Temporary Hose stations:

  • 2-THS-26-750-90 U2 Annulus El. 750 Az. 90
  • 2-THS-26-730-90 U2 Annulus El. 730 Az. 90
  • 2-THS-26-710-90 U2 Annulus El. 710 Az. 90
  • 2-THS-26-ANN-ENT E of U2 Reactor building
  • 2-THS-26-LWR-CONT Raceway Lower Containment Portable Fire Extinguishers:
  • U2-FW-6 U2 Safety Trailer
  • U2-FW-21 U2 Safety Trailer
  • U2-FW-23 U2 Safety Trailer
  • U2-FW-27 U2 Safety Trailer
  • U2-FW-29 U2 Safety Trailer
  • U2-FW-43 U2 Safety Trailer
  • U2-FW-53 U2 Safety Trailer
  • U2-FW-68 U2 Safety Trailer
  • U2-FW-78 U2 Safety Trailer
  • U2-FW-95 U2 Safety Trailer The following samples were inspected:
  • IP 64051 Section 02.07 - 15 samples Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The applicant generally implemented adequate fire protection measures and controls to support Unit 2 construction activities and minimize impact on Unit 1 operational activities.

P.1 Pre-Operational Activities P.1.1 Preoperational Test Program Implementation Verification (Inspection Procedure 71302)

a. Inspection Scope

02.01 (Weekly Inspection Activities): The inspectors conducted weekly tours of various accessible areas of the facility to assess equipment conditions, general plant conditions, and adherence to regulatory requirements. The areas inspected during this inspection period are listed below. The areas were inspected for fire hazard and availability of firefighting and extinguishing equipment (further discussed in Section F.1.1).

Preoperational testing and maintenance activities in progress were observed to verify they were being conducted in accordance with the applicants procedures. The inspectors engaged in discussions with test and maintenance personnel to verify the individuals had an understanding of the procedures being used and were following proper sequencing and work practices. While touring the areas, the inspectors observed work practices such as cable pulling, test instrumentation installation and storage, construction work, and FME controls to ensure methods used were in accordance with applicant procedures. Additionally, the inspectors reviewed problems identified during the preoperational testing to ensure they were being adequately documented and assessed. The following systems were inspected:

  • System 072-containment spray (CS)
  • System 067-essential raw cooling water (ERCW)
  • System 070-component cooling water (CCS)02.02 (Monthly Inspection Activities): During this inspection period, the inspectors reviewed the turnover package for the Unit 2 portion of the component cooling water system (System 70) as part of Startup Manual Procedure (SMP) 4.0, System Completion and Turnover, Rev.9, to verify jurisdiction controls were appropriate and applicant procedures were followed. Additionally, the inspectors reviewed the turnover package to ensure required preventative maintenance was incorporated into a schedule for accomplishment.

During this inspection period, the inspectors reviewed maintenance plans on safety-related equipment, to determine if the maintenance was scheduled in accordance with developed procedures and that these procedures were adequate for the maintenance being performed. The maintenance was not required to be performed but the methodology was discussed with the Refurbishment and Preventative Maintenance Manager to determine how systems with completed preoperational testing would be protected.

b. Observations and Findings

No findings were identified. The preoperational test program implementation verification inspections commenced during the inspection period and, therefore, the total number of systems being tested was limited. The applicant plans to turnover additional systems in the future at which point IP 71302 will be performed on a recurring basis.

c. Conclusions

The applicants implementation of the preoperational test program was in accordance with procedures for those activities observed during the inspection period.

P.1.2 (Discussed) Preoperational Test Procedure Review (Inspection Procedures 70300 and 70343)

a. Inspection Scope

Background: The purpose of IMC 2513, Light Water Reactor Inspection Program -

Preoperational Testing and Operational Preparedness Phase, issue date January 1, 1984, is to verify through direct observation, personnel interviews, and review of facility records that:

  • Systems and components important to the safety of the plant are fully tested to demonstrate that they satisfy their design requirements.
  • Management controls and procedures, including quality assurance programs, necessary for operation of the facility have been documented and implemented.

IMC 2513 defines the minimum inspection program for a finding of readiness for license issuance (IP 94300, Status of Plant Readiness for an Operating Licensee). IMC 2513 requires the procedural review of the mandatory tests defined in IMC 2513 and five of the primal tests defined in IMC 2513. The following inspection was performed in relation to satisfying the required procedural review.

Inspection Activities:

The inspectors reviewed pre-operational test procedure 2-PTI-072-02 to verify that the procedure contained the following administrative good practice attributes:

  • the title described the purpose of the procedure;
  • the cover page had appropriate information and approval signatures;
  • each page had appropriate identification information and the last page was clearly identifiable;
  • a clear statement of procedure purpose/objectives;
  • planning information such as prerequisites, precautions, required tools, reference documents, and coordination requirements;
  • clearly identified and appropriate QC hold points;
  • signoff requirements including concurrent and independent verification steps established where appropriate;
  • equipment alignment instructions are clear and concise;
  • actions to be taken within the steps are specifically identified (20 percent sample);
  • graphs, charts, tables, data sheets, and work sheets are clearly usable;
  • clear instructions for system restoration;
  • guidance for follow-up actions and points of contact;
  • overall, clear concise steps for testing with action critical (acceptance criteria);steps identified (20 percent sample);
  • clear quantitative acceptance criteria with acceptability and contingencies; and
  • overall sequence of the procedure consistent with the obtaining the intended result.

