IR 05000391/2010606
| ML102280522 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 08/13/2010 |
| From: | Haag R NRC/RGN-II/DCP/CPB3 |
| To: | Bhatnagar A Tennessee Valley Authority |
| References | |
| IR-10-606 | |
| Download: ML102280522 (21) | |
Text
UNITED STATES TVA NUCLEAR REGULATORY COMMISSION ust 13, 2010
SUBJECT:
WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INSPECTION REPORT 05000391/2010606
Dear Mr. Bhatnagar:
On July 2, 2010, 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 July 2, 2010, with Mr. Jerry Schlessel 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 associated with your construction refurbishment program.
Based on the samples reviewed, the inspection found that the refurbishment program was adequate to ensure all components and commodities are covered with one exception regarding those items that may not have unique identifiers which is described in the enclosed report. You had identified this area for corrective action prior to the inspection. In addition, the sample inspections of refurbishment implementation activities found these to be acceptable. Based on the results of this inspection, no findings or violations of significance were identified.
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
TVA 2 http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Should you have any questions concerning this letter, please contact me at (404) 997-4446.
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 05000391/2010606 w/Attachment
REGION II==
Docket No.: 50-391 Construction Permit No.: CPPR-92 Report No.: 05000391/2010606 Applicant: Tennessee Valley Authority (TVA)
Facility: Watts Bar Nuclear Plant, Unit 2 Location: 1260 Nuclear Plant Rd Spring City TN 37381 Dates: June 28 - July 2, 2010 Inspectors: P. Van Doorn, Senior Reactor Inspector, Construction Projects Branch 3 (CPB3), Division of Construction Projects (DCP)
Region II (RII) (Sections Q.1.1, E.1.1, E.1.4)
A. Issa, Project Inspector, CPB3, DCP, RII (Sections Q.1.1, E.1.1, E.1.2, E.1.4)
G. Khouri, Senior Construction Inspector, DCP, CPB2, RII (Sections E.1.1, E.1.3)
G. Crespo, Senior Construction Inspector, Division of Construction Inspection (DCI), RII (Section E.1.1)
T. Steadham, Construction Inspector, DCI, RII (Sections E.1.1, E.1.3)
M. McConnell, Senior Electrical Engineer, Office of Nuclear Reactor Regulation (NRR) (Section E.1.1)
P. Shemanski, Senior Electrical Engineer, NRR (Section E.1.1)
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 05000391/2010606 This team inspection included aspects of engineering and construction activities performed by TVA and its contractor regarding development and implementation of the construction refurbishment program. This report covered the period of June 28 - July 2, 2010. 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 had established a viable program to ensure all commodities and components are covered in the refurbishment process. However, the inspection identified several observations regarding process improvements as noted below.
Inspection Results
- Oversight activities for the refurbishment program were reviewed and determined to be thorough.
- The inspectors concluded that the program, if implemented as planned and inspection results are appropriately evaluated for possible expansion of sample size, is adequate to assure all components, structures, and commodities are scoped within the refurbishment program. One potential exception was identified by the applicant and was entered into the corrective action program.
- The inspectors noted that the program was not clear regarding the expected qualification requirements for passive inspection personnel and the process for consideration of real time field observations during construction was not well defined.
- Multiple examples were noted in completed vendor refurbishment packages where wording could lead to confusion or quality issues. No actual technical issues were noted and other steps or controls in the process would serve to assure quality.
REPORT DETAILS
Background Most of the equipment at Watts Bar Unit 2 was installed during the original construction period.
Since layup activities were terminated for a period of time after 2001, it is necessary to ensure the equipment is still capable of meeting its required specifications. In order to address this concern, the applicant established a refurbishment program to identify the scope of equipment in the program, and perform appropriate activities to assure design standards are met. The applicants general program procedure for refurbishment, 25402-000-GPP-0000-TI216, Watts Bar Unit 2 Completion Project Refurbishment Program, was submitted to NRC on July 8, 2009 and reviewed by the Office of Nuclear Reactor Regulation (NRR). This resulted in issuance of the NRC Safety Evaluation Report (SER) dated July 2, 2010 (TAC No. ME1708). In general the SER review found the program to be acceptable. The general program did not specify specific components, structures, and commodities in detail to be covered. This inspection reviewed detailed scoping procedures and activities and selected actual implementation activities to confirm components, structures, and commodities were adequately covered.
I. Quality Assurance Program Q.1 Quality Assurance (QA) Oversight Activities Q.1.1 Refurbishment Self-Assessment and Problem Identification and Resolution (IP 37002)
a. Inspection Scope
The inspectors reviewed a self-assessment and a Quality Assurance surveillance to determine if the applicants oversight was thorough and appropriate corrective actions were initiated based on the findings. In addition, the inspectors reviewed selected Problem Evaluation Reports (PERs) to determine if appropriate corrective actions were initiated. Specific documents reviewed are listed in the Attachment.
