Text

IR 05000391-09-602, on 01/01/2009 - 03/31/2009, Watts Bar Nuclear Plant Unit 2 Construction - NRC Integrated Inspection Report
	ML091210420
Person / Time
Site:	Watts Bar
Issue date:	04/30/2009
From:	Haag R; NRC/RGN-II/DCP/CPB3
To:	Bhatnagar A; Tennessee Valley Authority
References
	IR-09-602
	Download: ML091210420 (58)
	v • d • e

April 30, 2009

SUBJECT:

WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED INSPECTION REPORT 05000391/2009602

Dear Mr. Bhatnagar:

On March 31, 2009, 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 April 9, 2009, with Mr. Masoud Bajestani and other members of your staff.

This inspection examined activities conducted under your Unit 2 construction permit as they relate to safety and compliance with the Commissions rules and regulations, with the conditions of your construction permit, and with fulfillment of Unit 2 regulatory framework commitments.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents one NRC-identified finding which was determined to involve a violation of NRC requirements. However, because this finding was a Severity Level IV violation and was entered into your corrective action program, the NRC is treating it as a non-cited violation consistent with Section VI.A of the NRC Enforcement Policy. If you contest the non-cited violation in the enclosed report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTENTION: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at the Watts Bar Unit 2 Nuclear Plant.

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931

TVA

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

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 05000391/2009602 w/attachments

REGION II==

Docket No.:

50-391

Construction Permit No.:

CPPR-92

Report No.:

05000391/2009602

Applicant:

Tennessee Valley Authority (TVA)

Facility:

Watts Bar Nuclear Plant, Unit 2

Location:

1260 Nuclear Plant Rd

Spring City TN 37381

Dates:

January 1 - March 31, 2009

Inspectors:

W. Bearden, Senior Resident Inspector, Construction Projects

Branch 3 (CPB3), Division of Construction Projects (DCP)

Region II (RII)

T. Nazario, Resident Inspector, CPB3, DCP, RII

H. Abuseini, Resident Inspector, CPB3, DCP, RII

A. Issa, Project Inspector, CPB3, DCP, RII (Sections E.1.1, E.1.2)

J. Bartleman, Senior Construction Inspector, Construction Inspection Branch 2, Division of Construction Inspection (DCI),

RII (Sections C.1.1, C.1.3, Q.1.1, Q.1.2)

C. Fong, Construction Project Inspector, CPB2, DCP, RII

(Sections E.1.2, F.1)

P. VanDoorn, Consultant, CPB3, DCP, RII

(Sections Q.1.1, Q.1.3, Q.1.4)

Approved by:

Robert C. Haag, Chief

Construction Projects Branch 3

Division of Construction Projects

EXECUTIVE SUMMARY

Watts Bar Nuclear Plant, Unit 2

NRC Inspection Report 05000391/2009602

This integrated inspection included aspects of engineering and construction activities performed by TVA associated with the Watts Bar Unit 2 construction project. This report covered a three-month period of inspections in the areas of quality assurance; identification and resolution of construction problems; employee concerns program; construction activities; engineering activities; procurement; training and qualification of plant personnel; and fire protection. The inspection program for Unit 2 construction activities is described in NRC Inspection Manual Chapter (IMC) 2517. Information regarding the Watts Bar Unit 2 Construction Project and NRC inspections can be found at http://www.nrc.gov/reactors/plant-specific-items/watts-bar.html.

The inspectors concluded that TVA continued to implement adequate controls to conduct ongoing procurement, design, and construction activities. The inspection identified one NRC-identified Severity Level (SL) IV Non-Cited Violation (NCV).

Inspection Results

A SL IV NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for failure to accomplish activities affecting quality in accordance with instructions and procedures. The inspectors identified three examples associated with scaffolding deficiencies where procedural requirements were not implemented in accordance with applicant procedure MMTP-102, Erection of Scaffold/Temporary Work Platforms and Ladders. TVA entered the issue into the corrective action program and, as part of the corrective actions, immediately corrected the scaffolding to comply with procedural requirements, conducted an apparent cause evaluation and completed appropriate engineering evaluations.

The inspectors determined that this finding was more than minor because the finding represented an improper/uncontrolled work practice and represented a deviation that, if left uncorrected, could potentially adversely affect the seismic qualification of a system structure or component (SSC). The cause of this finding was directly related to the work practices component of the Human Performance cross-cutting area because TVA and Bechtel did not define and effectively communicate expectations regarding procedural compliance and as a result personnel failed to follow procedures (H.4.b). (Section E.1.1)

Management and quality assurance (QA) oversight and TVAs and Bechtels processes for identification and resolution of problems continued to be adequate. The inspectors also determined that the inspection sample requirements for some NRC inspection procedures were completed for the purposes of assessing the readiness of TVA and Bechtel to conduct construction activities. (Sections Q.1.1, Q.1.2, Q.1.3, Q.1.4, Q.1.5,

E.1.1 E.1.2 and Attachment 3)

A review, called the reconstitution process, of historical NRC inspection reports was completed to determine the status of previously performed inspections in satisfying the requirements specified in the construction inspection procedures. (Section OA.1)

Other areas inspected were adequate with no findings of significance identified. These areas included physical walkdowns, ongoing construction activities, protection of installed equipment, employee concerns, procurement, document control, training, and fire protection.