The inspectors also reviewed the procedure to verify that precautions or explanations were placed immediately ahead of the steps to which they applied. The inspectors performed a detailed review with the responsible test engineer to verify that the acceptance criteria met design requirements.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors determined that the applicants test procedure was written in a manner consistent with the guidance of procedure SMP-8.0, Watts Bar Nuclear Plant Unit 2 Administration of Preoperational Test Instructions, Rev. 9.

P.1.3 (Discussed) Preoperational Test Witnessing (Inspection Procedures 70312 and 70443)

a. Inspection Scope

The inspectors witnessed the performance of pre-operational testing to verify that the testing was conducted in accordance with approved procedures and to verify the adequacy of test program records and preliminary evaluation of test results. The inspectors performed the following activities associated with this test observation:

  • All test personnel were on station and had the latest revision of the procedure.
  • Test prerequisites were performed (50 percent sampling).
  • Plant systems were in service to support the test (50 percent sampling).
  • Test equipment was installed and within calibration.
  • Testing was performed in accordance with the approved procedure.
  • Testing interruptions and continuations were handled in accordance with approved procedures.
  • Testing events and discrepancies were properly documented.
  • Testing was executed and coordinated properly.
  • Data was properly collected.
  • Temporary equipment was installed and tracked appropriately.
  • Administrative test controls were properly followed.
  • Test personnel were using approved drawings and vendor manuals.

The inspectors observed the test to verify that the overall test acceptance was met. The inspectors conducted a review with the responsible test engineer to assure that the preliminary test evaluation was consistent with the inspectors observations. During the test, the inspectors observed important data gathering activities to ensure the data was properly gathered and recorded. A post-test cursory review of the test data was performed to verify legibility, traceability, and permanence of the data sheet entries.

The specific test observed was as follows:

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors determined that testing was being conducted in a manner consistent with the guidance of procedure SMP-9.0, Watts Bar Nuclear Plant Unit 2 Conduct of Test, Rev. 2. The inspectors observed that, when problems were encountered, testing was promptly suspended, the problems were documented, and management was immediately notified. The inspectors concluded that testing activities were performed in accordance with the test instructions, and communications and test staff were adequate to support testing. A preliminary review of the test data indicated, with the exception of the test deficiency notices, acceptance criteria had been met.

IV. OTHER ACTIVITES OA.1.1 (Discussed) Q-List Corrective Action Program (TI 2512/029)

a. Inspection Scope

Background: This Corrective Action Program (CAP) program was developed after TVA identified the following issues with the WBN Unit 1 Q-List Program:

  • Multiple Q-Lists existed.
  • Project personnel were inadequately trained.
  • Safety and quality related classifications were lacking or incorrect.
  • The Q-List contained incorrect component identifications.

As part of corrective action for the Unit 1 CAP, TVA developed a new Q-List, compared it to the old Q-List and reviewed records for maintenance and modification activities to assure that these activities had the appropriate QA program controls applied to them.

This effort resulted in over 5000 Unit 1 component classification upgrades. The resulting final Q-List and development plan was previously reviewed by the NRC and the Q-List CAP was closed for Unit 1 in NRC inspection report 50-390/94-27 and 50-391/94-27 (ADAMS Accession No. ML072530549). In this report, the NRC inspection team concluded:

  • The development and implementation of the new Q-List was satisfactory.
  • The historical reviews done by TVA, concerning the effects of the differences between the classification of items on the old and new list, were technically sound.
  • These reviews showed that the differences in classification of plant items resulted in no technical differences in the way work or maintenance was completed.

The Q-List has been incorporated into the Master Equipment List (MEL) maintained in the MAXIMO database. The safety-related and quality-related component classifications for both units were merged into the MEL from the updated Q-List. The MEL is intended to be a record of the final, as-installed hardware and components to be used to support operation, maintenance, and modifications.

In lieu of developing and comparing a new Unit 2 Q-List to the old Unit 2 Q-List, the applicant used the Unit 1 Q-List as the basis for the Unit 2 Q-List. The Unit 2 construction completion MEL was copied from the Unit 1 MEL with the unit designator changed to Unit 2 and all the data initially shown as unverified. Also, the Unit 2 components required for Unit 1 operation were removed from the Unit 2 list because they were already turned over to Unit 1 operations. For those components which had the same unique identifier (UNID) and function in both units, classification for Unit 2 was based on Unit 1 but verified to be correct. For those systems where the components in Unit 2 had a different UNID than the same components in Unit 1, the applicant evaluated the components in the Unit 2 MEL for proper classification. The applicant evaluated existing safety-related and quality-related components by program and system to determine acceptability as use as is. Components not meeting the programmatic acceptability requirements were, or are planned to be, replaced or refurbished to ensure the appropriate quality level is achieved.

Inspection Activities: The inspectors reviewed the Unit 2 Q-List CAP engineering complete closure package to ensure that the proposed actions would satisfy the concerns that initiated the Q-List CAP. The inspectors reviewed a sample of completed actions associated with the Q-List CAP to evaluate whether the program was adequately developed and implemented. The inspectors reviewed several implementing procedures associated with the Q-List CAP to determine if the corrective actions were adequately captured and communicated. Several procedures for entering, changing, and verifying information on the MEL and in MAXIMO were also reviewed to evaluate the adequacy of administrative controls. The inspectors reviewed a sample of training records and interviewed personnel responsible for updating and verifying information in MAXIMO to verify that they were adequately trained.

