ML14323A562

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Report for the Audit Regarding Implementation of Licensing Preservation Program
ML14323A562
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 12/03/2014
From: Justin Poole
Watts Bar Special Projects Branch
To: James Shea
Tennessee Valley Authority
Dion J
References
TAC MF2022
Download: ML14323A562 (14)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 3, 2014 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37402-2801

SUBJECT:

WATTS BAR NUCLEAR PLANT, UNIT 2- REPORT FOR THE AUDIT REGARDING IMPLEMENTATION OF LICENSING PRESERVATION PROGRAM (TAC NO. ME2022)

Dear Mr. Shea:

As part of the Watts Bar Nuclear Plant (WBN), Unit 2 operating licensing review reactivation, and consistent with the U.S. Nuclear Regulatory Commission (NRC) staff's requirements dated July 25, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072060688 (Staff Requirements Memorandum-SECY-07-0096)), the NRC staff required the Tennessee Valley Authority (TVA) to develop and implement a licensing basis preservation program to confirm the validity of previously completed NRC safety evaluations to the final WBN, Unit 2 design, or to identify topics that require supplemental review.

In its submittal dated December 9, 2008 (ADAMS Accession No. ML083460177), TVA provided its licensing-basis preservation program. Specifically, TVA submitted New Generation Development and Construction Procedure PP-20, "Unit 2 Licensing Basis Preservation," which described the methods or processes for determining potential changes that could affect the Unit 2 licensing basis during the ongoing design and construction activities.

In Supplement 22 of NUREG-0847, "Safety Evaluation Report Related to the Operation of Watts Bar Nuclear Plant, Units 1 and 2," the NRC staff documented the results of their review of TVA's Program for Maintenance and Preservation of the Licensing Basis for Units 1 and 2 (Section 25.9). After reviewing TVA's program for licensing preservation, the staff concluded that the program, if properly implemented, provides reasonable assurance that any effects on previously reviewed and resolved safety evaluation report topics will be evaluated for WBN, Unit 2. An open item was created to track an NRC audit of TVA's licensing preservation program, which is Open Item 12 in Appendix HH of the Supplemental Safety Evaluation Report (SSER).

The staff conducted an onsite audit August 12 - 14, 2014, of TVA's licensing preservation program. As a result of the audit, the staff concluded that there is reasonable assurance that the licensing preservation program meets its intended purpose. The enclosed Audit Report details the staff audit activities and conclusions. This letter contains the basis for closure of Open Item 12 in Appendix HH of the SSER.

J. Shea If you have any questions, please contact me at 301-415-2048, or by e-mail at Justin.Poole@nrc.gov.

Justin C. Poole, Senior Project Manager Watts Bar Special Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.: 50-391

Enclosure:

Audit Report cc w/enclosure: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE AUDIT OF THE LICENSING PRESERVATION PROGRAM FOR WATTS BAR NUCLEAR PLANT, UNIT 2 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-391 BACKGROUND AND AUDIT BASIS The U.S. Nuclear Regulatory Commission (NRC) directed the staff to align the Watts Bar Nuclear Plant (WBN), Unit 2 licensing basis with Unit 1 to the maximum extent possible in Staff Requirements Memorandum-SECY-07-0096. In 2008, the Tennessee Valley Authority (TVA) submitted its licensing basis preservation program, New Generation Development and Construction Procedure (NGDC) PP-20, "Unit 2 Licensing Basis Preservation Program," which describes the methods or processes for determining potential changes that could affect Unit 2 licensing basis during the ongoing design and construction activities (Agencywide Documents Access and Management System (ADAMS) Accession No. ML083460177). In April 2009, the NRC staff reviewed TVA's submittal and requested additional information regarding the licensing basis preservation program. In 2009, TVA provided Bechtel Procedure "Engineering Document Construction Release 25402-3DP-G04G-0081" (EDCR), Revision 2, which defines the work process for the preparation, review, approval, issuance, management, and control of Unit 2 design changes, including how each change would be evaluated for licensing-basis impact. The EDCR is a collection of documents, data, and references that provide design and construction-related information to allow field work to proceed.