Table of Contents

I. Quality Assurance Program..................................................................................................................... 1

Q.1 Quality Assurance Oversight Activities...1

Q.1.1 Quality Assurance Oversight (IPs 35060, 35061, 35960)...1 Q.1.2 In-Depth of QA Performance (IP 35061)2

Q.1.3 Review of QA Manual (IP 35100)3

Q.1.4 Identification and Resolution of Construction Problems (IP 40504)..3

Q.1.5 Safety Conscious Work Environment (IP 40504).4

II. Management Oversight and Controls4

C.1 Construction Activities4

C.1.1 Walkdowns (IPs 35061 and 50090).4

C.1.2 Protection of Installed Plant Equipment during Construction Activities (IPs 50051, 50053, and 50055).5 C.1.3 Electrical Penetrations (IPs 51051, 51053, 51055, 53053, and 53055).6

C.1.4 Safety Related Piping Work Observation (IPs 49063, 49065, 55050)...7

C.1.5 Radiograph Film Interpretation of Safety-Related Welds (IP 57090).7 C.1.6 Liquid Penetrant Examination of Safety Related Welds (IP 57060)...8 C.1.7 Electrical Systems and Components (IP 52051, 52053, 51061 and 51063)......................9

E.1 Engineering Activities..10

E.1.1 Engineering Organization, Document Control and Design Control IPs 37055, 35061, (35960)10 E.1.2 Procurement Activities (IPs 35060, 35065, and 35960)..13

T.1 Training and Qualification of Plant Personnel..14

T.1.1 Craft Training (IPs 35061, 46071 and 50090)..14

III. Operational Readiness Activities 15

F.1 Fire Protection (IP 64051).15

IV. Other Activities.16

OA.1 Construction Inspection Program Reconstitution Review..16

V. Management Meeting..17

X.1 Exit Meeting Summary..17 X.5 Public Meeting Summary..17

REPORT DETAILS

Summary of Plant Status

During the current inspection period, TVA continued to develop construction procedures and work instructions. Engineering design activities and physical plant walkdowns to determine the existing status of structures, systems, and components (SSCs) also continued during this inspection period.

I. Quality Assurance Program

Q.1 Quality Assurance (QA) Oversight Activities

Q.1.1 Licensee Management of QA Activities (Inspection Procedure (IP) 35060)

a. Inspection Scope

During this inspection period, the inspectors focused inspection efforts on assessing the readiness of TVA and Bechtel to conduct construction activities. This inspection is a follow-up to an initial inspection conducted in March 2008 and documented in Inspection Report 05000391/2008006. Subsequent inspections were performed utilizing applicable NRC inspection procedures and documented in NRC Inspection Reports 05000391/

2008007, 2008009, and 2008010. The inspectors reviewed the latest revision of the Bechtel Project Nuclear Quality Assurance Manual, Revision 3, to confirm that there were no substantive changes which affected QA effectiveness, that QA independence was maintained, and that administrative requirements, such as management approvals, were met.

The inspectors also reviewed problem evaluation reports (PERs) as part of TVAs corrective action program to verify that issues being identified under the corrective action program were being properly identified, addressed, and resolved by TVA. Additionally, the inspectors reviewed several construction completion project quality surveillance reports of reviews performed on field change requests and drawing revision authorizations. Specific documents reviewed are listed in Attachment 1.

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The revision described above to the Bechtel Project Nuclear Quality Assurance Manual met requirements, and QA effectiveness was not reduced by the change. Overall, adequate management and QA oversight was in place commensurate with activities in progress.

In addition, the inspections documented in this inspection report coupled with previous inspections documented in NRC Inspection Reports 05000391/2008006, 2008007, 2008009, and 2008010 completed the inspection requirements for IP 35060 from a construction readiness standpoint. Additional samples utilizing this inspection procedure may be conducted during future inspections as needed or as required by the specified frequency. See Attachment 3 to this inspection report.

Q.1.2 In-Depth Inspection of QA Performance (IP 35061)

a. Inspection Scope

The inspectors reviewed and observed site work and verified that it was being performed in accordance with NRC requirements, safety analysis report (SAR) commitments, and implementing procedures. The inspectors also reviewed and inspected the QA / Quality Control (QC) program to verify that requirements and commitments were being met and that prompt and effective action was taken to achieve permanent corrective action on significant discrepancies.

The inspectors verified by physical examination of purchased items that the items met design and purchase order (PO) requirements. The inspectors also reviewed pertinent documentation including individual certification/certificates of conformance, to ensure that the items were properly qualified according to 10 CFR 50 Appendix B, and met the design intent. The inspectors specifically reviewed documentation and physically inspected items associated with PO 00001827-04188 which included different sized American Society of Mechanical Engineers (ASME)Section III Class II studs and PO 0004248-00840 which included the following ASME Section III Class II items:

-

One 1 pipe cap, ASME SA105

-

Three 6 90 degree elbows ASME SA234 Grade WPB, LR, Schedule 80

-

One 20 pipe ASME SA 106 Grade B Schedule 80

These items are further discussed in Section E.1.2, Procurements Activities. Specific documents reviewed are listed in Attachment 1.