The inspectors reviewed MEL records of installed hardware for a sample of safety-related components in the component cooling water system (System 70). The sample was compared with the system requirements in the final safety analysis report (FSAR) to verify that the components were correctly classified and that system interfaces between safety related and quality related components aligned with the system safety function.

Additionally, the inspectors completed a walkdown of the Unit 2 portion of System 70, including some of the interfaces between Units 1 and 2, to independently verify that reliable data was established in the information system including:

  • The MEL accurately reflected the component status in the field.
  • The components were appropriately labeled in the field.
  • The MEL contained correct component safety and quality classifications, UNIDs, and locations.
  • The hardware information, such as type of component and manufacturer, was accurately documented in the MEL.

The most recent self-assessment of the MEL, a sample of PERs and associated corrective actions, and a sample of surveillance reports were reviewed to verify that the Q-List CAP was being implemented appropriately within the MEL. The inspectors also reviewed the process for replacing and updating component identification tags in the field to verify that the components maintained traceability and that any updated information was documented in the MEL.

Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

Because the Q-List captures the final, as-built components, the Unit 2 Q-List is still in an early stage of completion and the inspectors were not able to evaluate the adequacy of program implementation. Therefore, additional inspection activities are required prior to closure of the Q-List CAP. Specifically, further inspections will be required to monitor the implementation of the Q-List CAP once a larger portion of the Q-List is finalized.

OA.1.2 (Discussed) Generic Letter 89-10: Safety-Related Motor-Operated Valve Testing and Surveillance (Inspection Procedures 50073 and 50075, Temporary Instruction 2512/109)

a. Inspection Scope

Background: This generic letter (GL) 89-10 (ADAMS Accession No. ML8906290082)highlighted industry generic problems with motor operated valves (MOVs) and requested licensees to provide additional assurance of the capability of safety-related MOVs to perform their intended functions by reviewing MOV design bases, verifying MOV switch settings (initially and periodically), testing MOVs under design-basis conditions (where practicable), improving evaluations of MOV failures and necessary corrective action, and trending MOV problems.

Inspection Activities:

The inspectors observed testing conducted on two MOVs from their respective motor-control centers (MCCs) in the 480V switchgear rooms. Specifically, the inspectors witnessed testing being conducted at the MCC and reviewed the applicants evaluation of the MOV diagnostic test results. The valve tests witnessed and test data reviewed by the inspectors were associated with MOVs 2-FCV-67-83-B and 2-FCV-67-104-A.

The inspectors reviewed the applicants engineering complete package review, of the diagnostic tests performed on these two MOVs, and compared the valve setup and test results to verify they were in accordance with TVAs corporate MOV program.

Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified. While the field static (no flow) diagnostic tests are complete for these two valves, the remaining work is to conduct static and dynamic diagnostic testing of the safety-related valves contained in the WBN Unit 2 MOV program. The same procedures for MOV testing are utilized for both units at WBN.

c. Conclusions

The inspectors concluded that testing of safety-related MOVs is being conducted in accordance with the applicants procedures and MOV test program. Additional MOV testing needs to be observed both under static and dynamic test conditions.

OA 1.3 (Discussed) Unresolved Safety Issue A-47, Safety Implication of Control Systems in Light Water Reactor Nuclear Power Plants (Inspection Procedure 92701)

a. Inspection Scope

Background: In 1989, the NRC issued GL 89-19 (ADAMS Accession No. ML8909070029) requesting action to resolve Safety Issue A-47, Safety Implications of Control Systems in Light Water Reactor (LWR) Nuclear Power Plants pursuant to 10 CFR 50.54 (f). The NRC concluded that protection should be provided for certain control system failures and that selected emergency procedures should be modified to assure that plant transients resulting from control system failures do not compromise public safety.

Watts Bar is a Westinghouse pressurized water reactor (PWR) with two of three coincident logic for automatic main feedwater isolation and feedwater pump trip on steam generator high-high level. This is a safety grade trip in the reactor protection system. One of the three level transmitters for each loop provides an isolated output to the steam generator level control system located in a cabinet separate from the protection circuit. Based on this, Watts Bar is considered a Group 1 plant.

NRC technical report designations (NUREGs) 1217 and 1218 concluded that the overfill protection system for Group 1 plants is satisfied by providing adequate protection which includes demonstrating the evaluation of common mode failures due to fire.

For Unit 2, TVA issued framework letter dated January 29, 2008, Watts Bar Nuclear Plant (WBN) Unit 2 - Regulatory Framework for the Completion of Construction and Licensing for Unit 2 (ADAMS Accession No. ML080320443), Enclosure 2, Item 075, GL89-19, Request for Actions Related to Resolution of Unresolved Safety Issue A-47; Safety Implication of Control Systems in LWR Nuclear Power Plants -- Perform evaluation of common mode failures due to fire.