Specifically, Attachment J of the EDCR, "Licensing Basis Preservation Review Form," contains screening questions to identify potential impacts to the licensing basis. Appendix J of the Bechtel Procedure contains guidance on the completion of Attachment J for each EDCR issued.

This guidance will ensure that the Unit 2 licensing basis is implemented in the same manner as the corresponding Unit 1 licensing basis to obtain the same conclusion, to the maximum extent practical, as identified in NGDC PP-20. In NGDC PP-20, TVA stated that the process described in Appendix J addresses the corrective action program plans, special programs, generic communications, exemptions, reliefs, and other actions identified in the licensing basis preservation program.

In Supplement 22 of NUREG-0847, "Safety Evaluation Report Related to the Operation of Watts Bar Nuclear Plant, Units 1 and 2," the NRC staff documented the results of their review Enclosure

of TVA's Program for Maintenance and Preservation of the Licensing Basis for Units 1 and 2 (Section 25.9). After reviewing NGDC PP-20 and Appendix J of the Bechtel EDCR Procedure, the staff concluded that the program, if properly implemented, provides reasonable assurance that any effects on previously reviewed and resolved safety evaluation report topics will be evaluated for WBN, Unit 2. The NRC audit of TVA's implementation of NGDC PP-20 and EDCR Appendix J is documented as Open Item 12 in Appendix HH of the Supplemental Safety Evaluation Report (SSER).

AUDIT ACTIVITIES The onsite audit was conducted at the WBN facility from Tuesday, August 12, through Thursday, August 14, 2014. The NRC audit team staff was as follows:

Title Team Member Organization Team Lead Jeanne Dion NRR/DORL Technical Support- Licensing Justin Poole NRR/DORL Technical Support- Licensing Anthony Minarik NRR/DORL The NRC staff executed the onsite portion of the audit per the audit plan dated August 4, 2014 (ADAMS Accession No. ML14205A700). The staff reviewed a sample of closed and open EDCRs as listed in Attachments 1 and 2. Additionally, the staff reviewed TVA self-assessments of the licensing preservation program, TVA and Bechtel guidance procedures, and Problem Evaluation Reports (PERs) used to track relevant issues.

Prior to the onsite audit, the staff did a search of inspection reports and other documentation related to the licensing preservation program. In 2009, NRC inspectors identified areas where past Title 10 of the Code of Federal Regulations, Section 50.59 evaluations and screenings based their conclusions upon the unfinished state of Unit 2's facilities. The Inspection Reports 05000390/2009002 and 05000391/2009002 confirmed that there are fractional percentages of previous screenings and evaluations that will need to be revisited under the construction interface procedures tied to licensing basis preservation. This issue was tracked in PER 162088 to ensure that there is a clear reference to this activity within TVA's corrective action program (ADAMS Accession No. ML091140240).

AUDIT

SUMMARY

1.0 Entrance Meeting (Tuesday. August 12. 2014)

At the audit entrance meeting, the NRC staff audit team introduced itself, followed by introductions from the applicant's staff. The NRC staff presented a brief history of the licensing preservation program and the need for an audit to address Open Item 12 in a subsequent SSER. The list of participating NRC and licensee staff members is provided in Attachment 3.

The NRC audit team provided a brief overview of the audit's objectives and anticipated schedule. The applicant and contractor agreed to provide additional documents as requested to support the audit.

2.0 Licensing Preservation Program Overview The NRC staff reviewed NGDC PP-20, Revision 0, and documented its review in SSER 22.

Since that time, TVA has issued Revision 1 to NGDC PP-20. The changes are minor in that they change the document number (not title) of the controlling Bechtel Procedure for EDCR development. The changes do not impact the staff's previous conclusions in SSER 22.