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspectors determined that TVA and Bechtel continue to have adequate QA oversight commensurate with the level of activity and adequate corrective actions are being implemented.

In addition, the inspections documented in this inspection report coupled with previous inspections documented in NRC Inspection Reports 05000391/2008006, 2008007, 2008009, and 2008010 completed the inspection requirements for IP 35061 from a construction readiness standpoint. See Attachment 3 to this inspection report.

Q.1.3 Review of QA Manual (IP 35100)

a. Inspection Scope

The inspectors reviewed work and quality inspection procedures for construction activities, as well as for test control and control of test equipment, to confirm that these documents conformed to the approved QA program, met applicable QA administrative requirements, were issued to cover significant expected construction activities, were adequately controlled, and contained expected QA criteria (e.g. inspection hold points).

The inspectors also held discussions with TVA and Bechtel personnel regarding the status of these activities.

Additionally, the inspectors reviewed measuring and test equipment (M&TE) procedures and verified that test acceptance criteria were specified to assure adequate controls, calibration and adjustment of the M&TE. The inspectors also confirmed that adequate methods were in place for establishing traceability of an inspected/tested work activity to the instrument used for acceptance purposes. The inspectors reviewed the current M&TE lists and calibration certificate for a surface thermometer, instrument number 60027539. Specific documents reviewed are listed in Attachment 1.

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspectors determined that TVA and Bechtel had established procedures required to conduct construction activities. These procedures were approved and controlled in accordance with QA requirements and included expected QA criteria. This inspection sample, coupled with previous inspections documented in NRC reports 05000391/2008006, 2008009, and 2008010, completed the inspection requirements for IP 35100 for the purpose of assessing the readiness of TVA and Bechtel to conduct construction activities. See Attachment 3 to this inspection report.

Q.1.4 Identification and Resolution of Construction Problems (IP 40504)

a. Inspection Scope

The inspectors reviewed the self-assessment program procedure, a QA audit, several Bechtel QA reports, an applicant QA report, and selected PERs in order to assess QA oversight and adequacy of corrective actions. Specific documents reviewed are listed in

1.

b. Observations and Findings

No findings of significance were identified. The self-assessment program procedure was adequately written and provided guidance for selection of assessors, planning, defining personnel responsibilities, handling of findings and observations, and documentation.

c. Conclusions

The inspectors determined that TVA and Bechtel continued to maintain adequate QA oversight commensurate with the level of activity and implement appropriate corrective actions.

Q.1.5 Safety Conscious Work Environment (IP 40504)

a. Inspection Scope

During this inspection period, the inspectors focused on TVAs and Bechtels programs for resolving employee concerns. This inspection is a follow-up to an initial inspection conducted in March 2008 and documented in Inspection Report 05000391/2008006 which assessed the readiness of TVA and Bechtel to conduct construction activities.

This review included interviews with site employee concern representatives, evaluation of employees access to the employee concerns representative, review of a listing of new employee concerns, evaluation of any anonymous concerns, and corrective actions for selected concern files to evaluate the adequacy of the programs to provide employees with an alternate method to identify quality or safety-related concerns.

Specific documents reviewed are listed in Attachment 1.

b. Observations and Findings

No findings of significance were identified. The inspectors determined that TVAs and Bechtels employee concern programs were well managed and staffed with capable personnel.

c. Conclusions

The inspectors determined that TVA and Bechtel had established an acceptable program and environment for allowing employees to identify quality or safety-related concerns

The inspections performed in this section and in section Q.1.4 above, coupled with previous inspections documented in NRC reports 05000391/2008006, 2008009, and 2008010, completed the inspection requirements for IP 40504 for the purpose of assessing the readiness of TVA and Bechtel to conduct construction activities.

II. Management Oversight and Controls

C.1 Construction Activities C.1.1 Walkdowns (IPs 35061 and 50090)

a. Inspection Scope

The inspectors observed the field walkdown of Hanger/Support #2-03A-459 inside Unit 2 containment per Work Package WBN2-PD-003-1798-04. This activity was part of TVAs program to verify the field condition of safety-related hangers and supports. The inspectors reviewed TVAs procedure WDP-PD-2, Walkdown Procedure for Piping and Pipe Supports to determine whether adequate guidance to provide assurance of quality control and field work being performed. Specific documents reviewed are listed in

1. The following samples were inspected:

IP 50090 Section 02.01.a - one sample

IP 50090 Section 02.03.f - one sample

b. Observations and Findings

No findings of significance were identified. The inspectors determined that the hanger walkdown activity, including independent verification of hanger/support measurements, was being properly conducted.

c. Conclusions

The inspectors determined that walkdown activities for safety-related pipe hangers and supports were being performed in accordance with applicable procedures and documented appropriately.