The following samples were inspected:
- IP 37002 Section 02.01.c - 2 samples (complete)
- IP 37002 Section 02.02.f - 10 samples
b. Observations and Findings
No findings of significance were identified. The oversight activities reviewed were thorough, broad based, and self critical. A number of problems were identified by the oversight activities and corrective actions were initiated via PERs as appropriate.
Although the corrective actions specified seemed reasonable, the engineering evaluations required for the more significant problems had not been completed at the time of the inspection and therefore, were not inspected. The QA surveillance identified that increased management attention was warranted for refurbishment implementation activities, however, the applicant had only recently received the report and had yet to address this observation.
c. Conclusions
The oversight activities reviewed were thorough, broad based, and self critical. The inspection results are too limited to support a conclusion regarding corrective actions at this time.
II. Management Oversight and Controls E.1 Engineering Activities E.1.1 Refurbishment Scoping Inspection (IP 37002)
a. Inspection Scope
The inspectors reviewed various scoping documents in order to confirm that the applicants process was sufficiently thorough to assure all systems, structures, and components (SSCs) are either included in the refurbishment process or have been justified for exclusion. In addition, the inspectors verified that the process included appropriate refurbishment activities, inspections, and tests. The inspectors selected the Auxiliary Feedwater System (AFW), some safety-related portions of the Main Feedwater System (MFW), and the injection portion of the Chemical and Volume Control System (CVCS) for the primary emphasis during this inspection. Various components and passive commodities for these systems were selected to confirm that they were covered by the process. This was performed by reviewing systems drawings and the applicants Master Equipment List (MEL), and by walk down observations.
For passive mechanical commodities the inspectors reviewed mark up drawings and the lists of planned inspections for the above systems to confirm that the type and location of planned inspections were appropriate to evaluate the most probable degradation mechanism and to cover sufficient areas to bound the systems. Field walk downs were conducted of portions of the AFW and CVCS systems to verify inspection points and observe field conditions. Records of passive inspections performed to date on these systems were also reviewed.
For electrical and instrumentation components, the inspectors reviewed the general procedures that addressed scoping; the scoping database which had the components listed along with planned activities; the draft Environmental Qualification (EQ) master list; and selected specific component refurbishment procedures, to confirm that appropriate acceptance criteria were included. The specific component procedures included EQ procedures for electrical penetrations, electrical junction boxes, and motors; and procedures for inspection and testing of GE-HFA relays (including vendor advisories),
Westinghouse DS circuit breakers, 6.9 KV circuit breakers, and Reactor Trip breakers.
The inspectors also reviewed calculations used to analyze the effects of long term cable layup on the anticipated life expectancy. Following these reviews, the inspectors randomly selected 47 safety-related active electrical component samples from two systems, AFW and CVCS, to determine if they were all addressed by the refurbishment program. The inspectors utilized approved plant drawings, electrical equipment lists, and field walk downs to select the components. The components reviewed included time delay relays, motor control center (bucket) starters, flow switches, solenoid valves, flow transmitters, level control valves, isolation valve hand switch, level controller, level indicators, level transmitters, isolation valve motors, centrifugal charging pump motor, pressure differential controller, pressure controllers, relays, and isolation valve transfer switches. The inspectors also reviewed work control and procurement documents to determine if each of these components had an associated work order or purchase order to perform the intended refurbishment activity or an appropriate justification where no such work or purchase order existed.
For mechanical components, the inspectors randomly selected 60 safety-related active mechanical component samples from eight systems to determine if all components and commodities were addressed by the refurbishment program. The inspectors utilized approved plant drawings, mechanical equipment lists, and field walk downs to select the components. The inspectors also reviewed work control and procurement documents to determine if each of these components had an associated work order or purchase order to perform the intended refurbishment activity or an appropriate justification where no such work or purchase order existed. Additionally, the inspectors reviewed six active mechanical components that the applicant excluded from the scope of refurbishment to determine if the basis for exclusion was justified.
The inspectors also reviewed the training plan for personnel assigned to the applicants Maintenance Rule inspection which was credited for inspection of structures.
The inspectors held discussions with applicant personnel regarding criteria for EQ evaluations, voltage levels for main control room Westinghouse (W2) switches, relay impedance testing, blocking or motor winding support structures, inspection of broken or loose motor rotor bars, mechanical refurbishment activities, and passive inspection results.