Section 7.2.26, "Engineering Department Procedure Instruction EDCR 25402-3DP-G04G-00081, Revision 19," states:

An Attachment J, Licensing Basis Preservation Review Form, is required for EDCR and EDCR-2 packages. EDCRs issued via 25402-000-GPP-OOOO-N1204, Engineering Document Construction Release (EDCR) Process, or older revisions, shall receive an Attachment J review prior to closure. EDCRs previously closed shall be administratively changed, per Reference 5.8, to include an Attachment J review prior to system completion and turnover via Reference 5.4.

Per the Bechtel guidance, "Engineering Department Procedure Instruction EDCR- 25402-3DP-G04G-00081, Revision 19," only Unit 2 Bechtel Engineering licensing staff are qualified to complete Attachment J Parts 2 - 9. When an EDCR is closed and the work completed, Attachment J should be completed and included in the package.

A list of over 400 EDCR packages was provided to the audit team in advance of the audit. The audit team selected a sample of closed packages, as listed in Attachment 1, to review in detail.

The audit team also requested a list of EDCR packages that were still open and selected a few specific packages to review (Attachment 2).

The NRC staff reviewed the closed EDCRs (Attachment 1) and noticed that several packages were missing Attachment J, which is required by Engineering Department Procedure Instruction EDCR 25402-3DP-G04G-00081. TVA wrote a PER to correct previously closed EDCRs that did not receive an Attachment J form. For all currently open EDCRs, by process, they are not closed until all items, including Attachment J, have been completed. The staff also noted that several "documentation only" EDCRs did not have Attachment J included in the package.

The NRC staff compared the Bechtel Procedure as it existed when the staff performed its review and documented it in SSER 22 to the current version of Bechtel Procedure, Revision 19, with respect to Attachment J and guidance for completing EDCR packages. The differences between Revision 2 and Revision 19 appear to be minor. The main difference was an addition of screening criteria to Attachment J. One of the screening criteria states that if the EDCR is classified as a documentation only EDCR, per the procedure, further evaluation is not required, since these EDCRs do not perform any work. The other screening criterion is an evaluation on whether the design change is the same as Unit 1 and takes no exceptions from the applicable design standards. Per the procedure, if the work is functionally equivalent to Unit 1 and no exceptions were taken, then further evaluation is not required. Having this as a screening criterion is appropriate, since by meeting this criterion, the licensing basis between the two units would be preserved. The remainder of Attachment J remains almost identical to the version that was reviewed for SSER 22.

3.0 Onsite Audit Discussion Topics On August 13, 2014, Bechtel and TVA staff met with the audit team to clarify questions.

Prompted by questioning from the audit team, Bechtel and TVA looked at why a number of older EDCRs did not have Attachment J forms as part of the closure package. It was discovered that TVA and Bechtel poorly implemented the newly added Section 7.2.26 (see above) to the Bechtel Procedure that was added in Revision 2. The Bechtel guidance requires reviewing previous closed EDCRs and administratively changing them to include Attachment J forms prior to system completion and turnover. TVA created an NRC identified PER (PER 921136) to document the issue. The corrective actions include performing a licensing basis preservation review for all identified EDCRs that are missing Attachment J forms. The affected population of closed EDCRs appears to be around 40.

The Bechtel guidance states that Attachment J is not required for "documentation only" EDCRs.

One of the screening criterion in Attachment J is to identify if the EDCR is "documentation only" and associated with field work. The NRC staff noted that Attachment J should be filled out and maintained as part of the package, even if the EDCR is documentation only. TVA and Bechtel staff clarified that Attachment J forms should be attached to all EDCRs, even "documentation only" EDCRs.