C.1.2 Protection of Installed Plant Equipment during Construction Activities (IPs 50051, 50053, and 50055)

a. Inspection Scope

The inspectors conducted inspections of the reactor pressure vessel (RPV) core barrel and lower internals storage, preservation, housekeeping, and protection activities to determine whether requirements, work procedures, and inspection (QC) procedures were being met. On February 25, 2009, the inspectors entered the RPV core barrel and lower internals to observe the current condition and housekeeping measures in place.

The inspectors reviewed housekeeping procedure 25402-000-GPP-0000N2102 which establishes the measures for protection and cleanliness and reviewed associated records. The inspectors reviewed the Controlled Cleanliness Zone Area Registry Log, E of the Housekeeping procedure, and sampled some of the areas to verify that adequate controls and proper postings were in place. The inspectors also reviewed two PERs associated with the storage, preservation, housekeeping, and protection of the RPV. Specific documents reviewed are listed in Attachment 1.

The following samples were inspected:

IP 50051 Section 02.04.e - one sample

IP 50053 Section 02.01.c - one sample

IP 50053 Section 02.03.b - one sample

IP 50053 Section 02.03.d - one sample

IP 50055 Section 02.02.b - one sample

IP 50055 Section 02.02.c - two samples

b. Observations and Findings

No findings of significance were identified. The inspectors observed that TVA implemented adequate foreign material exclusion controls associated with activities in the RPV core barrel and lower internals. This included the installation of a protective covering over the top of the RPV core barrel and internals to prevent entry of foreign objects and debris and the entry control of tools, equipment, and personnel. TVA and Bechtel established a baseline housekeeping assessment for controlled cleanliness zones, including the RPV.

c. Conclusions

Adequate controls were in place to protect the RPV core barrel and lower internals.

C.1.3 Electrical Penetrations (IPs 51051, 51053, 51055, 53053, and 53055)

a. Inspection Scope

The inspectors witnessed the sealing of electrical penetrations associated with the Auxiliary Building Secondary Containment Enclosure (ABSCE) boundary modification in support of the temporary openings in Unit 2 containment. These openings will allow personnel and equipment access directly into Unit 2 without having to enter through the Unit 1 Radiologically Controlled Area (RCA). The inspectors witnessed sealing activities for penetrations A12248, A12249, and A12251 with construction personnel working under work order (WO) 07-823169016, UNID WBN-0-MISC-304.

The inspectors also reviewed corrective actions associated with PER 163249 which documented improper sealing of electrical floor penetration A12424. Records for the work and inspection of these penetrations were reviewed to determine whether requirements had been met. Additionally, IPs 53053 and 53055 were used as guidance.

Specific documents reviewed are listed in Attachment 1.

The following samples were inspected:

IP 51051 Section 02.02.c - one sample

IP 51051 Section 02.02.e - one sample

IP 51053 Section 02.01.f - one sample

IP 51053 Section 02.02.d - one sample

IP 51053 Section 02.02.e - one sample

IP 51055 Section 02.02.c - one sample

IP 51055 Section 02.02.d - one sample

IP 51055 Section 02.04 - one sample

b. Observations and Findings

No findings of significance were identified. The improper sealing of electrical floor penetration A12424 was determined not to be a violation of regulatory requirements.

c. Conclusions

Activities for installing and replacing electrical penetration seals were being conducted in accordance with procedures.

C.1.4 Safety Related Piping Work Observation (IPs 49063, 49065, 55050)

a. Inspection Scope

The inspectors observed work in progress associated with the removal of a 6-inch TVA Class B (ASME Section III, Class 2) pipe near Penetration 47A and replacement with new pipe section meeting ASME Class 2 requirements. The replacement was performed in support of system completion for the glycol piping in the ice condenser system. The work was being performed under WO 08-952876-000 and engineering document construction release (EDCR) 52612. The inspectors observed handling, cleanliness control, installation of pipe, cutting, and grinding and reviewed field drawings, procedures, material specifications, material test reports, gas tungsten arc welding (GTAW) weld performance test qualification test record, and documentation of quality-related inspections. Radiographic test (RT) non-destructive examination (NDE)was reviewed and documented separately in Section C.1.5. Specific documents reviewed are listed in Attachment 1.

The following samples were inspected:

IP 49063 Section 02.01 - one sample

IP 49063 Section 02.02 - one sample

IP 49063 Section 02.03 - one sample

IP 49065 Section 02.01 - one sample

IP 55050 Sections 02.06.a - one sample

IP 55050 Sections 02.06.b - one sample

IP 55050 Sections 02.06.c - one sample

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The activities observed relative to safety-related piping were adequate and completed in accordance with applicable drawings and specifications.

C.1.5 Radiograph Film Interpretation of Safety-Related Welds (IP 57090)

a. Inspection Scope

The inspectors reviewed radiographs of two completed welds on safety-related piping.

These welds were the first new ASME piping welds performed by Bechtel since construction reactivation. Additionally, these welds were performed in support of ongoing modifications in support of moving the existing ABSCE boundary. Radiographs were reviewed to determine whether they were prepared, evaluated, and maintained in accordance with applicable commitments and/or requirements.

