ML15181A446
| ML15181A446 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 06/29/2015 |
| From: | Haag R NRC/RGN-II/DCP/CPB3 |
| To: | Skaggs M Tennessee Valley Authority |
| References | |
| EA-15-075 IR 2015604 | |
| Download: ML15181A446 (80) | |
See also: IR 05000391/2015604
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
June 29, 2015
Mr. Michael D. Skaggs
Senior Vice President
Nuclear Generation Development and Construction
Tennessee Valley Authority
6A Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
SUBJECT: WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED
INSPECTION REPORT 05000391/2015604 AND NOTICE OF VIOLATION
Dear Mr. Skaggs:
On May 16, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of
construction and testing activities at your Watts Bar Unit 2 reactor facility. The enclosed
integrated inspection report documents the inspection results, which were initially discussed on
May 28, 2015, with you and other members of your staff. The inspection results were discussed
further on June 19, 2015, with Mr. ODell and other members of your staff.
This inspection examined activities conducted under your Unit 2 construction permit as they
relate to safety and compliance with the Commissions rules and regulations, the conditions of
your construction permit, and fulfillment of Unit 2 regulatory framework commitments. The
inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, one violation is cited in the enclosed Notice of Violation
(Notice) and the circumstances surrounding this violation are described in detail in the enclosed
report. The violation involved the failure to follow anchor bolt installation procedures. Although
determined to be a Severity Level IV violation, it is being cited because the criteria, specified in
Section VI.A.1 of the NRC Enforcement Policy, for a non-cited violation was not satisfied.
Please note that you are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. The NRC will use your
response, in part, to determine whether further enforcement action is necessary to ensure
compliance with regulatory requirements.
Additionally, the enclosed report documents one self-revealing finding of very low safety
significance. This finding did not involve a violation of regulatory requirements.
If you contest the violation or finding 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
M. Skaggs 2
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 Resident Inspector at the Watts Bar Unit 2 Nuclear Plant. In addition, if you disagree
with a cross-cutting aspect assignment in this report, you should provide a response within 30
days of the date of this inspection report, with the basis for your disagreement, to the Regional
Administrator, Region II, and the NRC Resident Inspector at Watts Bar Unit 2 Nuclear Plant.
In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of
Practice, a copy of this letter, its enclosures, 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 website at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Should you have questions concerning this letter, please contact us.
Sincerely,
/RA/
Robert Haag, Chief
Construction Projects Branch 3
Division of Construction Projects
Docket No. 50-391
Construction Permit No: CPPR-92
Enclosures: 1. Notice of Violation
2. Inspection Report 05000391/2015604 w/ Attachment
cc w/encls: (See next page)
ML15181A446 SUNSI REVIEW COMPLETE FORM 665 ATTACHED
OFFICE RII:EICS RII:DCP RII:DCP RII:DCP RII:DCP RII:DCP
SIGNATURE /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/
NAME S. Sparks E. Patterson P. Cooper M. Magyar J. Baptist A. Wilson
DATE 06/11/2015 06/18/2015 06/16/2015 06/17/2015 06/16/2015 06/18/2015
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO
OFFICE RII: DCP RII: DCP RII: DCP RII: DCI RII: DCI RII:DCI
SIGNATURE /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/
C. Stanberry-
NAME J. Seat C. Even C. Cheung G. Crespo C. Julian
Smith
DATE 06/17/2015 06/18/2015 06/16/2015 06/16/2015 06/18/2015 06/22/2015
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO
OFFICE RII: DCI RII: DCI RII: DCI RII: DCI RII:DRS RII:DRS
SIGNATURE /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/
NAME J. Vasquez E. Michel T. Steadham J. Christensen N. Coovert R. Hamilton
DATE 06/16/2015 06/16/2015 06/18/2015 06/18/2015 06/17/2015 06/16/2015
E-MAIL COPY YES NO YES NO YES NO YES NO YES NO YES NO
OFFICE OE:EB OGC
SIGNATURE /RA via Email/ /RA via Email/
NAME K. Hanley D. Cylkowski
DATE 06/11/2015 06/11/2015
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO
M. Skaggs 3
cc w/encls: Mr. R. R. Baron, Senior Manager
Mr. Gordon P. Arent Nuclear Construction Quality Assurance
Director, Licensing WBN Unit Two
Watts Bar Nuclear Plant Watts Bar Nuclear Plant
Tennessee Valley Authority Tennessee Valley Authority
P.O. Box 2000 P.O. Box 2000
Spring City, Tennessee 37381 Spring City, Tennessee 37381
Mr. O. J. Zeringue, General Manager Mr. Joseph Shea, Vice President
Engineering and Construction Nuclear Licensing
WBN Unit Two Tennessee Valley Authority
Watts Bar Nuclear Plant 1101 Market Street
Tennessee Valley Authority 3R Lookout Place
P.O. Box 2000 Chattanooga, TN 37402-2801
Spring City, Tennessee 37381
Mr. E. J. Vigluicci
Mr. Paul Simmons, Vice President Assistant General Counsel
WBN Unit Two Project Tennessee Valley Authority
Watts Bar Nuclear Plant 400 West Summit Hill Drive
Tennessee Valley Authority 6A West Tower
P.O. Box 2000 Knoxville, Tennessee 37402
Spring City Tennessee 37381
Mr. Lawrence E. Nanney, Director
Mr. James ODell, Manager Tennessee Department of Environmental
Licensing and Industry Affairs Health & Conservation
WBN Nuclear Plant Division of Radiological Health
Tennessee Valley Authority 3rd Floor, L&C Annex
P.O. Box 2000 401 Church Street
Spring City, Tennessee 37381 Nashville, TN 37243-1532
Mr. Joseph P. Grimes Mr. Kevin Walsh
Chief Nuclear Officer Site Vice President
and Executive Vice President Watts Bar Nuclear Plant
Tennessee Valley Authority Tennessee Valley Authority
1101 Market Place P.O. Box 2000
3R Lookout Place Spring City, Tennessee 37381
Chattanooga, Tennessee 37402-2801
County Mayor
County Executive P.O. Box 156
375 Church Street Decatur, Tennessee 37322
Suite 215
Dayton, Tennessee 37321 Ms. Ann P. Harris
Public
Mr. Sean Connors 341 Swing Loop
Plant Manager, WBN Nuclear Plant Rockwood, TN 37854
Tennessee Valley Authority
P.O. Box 2000
Spring City, Tennessee 37381
M. Skaggs 4
cc email distribution w/encls:
Greg Scott
Tennessee Valley Authority
Electronic Mail Distribution
Watts Bar 2 Licensing
Tennessee Valley Authority
Electronic Mail Distribution
Letter to Michael D. Skaggs from Robert C. Haag dated June 29, 2015.
SUBJECT: WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED
INSPECTION REPORT 05000391/2015604
Distribution w/encls:
Region II Regional Coordinator, OEDO
J. Quichocho, NRR
J. Poole, NRR
J. Dion, NRR
A. Minarik, NRR
V. McCree, RII
L. Douglas, RII EICS
M. King, RII DRP
L. Chattin, RII
OE Mail
ConE_Resource@nrc.gov
PUBLIC
NOTICE OF VIOLATION
Tennessee Valley Authority Docket No. 50-391
Watts Bar Nuclear Plant - Unit 2 Construction Permit No. CPPR-92
Spring City, TN
During an NRC investigation completed on April 9, 2015, a violation of NRC requirements was
identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
A. 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states that
activities affecting quality shall be prescribed by documented instructions, procedures, or
drawings, of a type appropriate to the circumstances, and shall be accomplished in
accordance with these instructions, procedures, or drawings. Instructions, procedures, or
drawings shall include appropriate quantitative or qualitative acceptance criteria for
determining that important activities have been satisfactorily accomplished.
TVA Procedure MAI-5.1B, Wedge Bolt (WB) Anchor Installation, Revision 21, is the
implementing/controlling procedure for anchor bolt installation and includes the
requirements for drilling the hole to be used for anchor bolt installation.
MAI-5.1B, Revision 21, Section 6.2.5.A.3, states that unless specifically permitted,
reinforcing steel shall not be cut or drilled to install anchors. Site Engineering approval is
required to drill through the reinforcing bar.
Contrary to the above, on or about December 1, 2011, contract employees assigned to drill
holes for anchor bolt installation willfully drilled into the reinforcing steel of the steam
generator housing, a safety related structure, without notifying Site Engineering, or obtaining
their approval as required by TVA Procedure MAI-5.1B. Specifically, the contract
employees damaged reinforcing steel in at least five locations associated with holes drilled
under work order 111335067 and work order 111335073.
This is a Severity Level IV violation (Enforcement Policy Sections 2.2.1.d, 2.3.2, 6.5).
Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional
Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the
subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation.
This reply should be clearly marked as a "Reply to a Notice of Violation; EA-15-075" and should
include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing
the violation or severity level; (2) the corrective steps that have been taken and the results
achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will
be achieved. Your response may reference or include previous docketed correspondence, if the
correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued as to why the construction permit should not be modified, suspended, or revoked, or why
such other action as may be proper should not be taken. Where good cause is shown,
consideration will be given to extending the response time.
Enclosure 1
2
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that delete such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by 10
CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated this 29th day of June, 2015
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.: 50-391
Construction Permit No.: CPPR-92
Report No.: 05000391/2015604
Applicant: Tennessee Valley Authority (TVA)
Facility: Watts Bar Nuclear Plant, Unit 2
Location: Spring City, TN 37381
Dates: April 1, 2015 - May 16, 2015
Inspectors: T. Nazario, Senior Resident Inspector, Construction Projects
Branch (CPB) 3, Division of Construction Projects (DCP),
Region II (RII)
E. Patterson, Resident Inspector, CPB3, DCP, RII
M. Magyar, Resident Inspector, CPB3, DCP, RII
P. Cooper, Resident Inspector, CPB3, DCP, RII
C. Cheung, Resident Inspector, CPB3, DCP, RII
J. Baptist, Senior Construction Project Inspector, CPB3, DCP, RII,
Section P.1
C. Even, Senior Construction Project Inspector, CPB3, DCP, RII,
Section P.1
A. Wilson, Construction Project Inspector, CPB3, DCP, RII,
Sections P.1 and OA.1.10
J. Seat, Construction Project Inspector, CPB3, DCP, RII, Section
P.1
N. Coovert, Reactor Inspector, Engineering Branch 1, Division of
Reactor Safety (DRS), RII, Sections O.1.1, O.1.2, O.1.3, and
OA.1.11
G. Crespo, Senior Construction Inspector, Construction Inspection
Branch (CIB) 1, Division of Construction Inspection (DCI), RII,
Sections OA.1.1, OA.1.6, OA.1.7, and OA.1.8
C. Julian, Senior Construction Inspector, CIB1, DCI, RII, Sections
P.1.2, OA.1.1, OA.1.6, OA.1.7, and OA.1.8
C. Smith-Standberry, Construction Inspector, CIB1, DCI, RII,
Section P.1.2
J. Vasquez, Construction Inspector, CIB2, DCI, RII, Section
OA.1.4
E. Michel, Senior Construction Inspector, CIB3, DCI, RII, Section
C.1.6
T. Steadham, Senior Construction Inspector, CIB3, DCI, RII,
Section OA.1.3
J. Christensen, Construction Inspector, CIB3, DCI, RII, Sections
P.1.11 and OA.1.3
Enclosure 2
2
Approved by: Robert C. Haag, Chief
Construction Projects Branch 3
Division of Construction Projects
EXECUTIVE SUMMARY
Watts Bar Nuclear Plant, Unit 2
This integrated inspection included aspects of engineering and construction activities performed
by Tennessee Valley Authority (TVA) associated with the Watts Bar Nuclear Plant (WBN) Unit 2
construction project. This report covered a seven-week period of inspections in the areas of
quality assurance (QA), identification and resolution of construction problems, engineering and
construction activities, preoperational testing, and follow-up of other activities. The inspection
program for Unit 2 construction activities is described in Nuclear Regulatory Commission (NRC)
Inspection Manual Chapter (IMC) 2517, Watts Bar Unit 2 Construction Inspection Program.
Information regarding the WBN Unit 2 Construction Project and NRC inspections can be found
at http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html.
Inspection Results
- A self-revealing finding of very low safety significance was identified for the applicants
failure to take appropriate measures during the removal of an abandoned cable in the
common unit main control room radiation monitor cabinet (0-M-12) in accordance with
Section 3.2.5 of MMDP-15, Conduct of Maintenance - Expectations and Standards.
The performance deficiency was determined to be more than minor because it
represented an improper work practice that impacted safety-related structures, systems,
and components (SSCs) resulting in unplanned actuations of the B train control room
isolation and high radiation in refueling area (HRRA) ventilation systems. This issue was
entered into the applicants corrective action program under problem evaluation report
(PER) 1019007. This finding has a cross-cutting aspect in the Work Management
aspect of the Human Performance area because individuals did not follow processes,
procedures, and work instructions [H.8]. (Section C.1.1)
(10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for
the failure to follow TVA Procedure MAI-5.1B, Wedge Bolt (WB) Anchor Installation.
The applicant identified damaged reinforcing steel in at least five locations associated
with holes drilled under work order 111335067 and work order 111335073. The
inspectors determined that the failure to follow anchor bolt installation procedures was a
performance deficiency. This violation is considered to be more than minor because it
represents an inadequate work process that if left uncorrected, could adversely affect
the quality of the construction, testing, analysis, or records of a safety-related SSC. The
applicant initiated PER 83861 to address this issue. The damages were evaluated by
the applicant and determined not to require repair due to the safety margin designed into
the walls. The inspectors reviewed this finding against cross-cutting area components
as described in IMC 0310, Components Within the Cross-Cutting Areas, and
determined that no cross-cutting aspect applied. (Section OA.1.12)
- The inspectors concluded that issues pertaining to several open items, including nine
inspection procedures (IPs), two Three Mile Island (TMI) Action Items, two unresolved
items (URIs), one generic letter (GL), one temporary instruction (TI), and one
supplemental safety evaluation report (SSER) Appendix HH item have been
appropriately addressed for WBN Unit 2. These items are closed.
2
- Other areas inspected were adequate with no findings identified. These areas included
QA; preoperational testing activities; motor operated valve (MOV) testing; and various
NRC inspection procedures.
Table of Contents
I. QUALITY ASSURANCE PROGRAM ............................................................................... 5
Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure
35007) ................................................................................................................... 5
II. MANAGEMENT OVERSIGHT AND CONTROLS ............................................................ 5
C.1 Construction Activities .................................................................................................... 5
C.1.1 Unit 1 and Unit 2 Construction Activity Interface Controls ..................................... 5
C.1.2 Reactor Vessel and Internals Work Observation (Inspection Procedure 50053) .. 8
C.1.3 (Closed) Structural Concrete Work Observation (Inspection Procedure 46053) ... 8
C.1.4 (Closed) Verification of As-Builts (Inspection Procedure 37051)......................... 11
C.1.5 (Closed) Environmental Inspection-Periodic (Inspection Procedure 80210) ....... 16
C.1.6 (Closed) Inservice Inspection - Review of Program (Inspection Procedure
73051), Inservice Inspection - Review of Procedures (Inspection Procedure
73052), and Preservice Inspection - Observation of Work and Work Activities
(Inspection Procedure 73053) ............................................................................. 17
P.1 Preoperational Activities ............................................................................................... 19
P.1.1 Preoperational Test Program Implementation Verification (Inspection Procedure
71302) ................................................................................................................. 19
P.1.2 (Closed) Preoperational Test Procedure Review (Inspection Procedures 70300
and 70338) .......................................................................................................... 20
P.1.3 Preoperational Test Witnessing (Inspection Procedures 70302 and 70312) ...... 22
P.1.4 Preoperational Test Witnessing (Inspection Procedures 70302, 70312, and
70438) ................................................................................................................. 23
P.1.5 Preoperational Test Witnessing (Inspection Procedures 70302, 70312, and
70433) ................................................................................................................. 24
P.1.6 Preoperational Test Witnessing (Inspection Procedures 70302 and 70312) ...... 25
P.1.7 Preoperational Test Witnessing (Inspection Procedures 70302 and 70312) ...... 26
P.1.8 Preoperational Test Witnessing (Inspection Procedures 70302 and 70312) ...... 28
P.1.9 Preoperational Test Witnessing (Inspection Procedures 70302, 70312, and
70439) ................................................................................................................. 29
P.1.10 Preoperational Test Witnessing (Inspection Procedures 70302, 70312, and
70443) ................................................................................................................. 30
P.1.11 Preoperational Test Results Evaluation (Inspection Procedures 70562) ............ 31
III. OPERATIONAL READINESS ACTIVITIES .......................................................................... 32
O.1 Operations ...................................................................................................................... 32
O.1.1 (Closed) Quality Assurance Program - Procurement Control (Inspection
Procedure 35746) ................................................................................................ 32
O.1.2 (Closed) Quality Assurance Program - Maintenance (Inspection Procedure
35743) ................................................................................................................. 34
O.1.3 (Closed) Quality Assurance Program - Surveillance Testing and Calibration
Control (Inspection Procedure 35745) ................................................................ 34
IV. OTHER ACTIVITES ........................................................................................................ 36
OA.1.1 (Discussed) Electrical Issues CAP - Sub-issue: Cable Separation and Electrical
Isolation (Temporary Instruction 2512/020) ......................................................... 36
4
OA.1.2 (Discussed) Construction Deficiency Report 05000391/89-08: Kapton Insulated
Pigtail Insulation Damage (Inspection Procedure 51053) ................................... 37
OA.1.3 (Discussed) Generic Letter 89-10: Safety-Related Motor Operated Valve Testing
and Surveillance (Temporary Instruction 2515/109 and Inspection Procedure
51053) ................................................................................................................. 38
OA.1.4 (Discussed) Generic Letter 2004-02 - Potential Impact of Debris Blockage on
Emergency Recirculation during Design Basis Accidents at Pressurized-Water
Reactors and Pressurized Water Reactor Containment Sump Blockage
(Temporary Instruction 2515/166) ....................................................................... 41
OA.1.5 (Closed) Temporary Instruction 2515/191: Followup on Fukushima Orders for
Watts Bar and Inspection of the Licensee's Responses to Mitigation Strategies
Order EA-12-049, Spent Fuel Pool Instrumentation Order EA-12-051 and
Emergency Preparedness Information Requested in NRC March 12, 2012 ....... 42
OA.1.6 (Discussed) Generic Letter 2006-02: Grid Reliability and the Impact on Plant Risk
and the Operability of Offsite Power (Inspection Procedure 92701) ................... 44
OA.1.7 (Closed) Three Mile Island Action Item II.D.3 - Direct Indication of Relief-and
Safety-Valve Position and Supplemental Safety Evaluation Report Appendix HH
Item 074: Installation of the Acoustic Monitoring System for the Power Operated
Relief Valves (Inspection Procedure 92701) ....................................................... 44
OA.1.8 (Closed) Generic Letter 79-36, Adequacy of Station Electric Distribution System
Voltages (Inspection Procedure 92701) .............................................................. 46
OA.1.9 (Closed) Unresolved Item 05000391/2014614-01, Potential failure to comply with
10 CFR 50.55a and Properly Implement the Scope of the ASME OM Code,
Associated with Generic Letter 89-04: Guidance on Developing Acceptable
In-Service Testing Programs; Temporary Instruction 2515/114: Inspection
Requirements for Generic Letter 89-04, Acceptable In-Service Testing Programs;
Temporary Instruction 2515/110: Performance of Safety-Related Check Valves47
OA.1.10 (Closed) Three Mile Island Action Item I.C.7 Nuclear Steam Supply System
Vendor Review of Procedures (Inspection Procedure 92701) ............................ 49
OA.1.11 (Closed) Unresolved Item 05000391/2015603-4, Boric Acid Tank C Design
Control ................................................................................................................. 50
OA.1.12 Followup and inspection of NRC Office of Investigation Report 2-2014-017 ....... 51
V. MANAGEMENT MEETINGS .......................................................................................... 53
X1 Exit Meeting Summary ..................................................................................................... 53
REPORT DETAILS
Summary of Plant Status
During the inspection period covered by this report, Tennessee Valley Authority (TVA)
performed construction completion and preoperational testing activities on safety-related
systems and continued engineering design activities of the Watts Bar Nuclear Plant (WBN), Unit
2 (U2).