4.0 Exit Meeting (Thursday, August 14, 2014)

The NRC staff audit team conducted an exit meeting with TVA staff following the closure of onsite audit activities. The NRC staff highlighted items reviewed and noted that detailed results of the on site audit trip will be documented in this report. The following items were discussed in detail at the exit meeting:

a. Closed EDCRs. The staff noted that several EDCRs from the sample list did not have Attachment J forms. The staff also noted that there was an inconsistent level of detail in answering screening questions.
b. Open EDCRs. No issues were identified in the sample open EDCRs reviewed during the audit.
c. The staff reviewed procedures and the change process to TVA's and Bechtel's implementation of the procedures. No issues were identified
d. The staff noted that actions from a previous TVA self-assessment yielded observations that did not appear to be implemented. TVA issued a new PER to open corrective actions and will track these issues and continue to perform self-assessments of the licensing preservation program.

CONCLUSION The NRC staff completed the WBN onsite audit per the plan issued on August 4, 2014. Overall, based on the audit performed, the staff finds that TVA's implementation of the licensing basis preservation program provides reasonable assurance that the program meets its intended purpose. The staff recommends that TVA continue to perform periodic self-assessments and apply corrective actions identified in related PERs.

While this report notes the completion of the onsite portion of the audit per the plan dated August 4, 2014, the NRC requests that TVA submit yearly self-assessments via letters to the NRC.

Principal Contributors: Jeanne A. Dion Justin C. Poole Anthony J. Minarik Date: December 3, 2014 Attachments:

1. Closed Engineering Document Construction Releases Reviewed by Staff
2. Open Engineering Document Construction Releases Reviewed by Staff
3. Onsite Audit Participants/Meeting Attendees
4. Onsite Audit Documents Reviewed

Closed Engineering Document Construction Releases Reviewed by Staff EDCR 52306, dated September 30, 2008, "UPGRADE UNIT 2 PWST ... "

EDCR 52319, dated May 7, 2014, "PROVIDE WESTINGHOUSE EAGLE 21 EQUIPMENT RACKS ... "

EDCR 52364, dated April9, 2010, "MODIFICATIONS OF MAIN CONTROL ROOM (MCR)

PANEL 2-M-7" EDCR 52368, dated November 9, 2010, " ... ENSURE COMPLIANCE WITH THE REQUIREMENTS OF NUREG 0737 SUPPLEMENT 1... "

EDCR 52480, dated May 1, 2014, "MODIFICATIONS OF SUPPORTS ON CHEMICAL AND VOLUME CONTROL SYSTEM, SEAL WATER INJECTION LOOPS# 3 AND# 4" EDCR 52490, dated February 28, 2012, "INSTALL SAMPLE LINES FROM PRIMARY MAKEUP WATER SYSTEM PUMPS 2A AND 28 DISCHARGE" EDCR 52493, dated AprilS, 2013, "MODIFICATION OF PIPE SUPPORTS ON THE SAFETY INJECTION SYSTEM" EDCR 52499, dated November 24, 2013, "MODIFICATION OF PIPE SUPPORTS FOR THE SAFETY INJECTION SYSTEM" EDCR 52500, dated November 11, 2013, "MODIFICATION OF PIPE SUPPORTS FOR THE SAFETY INJECTION SYSTEM" EDCR 52507, dated July 11, 2011, "MODIFICATION OF PIPE SUPPORTS ON ESSENTIAL RAW COOLING WATER SYSTEM" EDCR 52509, dated March 29, 2011, "ERCW RETURN AND SUPPLY LINES" EDCR 52521, dated February 11,2014, "REACTOR COOLANT SYSTEM DRAIN LINE FROM