Specific radiographs reviewed included the following:

Report #

Weld ID

Component

RT001 S61GLYCOLFW-6A 6 Inch diameter Ice Condenser Glycol Piping RT002 S61GLYCOLFW-6B 6 Inch diameter Ice Condenser Glycol Piping

Both welds were performed using the gas tungsten arc process in six-inch diameter ASME Class 2 piping in ice condenser system.

The records were compared to the applicable code (ASME Boiler and Pressure Vessel Code,Section III, 1971 Edition with Addenda through Summer 1973) to verify compliance. Additionally, the inspectors reviewed qualification records and eye examination documentation for the associated NDE examiners. Specific documents reviewed are listed in Attachment 1.

The following samples were inspected:

IP 57090 Section 02.03.a - two samples

IP 57090 Section 02.03.b - two samples

IP 57090 Section 02.03.c - two samples

IP 57090 Section 02.03.d - two samples

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspectors determined that the reviewed radiographs met applicable ASME code requirements and other regulatory requirements.

C.1.6 Liquid Penetrant Examination of Safety-Related Welds (IP 57060)

a. Inspection Scope

The inspectors reviewed the liquid penetrant report for the completed NDE for two safety-related attachment welds associated with the Unit 2 steel containment vessel.

The liquid penetrant report was reviewed to determine whether it was prepared, evaluated, and maintained in accordance with applicable commitments and/or requirements.

The inspectors reviewed NDE Report PT-004 which documented the liquid penetrant examination of containment attachment welds FW-04 and FW-05. Both welds were ASME Section III, Class MC welds. The nondestructive examination was performed as part of the base metal evaluation associated with PER 152573, which documented unintended partial removal of the above two attachment welds. The welds had a portion of the base metal removed during the recent removal of temporary latching bars for the containment air lock.

The records were compared to the applicable code (ASME Boiler and Pressure Vessel Code,Section III, 1971 Edition with Addenda through Summer 1973) to verify compliance. Additionally, the inspectors reviewed qualification records and eye examination documentation for the associated NDE examiners. Specific documents reviewed are listed in Attachment 1.

The following samples were inspected:

IP 57060 Sections 02.03.a - two samples

IP 57060 Sections 02.03.b - two samples

IP 57060 Sections 02.03.c - two samples

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspectors determined that the observed/reviewed NDE record met applicable ASME code requirements and other regulatory requirements.

C.1.7 Electrical Systems and Components (IP 52051, 52053, 51061 and 51063)

a. Inspection Scope

The inspectors observed and reviewed work associated with the point to point verification of wire within the solid state protection system (SSPS) cabinets. The SSPS is associated with the reactor trip system and the engineered safety features actuation system. The purpose of this verification was to determine the Unit 2 SSPS wiring configuration as compared to Unit 1 as-constructed drawings. The inspectors reviewed WOs 08-956285-000 and 08-956286-000.

The inspectors reviewed applicable work instructions to ensure that requirements were properly translated into the work procedures and that components had been correctly and permanently identified. The inspectors also verified cleanliness requirements had been maintained.

In addition, the inspectors performed a walkdown of cables in the annulus area and held discussions with TVA on PERs (162649 and 163461) related to unprotected and potential damaged cables. Specific documents reviewed are listed in Attachment 1.

The following samples were inspected:

IP 52051 Section 02.02.c - one sample

IP 52053 Section 02.02.e - one sample

IP 51061 Section 02.02.c - one sample

IP 51061 Section 02.02.d - one sample

IP 51063 Section 02.02.e - two samples

b. Observations and Findings

No findings of significance were observed.

c. Conclusions

Activities associated with electrical systems and components were adequate.

E.1 Engineering Activities

E.1.1 Engineering Organization, Document Control and Design Control (IPs 37055, 35061 and 35960)

a. Inspection Scope

The inspectors reviewed different types of engineering documents and interviewed personnel associated with ongoing design activities. The inspections covered procedure reviews; procedure implementation; calculations; specifications; drawings; design inputs; design interfaces with other disciplines/organizations; design verification of different engineering products; the use of design basis documents; the use of the master equipment list (MEL) database; document control; and associated PERs.

The inspectors reviewed ongoing design activities associated with TVAs plans to modify the auxiliary building secondary containment enclosure (ABSCE) boundary. This modification consisted of temporary construction openings being installed along the Unit 2 containment to support completion of work inside the Unit 2 reactor building. This interim ABSCE boundary and openings will allow direct access from the outside and minimize impact on Unit 1 by reducing access into the radiological controlled area. The inspectors observed the post modification test of the new interim ABSCE boundary and reviewed the test results. The inspectors also observed final installation and testing of the roll-up doors, and cutting activities of the new construction openings. After completion of Stage 3 of the ABSCE design package and following the recommendation to return the ABSCE to an operational status, the inspectors conducted an independent walkdown of the ABSCE boundary wall to verify that clearances between scaffolding and piping were maintained in accordance with applicable procedures. Specific documents reviewed are listed in Attachment 1.

b. Observations and Findings

One finding of significance was identified.