Inspection Activities: To address Unit 2 actions the inspectors performed the following:

The inspectors reviewed a sample of cable routing used in the safe shutdown analysis calculations EDQ00099920090012, Unit 1 and Unit 2 Appendix R Safe Shutdown Analysis, Rev. 2, and EDQ00099920090013, Appendix R- Unit 2 Cables Required or Safe Shutdown, Rev. 2. The review included a sample of conduit and grounding drawings, fire protection compartmentation drawings, and associated integrated cable and raceway design system (ICRDS) data, to verify that the steam generator hi-hi level protection and the level control system routing met the fire protection requirements of GL 89-19. In addition, the inspectors reviewed the safe shutdown analysis, for the Appendix R credited steam generator level instrumentation, to determine if instrumentation selection was accurate, cables met separation requirements, and the analysis supported safe shutdown. The inspectors interviewed the fire protection engineer, responsible for the safe shutdown analysis, to determine if the data (equipment, cables, cable runs, and fire areas) used in the software program credited for safe shutdown fire analysis was accurate and the design control measures were established to manage the as-constructed safe shutdown fire analysis. In addition, the inspectors discussed, with the fire protection engineer, the safe shutdown design strategy for the planned use of manual actions to satisfy the Appendix R requirements for the steam generator hi-hi level protection and the level control system.

Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The design methodology for the steam generator hi-hi level protection and the level control system routing met the fire protection requirements of GL 1989-19. Although the applicant did not meet the separation criteria for the level instrumentation, the applicants design includes the strategy to credit manually stopping the auxiliary feedwater pumps to satisfy Appendix R requirements. The motor-driven auxiliary feedwater pumps were designed to stop from the main control board (MCB) using their respective switches.

The turbine-driven auxiliary feedwater pump was designed to stop by closing one of three in-series valves (2-FCV-1-17-A, or 2-FCV-1-18-B, or 2-FCV-1-52) to isolate steam.

The as-designed Safe Shutdown Analysis accurately identified the cabling, routing, and fire areas for the listed valves. Additional inspection activities are recommended prior to closure of Unresolved Safety Issue A-47.

OA.1.4 (Discussed) Construction Deficiency Report 391/87-18: Deficiencies in Installation of Electrical Conduit and Conduit Supports (Inspection Procedure 51055)

a. Inspection Scope

Background: On December 9, 1985, TVA reported a problem in accordance with 10 CFR 50.55(e) relative to various discrepancies on conduits and conduit supports of Unit 1 and Unit 2. These conduit and conduit support discrepancies were reported to the NRC under CDR 390/86 -14 and 391/87-18 for Unit 1 and 2, respectively. NRC IIR 05000391/2013605 (ADAMS Accession No. ML13220A640), Section OA.1.8, documented previous inspection results and background details of CDR 391/87-18.

Inspection Activities: The inspectors interviewed applicant staff and reviewed the applicants engineering complete closure package, including referenced documents and actions associated with PERs 143879, 144966, and 144177, to determine if the corrective actions associated with the hardware deficiencies in conduit and conduit supports were resolved and properly documented. The inspectors observed the as-built condition of several conduits, identified in these PERs, and compared them against PER records, engineering evaluation walkdown packages, and engineering drawings to determine if they matched the as-built condition. The following conduit segments were walked-down by the inspectors:

  • Conduit segment of 2-2PM-292-7267G as shown in page 12 of Limited Scope Walkdown (LSWD) 497.
  • Conduit segment of 2-3VC-293-3449B as shown in page 10 of Walkdown Package WBN2-C-293-817-06.

Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

Corrective actions were conducted in accordance with the PERs corrective action plan, and the as-built condition matched final drawings and records. CDR 391/87-18 will remain open pending the review of programmatic aspects developed, by the applicant, for addressing previously identified issues associated with loose, damaged and missing hardware, and conduit parts.

OA.1.5 (Discussed) Construction Deficiency Report 391/86-59: Qualification of ASCO Solenoid Valve Conduit Connector Configuration (Inspection Procedure 51055)

a. Inspection Scope

Background: The subject deficiency was initially reported to the NRC on July 11, 1986, with an interim report issued on August 11, 1986, and the final report issued on October 5, 1987. After a review, the NRC determined this deficiency was associated with notice of violation 50-391/86-18-01, issued as part of NRC Inspection Report 50-390/86-18 and 50-391/86-18 (ADAMS Accession No. ML072480310).

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 Institute of Electrical and Electronics Engineers (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 CDR WBRD 50-391/86-59.

The first example of this violation was also documented in CDR 391/87-11, and closed in NRC IIR 05000391/2012609 (ADAMS Accession No. ML12356A073). The second example was addressed by CDR 391/86-59. Nuclear Central Office (NCO) tracking items NCO0870290002 and NCO870290004 were initially written to track CDR 391/86-59, and PER 143758, was later used to track these commitments.

The applicant determined that the cause of this deficiency was an ineffective interface review that resulted in the failure to maintain seismic qualification of instruments and their attachments. The applicant, as appropriate, revised and issued drawings, calculations, walkdowns and procedures to ensure that conduits attaching to instruments and equipment were properly installed and documented, and to prevent recurrence.

Inspection Activities: The inspectors interviewed applicant staff and reviewed the applicants engineering complete closure package, including referenced documents and actions associated with PER 143758 to determine if the corrective actions associated with maintaining seismic qualification of category IE and I(L) instrumentation and equipment were properly resolved and documented.

The inspectors observed the as-built condition of several instrument panels, identified in this PER, and compared them against the LSWD-0528, Rev. 0, package to determine if they matched the as-built condition. The following instrument panels were walked-down by the inspectors:

  • 2-PNL-276-L016
  • 2-PNL-276-L349A
  • 2-PNL-276-L349B
  • 2-PNL-276-L027
  • 2-PNL-276-L439A
  • 2-PNL-276-L665
  • 2-PNL-2-L-513 Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

Corrective actions were conducted in accordance with the PERs corrective action plan, and the as-built condition matched final drawings and records. Additional document review is planned to be performed to ensure that changes to procedures, instructions, and drawings do not affect original commitments for this CDR. Supplementary field observations are recommended to verify whether implemented corrective actions adequately accepted and corrected discrepancies on existing installations and control future rework and installations.