  1. 1 RCL CROSSOVER LEG TO DRAIN HEADER" EDCR 52527, dated December 2, 2011, "MODIFICATION OF PIPE SUPPORTS ON THE COMPONENT COOLING SYSTEM" EDCR 52528, dated May 21, 2013, "MODIFICATION OF PIPE SUPPORTS ON COMPONENT COOLING SYSTEM RETURN PIPING" EDCR 52529, dated February 12, 2013, "MODIFICATION OF PIPE SUPPORTS ON THE COMPONENT COOLING SYSTEM" EDCR 52532, dated September 19, 2013, "MODIFICATIONS OF PIPE SUPPORTS ON SYSTEM (072) CONTAINMENT SPRAY SYSTEM" EDCR 52533, dated September 30, 2013, "MODIFICATION OF PIPE SUPPORTS FOR THE CONTAINMENT SPRAY SYSTEM" EDCR 52534, dated September 30, 2013, "MODIFICATION OF PIPE SUPPORTS FOR THE CONTAINMENT SPRAY SYSTEM" EDCR 52556, dated April17, 2013, "MODIFICATION OF PIPE SUPPORTS FOR THE ICE CONDENSER SYSTEM" EDCR 52557, dated April 11, 2013, "MODIFICATION OF PIPE SUPPORTS FOR THE CHEMICAL AND VOLUME CONTROL SYSTEM" EDCR 52558, dated July 30, 2013, "MODIFICATION OF PIPE SUPPORTS FOR THE CHEMICAL AND VOLUME CONTROL SYSTEM" EDCR 52563, dated December4, 2013, "MODIFICATION OF PIPE SUPPORTS ON SAFETY INJECTION SYSTEM" EDCR 52594, dated February 4, 2009, "THIS ENGINEERING DOCUMENT CONSTRUCTION RELEASE (EDCR) PROCESS IS TO REPLACE THE AUXILIARY BUILDING" Attachment 1

EDCR 52621, dated March 5, 2009, "PROVIDE THREE (3) ROLL-UP DOORS AND TWO (2)

WALLS TO BE INSTALLED IN THE UNIT 2 REACTOR BUILDING EQUIPMENT HATCH AT EL.757" EDCR 52632, dated December 4, 2013, "UPDATING LOCAL INSTRUMENT PANEL DRAWINGS" EDCR 52661, dated August 26, 2008, "INSTALL A WIRELESS RADIO CONTROL SYSTEM ON THE FEEDWATER PUMP TURBINE MONORAIL CRANE AND A VARIABLE FREQUENCY DRIVE (VFD) FOR THE CRANE TOLLEY MOTORS" EDCR 52722, dated February 3, 2010, "THE UNIT 2 MAIN CONTROL ROOM PANEL 2-M-8" EDCR 52724, dated November 24, 2010, "THE UNIT 2 MAIN CONTROL ROOM PANEL 2-M-10" EDCR 52725, dated February 3, 2010, "THE UNIT 2 MAIN CONTROL ROOM PANEL 2-M-10" EDCR 52735, dated April14, 2009, "THE INSTALLATION OF AN ANTI-ROTATION PIN IN PLACE OF A TACK-WELD BETWEEN THE YOKE BUSHING AND YOKE" EDCR 52813, dated March 21, 2012, "REDESIGNS AND REINSTALLS NEW CLASS C ICE CONDENSER (IC) DRAIN PIPING" EDCR 52984, dated February 21,2012, "PROCURE AND INSTALL REACTOR HEAD SHIELDING SYSTEM ON UNIT 2 WESTINGHOUSE REACTOR VESSEL HEAD" EDCR 53057, dated November 24, 2009, "NEW INDICATORS AND ASSOCIATED SCALES PURCHASED AS A BULK ORDER" EDCR 53070, dated June 10, 2011, "PERFORM CHANGES TO THE 480V UNIT BOARD 2-BD-203-A" EDCR 53124, dated February 16, 2010, "WESTINGHOUSE WILL REPLACE ALL EXISTING GUIDE TUBE SUPPORT PINS" EDCR 53126, dated October 26, 2011, "MODIFICATIONS TO THE WBN2 STEAM GENERATORS AND PRESSURIZER" EDCR 53127, dated August 16, 2010, "MODIFICATIONS TO STEAM SEPARATION EQUIPMENT IN STEAM GENERATOR" EDCR 53128, dated August 14, 2013, "REPLACE MISSING SAFETY RELATED PIPING/COMPONENTS IN THE MAIN AND AUX FEEDWATER SYSTEM" EDCR 53247, dated May 21,2012, "REPLACE SIX MOISTURE SEPARATOR REHEAT (MSR)