Engineering procedures reviewed appeared to be adequate and were being implemented correctly. The engineering calculations reviewed incorporated the requirements of the design basis documents and implemented design interfaces correctly by using inputs from other calculations and transmitting outputs to other disciplines as required. Engineering specifications reviewed were completed in accordance with procedures and received the required reviews and certifications.

Drawings reviewed were included in the EDCR packages and will only be issued as stand-alone documents once they reflect the as-constructed condition. As such, drawings reviewed did not include a separate independent design verification signature since they were independently reviewed as part of the review of the EDCR package.

The inspectors noted that the WO procedure did not warn the users that the MEL had unverified fields and did not provide guidance on the handling of these fields. This was a concern for stand-alone WOs. PER 164596 was initiated to address this concern.

Document control facilities were inspected at the site. The inspectors noted that the controls used were similar to those used for Unit 1.

Test results of the interim ABSCE boundary were adequate.

Introduction:

The inspectors identified a Severity Level (SL) IV non-cited violation (NCV)of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings," for failure to accomplish activities affecting quality in accordance with instructions and procedures.

Description:

On March 12, 2009, the inspectors conducted an independent walkdown of the interim ABSCE boundary and reviewed DCN 52283, which implements the ABSCE modification. This modification is in support of Unit 2 construction activities. The inspectors identified three examples associated with scaffolding deficiencies where procedural requirements were not implemented in accordance with applicant procedure MMTP-102, Erection of Scaffold/Temporary Work Platforms and Ladders.

During the walkdown, the inspectors identified two examples where scaffolding did not meet clearance requirements in accordance with MMTP-102. Specifically, scaffolding 13016-3 and 16516 were found to have clearance violations which were not noted or evaluated on the scaffolding evaluations and, therefore, did not have the appropriate engineering review. The scaffolding was installed by the Unit 2 construction organization in support of Unit 2 construction activities and was located adjacent to piping which penetrates the interim ABSCE boundary wall. This boundary serves to maintain an effective barrier for airborne radioactive contaminants released in the auxiliary building during abnormal events on Unit 1, the operating unit. Both scaffolding configurations had less than the required clearance between the scaffolding and piping that is part of the interim ABSCE boundary in the Unit 2 pipe chase. These configurations were not appropriately evaluated to ensure that the associated SSCs and their respective safety-related functions were not impacted by the scaffolding during a seismic event.

In addition to the above two examples, the inspectors also identified an example where actions to perform a final scaffolding walkdown, in accordance with MMTP-102, were not conducted. This final walkdown was to include scaffolding in the vicinity of the interim ABSCE boundary walls and was to be conducted prior to return to operations of Stage 3; which was to establish the new boundary as stated in the design document (DCN 52283). As a result of these issues, the applicant initiated Level B PERs 165792 and 165806 to address both the non-conforming clearances and the final walkdown not being performed.

The scaffolding was immediately corrected to comply with procedural requirements. An apparent cause and appropriate engineering evaluations were also conducted for the scaffolding. The engineering evaluation concluded the as-found clearances were acceptable from a seismic analysis standpoint.

The inspectors determined that this finding was more than minor because the finding represented an improper/uncontrolled work practice and represented a deviation that, if left uncorrected, could adversely affect the seismic qualification of a SSC. The finding was determined to be of very low safety significance because, while improperly installed scaffolding has the potential to adversely affect SSCs, the specific examples identified did not result in a loss of a safety function or barrier integrity on Unit 1 and did not render equipment inoperable on Unit 1 due to seismic requirements. Subsequent to the issues being identified, a walkdown of scaffolding in the vicinity of the interim ABSCE boundary wall was performed by TVA which resulted in the identification of three additional non-conforming clearance configurations between scaffolding and SSCs along the interim ABSCE boundary wall. The three additional non-conformance clearance configurations were resolved.

The cause of this finding was directly related to the work practices component of the Human Performance cross-cutting area because TVA and Bechtel did not define and effectively communicate expectations regarding procedural compliance and as a result, personnel failed to follow procedures (H.4.b). After further review of MMTP-102, the inspectors determined that the scaffolding procedure was adequate; however, as discussed in the examples above, the procedure was not followed on several occasions by different personnel. As part of the corrective actions documented in PER 165792, management plans to issue a construction bulletin to stress the importance of following work instructions and DCN requirements as written.

Enforcement:

10 CFR 50, Appendix B, Criterion V, Instructions Procedures, and Drawings," states in part, that activities affecting quality shall be accomplished in accordance with prescribed instructions and procedures.

Contrary to the above, on March 12, 2009, the inspectors identified three examples

where MMTP-102 procedural requirements were not implemented, therefore, affecting the quality of safety-related activities and SSCs. TVA and Bechtel initiated immediate actions to correct the scaffolding and performed walkdowns during which three additional non-conforming clearance issues were identified. This finding was determined to be a SL IV violation using Supplement II of the Enforcement Policy. Because this was a SL IV violation and because it was entered into the corrective action program as PERs 165792 and 165806, this violation is being treated as a non-cited violation (NCV)consistent with Section VI.A of the NRC Enforcement Policy: NCV 5000391/2009602-01, Scaffolding Issues.

c. Conclusions

Activities associated with the ABSCE modification including testing were adequate with the exception of the procedural non-cited violation discussed above. In addition, the inspections documented in this inspection report coupled with previous inspections documented in NRC Inspection Reports 05000391/2008006, 2008007, 2008009, and 2008010 completed the inspection requirements for IPs 35061 and 35960 from a construction readiness standpoint. The inspection status of IP 37055 is shown in a table included in Attachment 3 to this inspection report.