I. QUALITY ASSURANCE PROGRAM
Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure
35007)
a. Inspection Scope
The inspectors continued to review problem evaluation reports (PERs), as part of the
applicants corrective action program, to verify that issues being identified under the
corrective action program were being properly identified, addressed, and resolved by the
applicant.
The inspectors also reviewed and followed up on the corrective actions of several PERs
discussed throughout various sections of this report.
b. Observations and Findings
No findings were identified.
c. Conclusions
The issues identified in the PERs reviewed were adequately identified, addressed, and
resolved.
II. MANAGEMENT OVERSIGHT AND CONTROLS
C.1 Construction Activities
C.1.1 Unit 1 and Unit 2 Construction Activity Interface Controls
a. Inspection Scope
The inspectors independently assessed applicant controls, associated with Unit 2
construction work activities, to prevent adverse impact on Unit 1 operational safety. The
inspectors attended routine Unit 1/Unit 2 interface meetings to assess the exchange and
sharing of information between the two site organizations. Periodic construction and
planning meetings were observed, at least once per week, to assess the adequacy of
the applicants efforts to identify those construction activities that could potentially impact
the operating unit. This included the review of select work activities, which the applicant
had screened as not affecting Unit 1, to verify the adequacy of that screening effort.
6
Additionally, the inspectors independently assessed select construction activities to
verify that potential impacts on the operating unit had been identified and adequately
characterized with appropriate management strategies planned for implementation.
Furthermore, the inspectors performed independent walkdowns of select construction
work locations to verify that controls to protect the operating unit provided an adequate
level of protection and had been properly implemented.
Specific work activities observed during the current inspection period included work
associated with:
- Work Order (WO) 116311349 - Implement wiring change per EDCR 55801 in 0-
M-12 for Unit 2
- WO 110841294 - Install sample tubing and support for SIS pump per EDCR
53917
- WO 110841293 - Install sample tubing and support from 2A-A and 2B-B RHR
pump min flow per EDCR 53917
- WO 114676213 - Land 1PL4728A for Unit 2 SIS to CCS pump
- WO 114676288 - Land 2PL4736B & 2PL4741B for Unit 2 SIS to normal breaker
on CCS pump
Specific work activities that the applicant had screened out as not affecting Unit 1
included, but were not limited to, work activities as noted in this inspection report.
b. Observations and Findings
The following finding was identified:
Introduction: A self-revealing finding of very low safety significance was identified when
unplanned actuations of the B train control room isolation (CRI) and high radiation in
refueling area (HRRA) ventilation systems occurred as a result of Unit 2 construction
activities in Cabinet 0-M-12. Personnel performing work inside Cabinet 0-M-12 failed to
take the necessary steps to insulate circuits and potential ground points and maintain
positive control of the leads in accordance with procedure MMDP-15, Conduct of
Maintenance - Expectations and Standards, Section 3.2.5 Field Work Performance.
Description: On April 24, 2015, during removal of an abandoned cable in the common
unit main control room radiation monitor cabinet (0-M-12) as part of WO 116311349, the
metal shielding protecting the cable made contact with an active terminal block. The
cable bundle was tie-wrapped in the back corner of the lower portion of the 0-M-12
cabinet, making it difficult for personnel performing work to gain access. When
construction personnel cut the tie-wrap holding the cable bundle, the cable bundle with
metal shielding fell from its attached position, making contact with the terminal block.
This caused a momentary electrical short, opening a breaker on the 120V vital
instrument power board 1-II that feeds several in-service radiation monitors on Unit 1.
The loss of power to these radiation monitors resulted in HRRA actuation and a B train
CRI actuation. As a result of the event, Unit 1 entered several Technical Specifications
(TS) limiting conditions for operation (LCOs). B train CRI and HRRA actuations were
reset in accordance with standard operating instructions at the time of the event and all
LCOs were exited appropriately.
7
The inspectors reviewed Section 3.2.5 of MMDP-15, Conduct of Maintenance -
Expectations and Standards, covering field work performance which stated the
following:
- If during the performance of troubleshooting or maintenance activities it becomes
necessary to lift and land leads, the following applies:
o For energized leads, necessary steps shall be taken to insulate circuits and
potential ground points such as terminal boxes and chassis in the near
vicinity of those circuits requiring lifting and landing
- For de-energized leads, all lifted wires shall require positive control until they are
either insulated or landed.
Contrary to the standards above, personnel did not insulate potential ground points in
the near vicinity of the work, nor did they maintain positive control of the wires.
The inspectors determined this issue to be a performance deficiency because the
applicant did not meet a self-imposed standard where the cause was reasonably within
the applicants ability to foresee and correct and could have been prevented.
Specifically, the applicant failed to take appropriate measures during the removal of an
abandoned cable in the common unit main control room radiation monitor cabinet (0-M-
12) in accordance with Section 3.2.5 of MMDP-15, Conduct of Maintenance -
Expectations and Standards. The performance deficiency was determined to be more
than minor in accordance with Inspection Manual Chapter (IMC) 2517 because it
represented an improper work practice that impacted safety-related SSCs resulting in
unplanned actuations of the B train CRI and HRRA ventilation systems. Specifically,
actuation of systems caused alarms in the Unit 1 control room, B train CRI, and entrance
into several TS LCOs. All systems responded as designed and there was no significant
impact to the operating unit (Unit 1).
This issue was entered into the applicants corrective action program under PER
1019007. Immediate corrective actions were taken to exit all LCOs. Additional
corrective actions for work planning, work processing, and work performance have been
implemented. This finding has a cross-cutting aspect in the Procedure Adherence
aspect of the Human Performance area, as defined in NRC IMC 0310, because
individuals did not follow processes, procedures, and work instructions [H.8].
Enforcement: The inspectors concluded that personnel failed to comply with the
standards and expectations for field work performance contained in Section 3.2.5 of
MMDP-15, Conduct of Maintenance - Expectations and Standards. This self-revealing
finding; however, does not constitute a violation of NRC requirements. Specifically, the
inspectors determined that the Conduct of Maintenance - Expectations and Standards,
procedure is an administrative procedure and not covered under the QA requirements
set forth in 10 CFR 50, Appendix B. This finding is identified as construction item finding
CIF 05000391/2015604-01, Failure to Comply with Conduct of Maintenance -
Expectations and Standards.
c. Conclusions
Overall, management oversight and controls were in place for observed construction
activities that could potentially impact the operating unit with the exception of the
8
example noted above where a Unit 2 construction activity affected Unit 1; however, there
was no significant impact to the operating unit (Unit 1).
C.1.2 Reactor Vessel and Internals Work Observation (Inspection Procedure 50053)
a. Inspection Scope
The inspectors continued to monitor in-place storage of the reactor pressure vessel.
The reactor pressure vessel, internals, core barrel, and reactor head continued to be in
their assembled state during the second quarter of 2015. The inspectors were able to
view the reactor head and the control rod drive mechanisms due to missile shield blocks
having been removed. In-place and installed storage inspections of these components
continued to be limited and the inspections listed in IP 50053 could not be accomplished
in their entirety due to the inaccessibility of the reactor pressure vessel components
during this time. However, the inspectors did review access controls to ensure
authorized entry of tools, equipment, and personnel; and also cleanliness controls were
adequate to verify that cleanliness requirements were being met. Work around the
reactor pressure vessel and inside the reactor building during the inspection period was
limited.
b. Observations and Findings
No findings were identified.
c. Conclusions
This quarterly inspection of the reactor pressure vessel storage was limited due to
inaccessibility as a result of the components having been assembled. For the areas
inspected, adequate controls were in place to protect the exterior portions of the reactor
vessel and internals.
C.1.3 (Closed) Structural Concrete Work Observation (Inspection Procedure 46053)
a. Inspection Scope
Background: As described in IMC 2517, TVA addressed WBN Unit 1 construction
quality issues as part of the implementation of its Nuclear Performance Plan (NPP). The
results of the NRC inspection program were published in NUREG-1528, Reconstitution
of the IMC 2512 Construction Inspection Program for Watts Bar Unit 1. In 1985,
construction on Watts Bar Unit 1 and Watts Bar Unit 2 was stopped due to the
identification of multiple construction QA issues. TVA completed Unit 1 in 1995 but had
conducted very little Unit 2-specific work since 1985. In 2007, TVA decided to finish the
Unit 2 plant. As part of confirming that all issues and inspection requirements will be
completed for Unit 2, a review of all NRC inspection reports was initiated to determine
the status of the required IPs, contained in NRC IMC 2512, in effect at the time
construction was stopped. This effort was called the reconstitution process. The NRC
used the results of the reconstitution process to identify areas which require additional
inspections. Integrated Inspection Report (IIR) 05000391/2009602 (Agency-Wide
Documents Access and Management System (ADAMS) Accession No. ML091210420),
Attachment 2, documented the reconstitution results for IP 46053. As stated in the IIR,
9
by July of 1983, 98 percent of concrete had been placed at Watts Bar and consequently
the level of concrete activities since the applicant resumed construction in 2008 had
been limited to minor modifications. As a result, because most of the concrete had been
placed for both Watts Bar Unit 1 and Unit 2 and because the number of samples
collected from NRC inspections prior to 2007 exceeded those required, the IIR
concluded that the requirements of the IP 46053 were met for Unit 2 with the exception
of samples associated with the observations of the laboratory. However, per the IIR,
these samples were considered satisfactory based on record reviews documented under
IP 46055 as well as the Concrete Quality Special Program documented in Section OA.3
of IIR 05000391/2009603 (ADAMS Accession No. ML092120326).
Inspection Activities: The purpose of IP 46053 is to determine by direct observation and
independent evaluation whether work and inspection performance relative to structural
concrete are being accomplished in accordance with specifications and procedures, as
well as to determine whether inadequacies in work activities associated with structural
concrete indicate a management control problem or generic weakness. In addition, this
IP confirmed concrete placements were properly performed and that the materials and
concrete testing activities at the onsite test laboratory were being controlled as required.
This included rebar and embedment placement, rebar splices, liner plate erection and
fabrication, concrete batching and delivery, placement, in process testing, curing,
interviews, acceptance, personnel qualification, evaluation of test results, observation of
testing, calibration, special considerations such as hot and cold weather, concrete
pumping, and large placements.
The reconstitution effort, documented in IIR 05000391/2009602, Attachment 2,
concluded all requirements for this IP had been previously met, and the inspection
reports documenting these samples are listed within that report. Section 02.06 of IP
46053 states that additional inspections may be conducted in the inspection areas
covered by IP 46053 at the discretion of regional management. As a result, additional
inspections were performed since construction of Watts Bar Unit 2 resumed in 2008 and
are documented in the following inspection reports:
- 05000391/2008007 Section C.1.1 (ADAMS Accession No. ML082110474)
- 05000391/2010603 Section C.1.4 (ADAMS Accession No. ML102170465)
- 05000391/2010604 Section C.1.5 (ADAMS Accession No. ML103060240)
- 05000391/2010605 Section C.1.5 (ADAMS Accession No. ML110410680)
- 05000391/2011602 Section C.1.5 (ADAMS Accession No. ML110800483)
- 05000391/2011603 Section C.1.2 (ADAMS Accession No. ML111370702)
- 05000391/2013612 Section C.1.2 (ADAMS Accession No. ML13088A066)
- 05000391/2013604 Section C.1.2 (ADAMS Accession No. ML13179A079)
This IP remained opened for the purpose of inspecting reinforced concrete repair
activities associated with the auxiliary building secondary containment enclosure
(ABSCE). These repairs would have consisted of reconstructing the reinforced concrete
sections of an 8x4 and 4x4 opening that were created for access associated with
construction activities. TVA however decided to modify this repair with a steel structure
in lieu of a reinforced concrete section. The inspector reviewed design drawings, design
calculations, field change requests, and conducted interviews with plant personnel. As a
10
result, the inspector gained reasonable assurance that this modification could
adequately perform its design basis function once constructed.
These concrete openings provided the inspector the opportunity to visually examine the
cross section and current condition of the historically constructed reinforced concrete. As
a result of this examination, the inspector concluded that there were no indications
observed that would indicate unacceptable aging or degradation of the concrete or
reinforcement. Furthermore, the inspector concluded that the concrete had been
maintained in a condition at least as adequate as assumed in design documentation.
Additionally, the inspector reviewed TVAs methodology, programs, and procedures for
ensuring passive concrete structures such as floor slabs, walls, roofs, and columns will
continue to perform their safety function. The majority of the Unit 2 SSCs are currently
inspected under the Watts Bar Unit 1 Maintenance Rule Program and thus were not
inspected under this IP as they are controlled by current operating procedures and
regulations. The remaining civil/structural SSCs are verified and inspected by the Watts
Bar Unit 2 Refurbishment Program, and include structures such as:
- Steel Containment Vessel
- Reactor Building (Interior Concrete Structures and Ice Condenser)
- Category I Water Tanks and Pipe Tunnels (Refueling Water Storage Tank
Foundation)
- Miscellaneous Tanks Foundation
This program assesses pre-service degradation mechanisms such as physical damage,
water damage due to freezing thaw cycles, and concrete spalling. The program also
assesses the condition of concrete structures by identifying defects, and evaluating if
necessary, attributes such as, exposed reinforcement, signs of corrosion staining,
settlement, and cracking. Any defects classified as acceptable with deficiencies or
unacceptable will be entered into the WBN Corrective Action Program.
Previously, TVA had submitted the Maintenance Rule and Refurbishment Plan to the
NRC under Commitment No. 113148346 for review. The result of this review, as
published in the NRC Staff Evaluation by the Office of Nuclear Reactor Regulation,
Regarding Program for Construction Refurbishment (ADAMS Accession No.
ML101720050) concluded that the program, when properly implemented, should
adequately manage the identification of potential degradation effects and refurbishment
activities. As a result of the review conducted during this inspection period, the inspector
did not identify any attributes or examples that would invalidate the conclusions
previously reached by NRC staff.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
11
c. Conclusions
The structural concrete work previously observed met procedural, specification, and
drawing requirements. IP 46053 is considered closed; however, if additional structural
concrete work is performed, inspections may be performed at the NRCs discretion.
C.1.4 (Closed) Verification of As-Builts (Inspection Procedure 37051)
a. Inspection Scope
Background: The objective of this procedure is to determine whether (1) as-built design
and construction drawings and specifications correctly reflect the as-built condition of the
plant; (2) changes from the original design (or safety analysis report) were properly
reviewed and approved; and (3) plant seismic and other stress calculations are based on
as-built conditions. The reconstitution process, described in Section C.1.3 of this
inspection report, determined that none of the inspection requirements for IP 37051 were
previously satisfied.
Inspection Activities: The closure of IP 37051 will be described in nine parts, all of which
must be satisfied for the successful completion of the IP. IP 37051 was implemented
during the construction phase of Watts Bar Unit 2 and is documented in the following
inspection reports:
- 05000391/2011605, Section C.1.8, (ADAMS Accession No. ML112201418)
- 05000391/2013605, Section C.1.2 and Section OA.1.9, (ADAMS Accession No.
- 05000391/2013607, Section C.1.2, (ADAMS Accession No. ML13273A512)
- 05000391/2013608, Section C.1.5, (ADAMS Accession No. ML13316A776)
- 05000391/2014602, Sections E.1.1 and E.1.2, (ADAMS Accession No.
- 05000391/2014603, Sections C.1.7 and E.1.1, (ADAMS Accession No.
- 05000391/2014604, Sections C.1.3 and OA.1.26, (ADAMS Accession No.