FLOW TRANSMITTERS (FT) WITH NEW HIGH TEMP. RATED FTS" EDCR 53343, dated October 25, 2013, "MODIFY, INSTALL AND REMOVE VALVES IN SYSTEM 70" EDCR 53399, dated July 22, 2013, "DISABLES THE LOAD DROP ANTICIPATORY (LOA)

FUNCTION" EDCR 53418, dated May 19, 2011, "SYSTEM UPGRADE, INJECTION WATER PUMPS AND MOTORS UPGRADED TO DECREASE PRESSURE DROP WHICH INCREASE THE HEAD. ALSO REPLACE VALVES AND PIPING FEEDING STANDBY MAIN PUMP AND INSTALL FLOW ELEMENT" EDCR 53441, dated October 9, 2013, "REPLACE OBSOLETE PRESSURE SWITCHES IN MAIN FEED PUMP" EDCR 53461, dated May 21,2012, "INSTALL PRESSURE RELIEF LINE UPSTREAM OF 2ND STAGE HEAT EXCHANGER TO THE CONDENSER" EDCR 53517, dated November 28, 2011, "MODIFY UNIT 2 DUCT SUPPORTS IN THE REACTOR BUILDING LOWER COMPARTMENT PURGE AIR EXHAUST SYSTEM" Attachment 1

EDCR 53863, dated June 18, 2011, "REPLACE VALVES 2-ISV-024-0500 & 2-ISV-024-0502 AND THE COOLING COIL OF THE MAIN BUS HEAT EXCHANGER 2-HTX-058-0102" EDCR 54142, dated November 7, 2011, "INCORPORATE U1 HISTORICAL DESIGN CHANGES INTO U2 SEPARATION AUXILIARY RELAY PANELS 2-R-73, 2-R-74, 2-R-77, AND 2-R-78" EDCR 54339, dated September 26, 2012, "VARIOUS SKIDS WERE NEVER INSTALLED FOR UNIT 2 AND ARE NEEDED DUE TO THE DIFFERENCE IN THE STEAM GENERATORS BETWEEN UNIT 1 AND 2" EDCR 54667, dated September 19, 2011, "ABANDONS THE UNIT 2 WASTE HEAT ENERGY PARK VALVES IN PLACE AND REMOVES ALL ELECTRICAL POWER TO THESE VALVES" EDCR 54752, dated November 4, 2011, "IMPLEMENTING THERMAL 11/1 DOCUMENT CHANGES FROM DCN 31939 AND DCN 27296 AS NECESSARY FOR THE UNIT 2 THERMAL PROGRAM" EDCR 55835, dated August 25, 2011, "PLUG THE STEAM GENERATOR TUBES AS NEEDED BASED ON EVALUATIONS OF ALL PRE-SERVICE EXAMINATIONS" Attachment 1