OA.1.6 (Discussed) Violation (VIO) 391/86-21-02: Instrument Valves, Foxboro Transmitters, and Instrument Panels Not Seismically Qualified (Inspection Procedure 51055)

a. Inspection Scope

Background: On February 12, 1987, NRC-identified Violation (VIO) 391/86-21-02 was issued as part of NRC Inspection Report 50-390/86-21 and 50-391/86-21(ADAMS Accession No. ML082280243). NRC inspectors identified three examples where instrument and equipment installations did not match configurations used during seismic qualification. The VIO concerned TVAs failure to ensure that vendor information, specifically seismic qualification reports and calculations, was correctly translated into specifications, drawings, procedures, instructions, and the field installation as required by 10 CFR Part 50, Appendix B, Criterion III.

This VIO included both hardware and documentation deficiencies. The deficiencies resulted mainly from modifications which impacted equipment seismic qualification. The examples included additional unused mounting holes in B-19 transmitter support brackets, conduit attachments to Foxboro N-E10 transmitters, and bolting configurations on floor mounted instrument panels, that were not consistent with the seismically qualified condition. For Unit 2, the applicants corrective action was to perform seismic analyses to address the deficient conditions and to replace all the Foxboro transmitters and support brackets existing in the plant with Rosemount transmitters.

Inspection Activities: The inspectors interviewed applicant staff and reviewed the applicants engineering complete closure package, including referenced documents and actions associated with PERs 143758, 143701, and 143538 and commitment tracking number 114113692, to determine if the corrective actions associated with the seismic qualification deficiencies were properly resolved and documented.

The inspectors observed the as-built condition of several instrument racks installed in series and associated with PER 143758. These instrument racks were compared against LSWD-0528 and installation drawings to determine if these matched the as-built condition. The instrument racks associated with the following instrument panels were walked-down by the inspectors:

  • 2-PNL-276-L016
  • 2-PNL-276-L349A
  • 2-PNL-276-L349B The inspectors observed the as-built condition of several Rosemount transmitters, including support brackets, associated with PERs 143758 and 143701. These transmitters were compared against design and installation drawings to determine if these matched the as-built condition. The following newly installed Rosemount transmitters were walked-down by the inspectors:
  • FT-70-215A
  • FT-70-215B Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

Corrective actions were conducted in accordance with the PERs corrective action plan, and the as-built condition matched final drawings and records. Additional document review is planned to ensure that changes to procedures, instructions, and drawings do not affect original commitments for this violation. Supplementary field observations are recommended to verify whether implemented corrective actions adequately accepted and corrected discrepancies on existing installations and control future rework and installations.

OA.1.7 (Discussed) Quality Assurance Records Corrective Action Program (Temporary Instruction 2512/028)

a. Inspection Scope

Background: The background of this CAP is outlined in NRC IIR 05000391/2010603 (ADAMS Accession No. ML102170465).

Inspection Activities: The inspectors interviewed responsible program management to determine the progress of activities implemented by the applicant, to assess the status of quality assurance records. In addition, the inspectors examined samples of in-process record assessments that were being processed by electrical engineering. The assessments of records for electrical cables, cable trays, conduits, equipment, and instruments were inspected to evaluate the assessments scope, diversity of records selected, and quality of records selected.

Documents and records reviewed for this inspection are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusion The inspectors determined that further inspection is recommended to evaluate the completed assessments performed by the applicant and to obtain sufficient samples to assure that the program objectives would be met.

OA.1.8 (Closed) Unresolved Item 05000391/2013613-01, Potential Inadequate Corrective Actions for Piping Misalignment (Inspection Procedure 92701)

a. Inspection Scope

Background: This issue was documented due to challenges experienced by the applicant regarding piping alignment to many components leading to a concern about the adequacy of the processes for piping alignment. The issue was first documented in PER 52882 which documented that multiple pumps had been affected and that personnel were not following procedures. The applicant also documented this problem in PER 719716 to address questions associated with the unresolved item (URI). This item was left open pending observation of field work, review of corrective actions, and evaluation of procedure adequacy.

Inspection Activities: The inspectors observed field work, reviewed the two PERs and associated corrective actions, reviewed procedure changes that were implemented and held discussions with applicant personnel.

Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified. Observations and reviews showed that the existing procedure controls were in place to ensure final piping alignment to components was correct. Inefficiencies had occurred due to procedures not adequately being tied to one another and weaknesses in craft knowledge. Information contained in the original PER 528852 led to corrective actions which were not documented in the PER. These included proposed procedure enhancements and establishment of a team to improve the alignment process. The original PER stated that personnel had not followed procedures for the alignment process on some non-safety-related pumps. This statement was contained in the corrective action plan portion of the PER. In addition, a corrective action for PER 719796 was to evaluate the previous PER. However, since processes existed to eventually ensure proper alignment, these were considered to be minor documentation weaknesses. Corrective action for PER 719796 did result in craft training and procedure improvements.

c. Conclusions

Processes were in place to ensure final alignment met requirements; therefore, this URI is closed without escalation to a violation.