The applicants construction process included various walk downs to evaluate field conditions for potential refurbishment activities. The inspectors conducted independent walk downs of portions of the above listed systems to confirm conditions matched those listed by the applicant, evaluate actual field conditions for components and commodities, evaluate locations of planned passive inspections to assure these cover appropriate areas such as low points, and confirm various field observed components were covered by the process. The following electrical components were observed:
Electrical Penetrations WBN-2-PENT-293-0038-D Junction Boxes WBN-2-JB-292-1428-A WBN-2-JB-292-1410-B WBN-2-JB-292-1967-A WBN-2-JB-292-1409-A Motors WBN-2-MTR-003-0118D-A WBN-2-MTR-003-0128-B WBN-2-MTR-003-0128D-B WBN-2-MTR-062-0104-B WBN-2-MTR-062-0108-A Specific documents reviewed are listed in the Attachment.
The following samples were inspected:
- IP 37002 Section 02.01.a - (complete; no sample size size is required by the IP)
- IP 37002 Section 02.01.b - 3 samples (complete)
b. Observations and Findings
No findings of significance were identified.
The inspectors noted that the program was adequate to assure all components, structures, and commodities are addressed by the refurbishment program with one potential exception. The program was not clear as to how the applicant was ensuring evaluations were performed on equipment that did not have unique identifiers and would not be listed specifically on the MEL, e.g., equipment in vendor supplied electrical cabinets and skid mounted equipment. The applicant was planning to inspect these components and had recognized the need to describe the process in more detail prior to the inspection. The applicant had initiated PER 233210 to address this area. Also, the program relies on the corrective action process to ensure negative observations are adequately addressed.
The inspectors noted that the program was not clear regarding the expected qualification requirements for passive inspection personnel and the process for consideration of real time field observations during construction was not well defined. The applicant initiated PER 237813 to address these concerns.
No significant problems were noted during the walk downs. The observations of electrical equipment showed that the applicant had accurately identified field conditions.
No significant degradation was noted during the passive walk downs and appropriate inspection points were planned.
The training plan for Maintenance Rule structural inspection was thorough and appropriately tied to the applicants procedure.
The inspectors noted that for piping supports, electrical cable, conduit, and cable tray systems; the applicant credited the established specific Corrective Action Programs (CAPs) for these areas. This was considered acceptable and these activities will be covered via the planned NRC inspections of the CAPs.
In general, the process for evaluated EQ considerations was adequate. However, two questions were raised. These involved the use of 86-degrees F as the average temperature equipment was exposed to during the layup period and the applicants intentions to not upgrade Category 2 EQ equipment to Category 1 during the refurbishment process. These issues will be handled through the NRC licensing process.
The inspectors identified an Unresolved Item (URI) related to the temporary support of AFW suction and discharge piping. During a walk down of the AFW system, the inspectors observed that the suction and discharge piping had been disconnected when the associated pump was removed for refurbishment and the piping did not have temporary supports installed. Later, the applicant identified that WO 08-952956-001, step 4.7 required temporary supports be installed for this piping. The inspectors concluded that in order to properly evaluate and disposition this issue, additional inspection would be required to determine
- (1) the impact of not installing the temporary supports on the continued qualification of the piping;
- (2) the reason why step 4.7.1 of the WO to install the supports, was not completed; and
- (3) the extent of condition. This is URI 05000391/606-01, Evaluation of the Use of Temporary Supports When Equipment is Removed.
c. Conclusions
The inspectors concluded that the program, if implemented as planned and if the inspection results are appropriately evaluated for corrective action, is adequate to assure all components, structures, and commodities are addressed with one potential exception which had been identified by the applicant for corrective action.
E.1.2 Vendor Refurbishment Implementation (IP 37002)
a. Inspection Scope
Section 02.02.a.1 of IP 37002 requires confirming requirements are met for 8 - 10 samples of components being refurbished by vendors. Likewise, Section 02.02.a.2 of IP 37002 requires confirming requirements are met for 8 - 10 samples of components being replaced by vendors. RII staff had previously performed a comprehensive procurement, receiving and storage inspection that was documented in quarterly integrated inspection report 05000391/2010603. This inspection covered all phases of procurement activities in details and sampled many purchase orders associated with refurbishment. Examples included:
- PO 42199-2, Main Steam Safety Valves, Refurb., ASME Section III, Rev. 2
- PO 63534, Snubber, Hydraulic, QA 1, for Steam Generators, Rev. 0
- PO 87607, Limit Switch, ARMS, for Actuator, QA 2, Rev. 0 Therefore, the vendor implementation portion of the refurbishment inspection focused on reviewing complex and unique refurbishment contracts that were not covered by the previously conducted procurement inspection discussed above. The inspectors reviewed the following two contracts along with associated PERs and WOs, in detail:
- 25402-011-FC2-P409-00001, Refurbish Main Steam Isolation Valves (MSIVs),dated May 6, 2009
- CWA # PSS-WBN-2-2009-009, Revision 0, AFW Pump Motor Refurbishment The following samples were inspected:
- IP 37002 Section 02.02.a.1 - 4 samples (2 during this inspection and 2 covered in procurement inspection)
- IP 37002 Section 02.01.a.2 - 2 samples (both covered in procurement inspection)
b. Observations and Findings
No findings of significance were identified.