- 05000391/2014605, Section OA.1.4, (ADAMS Accession No. ML14226A049)
- 05000391/2014607, Section OA.1.8, (ADAMS Accession No. ML14274A076)
- 05000391/2014608, Sections C.1.6 and OA.1.4, (ADAMS Accession No.
- 05000391/2014614, Sections C.1.2 and C.1.3, (ADAMS Accession No.
- 05000391/2014615, Sections C.1.6 and OA.1.7, (ADAMS Accession No.
Additionally, during the execution of IP 37055 Onsite Design Activities additional
inspection attributes were performed that contributed to the successful completion of IP
37051. The closure of IP 37055 is documented in IIR 05000391/2014602, Section E.1.1
(ADAMS Accession No. ML14086A063).
12
Section 02.01.a of this IP required that, prior to the issuance of an operating license, the
inspectors determine the adequacy of (1) the status of schedules for completion of as-
built design documents and (2) the procedures governing generation and completion of
as-built design documents including design modifications. Additionally, for design
modifications, the inspection procedure required that prior to the modification(s) being
declared operable, the inspectors verify that the controlled copy of all as-built documents
used by the plant operators were either revised and distributed for design changes, or
have been legibly marked-up on an interim basis to show all changes relating to the
modification(s). Lastly, for design modifications, the inspectors were to verify that
administrative controls and responsibilities have been clearly established. In addition, as
previously described, the execution of IP 37055 provided additional inspection related
samples that contributed to the successful completion of this inspection attribute.
Inspection report 05000391/2013608 (ADAMS Accession No. ML13316A776)
documents the inspection sample for IP 37051.
Section 02.01.b.1 of this IP required the selection of a representative sample of final
design documents for piping systems, including detailed design drawings and
construction specifications relative to the specified inspection items. The procedure
required that, for the selected safety-related systems, the inspector select one (or one
group of) isometric drawing(s) showing pipe welds, supports, and restraints and that the
inspector examine a representative sample of (1) supports - location, type, and
configuration; (2) pipe welds - location and identification; and (3) piping - location, size,
configuration, component location, weight (valves), and valve orientation (including
operators). By comparing final detailed construction drawings and specification
requirements with the actual installation, the inspectors had previously determined that
the final design drawings and specifications reflect as-built conditions for each item
indicated below and is documented in the following inspection reports:
- System 62, chemical and volume control system (CVCS); IIR 05000391/2014604
(ADAMS Accession No. ML14177A214),
- System 63, safety injection system (SIS); IIR 05000391/2014604 (ADAMS
Accession No. ML14177A214),
- System 67, essential raw cooling water (ERCW); IIR 05000391/2014602
(ADAMS Accession No. ML14086A063) and IIR 05000391/2013605 (ADAMS
Accession No. ML13220A640),
- System 68, reactor coolant system (RCS); IIR 05000391/2014608 (ADAMS
Accession No.ML14322A182),
- System 70, component cooling system (CCS); IIR 05000391/2014602 (ADAMS
Accession No. ML14086A063),
- System 72, containment spray (CS); IIR 05000391/2014604 (ADAMS Accession
No. ML14177A214),
- System 74, residual heat removal (RHR); IIR 05000391/2014604 (ADAMS
Accession No. ML14177A214), and
- System 84 Flood Mode Boration; IIR 05000391/2013608 (ADAMS Accession No.
In addition, during this inspection period, the inspectors compared final detailed
construction drawings and specification requirements with the actual installation for
13
System 003B, auxiliary feedwater, to verify that the final design drawings and
specifications reflect as-built conditions.
The inspectors performed inspection activities on the following mechanical systems,
structures, or components:
System 003B, auxiliary feedwater:
- pipe section between node 42 and node 82, node 98 and 102, on drawing 2-
47W427-205 including valves 2-FCV-3-136A, 2-FCV-3-136B, 2-FCV-3-179A, 2-
FCV-3-179B, and 2-CKV-3-810
- pipe support 03B-2AFW-R029
- portions of pipe support 03B-2AFW-R032
- pipe section between node 1 and node 10a, node 16 and 16B, on drawing 2-
47W427-208 including valve 2-CKV-3-864
- pipe support 03B-2AFW-V047
- portions of pipe support 03B-2AFW-R044
- pipe support 2-03A-370
Section 02.01.b.2 of this IP required the selection of representative sample of final
design documents for electrical raceways, including detailed design drawings and
construction specifications relative to the specified inspection items. The procedure
required that from different electrical divisions and locations in the plant, the inspector
select appropriate electrical drawings and specifications that include Class 1E conduit
and Class 1E cable tray runs of appropriate length. The procedure required that the
inspector examine the (1) location and routing; (2) supports; (3) separation and isolation;
(4) cable loading (physical and thermal); and (5) identification (conduit and tray). By
comparing final detailed construction drawings and specification requirements with the
actual installation, the inspectors previously determined that the final design drawings
and specifications reflect as-built conditions and are documented in the inspection
reports listed below.
For Class 1E Conduits:
- 05000391/2014603 (ADAMS Accession No. ML14129A381)
- 05000391/2014604 (ADAMS Accession No. ML14177A214)
- 05000391/2014615 (ADAMS Accession No. ML15044A424)
For Class 1E Cable Trays:
- 05000391/2014607 (ADAMS Accession No. ML14274A076)
- 05000391/2014615 (ADAMS Accession No. ML15044A424)
- 05000391/2014614 (ADAMS Accession No. ML14363A315)
Section 02.01.b.3 of this IP required the selection of representative sample of final
design documents for electrical cables, including detailed design drawings and
construction specifications relative to the specified inspection items. The procedure
required that the inspector review design and construction records (drawings, pull cards,
etc.) which represent as-built cable routing. For each cable selected, the procedure
required the inspector compare design with actual installation relative to routing,
identification, protection/isolation, and separation from redundant cables. Additionally,
14
for each cable or group of conductors selected, the inspectors were required to compare
design documents and as-built identification for each conductor at termination points. By
comparing final detailed construction drawings and specification requirements with the
actual installation, the inspectors determined the final design drawings and specifications
reflect as-built conditions and are documented in the inspection reports listed below:
- 05000391/2014615 (ADAMS Accession No. ML15044A424)
- 05000391/2014614 (ADAMS Accession No. ML14363A315)
As-built inspections of electrical cables were also previously inspected as part of the
activities performed for IP 51063, Electrical Cable Work Observation. IP 51063 was
closed in IIR 05000391/2014615.
Section 02.01.b.4 of this IP required the selection of representative sample of final
design documents for structures, including detailed design drawings and construction
specifications relative to the specified inspection items. The procedure required the
selection of structural steel assemblies from Seismic Category I structures. The
procedure specified that each assembly selected should contain at least three welded
and/or three bolted joints. The inspector was required to (1) determine whether the
structural assembly configuration conforms to final design; and (2) determine whether
joint location/orientation, dimensions, and configuration conform to the final design.
During this inspection period the inspectors compared final detailed construction
drawings and specification requirements with the actual installation and determined the
final design drawings and specifications reflect as-built conditions for each item indicated
below:
- RHR heat exchanger 2B steel brace - Seismic Category 1
- CS heat exchanger 2B steel brace - Seismic Category 1
- Control rod drive mechanism cooler 2B-B steel pedestal - Seismic Category 1(L)
Section 02.01.c of this IP required the inspector to examine plant changes not yet
incorporated into as-built drawings and to have the applicant verify (to the NRC
inspector) the status of review, approval, and revision of these identified changes from
the "original" design. In addition, as previously described, the execution of IP 37055 in
IIR 05000391/2014602 provided additional inspection related samples that contributed to
the successful completion of this inspection attribute. The portion of this inspection
attribute that was previously examined is documented in the following inspection reports:
- 05000391/2013608 (ADAMS Accession No.ML13316A776)
- 05000391/2014604 (ADAMS Accession No. ML14177A214)
Section 02.01.d of this IP required the inspector to examine as-built changes on
design/construction drawings which correctly reflect the as-built condition and have the
applicant verify (to the NRC inspector) that the changes were properly reviewed and
approved by appropriate personnel. In addition, as previously described, the execution
of IP 37055 in IIR 05000391/2014602 provided additional inspection related samples
that contributed to the successful completion of this inspection attribute. The portion of
15
this inspection attribute that was previously examined is documented in the following
inspection reports:
- 05000391/2014607 (ADAMS Accession No. ML14274A076)
- 05000391/2014608 (ADAMS Accession No. ML14322A182)
- 05000391/2014605 (ADAMS Accession No. ML14226A049)
- 05000391/2014604 (ADAMS Accession No. ML14177A214)
Section 2.02.a of this IP required the inspector to select a representative sample from
the drawings used for inspection in item 02.01.b where changes had been incorporated
in safety-related systems. The inspector is required to determine whether the as-built
condition of the plant was used as the input to the seismic analysis of the system or that
the as-built condition conforms to the original seismic criteria, as applicable. The portion
of this inspection attribute that was previously examined is documented in the following
inspection reports:
- 05000391/2014604 (ADAMS Accession No. ML14177A214)
- 05000391/2014615 (ADAMS Accession No. ML15044A424)
- 05000391/2014607 (ADAMS Accession No. ML14274A076)
- 05000391/2014605 (ADAMS Accession No. ML14226A049)
- 05000391/2014603 (ADAMS Accession No. ML14129A381)
- 05000391/2014602 (ADAMS Accession No. ML14086A063)
As-built inspections for this inspection attribute were previously inspected as part of the
activities performed for TI 2512/023, Inspection of the Watts Bar Nuclear Plant Hanger
Update Corrective Action Program Plan, which was closed in IIR 05000391/2014608
(ADAMS Accession No. ML14322A182). Additional as-built inspections for this
inspection attribute were also previously inspected as part of the activities performed for
TI 2512/021, Inspection of the Watts Bar Nuclear Plant Equipment Seismic Corrective
Action Program Plan, which was closed in IIR 05000391/2014615 (ADAMS Accession
No. ML15044A424).
Section 2.02.b of this IP required that the inspector determine what action the licensee
has taken to ensure that final as-built design documents (drawings, specifications, and
calculations) will be readily available to site operations personnel when commercial
operation is initiated. If certain as-built design documents (e.g., system analysis) are to
be retained by the nuclear steam system supply (NSSS) vendor or architect-engineer (A-
E) the inspector is required to examine the adequacy of applicants timely access to
such records for analysis of plant operating conditions. In addition, as previously
described, the execution of IP 37055 in IIR 05000391/2014602 provided additional
inspection related samples that contributed to the successful completion of this
inspection attribute. The portion of this inspection attribute that was previously
examined is documented in the following inspection reports:
- 05000391/2014604 (ADAMS Accession No. ML14177A214)
- 05000391/2014603 (ADAMS Accession No. ML14129A381)
- 05000391/2013607 (ADAMS Accession No. ML13273A512)
The following samples were inspected:
16
IP 37051 Section 02.01.b.1 - one sample
IP 37051 Section 02.01.b.4 - five samples
Documents reviewed are listed in the Attachment.
b. Observations and Findings:
No findings were identified.
Below is a summary of each section of IP 37051:
- Section 02.01 - Complete
- Section 02.02 - Complete
c. Conclusion:
Based on the activities reviewed in this and previous inspections, the inspectors
concluded that (1) as-built design and construction drawings and specifications correctly
reflect the as-built condition of the plant; (2) changes from the original design (or safety
analysis report) were properly reviewed and approved; and (3) plant seismic and other
stress calculations are based on as-built conditions. IP 37051 is considered closed;
however, additional activities may be performed at the NRCs discretion.
C.1.5 (Closed) Environmental Inspection-Periodic (Inspection Procedure 80210)
a. Inspection Scope
The following inspection reports have documented inspection of the environmental
activities associated with WBN Unit 2:
- IIR 05000391/2008010, Section C.1.4 (ADAMS Accession No. ML090291033)
- IIR 05000391/2010604, Section OA.1.4 (ADAMS Accession No. ML103060240)
- IIR 05000391/2013604, Section C.1.7 (ADAMS Accession No. ML13179A079)
- IIR 05000391/2014614, Section C.1.7 (ADAMS Accession No. ML14363A315)
These inspection results document the 18 month periodic inspection requirements
specified in Section 02.02 of IP 80210.
b. Observations and Findings
No findings were identified.
c. Conclusions
Past inspection results have concluded that the environmental programs required for
Unit 2 construction activities were properly implemented. The inspection requirements
for IP 80210 specify that a periodic inspection be performed every 18 months. Further
inspection of IP 80210 is not anticipated at this time. IP 80210 is closed. Additional
inspection may occur if 18 months have elapsed since the time of the last inspection.
17
C.1.6 (Closed) Inservice Inspection - Review of Program (Inspection Procedure 73051),
Inservice Inspection - Review of Procedures (Inspection Procedure 73052), and
Preservice Inspection - Observation of Work and Work Activities (Inspection
Procedure 73053)
a. Inspection Scope
For IP 73051 and IP 73052, the inspectors reviewed the Containment Preservice
Inspection (CPSI) Program Plan and the Preservice Inspection Program Plan to verify
those programs were in compliance with the 2001 Edition through 2003 Addenda of
Section XI of the American Society of Mechanical Engineers (ASME) Boiler and
Pressure Vessel (B&PV) Code, that they had been reviewed by an Authorized Nuclear
Inservice Inspector (ANII), and were reviewed and approved by the applicants
designated representatives. Specifically, the inspectors reviewed the Program Plans to
verify they met the requirements of Subsection IWE, Table IWE-2500-1 for the
containment system, and Subsection IWF, Table IWF-2500-1 for snubbers; reviewed the
ASME B&PV Code edition and addenda to verify the appropriate edition and addenda
were being applied per 10 CFR Part 50.55a and the approved proposed alternative
(ADAMS Accession No. ML110260025); reviewed comments provided by the ANII
during their review of those programs; and reviewed Program Plans to ensure they were
reviewed by the appropriate applicant representatives.
- IP 73051 Section 02.01 - one sample
- IP 73052 Section 02.01 - one sample
For IP 73053, the inspectors reviewed the qualifications and certifications of three Level
II non-destructive examination (NDE) examiners and one Level III examiner, involved in
the conduct of preservice inspection examinations, to ensure they met the requirements
of Section XI of the ASME B&PV Code. Specifically the inspectors reviewed the
certifications to ensure they contained the employers name, person being certified,
activity qualified to perform, level of qualification, and basis for certification. No Level 1
examiner certifications were available.
- IP 73053 Section 02.02 - 4 samples
The following tables list the inspections that were performed under this IP and
documented in earlier inspection reports.
IP 73051 Section Inspection Reports ADAMS Accession
Number
02.01 Program * 05000391/2009604, Section * ML093030479
Approval C.1.11
- 05000391/2010602, Section * ML101230144
C.1.16
- 05000391/2010604, Section * ML103060240
C.1.11
- 05000391/2012602, Section * ML12087A324
C.1.5
18
- 05000391/2013612, Section * ML13088A066
C.1.12
02.02 Program * 05000391/2009604, Section * ML093030479
Organization C.1.11
02.03 Quality * 05000391/2009604, Section * ML093030479
Assurance Program C.1.11
- 05000391/2010602, Section * ML101230144
C.1.16
- 05000391/2011608, Section * ML11311A082
C.1.12
02.04 Repair Program * 05000391/2011605, Section * ML112201418
C.1.10
02.05 Replacement * 05000391/2011605, Section * ML112201418
Program C.1.10
02.06 Records * 05000391/2009604, Section * ML093030479
C.1.11
02.07 Qualification of * 05000391/2009604, Section * ML093030479
Personnel C.1.11
02.08 Reporting * 05000391/2009604, Section * ML093030479
Requirements C.1.11
02.09 Relief Requests * 05000391/2009604, Section * ML093030479
C.1.11
- 05000391/2010603, Section * ML102170465
C.1.11
IP 73052 Section Inspection Reports ADAMS Accession
Number
02.01 Program * 05000391/2012602, Section * ML12087A324
Requirements C.1.5
02.02 Procedure * 05000391/2009604, Section * ML093030479
Approval C.1.12
- 05000391/2009603, Section * ML092120326
C.1.5
02.03 Non-Destructive * 05000391/2009604, Section * ML093030479
Examination (NDE) C.1.12
Procedure Review * 05000391/2009603, Section * ML092120326
C.1.5
- 05000391/2010603, Section * ML102170465
C.1.12
02.04 Code Repair or * 05000391/2011605, Section * ML112201418
Replacement C.1.10
Procedure Review
IP 73053 Section Inspection Reports ADAMS Accession
Number
02.01 Preservice * 05000391/2012602, Section * ML12087A324
inspection (PSI) plan C.1.6
review
19
02.02 Examiner * 05000391/2010602, Section * ML101230144
qualification review C.1.17
02.03 Observe four * 05000391/2009604, Section * ML093030479
different methods of C.1.13 (PT, UT)
examination of * 05000391/2009603, Section * ML092120326
components C.1.5 (UT)
- 05000391/2010602, Section * ML101230144
C.1.17 (ECT)
- 05000391/2010603, Section * ML102170465
C.1.13 (UT)
- 05000391/2010605, Section * ML110410680
OA.1.11 (UT)
- 05000391/2013612, Section * ML13088A066
C.1.9 (MT)
02.04 Pressure * 05000391/2011605, Section * ML112201418
Boundary Repair C.1.11
- 05000391/2013612, Section * ML13088A066
C.1.13
b. Observations and Findings
No findings were identified. The inspectors observed that the interface between the
basemat and containment vessel shell (679 elevation) is covered by an insulation
package which includes stainless steel flashing and caulking, and acts as a barrier to
protect the insulation underneath from moisture. Inspection of this barrier was
performed as a non-ASME Code examination (i.e. an augmented exam). The inspectors
questioned the applicant whether this barrier also acts to prevent moisture intrusion at
the basemat to containment vessel shell interface and should be inspected per the
ASME requirements, specifically Subsection IWE, Table IWE-2500-1, Category E-A,
Item E1.30, Moisture Barriers. The applicant subsequently revised their Containment
Preservice Inspection Program Plan to include the barrier as an Item E1.30 ASME Code
exam.
c. Conclusions
The inspectors determined that inspection procedures 73051, 73052, and 73053 have
been completed based on this inspection and previous inspection activities documented
in the inspection reports listed above. Inspection Procedures 73051, 73052, and 73053
are closed.