OA.1.9 (Closed) TMI Action Item II.K.3.5: Automatic Trip of Reactor Coolant Pumps During Loss-Of-Coolant Accident (LOCA) (Inspection Procedure 92701)

a. Inspection Scope

Background: As a result of the accident at TMI-2, the NRC created a number of action items designed to improve a plants ability to minimize accident occurrence and accident consequences. These TMI action items were initially outlined in NUREG-0660, NRC Action Plan Developed as a Result of the TMI-2 Accident (ADAMS Accession No.

ML072470524) and later clarified in NUREG-0737, Clarification of TMI Action Plan Requirements (ADAMS Accession No. ML102560051).

TMI Action Item II.K.3.5 resulted from the generic reviews of small-break loss of coolant accidents. Based on these reviews, specific requirements were generated to provide for the automatic trip of reactor coolant pumps (RCPs) at PWR plants. The NRC issued several documents during the early 1980s which provided information on the resolution of this issue. In 1983 and 1984, the Westinghouse Owner's Group developed guidance on alternate means of addressing requirements for tripping RCPs. The Westinghouse Owner's Group provided technical justification to substantiate the position that RCPs not be automatically tripped but should remain operational for non-LOCA transients and other accidents where their operation was beneficial to accident mitigation and recovery.

On July 28, 1985, the NRC issued GL 85-12, Implementation of TMI Action Item II.K.3.5, Automatic Trip of Reactor Coolant Pumps (ADAMS Accession No.

ML8507010252). This GL approved the Westinghouse Owners Group's position for the manual tripping of RCPs. The applicant's letters to the NRC dated August 29, 1985 (ADAMS Accession No. ML082410377), and January 13, 1986 (ADAMS Accession No.

ML082840480), stated that the RCPs at WBN would be tripped manually at 1400 psig reactor coolant system pressure in the event the reactor coolant system pressure was decreasing uncontrollably. This arrangement met the Westinghouse Owners Group's position.

Following NRC review of the applicant's submittals and additional information obtained from the applicant, the position for manually tripping of the RCPs was found acceptable.

The requirement to manually trip the RCPs was incorporated into the WBN Unit 1 emergency operating procedures (EOPs). NRC's approval was documented in a letter to the applicant dated June 8, 1990 (ADAMS Accession No. ML073541207)

For Unit 1, the NRC reviewed TVA's calculation WBN-OSG4-188, EOP Setpoints Verification Document, which indicated that instruments, which were to be used by the operators to monitor reactor coolant system pressure, were set at 1500 psig. Based on the accuracy of the instrumentation, the actual required calculated setpoint was 1474.5 psig and the setpoint of 1500 psig provided an additional safety margin in the conservative direction.

The NRC reviewed the WBN U1 EOPs, included in the document entitled Emergency Instructions. The EOPs implemented the Westinghouse Owners Group's emergency response guidelines and contained instructions for manually tripping the RCPs as the following criteria:

RCP Trip Criteria

-Phase B Isolation, OR

-One Changing pump OR one Safety Injection pump injecting AND Reactor Coolant System pressure decreasing uncontrolled to less than 1500 psig.

Subsequently, WBN Unit 1 revised the applicable procedures and it was discussed in NUREG-0847, Safety Evaluation Report (SER) Related to the Operation of Watts Bar Nuclear Plant, Units 1 and 2, Supplements 4 (ADAMS Accession No. ML072060488)and 16 (ADAMS Accession No. ML072060493). These SERs identified that WBN Unit 1 had satisfied all of the requirements of NUREG-0737. NRC inspection report (IR) 50-390/95-70 (ADAMS Accession No. ML072610753) verified the resolution of the action item for Unit 1.

Inspection Activities: Based on the information provided in the background section, the objective of this inspection was to gather and evaluate sufficient information to make a determination as to whether the applicant had adequately addressed TMI Action Item II.K.3.5 for WBN Unit 2. The inspection focused on a review of the applicants approved, but not issued, Unit 2 Emergency Operating Instructions (EOIs) to ensure the proposed procedural changes were adequately captured.

Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusions

The inspectors reviewed actions associated with TMI Action Item II.K.3.5 to verify the adequacy of the applicants actions. The inspectors concluded that the applicants efforts were sufficient to satisfy the intent of the respective TMI Action Item. TMI Action Item II.K.3.5 is considered closed.

OA.1.10 (Closed) Construction Deficiency Report 391/89-05: Failure of Auxiliary Feedwater Steam Generator Level Controllers (Inspection Procedure 92701)

a. Inspection Scope

Background: The subject deficiency was initially reported to the NRC on April 30, 1986, in accordance with 10 CFR 50.55(e) as NCR W-370-P. The deficiency was documented as CDR 50-390/86-51 for Unit 1. While no specific Unit 2 deficiencies had been identified, CDR 50-391/89-05 was assigned to track the applicable preventative actions.

As stated in TVA's final report to the NRC issued on July 7, 1989, there had been numerous failures of the model 8800 auxiliary feedwater (AFW) system steam generator level controllers supplied by Beckman. The controllers had failed to provide rated output because of component failures on the voltage/current (V/I) boards. Excessive heat buildup was believed to have contributed to the failure, but the exact cause for the controllers failing was not known. As such, the controllers were determined to be unreliable. The primary purpose of the AFW system is to provide sufficient feedwater to remove all primary system decay heat and reactor coolant pump heat in the event of a loss of main feedwater. The AFW steam generator level controllers are used to modulate the level control valves associated with the AFW turbine-driven and motor-driven pumps.

Since the failure state of the subject controllers was indeterminate, the controller output could have caused the level control valves to regulate the steam generator level outside of the desired level operating limits which could result in degraded AFW system performance and adversely affect the safe shutdown of the plant.

