IR 05000391/2014611
| ML14135A428 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 05/15/2014 |
| From: | Haag R NRC/RGN-II/DCP/CPB3 |
| To: | Skaggs M Tennessee Valley Authority |
| Michelle Adams | |
| References | |
| IR-14-611 | |
| Download: ML14135A428 (19) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION May 15, 2014
SUBJECT:
WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000391/2014611
Dear Mr. Skaggs:
On April 25, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of construction activities at your Watts Bar Unit 2 reactor facility. The enclosed inspection report documents the inspection results, which were discussed on April 25, 2013, with you and other members of your staff.
This problem identification and resolution (PI&R) inspection examined activities conducted under your Unit 2 construction permit as they relate to identification and resolution of problems, compliance with the Commissions rules and regulations, and with the conditions of your construction permit. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
No findings were identified during this inspection.
In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the 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 the 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 C. Haag, Chief Construction Projects Branch 3 Division of Construction Projects Docket No. 50-391 Construction Permit No: CPPR-92
Enclosure:
Inspection Report 05000391/2014611 w/Attachment
REGION II==
Docket No: 50-391 Construction Permit No: CPPR-92 Report No.: 05000391/2014611 Applicant: Tennessee Valley Authority (TVA)
Facility: Watts Bar Nuclear Plant, Unit 2 Location: 1260 Nuclear Plant Rd Spring City TN 37381 Inspection Dates: April 21 through April 25, 2014 Inspectors: A. Wilson, (Lead) Construction Project Inspector J. Baptist, Senior Construction Project Inspector D. Harmon, Construction Project Inspector E. Patterson, Construction Resident Inspector K. Steddenbenz, Construction Inspector C. Taylor, Senior Construction Project Inspector S. Temple, Construction Inspector Approved By: Robert C. Haag, Chief Construction Projects Branch 3 Division of Construction Projects Enclosure
EXECUTIVE SUMMARY
Watts Bar Nuclear Plant, Unit 2
NRC Inspection Report 05000391/2014611 Introduction This inspection assessed implementation of the corrective action program for the Watts Bar Unit 2 construction completion project. The inspection program for Unit 2 construction activities is described in NRC Inspection Manual Chapter 2517. Information regarding the Watts Bar Unit 2 Construction Project and NRC inspections can be found at http://www.nrc.gov/info-finder/reactor/wb/watts-bar/construction-insp-info.html.
Inspection Results
- In general, the threshold for initiating problem evaluation reports (PERs) was low and PERs were appropriately categorized. For the majority of PERs reviewed, the inspectors determined that problem evaluations were effective in identifying corrective actions that addressed the problem. [Section Q.1.1]
- The inspectors determined that adequate measures have been established to evaluate and incorporate applicable operating experience into the corrective action program.
[Section Q.1.1]
- The inspectors determined that TVA and Bechtel have established an acceptable program and environment for allowing employees to identify quality or safety-related concerns. [Section Q.1.1]
Table of Contents I. QUALITY ASSURANCE PROGRAM ..................................................................................... 5 Q.1 Quality Assurance Program Implementation ................................................................. 5 Q.1.1 Implementation of Corrective Action Program During Construction (IP 35007) ............... 5 V. MANAGEMENT MEETINGS .............................................................................................. 7 X.1 Exit Meeting Summary ..................................................................................................... 7
REPORT DETAILS
I. QUALITY ASSURANCE PROGRAM Q.1 Quality Assurance Program Implementation Q.1.1 Implementation of Corrective Action Program During Construction (Inspection Procedure 35007)
a. Inspection Scope
The inspectors assessed the adequacy of the Tennessee Valley Authority (TVA) and Bechtel program for identification, evaluation, and corrective action of conditions adverse to quality during the period since the previous problem identification and resolution inspection in April 2013. This was accomplished by reviewing selected PERs, verifying corrective actions were implemented and attending meetings where PERs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the Corrective Action Program (CAP) at an appropriate threshold.
The inspectors reviewed a sample of PERs and Service Requests (SRs) selected from the applicants CAP for Watts Bar Unit 2. The sample included problems addressed by a diverse selection of plant departments and problems classified under all of the significance levels. The sample also covered a diverse selection of sources, including problems identified in audits and assessments, nonconforming results from inspections and tests, findings from NRC inspections, concerns from anonymous sources, and concerns identified as adverse trends. Most PERs were reviewed after corrective actions had been implemented; however, some were reviewed after the corrective action plan was developed but prior to implementation.