P.1 Preoperational Activities
P.1.1 Preoperational Test Program Implementation Verification (Inspection Procedure
71302)
a. Inspection Scope
02.01 (Weekly Inspection Activities): The inspectors verified that the applicants
management control system was effectively discharging its responsibilities over the
20
preoperational testing program by facility record review, direct observation of activities,
tours of the facility, interviews, and discussions with applicant personnel. Preoperational
testing activities during the inspection period included the following systems or portions
thereof:
- System 063 - Safety Injection
- System 003B - Auxiliary Feedwater
- System 070 - Component Cooling Water System
- System 072 - Containment Spray System
As systems became available for preoperational testing, inspectors toured the
accessible areas of the facility to make an independent assessment of equipment
conditions, plant conditions, security, and adherence to regulatory requirements. The
inspectors also reviewed the following, as available and on a sampling basis, during the
tours:
- general plant/equipment conditions;
- plant areas for fire hazards - examined fire alarms, extinguishing equipment,
actuating controls, firefighting equipment, and emergency equipment for
operability and also verified that ignition sources and flammable material were
being controlled in accordance with the applicant's procedures;
- activities in progress (e.g., maintenance, preoperational testing, etc.) were being
conducted in accordance with the applicants procedures;
- watched for abuse of installed instrumentation such as stepping or climbing on
the instrumentation that could affect the calibration or ability to function;
- listened for the public address system announcements to determine that blind
spots do not exist; (i.e., cannot be heard clearly enough to be understood);
- construction work force was authorized to perform activities on systems or
equipment; and
- looked for uncontrolled openings in previously cleaned or flushed systems or
components.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
c. Conclusion
The applicants implementation of the preoperational test program was in accordance
with procedures for those activities observed during the inspection period.
P.1.2 Preoperational Test Procedure Review (Inspection Procedures 70300, 70336,
70338, 70343)
a. Inspection Scope
Background: The purpose of preoperational test inspection is to verify through direct
observation, personnel interviews, and review of facility records that:
21
- Systems and components important to the safety of the plant are fully tested to
demonstrate that they satisfy their design requirements.
- Management controls and procedures, including quality assurance programs,
necessary for operation of the facility have been documented and implemented.
IMC 2513 requires the procedural review of the mandatory tests defined in IMC 2513
and five of the primal tests defined in IMC 2513. The following inspections were
performed in relation to satisfying the required procedural reviews.
Inspection Activities: The inspectors reviewed procedures to verify that the test
procedure adequately addressed NRC requirements and licensing commitments
outlined in the final safety analysis report (FSAR), docketed correspondence, safety
evaluation report (SER), Technical Specifications, and Regulatory Guide 1.68. The test
procedures reviewed were:
- 2-PTI-003B-04, Auxiliary Feedwater Pumps & Valves Logic Test, Rev. 0 and 1
- 2-PTI-003B-05, Auxiliary Feedwater Dynamic Test, Rev. 1
- 2-PTI-072-01, Containment Spray Pump and Valves Logic Test, Rev. 0 and 1
- 2-PTI-074-01, Residual Heat Removal System Pump/Valves Logic, Rev. 1
Additionally, the inspectors reviewed preoperational test procedures to verify that the
procedures contained the following administrative good practice attributes:
- the title described the purpose of the procedure;
- the cover page had appropriate information and approval signatures;
- each page had appropriate identification information;
- the last page was clearly identifiable by markings;
- a clear statement of procedure purpose/objectives;
- planning information such as prerequisites, precautions, required tools, reference
documents, and coordination requirements;
- signoff requirements including concurrent and independent verification steps
established where appropriate;
- equipment alignment instructions are clear and concise;
- equipment identifiers are accurate;
- actions to be taken within the steps are specifically identified;
- instrumentation units are consistent for data collection;
- graphs, charts, tables, data sheets, and work sheets are clearly usable;
- calculation sheets are technically accurate;
- clear coordination instructions exist for test activities involving multiple test
personnel;
- clear instructions exist for system restoration;
- guidance for follow-up actions and points of contact;
- clear concise steps for testing with action critical (acceptance criteria) steps
identified;
- clear quantitative acceptance criteria with acceptability and contingencies;
- overall sequence of the procedure is consistent with obtaining the intended
result; and
22
- system boundaries were reviewed to verify adequate overlap exists between
tests to ensure the entire system will be tested.
The inspectors also reviewed the procedure to verify that precautions or explanations
were placed immediately ahead of the steps to which they applied. The inspectors
performed a detailed review with the responsible test engineer to verify that the
acceptance criteria met design requirements.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the applicants test procedures were written in a manner
consistent with the guidance of procedure SMP-8.0, Watts Bar Nuclear Plant Unit 2
Administration of Preoperational Test Instructions, Rev. 11. This completes the
procedure review of preoperational test procedures 2-PTI-003B-04, 2-PTI-003B-05, 2-
PTI-072-01, and 2-PTI-074-01. The preoperational testing procedure reviews for
Systems 003B and 072 (IPs 70338 and 70343) are closed.
P.1.3 Preoperational Test Witnessing (Inspection Procedures 70302 and 70312)
a. Inspection Scope
Background: The purpose of preoperational test inspection is to verify through direct
observation, personnel interviews, and review of facility records that:
- systems and components important to the safety of the plant are fully tested to
demonstrate that they satisfy their design requirements; and
- management controls and procedures, including QA programs, necessary for
operation of the facility have been documented and implemented.
IMC 2513 defines the minimum inspection program for a finding of readiness for license
issuance (IP 94302, Status of Watts Bar Unit 2 Readiness for an Operating License).
IMC 2513 requires the preoperational test witnessing of the mandatory tests defined in
IMC 2513 and five of the primal tests defined in IMC 2513. The following inspection was
performed in relation to satisfying the required preoperational test witnessing.
Inspection Activities: The inspectors witnessed activities associated with the
performance of preoperational test instructions 2-PTI-061-02, Ice Condenser Ice
Loading, Rev. 1, to verify that the testing was conducted in accordance with approved
procedures, 0-MI-61.06 Servicing Ice Condenser, Rev. 2; 2-MI-61.001 Initial Ice
Loading, Rev. 0; and 0-SOI-61.02 Ice Charging System, Rev. 2. In addition, the
inspections were completed to verify the adequacy of test program records and
preliminary evaluation of the test results.
The inspectors assessed the following attributes associated with these test observations:
23
- all personnel were on station and had the latest revision of the procedure;
- prerequisites were performed;
- plant systems were in service to support the test;
- test equipment was installed and within calibration;
- testing was performed in accordance with the approved procedure;
- test interruptions and continuations were handled in accordance with approved
procedures and documented in the chronological test log;
- testing events and discrepancies were properly documented in the test deficiency
log;
- testing was executed and coordinated properly;
- data was properly collected;
- temporary equipment was installed appropriately;
- administrative test controls were properly followed; and
- personnel were using approved procedures.
The inspectors observed the ice condenser preoperational tests to support the loading of
the Unit 2 ice condenser to verify that the ice baskets met the TS weight requirements
and the ice mixture chemistry requirements. The inspectors conducted a review with the
responsible test engineer to ensure that the preliminary test evaluations were consistent
with the inspectors observations. The inspectors observed the Unit 2 ice loading
activities to ensure the ice basket weights and chemistry data were properly gathered
and recorded. A cursory review of the data was performed to verify the adequacy of the
data sheet entries.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the Unit 2 ice loading activities were completed in
accordance with the approved procedures and the initial ice condenser basket weights
and chemistry data was properly recorded and evaluated.
P.1.4 Preoperational Test Witnessing (Inspection Procedures 70302, 70312, and 70438)
a. Inspection Scope
Background: The background for this preoperational test witnessing is the same as that
in the background section of P.1.3.
Inspection Activities: The inspectors witnessed activities associated with the
performance of preoperational test instruction 2-PTI-003B-05, Auxiliary Feedwater
System Dynamic Test, Rev. 1 to verify that the testing was conducted in accordance
with approved procedures and to verify the adequacy of test program records and
preliminary evaluation of test results. The following components logic tests were
selected for inspection of this item:
24
- Section 6.1, 2-PMP-3-118, Auxiliary Feedwater Pump 2A-A, Hydraulic
Performance Test
- Section 6.2, 2-PMP-3-118, Auxiliary Feedwater Pump 2A-A, 48 Hour Endurance
Test
The inspectors assessed the following attributes associated with these test observations:
- all test personnel were on station and had the latest revision of the procedure;
- test prerequisites were performed;
- plant systems were in service to support the test;
- test equipment was installed and within calibration;
- testing was performed in accordance with the approved procedure;
- test interruptions and continuations were handled in accordance with approved
procedures and documented in the chronological test log;
- testing events and discrepancies were properly documented in the test deficiency
log;
- testing was executed and coordinated properly;
- data was properly collected;
- temporary equipment was installed and tracked appropriately;
- administrative test controls were properly followed; and
- test personnel were using approved drawings and vendor manuals.
The inspectors observed the tests to verify that the overall test acceptance was met.
The inspectors conducted a review with the responsible test engineer to assure that the
preliminary test evaluations were consistent with the inspectors observations. During
the tests, the inspectors observed important data gathering activities to ensure the data
was properly gathered and recorded. A post-test cursory review of the test data was
performed to verify legibility, traceability, and permanence of the data sheet entries.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the applicants test procedure was performed in a
manner consistent with the guidance of procedure SMP-9, Watts Bar Nuclear Plant Unit
2 Conduct of Test, Rev. 5.
P.1.5 Preoperational Test Witnessing (Inspection Procedures 70302, 70312, and 70433)
a. Inspection Scope
Background: The background for this preoperational test witnessing is the same as that
in the background section of P.1.3.
Inspection Activities: The inspectors witnessed activities associated with the
performance of preoperational test instruction 2-PTI-062-02, Boric Acid Subsystem
Logic Test, Rev. 1 to verify that the testing was conducted in accordance with approved
25
procedures and to verify the adequacy of test program records and preliminary
evaluation of test results. The following components logic test was selected for
inspection of this item:
- Section 6.4, 2-FCV-62-140
The inspectors assessed the following attributes associated with this test observation:
- all test personnel were on station and had the latest revision of the procedure;
- test prerequisites were performed;
- plant systems were in service to support the test;
- test equipment was installed and within calibration;
- testing was performed in accordance with the approved procedure;
- test interruptions and continuations were handled in accordance with approved
procedures and documented in the chronological test log;
- testing events and discrepancies were properly documented in the test deficiency
log;
- testing was executed and coordinated properly;
- data was properly collected;
- temporary equipment was installed and tracked appropriately;
- administrative test controls were properly followed; and
- test personnel were using approved drawings and vendor manuals.
The inspectors observed the tests to verify that the overall test acceptance was met.
The inspectors conducted a review with the responsible test engineer to assure that the
preliminary test evaluations were consistent with the inspectors observations. During
the tests, the inspectors observed important data gathering activities to ensure the data
was properly gathered and recorded. A post-test cursory review of the test data was
performed to verify legibility, traceability, and permanence of the data sheet entries.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the applicants test procedure was performed in a
manner consistent with the guidance of procedure SMP-9, Watts Bar Nuclear Plant Unit
2 Conduct of Test, Rev. 5.
P.1.6 Preoperational Test Witnessing (Inspection Procedures 70302 and 70312)
a. Inspection Scope
Background: The background for this preoperational test witnessing is the same as that
in the background section of P.1.3.
Inspection Activities: The inspectors witnessed activities associated with the
performance of preoperational test instruction 2-PTI-063-04, Safety Injection System
26
RWST and Containment Sump Annunciators, Rev. 0 to verify that the testing was
conducted in accordance with approved procedures and to verify the adequacy of test
program records and preliminary evaluation of test results. The following components
logic tests were selected for inspection of this item:
- Section 6.1, RWST Low-Low Level Annunciator
- Section 6.2, RWST Level Full and Startup Makeup Annunciators
- Section 6.4, RWST Temperature Annunciators
The inspectors assessed the following attributes associated with these test observations:
- all test personnel were on station and had the latest revision of the procedure;
- test prerequisites were performed;
- plant systems were in service to support the test;
- test equipment was installed and within calibration;
- testing was performed in accordance with the approved procedure;
- test interruptions and continuations were handled in accordance with approved
procedures and documented in the chronological test log;
- testing events and discrepancies were properly documented in the test deficiency
log;
- testing was executed and coordinated properly;
- data was properly collected;
- temporary equipment was installed and tracked appropriately;
- administrative test controls were properly followed; and
- test personnel were using approved drawings and vendor manuals.
The inspectors observed the tests to verify that the overall test acceptance was met.
The inspectors conducted a review with the responsible test engineer to assure that the
preliminary test evaluations were consistent with the inspectors observations. During
the tests, the inspectors observed important data gathering activities to ensure the data
was properly gathered and recorded. A post-test cursory review of the test data was
performed to verify legibility, traceability, and permanence of the data sheet entries.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the applicants test procedure was performed in a
manner consistent with the guidance of procedure SMP-9, Watts Bar Nuclear Plant Unit
2 Conduct of Test, Rev. 5. This completes the planned test witnessing inspection of
preoperational test procedure 2-PTI-063-04 associated with refueling water storage tank
(RWST) and containment sump annunciator testing.
P.1.7 Preoperational Test Witnessing (Inspection Procedures 70302 and 70312)
a. Inspection Scope
27
Background: The background for this preoperational test witnessing is the same as that
in the background section of P.1.3.
Inspection Activities: The inspectors witnessed activities associated with the
performance of preoperational test instruction 2-PTI-067-01, ERCW Valve Functional
Test, Rev. 1 to verify that the testing was conducted in accordance with approved
procedures and to verify the adequacy of test program records and preliminary
evaluation of test results. The following components logic tests were selected for
inspection of this item:
- Section 6.2, 2-FCV-67-87
- Section 6.4, 2-FCV-67-89
- Section 6.5, 2-FCV-67-91
- Section 6.6, 2-FCV-67-95
- Section 6.7, 2-FCV-67-96
- Section 6.8, 2-FCV-67-97
- Section 6.10, 2-FCV-67-103
- Section 6.21, 2-FCV-67-138
- Section 6.22, 2-FCV-67-139
- Section 6.23, 2-FCV-67-141
- Section 6.25, 2-FCV-67-295
- Section 6.26, 2-FCV-67-296
- Section 6.27, 2-FCV-67-297
- Section 6.28, 2-FCV-67-298
- Section 6.38, 2-FCV-67-67
The inspectors assessed the following attributes associated with these test observations:
- all test personnel were on station and had the latest revision of the procedure;
- test prerequisites were performed;
- plant systems were in service to support the test;
- test equipment was installed and within calibration;
- testing was performed in accordance with the approved procedure;
- test interruptions and continuations were handled in accordance with approved
procedures and documented in the chronological test log;
- testing events and discrepancies were properly documented in the test deficiency
log;
- testing was executed and coordinated properly;
- data was properly collected;
- temporary equipment was installed and tracked appropriately;
- administrative test controls were properly followed; and
- test personnel were using approved drawings and vendor manuals.
The inspectors observed the tests to verify that the overall test acceptance was met.
The inspectors conducted a review with the responsible test engineer to assure that the
preliminary test evaluations were consistent with the inspectors observations. During
the tests, the inspectors observed important data gathering activities to ensure the data
28
was properly gathered and recorded. A post-test cursory review of the test data was
performed to verify legibility, traceability, and permanence of the data sheet entries.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the applicants test procedure was performed in a
manner consistent with the guidance of procedure SMP-9, Watts Bar Nuclear Plant Unit
2 Conduct of Test, Rev. 5. This completes the planned test witnessing inspection of
preoperational test procedure 2-PTI-067-01 associated with ERCW valve functional
testing.
P.1.8 Preoperational Test Witnessing (Inspection Procedures 70302 and 70312)
a. Inspection Scope
Background: The background for this preoperational test witnessing is the same as that
in the background section of P.1.3.
Inspection Activities: The inspectors witnessed activities associated with the
performance of preoperational test instruction 2-PTI-067-03, ERCW Valve Logic Test,
Rev. 1 to verify that the testing was conducted in accordance with approved procedures
and to verify the adequacy of test program records and preliminary evaluation of test
results. The following components logic tests were selected for inspection of this item:
- Section 6.1, 2-FCV-67-123
- Section 6.29, 2-FCV-67-143
- Section 6.30, 2-FCV-67-146
The inspectors assessed the following attributes associated with these test observations:
- all test personnel were on station and had the latest revision of the procedure;
- test prerequisites were performed;
- plant systems were in service to support the test;
- test equipment was installed and within calibration;
- testing was performed in accordance with the approved procedure;
- test interruptions and continuations were handled in accordance with approved
procedures and documented in the chronological test log;
- testing events and discrepancies were properly documented in the test deficiency
log;
- testing was executed and coordinated properly;
- data was properly collected;
- temporary equipment was installed and tracked appropriately;
- administrative test controls were properly followed; and
- test personnel were using approved drawings and vendor manuals.
29
The inspectors observed the tests to verify that the overall test acceptance was met.
The inspectors conducted a review with the responsible test engineer to assure that the
preliminary test evaluations were consistent with the inspectors observations. During
the tests, the inspectors observed important data gathering activities to ensure the data
was properly gathered and recorded. A post-test cursory review of the test data was
performed to verify legibility, traceability, and permanence of the data sheet entries.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the applicants test procedure was performed in a
manner consistent with the guidance of procedure SMP-9, Watts Bar Nuclear Plant Unit
2 Conduct of Test, Rev. 5.
P.1.9 Preoperational Test Witnessing (Inspection Procedures 70302, 70312, and 70439)
a. Inspection Scope
Background: The background for this preoperational test witnessing is the same as that
in the background section of P.1.3.