E.1.2 Procurement Activities (IPs 35060, 35065 and 35960)

a. Inspection Scope

The inspectors reviewed different types of procurement documents and interviewed personnel associated with ongoing procurement activities. The inspections covered:

procedure reviews; procedure implementation; procurement data sheets (PDSs); POs; commercial grade dedication plans and packages; QA procurement interface; QA review of procurement documents; technical requirements in procurement documents; QA inputs to procurements; imposing 10 CFR Part 21; item acceptance; TVAs approved suppliers list (ASL) and Bechtels evaluated suppliers list (ESL); interfaces with other disciplines/organizations; independent verification; review of procurement technical documentation by technical personnel; and associated PERs.

The inspectors reviewed TVAs procedure SPP-4.2, Material Receipt Inspection, Revision 20, and determined that it adequately implemented the receipt inspection requirements of American National Standards Institute (ANSI) N45.2.2, Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants.

Inspectors reviewed documentation associated with PO 00001827-04188 which included different sized ASME Section III Class II studs and PO 0004248-00840 which included the following ASME Section III Class II items:

-

One 1 pipe cap, ASME SA105

-

Three 6 90 degree elbows ASME SA234 Grade WPB, LR, Schedule 80

-

One 20 pipe ASME SA 106 Grade B Schedule 80

This review included procurement specifications, technical notes, material requirements details, nuclear supplier QA program requirements data sheets, PDSs, receipt verification/inspection requirements, and certificates of compliance.

The inspectors held discussions with TVA and Bechtel staff and reviewed activities, facilities, records, and procedures for procurement, receiving, and storage of items. The inspectors also reviewed the requirements specified in procurement documents for documentation and acceptance of safety-related items and inspected the facilities used for storage of these items. Documents reviewed are listed in Attachment 1.

b. Observations and Findings

No findings of significance were identified.

The inspectors observed that Bechtel was using the TVA process for procurement activities such as procurement engineering and commercial grade dedication. TVAs ASL is used except when purchasing ASME III products in which case Bechtels ESL is used. Procurement documents reviewed such as PDSs, POs, and commercial grade dedication plans and packages complied with the applicable TVA procedures, received independent verification and included adequate technical requirements. Safety-related POs reviewed were issued to vendors listed on either the ASL or the ESL and invoked the requirements of 10 CFR Part 21. The inspectors could not find a defined QA procurement interface. However, QA signed off on the material request forms and procurement used the ASL and the ESL that were compiled by QA for safety-related purchases. Procurement technical documentation and commercial grade dedication reports were reviewed by technical personnel. Receipt inspection reports reviewed determined the acceptance of purchased items.

The inspectors verified that specified design parameters for the POs were in accordance with those listed in applicable TVA specifications. Procurement specifications were found to have adequately identified applicable technical requirements as well as requirements pertaining to 10 CFR 21, Quality Assurance, Environmental Qualification, and acceptance of the items.

The inspectors observed the physical condition of the items associated with POs 0004248-00840 and 00001827-04188 and witnessed no signs of damage or deterioration. The inspectors also verified that adequate identification appeared on these and other items and that ASME items were clearly tagged and physically separated from non-ASME items.

The inspectors reviewed TVAs procedure SPP-4.3, Material Storage and Handling, Revision 6, and determined that it adequately implemented the storage requirements of American National Standards Institute (ANSI) 45.2.2. The inspectors reviewed TVAs periodic inspection records of the storage facilities to verify compliance with requirements for records of storage conditions. The inspectors also independently verified that the facilities used for onsite storage of items met the requirements specified by TVAs procedure. The inspectors observed that storage conditions were adequate, access to storage areas was controlled, items were identified with tags, and special storage requirements (e.g., physical separation of ASME components) were met. The inspectors inspected the receiving warehouse and observed designated areas where nonconforming items were to be segregated and tagged. The inspectors also reviewed EDCR 52621, Roll-up Doors and determined that the appropriate receiving inspection organization was aware of the source verification results for the design change.

c. Conclusions

The inspections documented in this inspection report coupled with previous inspections documented in NRC Inspection Reports 05000391/2008006, 2008007, 2008009, and 2008010 completed the inspection requirements for IPs 35060, 35065, and 35960 from a construction readiness standpoint. QA and management oversight of procurement activities was adequate.