The inspectors also reviewed the applicants alternate issue tracking systems that address issues that were not classified as conditions adverse to quality. This review targeted verification of appropriate characterization and closure of issues managed outside the corrective action program. The alternative issue tracking systems that were sampled included Test Deficiency Notices (TDNs) and Quality Control (QC) Rejects.
These systems were defined as corrective Work Processes approved to track/implement correction, according to TVAs CAP procedure (NC-PP-3, Revision 15).
The inspectors reviewed applicable portions of TVAs and Bechtels Quality Assurance Program (QAP) implementing procedures in order to ensure that commitments for the identification, evaluation, and resolution of conditions adverse to quality had been adequately addressed. The inspectors review evaluated the applicants consideration for extent of condition, generic implications, common cause and previous occurrences (trending), including the identification of root and contributing causes along with actions to prevent recurrence for significant conditions adverse to quality.
The inspectors reviewed TVAs and Bechtels respective programs for resolving employee concerns. The inspectors interviewed TVA and the major contractors (Bechtel) employee concern representatives, reviewed a sample of PERs referred to employee concerns and PERs initiated as a result of employee concerns. The inspectors also reviewed several anonymous PERs to determine if they had been adequately captured and addressed. The inspectors reviewed and evaluated the adequacy of the programs, which provide employees with an alternate method to identify quality or safety-related concerns. The inspectors also reviewed surveys and assessments of the employee concerns programs.
The inspectors reviewed a sample of the applicants management and quality assessments, audits, and trend reports to verify adverse results were properly evaluated and dispositioned within the corrective action program. The inspectors reviewed the revision history for corrective action program implementing procedures and assessed the integration of industry operating experience into the corrective action process. Direct observations by inspectors included meetings of the Project Review Committee (PRC)and the Construction Completion Management Review Committee (CCMRC) as they screened newly reported problems and reviewed dispositions for selected issues.
Specific PERs and other documents reviewed are listed in the attachment.
b. Observations and Findings
No findings were identified.
The inspectors made the following observations as a result of their inspections:
- (1) Effectiveness of Identifying, Evaluating, and Correcting Problems Identifying Problems The inspectors determined that, for the most part, the applicant was effective in identifying problems and entering them into the CAP. PERs normally provided complete and accurate characterization of the subject issues. Employees were encouraged by management to initiate PERs.
Evaluating Problems The inspectors attended several meetings throughout the week, including the PRC and the CCMRC. It was determined that the applicant had adequately prioritized issues entered into the CAP consistent with established procedures. SRs that were being initiated and discussed during the meetings were being appropriately dispositioned. The inspectors determined that the threshold of closing items as SRs, closing items to a work order (WO), and creating a PER when necessary was adequate.
Correcting Problems Based on a review of numerous PER corrective actions and their implementation, the team found, for the most part, that the applicants corrective actions developed and implemented for problems were commensurate with the safety significance of the issues.
- (2) Use of Operating Experience The inspectors determined that the applicants measures used to identify, evaluate and incorporate applicable industry and operating experience (I&OE) information into the corrective action program contained processes for including vendor recommendations and internally generated lessons learned. The I&OE information was collected, evaluated, and communicated to the affected internal stakeholders as specified in TVA and Bechtel procedures. The inspectors determined that appropriate corrective actions were developed and taken for the sample of I&OE problem evaluation reports reviewed for the Watts Bar Unit 2 Construction Completion Project.
- (3) Safety Conscious Work Environment (SCWE)
The inspectors reviewed several anonymous PERs and PERs that either referred to the employee concerns program (ECP) or PERs generated as a result of employee concerns. Employees interviewed expressed knowledge of the employee concerns program and the ability to raise safety related concerns through various available means. The inspectors also interviewed senior employee concerns coordinators from both TVA and Bechtel. The inspectors determined that TVAs and Bechtels employee concern programs were adequate. The senior employee concerns coordinators expressed knowledge of the ECP and the ability to raise safety related concerns through various available means. The inspectors noted that the ECP staff provide several training sessions, they provide ECP information in newsletters, and they also walk around the site frequently, talk daily to staff, and attend several meetings to ensure that staff are aware of the ECP and know how to raise concerns if necessary. Also, there appeared to be strong management support for both the Bechtel and TVA ECP.
- (4) Corrective Action Program Performance Insights The sample of audits, assessments, and surveillances reviewed by the inspectors confirmed that management and quality personnel actively conducted observations and effectiveness reviews of the corrective action program. These program assessments concluded that overall, the corrective action program was effectively implemented. The applicant continues to track and trend issues, run summary reports on the trend data, and present results to management in several meetings, such as the site status meeting, CCMRC, etc.