Inspection Activities: The inspectors witnessed activities associated with the
performance of preoperational test instruction 2-PTI-070-01, Component Cooling Water
Pump/Valve Functional Test, Rev. 1 to verify that the testing was conducted in
accordance with approved procedures and to verify the adequacy of test program
records and preliminary evaluation of test results. The following components logic tests
were selected for inspection of this item:
- Section 6.4, 2-FCV-70-134
- Section 6.7, 2-FCV-70-92
- Section 6.9, 2-FCV-70-100
- Section 6.13, 2-FCV-70-156
- Section 6.16, 2-FCV-70-3-B
- Section 6.19, Thermal Barrier Booster Pump 2B-B Operational Test
- Section 6.22, Component Cooling Pump C-S Pump Logic (Train A)
The inspectors assessed the following attributes associated with these test observations:
- all test personnel were on station and had the latest revision of the procedure;
- test prerequisites were performed;
- plant systems were in service to support the test;
- test equipment was installed and within calibration;
- testing was performed in accordance with the approved procedure;
- test interruptions and continuations were handled in accordance with approved
procedures and documented in the chronological test log;
30
- testing events and discrepancies were properly documented in the test deficiency
log;
- testing was executed and coordinated properly;
- data was properly collected;
- temporary equipment was installed and tracked appropriately;
- administrative test controls were properly followed; and
- test personnel were using approved drawings and vendor manuals.
The inspectors observed the tests to verify that the overall test acceptance was met.
The inspectors conducted a review with the responsible test engineer to assure that the
preliminary test evaluations were consistent with the inspectors observations. During
the tests, the inspectors observed important data gathering activities to ensure the data
was properly gathered and recorded. A post-test cursory review of the test data was
performed to verify legibility, traceability, and permanence of the data sheet entries.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the applicants test procedure was performed in a
manner consistent with the guidance of procedure SMP-9, Watts Bar Nuclear Plant Unit
2 Conduct of Test, Rev. 5. This completes the planned test witnessing inspection of
preoperational test procedure 2-PTI-070-01 associated with component cooling water
pump/valve logic testing.
P.1.10 Preoperational Test Witnessing (Inspection Procedures 70302, 70312, and 70443)
a. Inspection Scope
Background: The background for this preoperational test witnessing is the same as that
in the background section of P.1.3.
Inspection Activities: The inspectors witnessed activities associated with the
performance of preoperational test instruction 2-PTI-072-01, Containment Spray Pump
Valve Logic Test, Rev. 1 to verify that the testing was conducted in accordance with
approved procedures and to verify the adequacy of test program records and preliminary
evaluation of test results. The following components logic tests were selected for
inspection of this item:
- Section 6.3, 2-FCV-72-22 and 2-FCV-72-44
- Section 6.6, 2-FCV-72-41
- Section 6.11, Containment Spray Pump 2A-A Flow Performance Test
The inspectors assessed the following attributes associated with these test observations:
- all test personnel were on station and had the latest revision of the procedure;
- test prerequisites were performed;
31
- plant systems were in service to support the test;
- test equipment was installed and within calibration;
- testing was performed in accordance with the approved procedure;
- test interruptions and continuations were handled in accordance with approved
procedures and documented in the chronological test log;
- testing events and discrepancies were properly documented in the test deficiency
log;
- testing was executed and coordinated properly;
- data was properly collected;
- temporary equipment was installed and tracked appropriately;
- administrative test controls were properly followed; and
- test personnel were using approved drawings and vendor manuals.
The inspectors observed the tests to verify that the overall test acceptance was met.
The inspectors conducted a review with the responsible test engineer to assure that the
preliminary test evaluations were consistent with the inspectors observations. During
the tests, the inspectors observed important data gathering activities to ensure the data
was properly gathered and recorded. A post-test cursory review of the test data was
performed to verify legibility, traceability, and permanence of the data sheet entries.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the applicants test procedure was performed in a
manner consistent with the guidance of procedure SMP-9, Watts Bar Nuclear Plant Unit
2 Conduct of Test, Rev. 5. This completes the planned test witnessing inspection of
preoperational test procedure 2-PTI-072-01, Containment Spray Pump Valve Logic
Test.
P.1.11 Preoperational Test Results Evaluation (Inspection Procedures 70562)
a. Inspection Scope
Background: The purpose of preoperational test inspection is to verify through direct
observation, personnel interviews, and review of facility records that:
- Systems and components important to the safety of the plant are fully tested to
demonstrate that they satisfy their design requirements, and
- Management controls and procedures, including quality assurance programs.
Necessary for operation of the facility have been documented and implemented.
IMC 2513 requires the pre-operational test results review of the mandatory tests defined
in MC 2513 and five of the primal tests defined in MC 2513. IIR 05000391/2014608
(ADAMS Accession No. ML14322A182) documented the test witnessing inspection of
the performance of IP 70462, Preoperational Test Witnessing-Reactor Coolant System
32
Cold Hydrostatic Test. The following inspection was performed using IP 70562 to
satisfy the review of facility records of the mandatory test.
Inspection Activities: The inspectors reviewed test result package 2-PTI-068-14, Unit 2
Cold Hydro Summary Report, Rev. 1 dated January 15, 2015, to verify that the
hydrostatic test was performed in accordance with the applicable procedure.
Specifically, the inspectors reviewed the summary report to verify:
- changes were made in accordance with applicants administrative controls;
- the test procedure satisfied the commitments to testing made by the applicant;
- the system boundary contained all required components, pressure vessels,
piping, pumps, and valves;
- the hydrostatic test met the requirements required by ASME Boiler and Pressure
Vessel Code (BPVC)Section III;
- test deficiencies are resolved and retest requirements have been completed; and
- test results have been reviewed and approved by appropriate personnel.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
Based on the review of the applicants hydrostatic test results package, the inspectors
determined that the test was performed in accordance with the appropriate procedure
and met the requirements invoked by NRC regulations and ASME B&PV Code Section
III. IP 70562 is considered closed based on this review.
III. OPERATIONAL READINESS ACTIVITIES
O.1 Operations
O.1.1 (Closed) Quality Assurance Program - Procurement Control (Inspection Procedure
35746)
a. Inspection Scope
Background: This IP provided guidance to the inspectors in reviewing QA program
documentation to verify that the applicant had developed and implemented a QA
Program related to the control of procurement activities that was in conformance with
regulatory requirements, commitments in the application and industry guides and
standards. This inspection was a follow-up from the inspection that was documented in
IIR 05000391/2014607 (ADAMS Accession No. ML1427A076). With respect to Unit 1
operations, these controls had been previously established and implemented by the
licensee, and are inspected under the NRC reactor oversight process (ROP).
Inspection Activities: This inspection was performed in accordance with IMC 2513, titled
Light Water Reactor Inspection Program - Preoperational Testing and Operational
33
Preparedness Phase, dated August 5, 2008, and based upon an NRC letter to TVA,
dated November 8, 2013, titled Watts Bar Nuclear Plant Unit 2 Construction -
Operational Preparedness Inspection Plan, (ADAMS Accession No. ML13312A082)
which described the scope of inspections for the inspection procedures listed in
Appendix B of IMC 2513. Specifically, this inspection was performed to satisfy the
requirements for Section II.2.b of IP 35746, Procurement Control, dated October 1,
1976; which required a sampling of Unit 2 safety-related items that had been received,
stored, and handled by the organization that would support Unit 2 once it became
operational.
The inspectors reviewed a sample of procurement orders for recently purchased safety-
related items that had been received on-site. The sample included items from the
following categories: mechanical, electrical, instrument/electronic, and consumables.
The inspectors verified that the associated procurement documents were prepared in
accordance with administrative controls; the items were purchased from qualified
vendors; and the procurement documents contained requirements for the
vendor/supplier to supply appropriate documentation of the quality, including component
traceability. The inspectors also verified that the documentation was located with the
procured items in the correct storage locations, and that the items were stored in
accordance with the documentation requirements.
The inspectors also reviewed the open issues previously documented in IIR
05000391/2014607. The inspectors reviewed the construction contractors Evaluated
Suppliers List and the TVA Acceptable Supplier List (ACL) that had been identified as
being different from each other, specifically that some of the vendors used for WBN Unit
2 construction were not on TVAs ACL. The inspectors reviewed supplier lists and
interviewed Procurement and QA personnel, both from the applicant and the
construction contractor. The inspectors noted that although the lists were different, no
supply parts purchased for Unit 2 construction came from suppliers that were not on the
TVA ACL. The extra suppliers on the contractors list were not used for Unit 2
construction. In addition, the inspectors reviewed the procurement procedures that were
required to qualify suppliers if they would be used for future purchases. The inspectors
also reviewed Watts Bar Nuclear Plant Operational Spares Strategy Document, and
noted that it had been revised since the last inspection. The critical spares for WBN Unit
2 had been identified based upon the differences between WBN Unit 1 and WBN Unit 2.
Purchases were being performed for those spares necessary for WBN Unit 2 startup and
operation.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
Based upon the review of the sample and the programmatic process review, the
inspectors concluded that TVA had adequately planned to transition from a single unit to
a dual unit procurement control program. No further inspection is required for adequate
implementation of IP 35746. IP 35746 is closed.
34
O.1.2 (Closed) Quality Assurance Program - Maintenance (Inspection Procedure 35743)
a. Inspection Scope
Background: This IP provided guidance to the inspectors to verify the applicant had
developed and implemented a QA Program, relating to maintenance activities, that was
in conformance with proposed TS, regulatory requirements, commitments in the
application, and applicable industry guides and standards. This inspection was a follow-
up from the inspection that was documented in IIR 05000391/2015603 (ADAMS
Accession No. ML15124A921). With respect to Unit 1 operations, these controls had
been previously established and implemented by the licensee, and are inspected under
the NRC ROP.
Inspection Activities: This inspection was performed in accordance with IMC 2513, dated
August 5, 2008, and based upon an NRC letter to TVA, dated November 8, 2013.
Specifically, this inspection was performed to satisfy the requirements for Section II.2.c
of NRC IP 35743, Maintenance, dated January 1, 1982; which required the inspectors
to verify that Unit 2 equipment was on a preventive maintenance master schedule and to
verify that the required maintenance activities were performed and documented.
The inspectors reviewed the associated program documents and procedures for TVA
nuclear power group (NPG) and for Unit 2 construction, which included the quality
assurance plans, preventative maintenance, on-line work control, and the corrective
action program. The inspectors performed interviews, reviewed program documents,
and reviewed the work management schedules of preventive maintenance activities
(PMs) for systems that had been completed and turned over to the operations
department. The inspectors reviewed a sampling of Unit 2 equipment and systems as
documented in the master list and verified that the PMs had been completed or credited
as complete based upon previous work performed and documented as required per the
applicants work management process. The inspectors verified that the PMs were
consistent with the vendors recommendations.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
Based upon the review of the sample and the programmatic process review, the
inspectors concluded that TVA had adequately planned to transition from a single unit to
a dual unit maintenance program. No further inspection is required for adequate
implementation of IP 35743. IP 35743 is closed.
O.1.3 (Closed) Quality Assurance Program - Surveillance Testing and Calibration
Control (Inspection Procedure 35745)
a. Inspection Scope
35
Background: This IP provided guidance to the inspectors to verify the applicant had
developed and implemented programs for control and evaluation of: (1) surveillance
testing, calibration, and inspection required by proposed TS, in-service inspection of
pumps and valves as described in 10 CFR 50.55a.(g); and (2) calibration of safety-
related instrumentation not specifically controlled by TS. This inspection was a follow-up
from the inspection that was documented in IIR 05000391/2015603 (ADAMS Accession
No. ML15124A921). With respect to Unit 1 operations, these controls have been
previously established and implemented by the licensee, and are inspected under the
NRC ROP.
Inspection Activities: The inspection was performed in accordance with IMC 2513, dated
August 5, 2008, and based upon an NRC letter to TVA, dated November 8, 2013.
Specifically, this inspection was performed to satisfy Sections II.1.b and II.2.b of IP
35745, Surveillance Testing and Calibration Control, dated April 1, 1979, which
required the inspectors to verify: (1) Unit 2 surveillance tests required by TS were
included in a master schedule and that the planned schedule was in accordance with the
requirements of the TS; and (2) safety-related plant instruments which were not
specifically required to be calibrated by TS had been included in a master calibration
program, calibration procedures had been prepared and approved, and that calibration
of the instruments had been performed.
For Section II.1.b., the inspectors verified that a master schedule for Unit 2 surveillance
tests required by TS had been established. The inspectors also verified that the
surveillance frequency and applicable Mode tied to surveillance completion was
consistent with the applicable TS. The inspectors verified that the surveillance
procedures were consistent with the requirements of the TS. For Section II.2.b., the
inspectors verified that the calibration requirements had been established for safety-
related plant instruments which were not specifically required to be calibrated by TS.
The inspectors verified safety-related instruments were included in a master calibration
program. The inspectors verified that the calibration procedures have been prepared,
approved, and consistent with vendors requirements. The inspectors also verified that
the calibration of the instruments had been performed and documented in accordance
with the applicant work management process. For both IP sections, the inspectors
performed interviews with the dual-unit work control center personnel and verified that
the surveillances and calibrations were on the work management schedule for their next
scheduled performance.
b. Observations and Findings
No findings were identified.
c. Conclusions
Based upon the review of the sample and the programmatic process review, the
inspectors concluded that TVA had adequately planned to transition from a single unit to
a dual unit surveillance testing and calibration program. No further inspection is required
for adequate implementation of IP 35745. IP 35745 is closed.
36
IV. OTHER ACTIVITES
OA.1.1 (Discussed) Electrical Issues CAP - Sub-issue: Cable Separation and Electrical
Isolation (Temporary Instruction 2512/020)
a. Inspection Scope
Background: The bases for the cable separation requirements for WBN are the Institute
of Electrical and Electronics Engineers (IEEE) 279-1971, IEEE 308-1971, and
Regulatory Guide (RG) 1.6. The applicant determined that examples of redundant
divisions of enclosed raceways existed with less than the minimum required 1-inch
separation. This sub-issue was divided into three categories:
- Separation between redundant divisions of Class 1E raceways,
- Internal panel separation between redundant enclosed divisions of Class 1E
cables,
- Coil-to-contact and contact-to-contact isolation between Class 1E and non-Class
1E circuits.
In prior NRC inspections, IIR 05000391/2011602 - Section OA.1.5 (ADAMS Accession
No. ML110800483), IIR 05000391/2011608 - Section OA.1.8 (ADAMS Accession No.
ML11311A082), and IIR 05000391/2013604 - Section OA.1.29 (ADAMS Accession No.
ML13179A079), NRC inspectors gathered a limited sample demonstrating adequate
separation internal to control panels and between raceways containing redundant
divisions of Class 1E circuits. However, in IIR 05000391/2014605 - Section OA.1.2
(ADAMS Accession No. ML14226A049), inspectors observed that the completed
installation for conduit 2VC6034A installed under closed WO 113325528 failed to
maintain the required 1-inch minimum separation with different divisional conduits.
Inspection Activities: The inspectors reviewed work orders to verify that documented
work activities ensured compliance with separation requirements identified in TVA
design criteria WB-DC-30-4, Separation / Isolation. The inspectors conducted walk-
downs of the proximity between conduit pairs to verify that reworked conduits were
properly installed in relation to separation between redundant divisions of Class 1E
raceways.
The inspectors reviewed the following conduit pairs and WO packages in order to
assess their quality and adequacy and to ensure that physical separation requirements
were implemented:
- 2VC2039A/2PM6396G (WO 113325343)
- 2VC4456B/2PM6396G (WO 114655552)
- 2VC4432B/2PM6619A (WO 113427588)
- 2PM7214D/MC635A (WO 111123610)
- 2VC4432B/2VC4421A (WO 113427588)
Documents reviewed are listed in the Attachment.
37
b. Observations and Findings
No findings were identified.
c. Conclusions
Additional field observations of completed work are recommended to demonstrate that
physical separation and electrical isolation requirements have been met. Therefore, the
inspectors concluded that this Sub-Issue will remain open until a larger sample of
conduits can be inspected.
OA.1.2 (Discussed) Construction Deficiency Report 05000391/89-08: Kapton Insulated
Pigtail Insulation Damage (Inspection Procedure 51053)
a. Inspection Scope
Background: The historical concern that primary containment electrical penetrations
containing Kapton insulated pigtails were found with nicks in the insulation, such that
their ability to support the safety function of the serviced load or signal, was initially
reported to the NRC on August 25, 1989, in accordance with 10 CFR Part 50.55(e) as a
condition adverse to quality report (CAQR) WBP 890302 for Unit 1 and CAQR WBP
89436 for Unit 2. The follow-up final report associated with the notification (ADAMS
Accession No. ML073551006) was transmitted by letter dated September 25, 1989, and
identified the apparent cause, safety implications, and planned or completed corrective
actions. By letter dated April 30, 1993 (ADAMS Accession No. ML073241164), the
applicant changed the original commitment, which required quality control (QC)
inspection of all penetration pigtail wires for damage, to state that appropriately trained
modifications personnel utilizing a two-party inspection process would be used instead.
The background on this issue is discussed in further detail in Section OA.1.4 of IIR
05000931/2014607 (ADAMS Accession No. ML14274A076).
Inspection Activities: The inspectors observed qualified Kapton inspectors performing
quality inspections of the individual strands comprising the Kapton insulation system for
2-PENT-293-0038-D (inboard and outboard) and 2-PENT-293-0008-A (inboard). The
inspectors also observed repairs resulting from the inspections to verify that proper
procedures were followed.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors concluded that the inspection performed and the portions of the repairs
observed were adequate. Additional samples will be inspected.