Multiple examples were noted in completed vendor refurbishment packages where wording could lead to confusion or quality issues or engineering direction was obtained inappropriately. No actual technical issues were noted and other steps or controls in the process would serve to assure quality. These involved:
- A manager of Parts and Services being allowed to make engineering decisions
- Allowing a contractor to unilaterally make changes to dwgs, design, or specifications
- A reference to original design/manufacturers specifications which do not exist
- Specifying motor performance as similar to U1 rather than per the specifications The applicant initiated PERs 237879, 237861 to address these issues.
c. Conclusions
The inspection results are too limited to support a conclusion at this time.
E.1.3 Active Mechanical System Components Onsite Inspection/Refurbishment (IP 37002)
a. Inspection Scope
The inspectors selected three safety-related valves that were being refurbished on-site to determine if the completed implementation activities were appropriate. For these valves, the inspectors reviewed completed work orders to determine if the appropriate refurbishment activities occurred (such as replacing degraded lubricants, gaskets, packing, and elastomers), associated corrective actions were performed, and testing was performed or included in an established test program. Additionally, the inspectors performed field observations on four valves with active work in progress to determine if work was being performed in accordance with approved procedures and if the procedures were appropriate to the circumstances.
The inspectors reviewed three completed work orders generated by the program to determine if the records were legible, retrievable, met the applicants records management requirements, and reflected completed work.
The following samples were inspected:
- IP 37002 Section 02.02.b - 3 samples of one type
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
The inspection results are too limited to support a conclusion at this time.
E.1.4 Passive Commodities Inspection/Refurbishment (IP 37002)
a. Inspection Scope
The inspectors selected passive piping inspection records for review. These included carbon steel and stainless steel piping in the three systems identified in Section E.1.1.
The inspectors also performed field walk downs as described in Section E.1.1.
In addition, the inspectors observed four field inspections of piping in the safety-related portion of the carbon steel Main Feedwater system at the following valve locations:
- 2-CKV-003-0670, Steam Generator 2 MFW Bypass Line Check
- 2-CKV-003-0669, Steam Generator 2 MFW Bypass Line Check
- 2-CKV-003-0678, Steam Generator 3 MFW Bypass Line Check
- 2-CKV-003-0679, Steam Generator 3 MFW Bypass Line Check Specific documents reviewed are listed in the Attachment.
The following samples were inspected:
- IP 37002 Section 02.02.d - two samples (two piping environments)
b. Observations and Findings
No findings of significance were identified.
The applicants inspections observed were thorough and no degradation was noted.
The inspectors noted one component which the applicant failed to include in the program, charging pump oil reservoirs. This was considered a minor oversight since the probability of degradation was low and other means to evaluate this component existed.
The applicant initiated PER 237865 for this concern.
As described in Section E.1.1, the inspectors noted that for piping supports, electrical cable, conduit, and cable tray systems; the applicant credited the established specific CAPs for these areas. This was considered acceptable and these activities will be covered via the planned NRC inspections of the CAPs.
c. Conclusions
The inspection results are too limited to support a conclusion at this time.
E.1.5 Record Review (IP 37002)
a. Inspection Scope
Records were reviewed as indicated in the preceding paragraphs, which included work packages, and inspection records.
Specific documents reviewed are listed in the Attachment under the various headings.
The following samples were inspected:
- IP 37002 Section 02.02.e - 17 samples
b. Observations and Findings
No findings of significance were identified.
c. Conclusions
The inspection results are too limited to support a conclusion at this time.
V.
Management Meetings X.1
Exit Meeting Summary
On July 2, 2010, the NRC inspectors presented the inspection results to Mr. Jerry Schlessel and other members of his staff. Although proprietary information was reviewed during the inspection, no proprietary information was included in this inspection report. An additional phone exit meeting was held on August 11, 2010 with Mr. Greg Scott to discuss the Unresolved Item discussed in Section E.1.1.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Applicant personnel
- D. Beckley, Electrical Design Manager, Bechtel
- B. Crouch, Licensing Manager, Unit 2
- H. Evans, Active Refurbishment Supervisor, Bechtel
- T. Franchuk, Quality Manager, Bechtel
- E. Freeman, Engineering Manager, TVA, Unit 2
- D. Osborne, Lead Civil Engineer, TVA, Unit 2
- J. Schlessel, Construction Manager, TVA, Unit 2
INSPECTION PROCEDURES USED
IP 37002 Construction Refurbishment Process - Watts Bar Unit 2
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000391/2010606-01 URI Evaluation of the Use of Temporary Supports When Equipment is Removed
Closed
None
Discussed
None