TVA's initial investigation was focused on the solder that had blistered on the failed voltage/current output boards for Unit 1 controllers, LIC-3-156,-171, and -148. All other Beckman model 8800 controllers were inspected and blistering was found on other boards. As stated in the TVA's final report, the defective boards were returned to the manufacturer who determined that repairs could be made but would not certify that the repairs would meet the original procurement requirements. Additionally, it was determined that replacement parts would soon not be available as the board was no longer being produced. Therefore, TVA decided to purchase new controllers to replace the ones presently installed at Watts Bar. DCN P-03373-B was issued to replace existing Unit 1 Beckman control system and associated components with new Foxboro components. The replaced controllers are UNIDs 1-LIC-3-148, -156, -164,-171,-172, -

173,-174, and -175. The NRC reviewed TVA's response for adequacy, recurrence control, and performed field inspections to verify implementation of DCN P-03373-B. The NRC concluded that the corrective actions implemented were adequate and closed the CDR for Unit 1 in NRC IRs 50-390/94-45 and 50-391/94-45 (ADAMS Accession No.

ML072980547)

For Unit 2, the corrective action for the corresponding Unit 2 CDR 391/89-05 is addressed by EDCR 52343. The issued EDCR replaces the existing Beckman control system and all associated components with the new Foxboro SPEC 200 system. The replaced controllers are UNIDs 2-LIC-3-148,-156,-164,-171,-172,-173,-174, and -175.

Remaining Unit 2 Actions:

While not all field work is not completed, engineering actions to resolve the issue have been completed and the remaining modifications are being tracked by PER 172734. This commitment will be closed by the applicant after the completion of EDCR 52343.

Inspection Activities: The inspectors reviewed the applicants engineering complete closure package, WO (09-954559-001), proposed work instructions (EDCR 52343, Rev.

A), proposed drawing changes, and installed equipment to verify corrective actions related to CDR 391/89-05 were adequate.

b. Observations and Findings

No findings were identified.

c. Conclusions

Based on the review of the applicants methodology for addressing this concern and the actual completed work observed this inspection period, the inspectors determined that the remaining work activities are contained within a controlled program and CDR 50-391/89-05 is closed.

OA.1.11 (Closed) Inspection and Enforcement Bulletin 79-27: Loss of Non-Class 1E Instrumentation and Control Power System Bus during Operation (Inspection Procedure 35007)

a. Inspection Scope

Background: NRC inspection and enforcement Bulletin (BL) 79-27 (ADAMS Accession No. ML7910250499) was issued in response to a reactor trip event in which a non-Class 1E inverter tripped and failed to successfully transfer loads to the alternate regulated alternating current (AC) power supply. Instrument power was lost to the integrated control system and one channel of the non-nuclear instrument instrumentation system.

This rendered most of the control room indicators for the reactor coolant system and secondary plant systems inoperable. All valves controlled by the integrated control system assumed their respective failure configurations, causing an excessive cool down rate for the reactor system.

The applicants response to the actions recommended by this bulletin was previously inspected in NRC IR 50-390/95-38 and 50-391/95-38 (ADAMS Accession ML072760552). The inspection reports documented that the applicant sufficiently addressed the recommended actions of the BL for Unit 1 operations and had provided sufficient technical bases to substantiate a determination that no design changes were required for Watts Bar.

Inspection Activities: The inspectors interviewed licensed operations personnel, reviewed the applicants corrective action closure reports, examined electrical interconnection schematics, and assessed abnormal operating instructions (AOIs) that had been drafted to guide operator response to loss of instrument and control power events. The review was performed to determine whether adequate guidance will be provided to Unit 2 operators for a postulated loss of instrument and control power.

Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusion Based on a review of the applicants engineering complete closure package and the aforementioned inspection activities, the inspectors determined that the applicant had implemented actions that would be sufficient to address the recommendations of BL 79-27. This inspection item, BL 79-27, is closed.

OA.1.12 (Closed) Construction Deficiency Report 391/86-21: Non-Quality Assurance Data Used in Calculations for Cable Tray and Conduit Loading (Inspection Procedure 35007)

a. Inspection Scope

Background: Actions taken by TVA to address this deficiency for Unit 2 have been previously inspected and documented in NRC IIR 05000391/2012605 (ADAMS Accession No. ML12220A536), Section OA.1.4, and NRC IIR 05000391/2013604 (ADAMS Accession No. ML13179A079), Section OA.1.25. No findings were identified during those inspections; however, the inspectors determined that further inspection was required to verify completion of remaining Unit 2 actions.

Inspection Activities: During this inspection, commitment closure documents and QA records used to implement the remaining Unit 2 actions were examined to evaluate the scope and status of actions planned to address this area of concern. The inspectors conducted multiple walkdowns and used direct observation to verify completed work performed under field WOs issued to resolve the identified deficiencies via several implementing documents to include LSWD 542, EDCR 52934, and EDCR 55231. The field observations included verification of the accuracy of ICRDS data for cables installed in the plant and verification of corrective actions such as tray modifications, tray support modifications, tray support installation, re-torqueing of tray support wedge bolts, cable installation, and conduit installation. The inspectors conducted interviews and reviewed QA records to verify that all the completed work sampled was accomplished in accordance with approved design and associated instructions, procedures, and drawings.