- (5) Corrective Action Program Effectiveness As discussed above, in general, the applicants CAP was effective and adequate. The inspectors determined that the applicant has maintained implementation of the CAP at an effective level since the last NRC PI&R inspection (April 2013).
c. Conclusions
As documented above, the inspectors determined that implementation of the CAP for the Watts Bar Unit 2 construction completion project was generally adequate. The threshold for initiating PERs was appropriate, PERs were categorized in accordance with their significance, and problem evaluations were effective in identifying appropriate corrective actions.
In regards to maintaining a Safety Conscious Work Environment, the inspectors determined that TVA and Bechtel had established an acceptable program and environment for allowing employees to identify quality or safety-related concerns.
V. Management Meetings X.1
Exit Meeting Summary
On April 25, 2014, the inspectors presented the inspection results to you and other members of your staff. Proprietary information reviewed during the inspection was returned and no proprietary information was included in this inspection report.
SUPPLEMENTAL INFORMATION
Partial List of Persons Contacted
Applicant personnel
- D. Charlton, TVA - Licensing
- B. Gillham, TVA - Licensing
- B. Heinmiller, Bechtel - CAP Manager
- Y. Hink, Bechtel - Employee Concerns
- R. Kirckpatrick, TVA - Engineering
- T. Niessen, TVA Audits & Assessment Manager
- D. Voeller, TVA - Construction Manager
Inspection Procedure Used
IP 35007 Quality Assurance Program Implementation during Construction
List of Items Opened, Closed, and Discussed
Opened
None
Opened and Closed
None
Discussed
None
List of Documents Reviewed
Problem Evaluation Reports
2178 Trend in Red-Line Process Issues
394793 Ineffective Preventive Actions Associated with PER 262178
581841 ASME Non-conformance
615657 Improvements Needed to Prevent Recurrence of Missed QC Holdpoints
706129 Potential problem with Westinghouse ARD relays for DC application
708450 NRC Id'd: Hardware Non-Conformance for HVAC Support in Closed WO 709036 Anonymous PER: Hostile Work Environment
709637 Multiplication Error in Rosemount 1152 Calculation
713135 ASME Hardware Non-Conformance DRAVO Spool S/N 11450 Historic Issue
713742 PER closure - QA Assessment NC-WB-13-006
715564 NRC Id-d: Upper Lateral Support Material Not Tested In Accordance with
Requirements
24028 WO 110932752 does not provide adequate precautions for work on ABSCE support
25478 ASME III Hardware Non-Conformance.Sys 030/067 Indication On Piping For
WBN-2-Ccu-030-0078-B
735081 Hardware Non-Conformance: QA3 Mat'l Used In QA1 Application. Sys 3, 61, 62, 63,
68, 70, 72
738567 Missing cross reference for PER to WO 738580 Work not completed to address non-conforming condition
739613 Evaluate Westinghouse TB-13-1 applicability to WBN2.
741744 Historical: Wood insulation discovered in ice condenser personnel access door
2527 CCE, SYS WBN063, WBN-2-3VC-293-6044-B, Conduit exceeds 360° bends with
cable pulled in
2574 Unit 2 construction radiography. Weld 2-062B-D139-27 C1R0; metallic debris in pipe
743615 Adverse Trend for By-passed ANI/QC Holdpoints, Witness points, reviews, and
notifications
745899 Supplier Quality Rep, personnel qualification records are not in EDMS
748557 Common Q Panels may not have properly adjusted retaining angle brackets for
seismic event
750214 Anonymous PER: Bechtel Supervisor rushing craft to the field w/o proper paperwork
753260 ASME related: Failure to follow procedure MGT-0003
754455 A Dye Penetrant Exam Of Weld# 2-063b-T071-28-C0r0, Revealed A 3-1/2" Linear
Indication In The Pipe
754469 ASME Related, Errors in PCI Documents (RTD Bypass) Found During Final Review
756990 Potentially Reportable Hardware Non-Conformance: 10 CFR Part 21 notification
763291 Pressurizer PORV Cv Design Change
766429 Errors in WBNTSR008 calculation
766488 Anonymous PER: Issues with FCR approval process