Open Engineering Document Construction Releases Reviewed by Staff EDCR 52348, revised June 12, 2009, "COMPLETE INSTALLATION/REFURBISHMENT OF HYDROGEN MITIGATION SYSTEM IN UNIT 2 REACTOR BUILDING" EDCR 52408, revised October 10, 2013, "INSTALL ANTICIPATED TRANSIENT WITHOUT SCRAM (ATWS) MITIGATION SYSTEM" EDCR 52421, revised April23, 2014, "REPLACE UNQUALIFIED WESTINGHOUSE SOURCE/INTERMEDIATE RANGE NEUTRON MONITORING SYSTEM WITH A REG GUIDE 1.97" EDCR 52449, revised June 6, 2014, "MODIFY THE PRESSURIZER LEVEL AND PRESSURE MONITROING SENSING LINES AND TRASNMITTERS" EDCR 52469, revised March 17, 2008, "REPLACE HORIZONTAL "T" SECTIONS OF UNIT 2 HVAC DUCTWORK" EDCR 52654, revised April24, 2014, "REPLACE UNIT 2 REACOTR COOLANT PUMP POWER CABLES" EDCR 52740, revised July 30, 2009, "RECONFIGURE TURBINE DRIVEN AUXILIARY FEEDWATER CONTROL VALVES" EDCR 52987, revised April 24, 2014, "INSTALL NEW THERMOWELLS AND RTDS FOR RCS HOT AND COLD LEGS ON UNIT TWO" EDCR 53178, revised April 23, 2014, "BACKUP NITROGEN COMPRESSED AIR, AND SYSTEM 32 CONTROL AIR" EDCR 53196, revised July 7, 2014, "REPLACE/REPAIR THE MISSING/DISCONNECTED TEMPERATURE ELEMENTS AND TEMPERATURE SWITCHES IN THE UNIT 2 ICE CONDENSER" EDCR 53395, revised May 21, 2014, "SEISMIC QUALIFICATION OF HVAC EXHAUST DUCT DAMPER" EDCR 53479, revised August 8, 2014, "THIS IS A MULTI-DISCIPLINE EDCR TO INCORPORATE HISTORICAL CHANGES TO GENERATOR COOLING" EDCR 53587, revised December 8, 2009, "INSTALL NEW THERMOWELLS AND RTDS FOR RCS HOT AND COLD LEGS ON UNIT 2" EDCR 54057, revised February 19, 2010, "WESTINGHOUSE WILL PERFORM VARIOUS WORK ON THE FUEL HANDLING SYSTEM" EDCR 54499, revised July 24, 2014, "CHANGE INSTALLS THERMAL OVERLOAD AND/OR TORQUE SWITCH BYPASS CAPABILITY" EDCR 55523, revised December 5, 2013, "INSTALL FIRE RATED PROTECTIVE WRAP" Attachment 2

Onsite Audit Participants/Meeting Attendees U.S. Nuclear Regulatory Commission (NRC) Staff:

Justin C. Poole, NRC Senior Project Manager Jeanne A. Dion, NRC Project Manager Anthony J. Minarik, NRC Project Manager Tennessee Valley Authority (TVA) Staff:

Rusty Stroud, TVA Licensing James Adair, TVA Engineer Jim O'Dell, TVA Licensing Lisa Pritchett, TVA Nuclear Construction Licensing Bechtel Staff:

Ron Stamps, Bechtel Engineer Attachment 3

Onsite Audit Documents Reviewed Watts Bar Nuclear Plant, Unit 2: System Completion and Turnover, SMP-4.0, Revision 0011 Watts Bar Nuclear Plant, Unit 2: Startup Manual Instruction, SMP-1.0, Revision 0002 Engineering Department Procedure Instruction- Engineering Department Procedure System 25402-3DP-G01 G-00001, Revision 4 Engineering Department Procedure Instruction- Engineering Document Construction Release - 25402-3DP-G04G-00081, Revision 19 "Project Engineering Procedures Manual Master Index- Exhibit B. 25402-3DP-GOOG-00001-122" Tennessee Valley Authority Letter to the U.S. Nuclear Regulatory Commission dated June 17, 2011, "Transmittal of Quality Assurance Assessment Report- Licensing Basis Preservation" Attachment 4

ML14323A562 OFFICE NRR/DORL/LPWB/PM NRRIDORL/LPWB/LAiT NRRIDORLILPWB/LA NRR/DORLILPWB/BC NRR/DORLILPWB/PM NAME JDion LRonewicz BCiayton JQuichocho JPoole DATE 12/01/14 11/28/14 11/28/14 12/03/14 12/03/14