T.1 Training and Qualification of Plant Personnel T.1.1 Craft Training (IPs 35061, 46071 and 50090)

a. Inspection Scope

The inspectors observed activities associated with new employee indoctrination and training. The inspectors monitored craft classroom training sessions including required training for obtaining piping support data in support of piping support walkdowns. This training covered procedural requirements contained in WDP-GEN-1, Walkdown Procedure for General Walkdown Requirements. The inspectors also observed anchor bolt classroom training and field demonstrations. As part of this training observation, the inspectors also reviewed procedures 25402-000-GPP-0000-N3212, Drilled-In Anchors and Core Drilling Operations, and MAI-5.1E, Expansion Shell Anchors Installation.

Documents reviewed are listed in Attachment 1.

The following samples were inspected:

IP 46071 Section 02.01.a - one sample

IP 46071 Section 02.01.b - one sample

IP 46071 Section 02.01.c - one sample

IP 50090 Section 02.01.f - one sample

IP 50090 Section 02.02.a. - one sample

b. Observations and Findings

No findings of significance were identified.

The inspectors noted that during the general walkdown procedure training neither lessons learned nor operating experiences were discussed. This expectation is addressed in Bechtels Training Procedure, 25402-MGT-0001, Attachment C, which included an instructor evaluation describing evaluation criteria for the discussion of operating experience. PER 162946 was initiated to address this observation.

c. Conclusions

TVAs program for training of newly hired personnel was adequate for the current level of construction activities being performed.

III. Operational Readiness Activities

F.1 Fire Protection (IP 64051)

a. Inspection Scope

The inspectors held discussions with TVAs fire protection engineer regarding fire protection requirements applied to Unit 2 construction activities which were established to prevent an adverse affect of a fire on Unit 1 operations. The inspectors reviewed applicable fire protection procedures, observed several fire suppression and detection devices dedicated for Unit 2 areas inside the reactor building, auxiliary building and turbine building. The inspectors conducted a walkdown of the Unit 2 fire protection/prevention controls that had been established by TVA. Specific documents reviewed are listed in Attachment 1.

The following samples were inspected:

IP 64051 Sections 02.02 - one sample

IP 64051 Sections 02.03 - one sample

IP 64051 Sections 02.04 - one sample

IP 64051 Sections 02.05 - one sample

IP 64051 Sections 02.06 - one sample

IP 64051 Sections 02.07 - twelve samples

IP 64051 Sections 02.08 - one sample

b. Observations and Findings

No findings of significance were identified.

The inspectors verified that the common CO2 tank had adequate level and pressure indication and that the current values of these measurements were acceptable. The inspectors also observed welding being performed in the Unit 2 auxiliary building and verified that adequate fire protection/prevention provisions were in place for this activity.

c. Conclusions

The work in progress had adequate permits and protection in place to minimize any impact on Unit 1. TVAs fire protection measures in place to support Unit 2 construction activities were also adequate.

IV.

Other Activities

OA.1 Construction Inspection Program Reconstitution Review

a. Inspection Scope

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 Manual Chapter 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.

To address the multiple construction QA issues identified in 1985, the NRC will inspect the implementation of the TVA Corrective Action Programs (CAP) and Special Programs (SP). In addition, the NRC plans to inspect other areas deemed necessary, based on additional reviews of historical allegations, previous open items, generic issues, and construction deficiency reports. Reconstitution of IPs dealing with TVAs procedures and programs was determined to be unnecessary because these were common for both units and the Unit 1 reconstitution effort documented in NUREG-1528 confirmed adequate reviews were completed. Also, one IP (65051, Low-Level Radioactive Waste Storage) was determined to not be applicable and several IPs were known to cover work not yet completed so these were not considered for reconstitution. New work or activities performed in areas covered by the IPs will be inspected, utilizing all applicable IPs, as part of the rework inspection effort. Specific NRC inspection report numbers credited for each IP during reconstitution reviews and results summaries are listed in

2.

b. Observations and Findings

The reconstitution reviews identified that many of the inspection requirements specified in IMC 2512 IPs were completed during previously performed NRC inspections of Unit 2 SSCs. Little Unit 2-specific work was accomplished after 1985; however, common systems were completed for Unit 1 operation which could be credited for Unit 2 inspections. Limited credit was given to common systems to assure sufficient Unit 2-specific activities were covered.

c. Conclusions

The reconstitution effort was completed and the status of previously performed inspections as compared to requirements in IMC 2512 IPs was defined from these reviews. The required inspections are shown on Attachment 2.

V.

Management Meetings

X.1

Exit Meeting Summary

On April 9, 2009, the resident inspectors presented the inspection results to Mr. Masoud Bajestani and other members of his staff. Although some proprietary information may have been reviewed during the inspection, no proprietary information was included in this inspection report.

X.5 Public Meeting Summary

On April 14, 2009, the NRCs Chief of Construction Projects Branch 3, and the Resident Inspectors, held a Category 3 meeting for members of the public and local officials. This Category 3 public meeting provided an informative presentation to engage the public in a discussion of the NRCs annual assessment of the Watts Bar Nuclear Plant Unit 2 construction project for the period from January 1 through December 31, 2008. The members of the public expressed no concerns about the construction activities at the Watts Bar facility. The presentation material used for discussions (Attachment 4) and the list of attendees (Attachment 5) are attached to this report.