38
OA.1.3 (Discussed) Generic Letter 89-10: Safety-Related Motor Operated Valve Testing
and Surveillance (Temporary Instruction 2515/109 and Inspection Procedure
51053)
a. Inspection Scope
The inspectors observed applicant activities in response to GL 89-10, "Safety-Related
Motor-Operated Valve Testing and Surveillance." The inspectors performed Part 2
inspections as documented in TI 2515/109. The inspectors performed these reviews to
determine if the applicant had established and was implementing a program that will
ensure the proper performance of MOVs in safety-related systems. The inspectors
observed dynamic MOV diagnostic tests for the following GL 89-10 MOVs:
- 2-FCV-63-0006;
- 2-FCV-63-0007;
- 2-FCV-63-0008;
- 2-FCV-63-0011; and
- 2-FCV-63-0047.
For these MOVs the inspectors reviewed the test activities to determine if they were
properly controlled and handled. To make those determinations, the inspectors
reviewed work instructions, applicable design specifications, calculations, system
descriptions, work packages, and approved procedures. The inspectors reviewed
applicable MOV sizing calculations to determine if the applicant adequately sized the
MOVs in accordance with GL 89-10 and if the switch settings were consistent with the
expected design basis conditions for operation of the valve.
During the observance of these tests, the inspectors determined if:
- test personnel accomplished activities in accordance with the applicable test
procedure and work instructions;
- fluid pressure, differential pressure, and flow adequately replicated applicable
design basis conditions;
- measuring and test equipment used during the test was properly identified,
traceable, and within the current calibration interval;
- measuring and test equipment was suitable for the application, was used within
the calibrated range, and was recorded in the applicable work orders;
- test results were recorded during the activity; and
- test discrepancies were properly identified for resolution.
The inspectors reviewed MOV thrust and torque capability engineering calculations for
five MOVs listed above to determine if the:
- actuator selections were in compliance with applicable site specifications and
design requirements;
- design inputs for design basis operating conditions (such as temperature, flow,
and pressure - including differential pressure) were consistent with the
applicable system description and the Final Safety Analysis Report;
39
- calculations complied with design standard DS-M18.2.22, TVA Mechanical
Design Standard for MOV Design Basis and Joint Owners Group (JOG) Review
Methodologies, Revision 6; and
- calculations complied with design standard DS-M18.2.21, Mechanical Design
Standard for Motor Operated Valve Thrust and Torque Calculations, Revision
21.
The inspectors previously reviewed applicant actions to address GL 89-10; therefore,
this inspection was a limited scope inspection of the requirements of this TI. In
accordance with requirements of TI 2515/109, Revision 4, the inspectors evaluated and
answered the questions for Part 2 of the TI as documented in the Observations and
Findings section below: Questions 04.04 through 04.11.
The following samples were inspected:
- IP 51053, Section 02.02.g - 5 samples
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
In accordance with requirements of TI 2515/109, Revision 4, the inspectors evaluated
and answered the following questions for Part 2 of the TI:
Part 2, Verification of Program Implementation:
For a sample of MOVs from the population of MOVs in the generic letter program:
04.04 Select a sample of MOVs for detailed review from the population of MOVs in the
generic letter program.
The inspectors sampled five GL 89-10 MOVs, 2-FCV-63-0006, 2-FCV-63-0007,
2-FCV-63-0008, 2-FCV-63-0011, and 2-FCV-63-0047, to review as part of this
inspection. Based on the previous samples obtained as documented in IIRs
05000391/2011608 (ADAMS Accession No. ML11311A082, 2 samples),
05000391/2013610 (ADAMS Accession No. ML14049A158, 2 samples),
05000391/2014615 (ADAMS Accession No. ML15044A424, 1 sample), and this
report (5 samples), the inspectors determined that the sample requirements
contained in Section 05.02.k of the TI have been met.
04.05 Verify that the licensee has performed design-basis reviews of the sampled
MOVs consistent with the generic letter or its commitments (where accepted
under Part 1), as appropriate.
The inspectors determined that the applicants design basis review was adequate
for the sampled valves.
04.06 Verify that the licensee has adequately sized the sampled MOVs in accordance
with the generic letter or its commitments (where accepted under Part 1), as
40
appropriate. Verify that switch settings are consistent with the expected design
conditions for operation of the valve.
The inspectors verified that the applicant properly sized the sampled MOVs and
that the limit and torque switch settings were appropriate. The inspectors verified
the adequacy of the engineering design was completed in accordance with
applicable site specifications and design criteria. The inspectors reviewed the
applicable thrust/torque and actuator capability engineering calculations for the
sampled MOVs to ensure that the applicant had appropriately sized the
actuators. The inspectors observed dynamic MOV testing on the sampled valves
and determined that the applicant appropriately set the limit and torque switches.
04.07 Verify that the licensee has demonstrated the design-basis capability of the
sampled MOVs and the adequacy of the licensee's program applied to the
sampled MOVs in accordance with the generic letter or its commitments (where
accepted under Part 1), as appropriate.
The inspectors reviewed the reconciled MOV calculation(s) for the sampled
MOV(s) and determined that the applicant adequately incorporated the dynamic
test results into the calculation(s). The valve factor and rate of loading used in
the calculations exceeded the values obtained during dynamic testing. Design
assumptions were conservative and the applicant effectively demonstrated
adequate margin for actuator capability under worse case accident scenarios.
04.08 Verify that the licensee has established a method for periodic verification of
adequate capability of the sampled MOVs in accordance with the generic letter or
its commitments (where accepted under Part 1), as appropriate.
This will be verified during inspection activities for GL 96-05.
04.09 Verify that the licensee has analyzed MOV failures which have occurred and has
an effective corrective action plan to prevent reoccurrence and the licensee
trends failures of MOVs in accordance with the generic letter or its commitments
(where accepted under Part 1), as appropriate.
The applicant maintained established procedures, which were common to all
TVA nuclear units including Watts Bar Unit 2, to analyze MOV failures. The
inspectors determined that these procedures were adequate.
04.10 Verify that the licensee is meeting the program schedule in accordance with the
generic letter or its commitments (where accepted under Part 1), as appropriate.
This item is not applicable for Watts Bar Unit 2 because the unit is under
construction.
04.11 Verify quality assurance program implementation in the design control and
testing of the sampled MOVs.
Based on the activities inspected, the inspectors determined that the applicant
was properly implementing their quality assurance program with regards to Unit 2
41
Based on the results of this inspection and previous inspections documented above, the
inspectors concluded that all inspection activities for Part 2 of this TI are complete.
c. Conclusions
Based on the activities reviewed, MOV testing was conducted by qualified individuals
using qualified procedures, design calculations were performed in accordance with
applicable specifications, and the applicant was adequately implementing GL 89-10
requirements. Because Watts Bar Unit 2 has not operated yet, the applicant has not
fully established a GL 89-10 program; therefore, the requirements of GL 89-10 have not
been fully implemented and additional inspection activities are required to complete this
TI. These activities include additional samples for Part 3 requirements of this TI. Based
on this limited review and the remaining actions by the applicant, no additional
conclusion is warranted for this inspection.
OA.1.4 (Discussed) Generic Letter 2004-02 - Potential Impact of Debris Blockage on
Emergency Recirculation during Design Basis Accidents at Pressurized-Water
Reactors and Pressurized Water Reactor Containment Sump Blockage
(Temporary Instruction 2515/166)
a. Inspection Scope
Background: GL 2004-02, Potential Impact of Debris Blockage on Emergency
Recirculation During Design Basis Accidents at Pressurized-Water Reactors, requested
licensees to evaluate the emergency core cooling system (ECCS) and containment
spray systems (CSS) recirculation functions and take actions, if appropriate. Pressurized
water reactor recirculation sump screens have been identified to be potentially
susceptible to debris blockage during design basis accidents requiring recirculation
operation of ECCS or CSS and on the potential for additional adverse effects due to
debris blockage of flow paths necessary for ECCS and CSS recirculation and
containment drainage.
In response to the generic letter mentioned above, WBN determined that they would
remove the outer trash racks provided on each side of the sump and install a new Sure-
Flow strainer. The new strainer has an available flow area of 4600 ft² compared to the
original screen area of approximately 200 ft². The new strainer openings are 0.085
inches in diameter compared to the 0.25 inch mesh that cover the outer trash racks. The
Sure-Flow strainer has an advanced configuration intended to be much more resistant
to potential sump blockage.
Unit 2 containment is a mirror image to Unit 1s containment. Therefore, the results of
debris generation, transport analyses, and downstream effects will be the same for Unit
2 as for Unit 1. The WBN Unit 2 letter to the NRC dated March, 4, 2011 (ADAMS
Accession No. ML110680248) stated that Unit 2 actions are to replace containment
sump intake screens with an advanced design containment sump strainer arrangement
under Engineering Document Construction Release (EDCR) 53580. The design is the
same as that used for Unit 1 except that the strainer stack to plenum opening was
increased in size. This change reduces the strainer pressure drop, thus increasing the
margin to plugging the strainer when compared to Unit 1.
42
Inspection Activities: The inspectors performed a walkdown of the containment sump
strainer assembly 2-STN-063-0200. Specifically, the inspectors reviewed WOs
associated with the installation of the containment sump strainer assembly, plenum, and
support beams as well as their respective construction drawings to determine if:
- the maximum 0.085 gap, allowed by design, was attained throughout the
components and instrument penetrations of the strainer assembly;
- the as-built configuration of the strainer was in conformance with the construction
sequence described on the work orders;
- as-built dimensions were within the tolerances required by construction drawings
and specifications; and
- installation and torqueing of connections was properly documented and
controlled by quality control inspections.
In addition, the inspectors reviewed certificates of conformance, installation procedures,
and EDCRs to verify if construction activities were completed and programmatically
controlled in response to GL 2004-02.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
Based on the activities reviewed, the inspectors concluded that the installation of the
containment sump strainer assembly was completed in accordance with the as-built
configurations reflected in construction drawings and specifications. This item will
remain open pending review of related calculations, review of the final coatings
walkdown report, review of drawings and calibration reports associated with the sump
level indicator and sump radiation monitoring device, and a final walkdown of the
containment sump.
OA.1.5 (Closed) Temporary Instruction 2515/191: Followup on Fukushima Orders for
Watts Bar and Inspection of the Licensee's Responses to Mitigation Strategies
Order EA-12-049, Spent Fuel Pool Instrumentation Order EA-12-051 and
Emergency Preparedness Information Requested in NRC March 12, 2012
a. Inspection Scope
Background: On March 12, 2012, the NRC issued Mitigation Strategies Order
EA-12-049, (ADAMS Accession No. ML12054A735) requiring all U.S. nuclear power
plants to implement strategies that will allow them to cope without their permanent
electrical power sources for an indefinite amount of time.
The Order was issued in response to the Fukushima accident. The NRC created a task
force of senior NRC staff that reviewed the circumstances of the event to determine what
lessons could be learned. In July 2011, the task force provided recommendations to
43
enhance U.S. reactor safety; these became the foundation of the NRC's post-Fukushima
activities.
These diverse and flexible coping strategies (also known as FLEX) are expected to use
a combination of currently installed equipment (e.g., steam-powered pumps), additional
portable equipment that is stored on site, and equipment that can be flown in or trucked
in, to maintain the proper cooling temperature for the reactor core and spent fuel.
On July 15, 2013, TVA submitted a letter (ADAMS Accession No. ML13206A383) to the
NRC updating their FLEX strategy plans to comply with NRC Order EA-12-049.
Since that time, TVA has implemented several of these actions, made modifications to
the plant, and introduced new equipment. The NRC has witnessed and inspected a
sampling of these modifications as noted below. The inspections centered on critical
design and structural attributes. Additionally, inspections were performed of as-built and
completed modifications to verify that specifications, drawings, requirements, and
standards were met.
Several of these inspections for Unit 2 have been documented in IIRs:
- 05000391/2014604 (ADAMS Accession No. ML14177A214)
- 05000391/2014605 (ADAMS Accession No. ML14226A049)
- 05000391/2014607 (ADAMS Accession No. ML14274A076)
Inspection Activities: Recent inspections for TI 2515/191 were conducted from March 30
to April 3, 2015 and documented in a separate inspection report numbered
05000390/2015609 and 05000391/2015616 (ADAMS Accession No. ML 15173A317).
The inspectors reviewed the NRC inspection report which concluded that the inspection
team had verified that plans for complying with NRC Orders EA-12-049, Order Modifying
Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-
Basis External Events (ADAMS Accession No. ML12229A174) and EA-12-051, Order
Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS
Accession No. ML12056A044) are in place and are being implemented by the applicant.
The inspection team had also verified that the applicant had implemented staffing and
communications plans provided in response to the March 12, 2012, request for
information letter and multi-unit dose assessment information provided per COMSECY-
13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan
Lessons Learned, dated March 27, 2013 (ADAMS Accession No. ML12339A262).
b. Observations and Findings
No findings were identified.
c. Conclusions
Based on completion of earlier inspections of plant modifications to implement
diverse/flexible coping strategies and the completion of TI 2515/191, the NRC has
completed its inspection of post Fukushima activities as related to construction
inspections for Unit 2.
44
OA.1.6 (Discussed) Generic Letter 2006-02: Grid Reliability and the Impact on Plant Risk
and the Operability of Offsite Power (Inspection Procedure 92701)
a. Inspection Scope
Background: GL 2006-02 Grid Reliability and the Impact on Plant Risk and the
Operability of Offsite Power (ADAMS Accession No. ML060180352) was issued on
February 1, 2006, to determine if compliance was being maintained with regulatory
requirements governing electric power sources and associated personnel training. The
NRC completed a safety evaluation (ADAMS Accession No. ML100080768) of TVAs
response to GL 2006-02 for Unit 2. The SER, dated January 20, 2010, concluded that
TVAs response and regulatory commitments made for GL 2006-02 were acceptable.
The report also indicated that prior to closing out the review of TVAs response to this GL
for Unit 2, the following would be required:
- independent verification that the regulatory commitments discussed have been
met, and
- a review of the associated electrical design calculations for WBN Unit 2.
IIR 05000391/2014608 Section OA.1.5 (ADAMS Accession No. ML14322A182)
previously addressed this issue.
Inspection Activities: The inspectors reviewed the current version of calculation
EDQ00099920070002 Rev. 43 to verify the adequacy and functionality of the auxiliary
power system to support dual unit operations. The inspectors reviewed TVA-SPP-
10.010, Rev. 4, NERC Standard Compliance Processes Shared by TVAs Nuclear
Power Group and Transmission Organizations, dated March 24, 2014, to understand
operation protocols in place between WBN and the power system operator (PSO).
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors identified that additional inspection is required. Specifically, inspection of
the updated PSO offsite power grid analysis, WB2/PSO protocols and implementing
procedures, and procedures for offsite power restoration. This item will remain open.
OA.1.7 (Closed) Three Mile Island Action Item II.D.3 - Direct Indication of Relief-and
Safety-Valve Position and Supplemental Safety Evaluation Report Appendix HH
Item 074: Installation of the Acoustic Monitoring System for the Power Operated
Relief Valves (Inspection Procedure 92701)
a. Inspection Scope
Background: This Three Mile Island (TMI) action item requires that RCS relief and safety
valves have positive indication of valve position in the main control room and that
45
indication is derived from a reliable valve-position detection device or a reliable
indication of flow in the discharge pipe. The inspectors had previously documented their
review of actions to address this item in IIR 05000391/2014608 (ADAMS Accession No.
Inspection Activities: During this inspection period, the inspectors reviewed the overall
status of the actions to comply with the subject TMI action item. The inspectors reviewed
drawings and conducted walkdowns with responsible staff to verify the installation of the
acoustic monitoring system components and pressurizer relief tank (PRT) condition
sensors, and to verify indications are provided in the main control room; in accordance
with TVAs overall response to this TMI action item. This review included:
- temperature downstream of the power-operated relief valves (PORVs)
- PORV direct valve position indication light
- PRT temperature
- PRT pressure
- PRT fluid level
- acoustic monitoring display
- sealed piezoelectric accelerometers
- charge converters
- control room display components
The inspectors reviewed the work performed under WOs 110800410, 114834946,
114853758, 113474274, 113576853, and 116574299 associated with the acoustic
monitoring system of the pressurizer safety relief valves and PORVs to verify installed
wiring for the monitoring and indication systems. The inspectors used drawing 2-
47W813-1, Rev. 33 to identify installed components. The inspectors visually verified the
completed installation of the sealed piezoelectric accelerometers on the downstream
piping of the two pressurizer PORVs: 2-XE-68-334 and 2-XE-38-68-340A. Installed
components for PRT temperature 2-TE-68-309, pressure 2-PT-68-301/2-PT-68-311C
and tank level 2-LT-68-300/2-LT-68-312C indications were visually verified. The
inspectors reviewed manufacturer drawings and installation instructions to verify the
adequacy of installed equipment configurations.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified. All components necessary to drive the signals for these
indications were installed.
c. Conclusions
The inspectors determined that TVA had completed the installation, including wiring and
connections for WBN Unit 2 TMI action item II.D.3 - Direct Indication of Relief and
Safety Valve Position and SSER Appendix HH Item 074: Installation of the Acoustic
monitoring system for the Power Operated Relief. Therefore, these items are closed.
46
OA.1.8 (Closed) Generic Letter 79-36, Adequacy of Station Electric Distribution System
Voltages (Inspection Procedure 92701)
a. Inspection Scope
Background: As indicated in the NRC GL 79-36, all licensees are required to review the
electric power systems at each of their nuclear power plants to determine analytically if,
assuming all onsite sources of alternating current power are not available, the offsite
power system and the onsite distribution system is of sufficient capacity and capability to
automatically start as well as operate all required safety loads. This includes the
protection of safety loads from undervoltage conditions, designed to provide the required
protection without causing voltages in excess of maximum voltage ratings of safety loads
and without causing spurious separations of safety buses from offsite power. In order to
address dual unit operation a separate analysis should be performed for each unit
assuming (1) an accident in the unit being analyzed and simultaneous shutdown of all
other units at the station; or (2) an anticipated transient in the unit being analyzed and
simultaneous shutdown of all other units at the station, whichever presents the largest
load demand situation.