777477 Personal documenting approval of ASME Section III Design Specification not
adequately qualified
781458 QA identified Adverse Trend in CAP Action Closure Quality
788677 Anonymous PER: Work orders have recurring problems
790185 Unauthorized Rework on Flex Conduit 800044
790717 Review of WO#110990376 R1 CCE, SY
- S. WBN074, and WBN063 associated
commodities
790722 Incorrect dimensions not identified on FCR 61876 AA-02
790730 ASME: Missing dates for approval/concurrence reviews for Supplier Quality
Procedure and Manual
791834 FCR written to document As-built condition of installation does not match layout
piping DRA
793461 Work Order Signatures
794620 ASME WO 111059418 was closed without obtaining N-5 and ANI final review as
required by N1206
794668 Vendor Heat Loss Calculation for Metal Reflective Insulation Does Not Match Design
Drawings
800044 NRC Identified, Potential Over Torque of Wrapper Plug Assembly
800570 Unit 2, 2-FCV-070-0087 MOV actuator mounting hardware is not correct 802311
ASME WO 115220992 WBN-2-CKV-062-0532-B SENSITIZATION
804263 ASME System WBN068 Issues found with Archived PER 215474 & BIT 1405
807454 Instrumentation tubing sulfur content outside acceptable values for orbital welding
808623 PRZR instrument nozzle couplings removed
819918 Anonymous PER: Work Orders not Being Worked per Procedures
2473 Cable 2PV6750 in Bend Radius Violation (SYS WBN098)
2928 System WBN067 TIC's may not maintain position retention
834004 Hardware Non-conformance: 3/4" rebar was cut without authorization
838631 ECP Referral: Potential damaged rebar and tube bending tool causing damage to
3/4" SS tubing
2892 Insufficient Clearance Between Valve WBN-2-CKV-063-0634 and Crane Wall
2964 SU Trend PER due to HU incidents at undesirable level
844207 SUT SYS WBN027 TDN 13-446 Time Delay Relays did not meet acceptance Criteria
844218 NRC Identified: Unit 2 Rack 2 Narrow Range RTD WO 113471100 PMT Data
844222 TDN Trending and Processing Errors
844234 NRC Identified - Valve data sheets reference incorrect material specification
845228 System WBN063 Potential Proximity Interactions
850485 Pipefitter performed unauthorized work
851810 During disassembly of the 2A Safety Injection Pump, multiple deficiencies were
identified
857648 Anonymous PER: Craft Being Pushed to Work Fast in an Unsafe Manner
857667 ASME Section III Components - Trend PER - assembly quality issues with OEM
861461 PER 469477 and PER 708506 have been closed without all actions being
completed/addressed as required
863840 SUTR SYS WBN062 WBN-2-GR-062-0108-A
875435 Administrative Closure Issues Found during and Engineering Review of Closed
PERs
2509 Incorrect wire installed on the output side of Temperature Modulators
875435 Administrative Closure Issues Found during an Engineering Review of Closed PERs
876414 Missing 18 inch mirror insulation at Acc room #3,el. 702' Az 180, SIS piping
877650 CCM SYS WBN040 UNID-2-PIPE-040-G. Nail identified inside RCP 4 oil drain line
on EL. 716
877665 PI&R NRC ID'd: ASME Code III Hardware SRs closed to work performed, rather
than going to a PER
Service Requests
695055 Existing Root Valve 2-RTV-062-0442A is not operating smoothly
24339 Loose bolting on 2-RFV-067-0573B-B
24351 Loose bolting on 2-RFV-067-1033A-A, 1029B-b and 2-FE-067-0183
24525 SR closed to WO for ASME item without creating a PER
2302 Hardware Non-conformance: QA3 Mat'l used in QA1 Application, SYS 3, 61, 62, 63,
68, 70, 72
739452 Commodity Clearance Violation on HVAC Support 75-4517
739531 ASME Hardware Nonconformance Inadequate Socket Depth of Valves 2-DRV-068-
0557 and -0558
754881 MAI-5.1B requirements were not completed, System WBN293
780734 QA identified Adverse Trend in CAP Action Closure Quality
787376 Loose Bolting on Relief Valve in Unit 2
2916 Solenoid Valve top cover bent
807559 Historical Issue: Broken Embedded Ground Cable
836724 ASME Hardware Nonconformance - System 6.1 Indications Violated Min Wall Repair
IAW Bechtel SPM