Documents reviewed are listed in the Attachment.

b. Observations and Findings

No findings were identified.

c. Conclusion Based on a review of the applicants engineering complete closure package and the aforementioned inspection activities, the inspectors determined that the applicant had implemented actions that would be sufficient to address the issues identified in CDR 50-391/86-21 and the historical concerns about the accuracy of data used in electrical calculations. This inspection item, CDR 50-391/86-21, is closed.

V. MANAGEMENT MEETINGS X1

Exit Meeting Summary

An exit meeting was conducted on October 10, 2013, to present inspection results to you and other members of your staff. The inspectors identified that no proprietary information had been received during the inspection and none would be used in the inspection report. The applicant acknowledged the observations and provided no dissenting comments.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Applicant personnel

H. Baldner, TVA - Licensing
R. Baron, TVA - QA Manager
D. Beckley, Bechtel - Electrical Design
J. Boykin, TVA - QA Specialist
D. Charlton, TVA - Licensing
J. Clark, TVA - QA Specialist
T. Das, Bechtel - Engineering
J. Fisher, TVA - Licensing
B. Gillham, TVA - Licensing
R. Goyal, Bechtel - Civil Engineering
D. Helms, TVA - Engineering
R. Hruby, TVA - General Manager
J. Kepler, TVA - Control Systems Supervisor, Unit 2
K. Lovell, TVA - PM and Refurbishment
B. Mahoney, Bechtel - Field Engineering
M. McGrath, TVA - Licensing
J. ODell, TVA - Regulatory Compliance
R. Onis, TVA - QA Oversight
G. Scott, TVA - Licensing
N. Welch, TVA - Properational Startup Manager
O. J. Zeringue, General Manager Engineering and Construction

INSPECTION PROCEDURES USED

IP 35007 Quality Assurance Program Implementation During Construction and Pre-

Construction Activities

IP 37002 Construction Refurbishment Process - Watts Bar Unit 2

IP 37051 Verification of As-Builts

IP 48055 Structural Steel and Support Record Review

IP 49053 Reactor Coolant Pressure Boundary Piping - Work Observation

IP 49055 Reactor Coolant Pressure Boundary Piping Record Review

IP 50053 Reactor Vessel and Internals Work Observation

IP 50073 Mechanical Components - Work Observation

IP 50075 Safety Related Components - Records Review

IP 50090 Pipe Support and Restraint Systems

IP 51053 Electrical Components and Systems - Work Observation

IP 51055 Electrical Components and Systems - Record Review

IP 51063 Electrical Cable - Work Observation

IP 64051 Fire Protection

IP 70300 Preoperational Test Procedure Review

IP 70312 Preoperational Test Witnessing

IP 70343 Containment Spray System Test - Preoperational Test Procedure Review

IP 70443 Containment Spray System Test - Preoperational Test Witnessing

IP 71302 Preoperational Test Program Implementation Verification

IP 92701 Follow-up

TI 2512/015 Inspection of Watts Bar Nuclear Plant Employee Concerns Program

TI 2512/028 Inspection of Watts Bar Nuclear Plant QA Records Corrective Action

Program Plan

TI 2512/029 Inspection of Watts Bar Nuclear Plant Q-List Corrective Action Program

Plan

TI 2512/109 Inspection Requirements for Generic Letter 89-10, Safety-Related Motor-

Operated Valve Testing and Surveillance

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

None

Closed

49055 IP Reactor Coolant Pressure Boundary Piping Record Review (Section C.1.8)

48055 IP Structural Steel and Supports Record Review (Section C.1.9)

05000391/2013613-01 URI Potential Inadequate Corrective Actions for Piping Misalignment (Section OA.1.8)

TMI II.K.3.5 AI Automatic Trip of Reactor Coolant Pumps During Loss-Of-Coolant Accident (LOCA)

(Section OA.1.9)

391/89-05 CDR Failure of Auxiliary Feedwater Steam

Generator Level Controllers (Section OA.1.10)

79-27 BL Loss of Non-Class 1E Instrumentation and Control Power System Bus during Operation (Section OA.1.11)

391/86-21 CDR Non-Quality Assurance Data Used in Calculations for Cable Tray and Conduit Loading (Section OA.1.12)

Discussed

50090 IP Pipe Support and Restraint Systems (Section C.1.2)

49053 IP Reactor Coolant Pressure Boundary Piping Work Observations (Section C.1.3)

50053 IP Reactor Vessel and Internals Work Observation (Section C.1.4)

37051, 50073 IP Verification of As-Builts (Section C.1.5)

51053, 37002 IP Electrical Components and Systems - Work Observation) (Section C.1.6)

51063, 37002 IP Electrical Cable - Work Observation (Section C.1.7)

70300, 70343 IP Preoperational Test Procedure Review (Section P.1.2)

70312, 70443 IP Preoperational Test Witnessing (Section P.1.3)

2512/029 TI Q-List (Section OA.1.1)

89-10 GL Safety-Related Motor-Operated Valve Testing and Surveillance (Section OA.1.2)

USI Safety Implication of Control Systems in LWR Nuclear Power Plants (Section OA.1.3)

391/87-18 CDR Deficiencies in installation of electrical conduit and conduit supports (Section OA.1.4)

391/86-59 CDR Qualification of ASCO solenoid valve conduit connector configuration (Section OA.1.5)

86-21-02 VIO Instrument valves, Foxboro transmitters, and instrument panels not seismically qualified (Section OA.1.6)

2512/028 TI Quality Assurance Records (Section OA.1.7)

LIST OF DOCUMENTS REVIEWED