Inspectors previously reviewed several calculations and documents associated with
electrical distribution system voltages for dual unit operations with followup interviews
with responsible staff from the electrical and mechanical design groups to address
required clarifications. The previous reviews were documented in IIR
05000391/2011612, Section E.1.1 (ADAMS Accession No. ML11348A081),
05000391/2014605, Section OA.1.5 (ADAMS Accession No. ML14226A049), and
05000391/2014608, Section OA.1.8 (ADAMS Accession No. ML14322A182).
Inspection Activities: The inspectors reviewed and discussed voltage drop studies,
calculations, maximum distribution equipment loading, motor block starting during safety
injection (SI) signal loading for containment phases A and B isolation conditions, feeder
and circuit wire sizes, cable temperature ratings and current capacities, control circuit
protection integrity, motor block starting under SI signal with concurrent degraded
voltage conditions, load shedding and load restoration from degraded voltage and loss
of voltage conditions. This review was to verify equipment performance to maintain
adequate station electric distribution system voltages and to establish the adequacy and
functionality of the auxiliary power system to support dual unit operation.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors concluded that the calculations and information provided for dual unit
operation analysis with a unit experiencing accident conditions and simultaneous
shutdown of the other unit as required by the GL were addressed adequately. GL 79-36
is closed.
47
OA.1.9 (Closed) Unresolved Item 05000391/2014614-01, Potential failure to comply with 10
CFR 50.55a and Properly Implement the Scope of the ASME OM Code, Associated
with Generic Letter 89-04: Guidance on Developing Acceptable In-Service Testing
Programs; Temporary Instruction 2515/114: Inspection Requirements for Generic
Letter 89-04, Acceptable In-Service Testing Programs; Temporary Instruction
2515/110: Performance of Safety-Related Check Valves
a. Inspection Scope
Background: During the initial inspection of TVAs inservice testing (IST) program to
support dual unit operations, inspectors identified URI 05000391/2014614-01 (ADAMS
Accession No. ML14363A315), Potential Failure to Comply with 10 CFR 50.55a and
Properly Implement the Scope of the ASME Operation and Maintenance (OM) Code.
The inspection noted that the safety injection cold leg accumulator isolation valves and
nitrogen charging isolation valves (FCV-63-67, FCV-63-80, FCV-63-98, FCV-63-118,
FCV-63-63, FCV-63-87, FCV-63-107, and FCV-63-127) were classified as passive in the
TVA IST program. As a result of this classification, the program planned to verify
position of these valves remotely every two years. Valves classified as active, however,
per ASME OM Code 2004, 2006 Addenda, are required to be stroke time tested. TVAs
IST program did not include a justification for classifying these valves as passive instead
of active. In addition, the inspectors identified several emergency operating procedures
where the valves are required to be repositioned in order to prevent excessive quantities
of nitrogen from being injected into the RCS during a post-accident condition.
Furthermore, the emergency response guidelines, provided by the vendor, documented
that the injection of nitrogen could inhibit natural circulation or lead to RCS pressure
control difficulties. As a result, further review was required for clarification/interpretation
of the existing application of the ASME OM code.
Inspection Activities: The NRC Office of Nuclear Reactor Regulation (NRR) staff
reviewed TVAs IST program to determine if the ECCS accumulator isolation valves met
the requirements of 10 CFR Part 50.36, 50.55a, and the ASME OM Code, to be
classified under a maintenance designation of passive. The NRC NRR staff documented
their review in a letter to the NRC regional staff (ADAMS Accession No. ML15140A441).
In addition, the NRR staff reviewed the Watts Bar Unit 2 TS, the normal operating
procedures, the safe shutdown requirements, the Watts Bar Updated Final Safety
Analysis Report, and the Westinghouse analysis WCAP-9601, Report on Small Break
Accidents for Westinghouse NSSS Systems, Volumes I - III. The review was
conducted to verify the potential nitrogen gas injection into the RCS system, while the
plant was cooling down from MODE 3 to MODE 4 at a fixed rate with an open
accumulator isolation valve, was properly analyzed. The staff reviewed the WCAP-9601
analysis to verify that the non-condensable gas, caused by the nitrogen addition into the
RCS through the open accumulator valves, would not disrupt core cooling from either a
hydraulic or thermal perspective.
b. Observations and Findings
No findings were identified.
48
The inspection reviewed TVAs position that the accumulator isolation valves were
passive due to the valves being in their open safety position with power removed. These
valves are included in the TS surveillance requirements (SRs) for Watts Bar Unit 2 and
verify that the accumulator isolation valves are fully opened every two hours and that
power is removed from each accumulator isolation valve when the pressurizer pressure
is greater than 1000 psig every 31 days. The SRs indicate that the accumulator isolation
valves are to remain open and de-energized while in MODE 1 and while transitioning to
MODE 3. Therefore, the inspection determined that in order to reach hot standby (the
safe shutdown condition) the accumulator isolation valves are not required. The IST
program met the requirement of 10 CFR Part 50.36, 50.55a, and the classification of the
valves met the definition of the ASME OM Code for passive valves.
The inspection reviewed the impacts of the accumulator isolation valves on the RCS.
The inspection found that when the reactor is in hot standby, Mode 3, the accumulator
isolation valves will remain open, the accumulators would not inject into the RCS. This
is due to the RCS pressure remaining above the pressure of the accumulators.
The inspection reviewed the impacts of the accumulator isolation valves on the
emergency operating procedures (EOPs) for emergency shutdown. In the EOPs, the
accumulator isolation valves are listed as needed for emergency shutdown, but not all of
those procedures are required for safe shutdown. The requirements for safe shutdown
do not credit or list the accumulator isolation valves. Therefore, the accumulator
isolation valves are not required for safe shutdown for Watts Bar Unit 2.
The inspection identified that while the plant is in a controlled shutdown condition,
cooling down at a fixed rate, there was a potential for an open accumulator isolation
valve to inject cold borated water and nitrogen gas into the RCS when going from MODE
3 to MODE 4. It was found that prior to entry into MODE 4, the operators would take the
action to isolate the accumulator isolation valves. Furthermore, in the event the
operators were unable to isolate the accumulator isolation valves, the plant could safely
remain in MODE 3, the safe shutdown condition.
The inspection identified that, when in MODE 4, the RCS pressure would be low enough
to allow accumulator injection into the RCS. The inspectors reviewed the potential for
pressurized thermal shock (PTS) and the potential for impacts resulting from nitrogen
addition into the RCS. The inspection determined the injection of cold water from the
accumulators would not result in a PTS event as defined by 10 CFR 50.61. The
inspection also reviewed the Westinghouse analysis WCAP-9601. This analysis used a
variety of break sizes with the assumption that accumulator nitrogen emptied into the
RCS in a similar manner to the pressurizer vapor space calculation. The analysis also
showed that most of the non-condensable gas dissolved in the accumulator water. As a
result, the WCAP-9601 analysis concluded that a small amount of non-condensable gas
would not disrupt core cooling from either a hydraulic or thermal perspective. Therefore,
injection of nitrogen into the RCS from the accumulators would not disrupt core cooling
during small break accidents.
c. Conclusions
URI 05000391/2014614-01, Potential Failure to Comply with 10 CFR 50.55a and
Properly Implement the Scope of the ASME OM Code, is closed. The inspectors
49
concluded that based on (1) the appropriate application of the ASME OM code, (2) the
safe shutdown conditions for Watts Bar Unit 2, and (3) the review of the Westinghouse
analysis WCAP-9601, the accumulator isolation valves can be designated as passive,
and the concern for PTS and injection of nitrogen into the RCS from the accumulators
was adequately analyzed.
GL 89-04 and associated TIs will remain open. TVA will complete preservice testing for
each component in the IST program in accordance with the ASME OM code, and
additional observations of these tests will be witnessed by the inspectors in order to
close the GL and TIs.
OA.1.10 (Closed) Three Mile Island Action Item I.C.7 Nuclear Steam Supply System
Vendor Review of Procedures (Inspection Procedure 92701)
a. Inspection Scope
Background: TMI Action Item I.C.7 required the NSSS vendor (Westinghouse) review
the licensee's startup test program, low power and power ascension procedures, and
plant emergency procedures. This commitment was documented in TVA framework
letter dated January 29, 2008, Watts Bar Nuclear Plant Unit 2 - Regulatory Framework
for the Completion of Construction and Licensing for Unit 2 (ADAMS Accession No.
ML080320443). The commitment was contained in Enclosure 2, Item 106, I.C.7, NSSS
Vendor Revision of Procedures - Revise power ascension and emergency procedures
which were reviewed by Westinghouse.
For Unit 1, Action Item I.C.7 was closed in NRC Inspection Reports 50-390/85-08 and
50-391/85-08 (ADAMS Accession No. ML082190701). The inspectors documented that
the applicant had implemented the Westinghouse Owners Group generic emergency
procedures, which had been approved by NRC staff. Unit 1 actions were further
explained in TVA letter to NRC dated July 27, 1992 (ADAMS Accession No.
ML073520471). This letter explains that the WBN EOPs conform to the Westinghouse
generic guidelines and that WBN no longer depends on EOPs developed by identifying
differences between Sequoyah Nuclear Plant and WBN. In Supplement 10 to the Safety
Evaluation Report for Watts Bar Nuclear Units 1 and 2 (ADAMS Accession No.
ML072060473) dated October, 1992, the NRC staff indicated that WBN procedures
conformed to the Westinghouse Owners Group guidelines and that the license condition
was no longer necessary.
Inspection Activities: The inspectors reviewed the applicants final closure package to
verify that the intent of TMI Action Item I.C.7 had been met for WBN Unit 2. The
inspectors reviewed a list of the 39 power ascension and low power procedures required
for Unit 2 start-up. Procedures had been developed, had independent qualified reviews,
and had been approved by the Plant Operating Review Committee Test Review Group
(TRG). The inspectors reviewed an audit report created for each procedure to verify
reviews were performed, and had Westinghouse representation. The inspectors
reviewed technical instruction 2-TI-439, Test Review Group, Rev. 2, to verify that a
Westinghouse representative is required to be a review member of the TRG.
Documents reviewed are listed in the Attachment.
50
b. Observations and Findings
No findings were identified.
c. Conclusions
Based on the above activities and review of the final closure package, the inspectors
determined that the NSSS vendor has provided reviews of low power and power
ascension test procedures. In addition, WBN emergency procedures conform to the
Westinghouse Owners Group guidelines. TMI Action Item I.C.7 is closed.
OA.1.11 (Closed) Unresolved Item 05000391/2015603-4, Boric Acid Tank C Design Control
a. Inspection Scope
Background: The inspectors identified discrepancies with control room alarm response
procedure, 2-ARI-109-115, Rev. 5U2 for annunciator 112-A, BAT C Level Hi/Lo, and
calculation CN-SUA-10-07, Watts Bar Unit 2 Boric Acid Tank Level Setpoint and
Scaling Document (SSD) Supporting Calculation Note, Rev. 1. This error applied to
Unit 1 and Unit 2.
In addition, the inspectors also identified discrepancies with calculation
EPMPDM071197, Boric Acid Concentration Analysis for BAT and RWST, Rev. 8,
Appendix E, Justification of Applicability to Unit 2 Operation, and Calculation CN-SUA-
10-7, Watts Bar Unit 2 Boric Acid Tank Level Setpoint and Scaling Document
Supporting Calculation Note. This issue was documented as URI 05000391/2015603-
4, Boric Acid Tank C Design Control. (ADAMS Accession No. ML15124A921)
Inspection Activities: The inspectors performed interviews and reviewed corrective
action documents, revised calculations, and procedures to determine the impact of the
calculation errors.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
The inspectors determined that the errors identified in the calculations and annunciator
procedures did not impact safety-related equipment or personnel safety.
c. Conclusions
The applicant captured this concern in their corrective action program under PERs
1007729, 1008723, and 1009641 and subsequently revised the alarm response
procedures and calculation to correct the errors. There was no violation of NRC
requirements identified. No further inspection is required; URI 05000391/2015603-4 is
closed.
51
OA.1.12 Followup and inspection of NRC Office of Investigation Report 2-2014-017
a. Inspection Scope
The inspectors reviewed the NRC Office of Investigations (OI) Report 2-2014-017, which
was related to compliance with anchor bolt installation procedures.
b. Observations and Findings
Introduction: On April 9, 2015, the NRC OI completed an investigation to determine
whether on or about December 1, 2011, Bechtel employees, while working at WBN Unit
2, deliberately failed to follow anchor bolt installation procedures. The OI investigation
concluded that two Bechtel employees, former pipefitters at WBN Unit 2, deliberately
violated TVA procedural guidelines when they damaged rebar during drilling activities.
Description: On November 13, 2013, the NRC received information that procedural
requirements associated with the installation of anchor bolts were being violated at
WBN2. Specifically, Bechtel pipefitters had damaged rebar by drilling through or into the
rebar to install the anchor bolts. The area of concern was associated with the holes
drilled into the steam generator (SG) housing walls for anchor bolt installation associated
with unistrut supports for SG snubber oil reservoir lines.
TVA Procedure MAI-5.1B, Wedge Bolt (WB) Anchor Installation, Revision 21, is the
implementing/controlling process for anchor bolt installation, and includes the
requirements for drilling the hole to be used for anchor bolt installation. MAI-5.1B,
Revision 21, Section 6.2.5.A.3, states that unless specifically permitted, reinforcing steel
shall not be cut or drilled to install anchors. Site Engineering approval is required to drill
through the reinforcing bar. Based on the evidence developed during the investigation,
NRC OI substantiated that Bechtel employees deliberately failed to follow procedure
MAI-5.1B. The NRC review found that during anchor bolt installation associated with
unistrut supports for SG snubber oil reservoir lines, a Bechtel employee had
encountering rebar when drilling. Employees with knowledge of this incident did not
report to Site Engineering for approval to drill into the reinforcing bar. The employees
reconfigured the drill by obtaining a drill bit that could intentionally drill through the
reinforcing steel without engaging the drill stop. The incident was not documented in
TVA work orders.
After receiving information from the NRC about this issue, the applicant initiated PER
83861 to address this concern. TVA removed the suspect anchor bolts associated with
WO 111335067 and confirmed damage to rebar in three locations. As part of the extent
of condition evaluation, TVA reviewed a list of WOs performed by the same individuals.
TVA determined that rebar was also damaged in two locations associated with WO 111335073. Each were evaluated by Engineering and determined not to require repair
due to safety margin designed into the walls being enough to accept the damage. In
addition, TVA also accepted possible damage to 25 other locations as a conservative
measure even though there is no evidence that damage has occurred. This is because if
TVA excavated these and there was evidence of damage, the engineering disposition
would be to accept the damage without repair, thus the repair effort would not provide
any safety benefit.
52
The inspectors determined that the failure to follow anchor bolt installation procedures
was a performance deficiency. The performance deficiency is considered to be more
than minor in accordance with IMC 2517 because it represents an inadequate work
process that if left uncorrected, could adversely affect the quality of the construction,
testing, analysis, or records of a safety-related SSC. Specifically, unreported or
unanalyzed damage to reinforcing bar could adversely affect the quality of construction
of a safety-related SSC. The inspectors reviewed this finding against cross-cutting area
components as described in IMC 0310, Components Within the Cross-Cutting Areas
and determined that no cross-cutting aspect applied.
Enforcement: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings, requires that activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appropriate to the circumstances and
shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative
acceptance criteria for determining that important activities have been satisfactorily
accomplished.
TVA Procedure MAI-5.1B, Wedge Bolt (WB) Anchor Installation, Revision 21, is the
implementing/controlling process for anchor bolt installation, and includes the
requirements for drilling the hole to be used for anchor bolt installation.
MAI-5.1B, Revision 21, Section 6.2.5.A.3, states that unless specifically permitted,
reinforcing steel shall not be cut or drilled to install anchors. Site Engineering approval is
required to drill through the reinforcing bar.
Contrary to the above, on or about December 1, 2011, contract employees assigned to
drill holes for anchor bolt installation willfully drilled into the reinforcing steel of the steam
generator housing, a safety-related structure, without notifying Site Engineering, or
obtaining their approval as required by TVA Procedure MAI-5.1B. Specifically, the
contract employees damaged reinforcing steel in at least five locations associated with
holes drilled under work order 111335067 and work order 111335073.
As discussed in the NRC Enforcement Policy, willful violations are a particular concern
to the NRC. In this case, the NRC concluded that the actions of the pipefitters were
willful. In reaching this conclusion, the NRC noted that during transcribed interviews with
NRCs OI representatives, both individuals involved were trained in the anchor bolt
installation procedures and did not lack an understanding or knowledge of the
procedure. The involved individuals acted deliberately when they violated the procedure
to drill into rebar.
In consideration of the fact that the individuals were craft laborers with no supervisory
responsibilities, and that the damage to the structure was evaluated and determined not
to require repair, the NRC concluded that this violation should be characterized at
Severity Level IV. Furthermore, because this violation was not the result of an isolated
action of one employee, and was not identified by the applicant, the non-cited violation
criteria of paragraph 2.3.2.a.4.(a) and (c) were not satisfied, such that this violation will
be cited.
53
This is identified as violation (VIO)05000391/2015604-02, Failure to Follow Anchor Bolt
Installation Procedure.
c. Conclusions
Further inspection of this issue will be required after receipt of the applicants written
response to the NOV.