855583 ASME Section III Components - Trend PER - assembly quality issues with OEM
863108 SUTR SYS WBN062 WBN-2-GR-062-0108-A
875013 Administrative Closure Issues Found during and Engineering Review of Closed
PERs
875329 CCM SYS WBN040 UNID-2-PIPE-040-G. Nail identified inside RCP 4 oil drain line
on EL. 716
876118 Missing 18 inch mirror insulation at Acc room #3,el. 702' Az 180, SIS piping
876378 PI&R NRC ID'd: ASME Code III Hardware SRs closed to work performed, rather
than going to a PER
Test Deficiency Notices13-217 2-HS-67-111C hand switch does not operate valve, no continuity in switch contact
circuit
13-244 Torque switch operation is suspect
13-280 Max seating/unseating est motor torques exceeds limit on design rwg
13-281 Running average est motor torques exceeds limit on design rwg
13-338 Fuses are blowing after long delay
13-361 No seating torque on MOVATS; suspect not tightly closed
13-390 MEL data is not filled out correctly
13-486 High running load during MOVATS test
13-505 Packing/running load exceeded
13-515 High running load during MOVATS test
13-525 Diode in JB 1910 is installed in the reverse direction
13-526 Diode in JB 1910 is installed in the reverse direction
14-046 High packing/running load
14-058 Packing/running load exceeded
14-108 Wiring issue. DRA does not match Cat 1 drawing
14-204 Unclear design output for valve stroke time requirements
Procedures and Programs
25402-MGT-000, Corrective Action Program, Rev. 16
25402-MGT-0004, Incident Investigation and Root Cause Analysis, Rev. 4
25402-000-GPP-0000-N3702, Arc Strike Removal / Base Metal Repair of Piping / Components
and Structural / Miscellaneous Steel, Rev. 2
25402-00-GPP-0000-N1206, "Work Order Processing," Rev. 18
NC-PP-3, Watts Bar Unit 2 Corrective Action Program, Rev. 15
NC-PP-8, Watts Bar Unit 2 Operating Experience / Construction Experience Plan, Rev. 2
NC-PP-6, Completion of TVA NC Partial ASME Section III Division 1 N-5 Data Reports,
Rev. 13
NPG-SPP-06.4, Measuring and Test Equipment, Rev. 2
Audit Reports
Audit Report No. NC1302, Corrective Action Program, dated 6/26/13
Bechtel Audit No. 25402-WBN-AR13-0002, Bechtel Quality Assurance Manuals, Rev. 0
Quality Assurance Assessment Report NC-WB-13-006, Problem Evaluation Report Closures,
dated 4/18/13
Miscellaneous
2013 Assessment of WB2 Safety Conscious Work Environment and Safety Culture
Bechtel Annual SCWE Pulsing Survey; 2012 and 2013 Results Comparison
Bechtel CAP Status Report, dated February 2014
Bechtel Employee Concerns Cases Associated with PERs; 04/01/2013 through 04/23/2014
CAP Trend Report; March 2014
Test Deficiency Notice Trending; 03/19/2014 through 04/17/2014
Watts Bar Nuclear Plant U1/U2 Corrective Action Program Transition Strategy Document
WBC ECP Pulsing Results; Completed 10/23/2013
WBC ECP Pulsing Results; Completed 03/27/2014
WBN U2 CAP Metrics Report, dated February 2014
WBN U2 CAP Self-Assessment WBN2-CAP-14-1, dated 3/25/14
Drawing
2-45B2768-11E, Rev. 7
2-47A8910-63-01, Rev. 2
Calculation
MDQ0020632008-0229, Rev. 003
Field Change Requests
FCR 60603-A, DRA No. 5331-168, -190, -408, and -409, Rev. 0
FCR 59905-A, AA-07, dated 8/1/12
Work Orders
WO 114633238, CCM SYS 067 WBN-2-RFV-067-1033A-A ASME Class 3
WO 115149219, CCM EDCR2 53580 SYS 063 PER 760933 2-RFV-063-0627-B PER 760933
FCR 61757-A AA-09
List of Acronyms
ADAMS Agencywide Document Access Management System
CAP Corrective Action Program
CCMRC Construction Completion Management Review Committee
CFR Code of Federal Regulations
ECP Employee Concerns Program
I&OE Industry and Operating Experience
IP Inspection Procedure (NRC)
NRC Nuclear Regulatory Commission
PARS Publicly Available Records
PER Problem Evaluation Report
PI&R Problem Identification and Resolution
PRC Project Review Committee
QA Quality Assurance
QAP Quality Assurance Program
QC Quality Control
SCWE Safety Conscious Work Environment
SR Service Request
TDN Test Deficiency Notice
TVA Tennessee Valley Authority
WBN Watts Bar Nuclear Plant
WO Work Order