V. MANAGEMENT MEETINGS
X1 Exit Meeting Summary
An exit meeting was conducted on May 28, 2015, to present inspection results to you
and other members of your staff. Further discussion was conducted on June 19, 2015,
with Mr. ODell. The inspectors identified that no proprietary information had been
received during the inspection and none would be used in the inspection report. The
applicant acknowledged the observations and provided no dissenting comments.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Applicant personnel
A. Bangalore, Bechtel - Electrical Engineer
D. Blaylock, Bechtel
T. Blount, Bechtel - Field Engineer
C. Boudreaux, Startup Testing Engineer - TVA
M. Bowman, Electrical Engineer - TVA
J. Calle, TVA - Dual Unit Transition Manager
G. Carroll, TVA - Engineering
D. Colvin, Bechtel
C. Deblok, TVA - WBN2 Surveillance Program Coordinator
M. Dick, Bechtel
M. Griger, Crane Nuclear Services
A. Hasty, Bechtel
M. Hennessy, Bechtel
S. Hilmes, TVA - Electrical Engineer
J. Kepler, TVA - Engineering Group Supervisor
T. Lund, TVA - Engineering
K. McCormack, Startup Testing Engineer - TVA
S. Michael, Startup Testing Engineer - TVA
D. Myers, Senior QA Manager
J. Myers, Bechtel - Quality Assurance
J. ODell, TVA - Regulatory Compliance
G. Peterson, Electrical Engineer - Bechtel
L. Peterson, WBN2 Site Support Manager
R. Phipps, Bechtel - Test Engineer
G. Scott, TVA - Licensing
D. Shutt, TVA - Licensing
M. Skaggs, TVA - Senior Vice President
T. Wallace, WBN2 Senior Manager Operations Unit 2 Construction
T. Womack, Electrical Engineer - TVA
O. J. Zeringue, TVA - General Manager Engineering and Construction
Attachment
2
INSPECTION PROCEDURES USED
IP 35007 Quality Assurance Program Implementation During Construction and
Pre-Construction Activities
IP 35743 QA Program (Maintenance)
IP 35745 QA Program (Surveillance Testing and Calibration Control)
IP 35746 QA Program (Procurement Control)
IP 37051 Verification of As-Builts
IP 46053 Structural Concrete Work Observation
IP 50053 Reactor Vessel and Internals Work Observation
IP 51053 Electrical Components and Systems - Work Observation
IP 70300 Preoperational Test Procedure Review
IP 70302 Preoperational Test Program Implementation
IP 70312 Preoperational Test Witnessing
IP 70338 Auxilliary Feedwater System Test- Preoperational Test Procedure Review
IP 70433 Chemical Control System Test - Preoperational Test Witnessing
IP 70343 Containment Spray System Test- Preoperational Test Procedure Review
IP 70438 Auxiliary Feedwater System Test - Preoperational Test Witnessing
IP 70439 Component Cooling Water System Test - Preoperational Test Witnessing
IP 70443 Containment Spray System Test - Preoperational Test Witnessing
IP 70562 Reactor Coolant System Hydrostatic Test Results Evaluation
IP 71302 Preoperational Test Program Implementation Verification
IP 73051 Inservice Inspection - Review of Program
IP 73052 Inservice Inspection - Review of Procedures
IP 73053 Preservice Inspection - Observation of Work and Work Activities
IP 80210 Environmental Inspection-Periodic
IP 92701 Followup
TI 2512/020 Inspection of Watts Bar Nuclear Plant - Electrical Issues Corrective
Action Program Plan
TI 2515/109 Safety Related MOV Testing and Surveillance
TI 2515/110 Performance of Safety-Related Check Valves
TI 2515/114 Inspection Requirements for Generic Letter 89-04, Acceptable Inservice
Testing Programs
TI 2515/166 Containment Sump Blockage
TI 2515/191 Inspection of the Licensee's Responses to Mitigation Strategies Order
EA-12-049, Spent Fuel Pool Instrumentation Order EA-12-051 and
Emergency Preparedness Information Requested in NRC March 12, 2012
3
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000391/2015604- VIO Failure to Follow Anchor Bolt Installation Procedure
02 (Section OA.1.12)
Opened and Closed
05000391/2015604- CIF Failure to Comply with Conduct of Maintenance -
01 Expectations and Standards (Section C.1.1)
Closed
46053 IP Structural Concrete Work Observation (Section C.1.3)
37051 IP Verification of As-Builts (Section C.1.4)
80210 IP Environmental Inspection-Periodic (Section C.1.5)
73051 IP Inservice Inspection Review of Program (Section
C.1.6)
73052 IP Inservice Inspection Review of Procedures (Section
C.1.6)
73053 IP Preservice Inspection - Observation of Work and Work
Activities (Section C.1.6)
70338 IP Auxilliary Feedwater System Test- Preoperational Test
Procedure Review (Section P.1.2)
70343 IP Containment Spray System Test- Preoperational Test
Procedure Review (Section P.1.2)
70562 IP Reactor Coolant System Hydrostatic Test Results
Evaluation (Section P.1.11)
35746 IP Quality Assurance Program - Procurement Control
(Section O.1.1)
35743 IP Quality Assurance Program - Maintenance (Section
O.1.2)
35745 IP Quality Assurance Program - Surveillance Testing and
Calibration Control (Section O.1.3)
2515/191 TI Followup on Fukushima Orders for Watts Bar and
Inspection of the Licensee's Responses to Mitigation
Strategies Order EA-12-049, Spent Fuel Pool
Instrumentation Order EA-12-051 and Emergency
4
Preparedness Information Requested in NRC March
12, 2012 (Section OA.1.5)
II.D.3 TMI Action Direct Indication of Relief-and Safety-Valve Position
Item (Section OA.1.7)
Open Item 74 SSER Installation of the Acoustic Monitoring System for the
Appendix HH Power Operated Relief Valves (Section OA.1.7)
79-36 GL Adequacy of Station Electric Distribution System
Voltages (Section OA.1.8)
05000391/2014614- URI Potential Failure To Comply With 10 CFR 50.55a and
01 Properly Implement the Scope of the ASME OM Code
(Section OA.1.9)
I.C.7 TMI Action Nuclear Steam Supply System Vendor Review of
Item Procedures (Section OA.1.10)
05000391/2015603- URI Boric Acid Tank C Design Control (Section OA.1.11)
04
Discussed
2512/020 TI Electrical Issues CAP - Sub-issue: Cable Separation
and Electrical Isolation (Section OA.1.1)
391/89-08 CDR Kapton Insulated Pigtail Insulation Damage (Section
OA.1.2)
1989-10 GL Safety Related Motor Operated Valve Testing and
Surveillance (Section OA.1.3)
2515/109 TI Safety Related Motor Operated Valve Testing and
Surveillance (Section OA.1.3)
2004-02 GL Potential Impact of Debris Blockage on Emergency
Recirculation during Design Basis Accidents at
Pressurized-Water Reactors and Pressurized Water
Reactor Containment Sump Blockage (Section
OA.1.4)
2006-02 GL Grid Reliability and the Impact on Plant Risk and the
Operability of Offsite Power (Section OA.1.6)
5
LIST OF DOCUMENTS REVIEWED
II. MANAGEMENT OVERSIGHT AND CONTROLS
C.1 Construction Activities
C.1.3 Structural Concrete Work Observation
Calculations
WCG-2-301, Temporary Construction Opening in Slab at El. 729-0 in Unit 2 Auxiliary Building,
Rev.3
Drawings
2-48W895-1, Concrete El. 729.0 Construction Opening Closure, Rev. 0
2-48W1210-41. Misc. Steel Surface Mounted Plates Elevations, Section & Details, El. 763.5,
Rev 2.
Procedures
0-TI-119, Maintenance Rule Performance Indicator Monitoring, Trending, and Reporting -
10CFR50.65, Rev. 1
0-TI-445, Examination of Structures for Maintenance Rule, Rev.2
25402-3DP-G04G-00090, Engineering Department Procedure Instruction, Engineering
Evaluation for Commodity Refurbishment, Rev. 9
Miscellaneous
DCN 55050, ABSCE Boundary, Rev. 1
C.1.4 Verification of As-Builts
Drawings
Final Assembly CRDM Air Cooling Unit, 30396, Rev. B
Miscellaneous Steel Tank & Equipment Supports, 48N1231-1, Rev. 20
Miscellaneous Steel Tank & Equipment Supports, 48N1231-2, Rev. 18
TDAFW Supply, 2-47W427-205 R2
TDAFW Discharge, 2-47W401-212 R2
TDAFW Discharge, 2-47W427-208 R2
TDAFW Supply, WBN-E-2882-IC-113 R5
TDAFW Discharge, WBN-E-2882-IC-101 R4
ASME Code Data Reports:
NPV-1, 2-CKV-003-810B
NPV-1, 2-CKV-003-864
NPV-1, 2-FCV-003-0136A
NPV-1, 2-FCV-003-0136B
NPV-1, 2-FCV-003-0179A
NPV-1, 2-FCV-003-0179B
NPP-1, 03B-AF-2
Pipe Supports:
DRA 52433, 03B-2AFW-R029
DRA 52433, 03B-2AFW-R032
6
DRA 52433, 03B-2AFW-R044
DRA 52433, 03B-2AFW-V047
P.1 Preoperational Activities
P.1.1 Preoperational Test Program Implementation Verification
WO 112645542 - 2-SI-70-702, Containment Isolation Valve Local Leak Rate Test Component
Cooling
WO 114675788 - SUT System 70 WBN-1-FCV-070-0153-B Land OPL6888B
WO 114806910 - Perform 2-PTI-072-01, Rev. 1
P.1.2 Preoperational Test Procedure Review
Drawing:
2-47W803-2; Flow Diagram Auxiliary Feedwater System; Rev. 31
2-47W812-1, Flow Diagram Containment Spray System, Rev. 26
2-45W760-72-1, Wiring Diagrams Containment Spray System Schematic Diagram, Rev. 9
2-45W760-72-2, Wiring Diagrams Containment Spray System Schematic Diagram, Rev. 8
2-45W760-72-3, Wiring Diagrams Containment Spray System Schematic Diagram, Rev. 5
2-45W760-72-4, Wiring Diagrams Containment Spray System Schematic Diagram, Rev. 5
Procedures:
2-PTI-003B-05, Auxiliary Feedwater System Dynamic Test, Rev. 1
2-PTI-003B-04, Auxiliary Feedwater Pumps & Valves Logic Test, Rev. 0 and 1
2-PTI-072-01, Containment Spray Pump Valves Logic Test, Rev. 0 and 1
2-PTI-074-01, Residual Heat Removal System Pump/Valves Logic, Rev. 1
Test Scoping Documents:
2-TSD-3B-5; Auxiliary Feedwater System Pumps Rev. 5
2-TSD-72-1, Containment Heat Removal Spray System Rev. 4
2-TSD-74-1, Residual Heat Removal System Component Testing, Rev. 3
System Descriptions:
WBN2-3B-4002; Auxiliary Feedwater System; Rev. 2
WBN2-74-4001 System Description for Residual Heat Removal System, Rev. 5
WBN2-72-4001 System Description for Containment Heat Removal Spray System, Rev. 3
P.1.11 Preoperational Test Results Evaluation
Report:
Unit 2 Cold Hydro Summary Report 2-PTI-068-14, Revision 1 dated January 15, 2015
III. OPERATIONAL READINESS ACTIVITIES
O.1.1 Quality Assurance Program - Procurement Control (IP 35746)
Specifications
NESSD 2-02-070-130B-B, NE Setpoint and Scaling Document, Rev.0
NESSD 2-F-63-91B, NE Setpoint and Scaling Document, Rev. 0
NESSD, 2-PD-3-132C, NE Setpoint and Scaling Document, Rev. 0
WBN-VTM-D232-0050, Dragon Valves, Rev. 20
7
WBN-VTM-W120-5019, Common Q System Requirement Specification, Rev. 0
Drawings
45N2641-9, Control Board Panel 2-M-1 and 2-M-2, Rev. 9
45N2642-4, Unit Control Board Panel 2-M-3, Rev. 12
47W427-231, AFW Pump Turbine Steam Supply Loops 1 & 4 Mainsteam Lines to Turbine &
Exhaust From Turbine to Atmosphere, Rev. 5
47W610-68-8, Reactor Coolant System, Rev 10
47W610-68-9, Reactor Coolant System, Rev. 8
Misc.
FSAR Change Sections 5.5-15a & 5.5-15b, EDCR 55707, Amendment 100, dated 08/02/2010
FSAR Change, Section 10.4.7.1, EDCR 53876, Amendment 97, dated 01/07/2010
FSAR Change Section 11.4, EDCR-2 52340, Amendment 95, dated Nov. 24, 2009
Procedures
0-TI-02, Criteria for Issuing Engineering Document Construction Releases (EDCR) Potentially
Impacting WBN Unit 0 and/or Unit 1 Design, Rev. 0005
2-AOI-7.05, Flood Mode Cold Leg Accumulator Venting and Filling, Rev. 0000B
2-AOI-20, Malfunction of Reactor Control System, Rev. 0000A
2-SI-3-66, 18 Month Channel Calibration of Post Accident/ Remote Shutdown Monitoring AFW
Loop 2-LPF-3-170A, Rev. 0001
2-TMI-30.127, Calibration of Annulus Differential Pressure/AB EGTS Air Difference Purge, Rev.
0000A
25402-ADM-0001, Watts Bar Nuclear Plant Unit 2 Construction Completion Project, Document
Control, Rev. 14
NC PP-10, Watts Bar Nuclear Plant Unit 2 Changes to Final Safety Analysis Report, Technical
Specifications (TS), TS Bases, Technical Requirements Manual (TRM) and TRM Bases,
Rev. 5
NPG-SPP-31.0, Procedures and Document Control, Rev. 0002
NPG-SPP-31.1, Document Control, Rev. 0003
NPG-SPP-31.2, Records management, Rev. 0004
0-TI-441, Operational Readiness Process for Unit 2 Systems, Rev. 0002
25402-3DP-G04G-0081, WBN2 Construction Completion Project, Engineering Document
Construction Release, Rev. 020
NC-PP-37, System Turnover to Operations, Rev. 0001
NPG-SPP-01.2, Administration of Site Technical Procedures, Rev. 0008 and Rev. 011
SMP-4.0, Watts Bar Nuclear Plant Unit 2 System Completion and Turnover, Rev. 0014
TVA-NPG-PLN89-A, Nuclear Quality Assurance Plan (NQAP) (Quality Assurance Program
Description), Rev. 0030
Watts Bar Unit 2 Construction Completion Project, Bechtel Project Nuclear Quality Assurance
Manual, Rev. 1
O.1.2 Quality Assurance Program - Maintenance (IP 35743)
Preventative Maintenance (PMs) and PM Work Instructions
620610032, Glycol Supply Header Bypass Check Valve Inspection and Rebuild in accordance
with 0-MI-0.007 and Attachment A, MEQ Required (>40Y), ACTIVE
620610034, Glycol Cooled Floor Supply Bypass Check Valve Inspection and Rebuild in
accordance with 0-MI-0.007 and Attachment A, MEQ Required (>40 Y), ACTIVE
620610043, 2-CKV-061-0684, Glycol Cooled Floor Pump 2A Discharge Check Valve, Rebuild
Check Valve, in accordance with 0-MI-0.017 and Attachment A, ACTIVE
8
620610044, 2-CKV-061-0748, Glycol Cooled Floor Pump 2B Discharge Check Valve, Rebuild
Check Valve, in accordance with 0-MI-0.017 and Attachment A, ACTIVE
620720030, WBN-2-MVOP-072-0002-B, Containment Spray Header B Isolation Valve Operator,
Perform the routine inspection and maintenance of a Limitorque Motor Actuator in
accordance with Master PM M1380V and Attachment A, ACTIVE
620720031, 2-MVOP-072-0021-B, Radwaste to Spray Header B Flow Control Valve, Perform
the routine inspection and maintenance of a Limitorque Motor Actuator in accordance with
Master PM M1380V and Attachment A.
Procedures
25402-000-GPP-0000-N2303, Watts Bar Nuclear Plant Unit 2 Construction Completion Project,
Construction Equipment Maintenance, Rev. 0
NC-PI-5, Watts Bar Nuclear Plant Unit 2 Instruction Validation, Rev. 0005
NC PP-28, Watts Bar Unit 2, PM Project, Procedure Review and Approval, Rev. 001
NC-PP-32, Watts Bar Nuclear Plant Unit 2 Development and Issue of Operating and Technical
Instructions, Rev.0006
NPG-SPP-06.2, Preventive Maintenance, Rev. 0010
25402-000-GPP-0000-N2303, Watts Bar Nuclear Plant Unit 2 Construction Completion Project,
Construction Equipment Maintenance, Rev. 0
TI-434, Power Ascension Testing
O.1.3 Quality Assurance Program - Surveillance Testing and Calibration Control (IP 35745)
Surveillances
2-SI-0-24, Measurement of the At-Power Moderator Temperature Coefficient, Rev .1
2-SI-32-901-A, Valve Full Stroke Exercising During Cold Shutdown Control Air (Train A), Rev. 3
2-SI-57-1-B, 18 Month Unit 2 B Train ESF Load Sequence and Reset Timer Test, Rev. 11
2-SI-61-1, Determination of Boron and Ph on Ice Condenser Ice, Rev. 2
2-SI-61-901-B, Valve Full Stroke Exercising During Plant Operation Ice Condenser System
(Train B), Rev. 1
2-SI-62-901-A, Centrifugal Charging Pump 2A-A Quarterly Performance Test, Rev. 1
2-SI-63-1, 18 Month Channel Calibration Cont. Sump Lvl Channel I, LP-63-180 (L-920), Rev. 3
2-SI-63-5, RWST Boron Determination, Rev. 0
2-SI-63-7, ECCS Throttle Valve Position Verification, Rev. 1
2-SI-63-10-B, ECCS Pumps Venting Train B, Rev. 1
2-SI-63-907, RHR Hot Leg and Cold Leg Injection Check Valve Testing During Refueling
Outages, Rev. 1
2-SI-63-917, Testing of Cold Leg Accumulator Check Valves, Rev. 0
2-SI-65-9-A, 18 Month Emergency Gas Treatment System Pressure Test - Train A Rev. 0
2-SI-67-61, 18 Month Channel Calibration Remote Shutdown Monitoring ERCW Supply Header
B Flow Loop 2-LPF-67-62C, Rev. 8
2-SI-68-24, Verification of Reactor Subcriticality for 100 Hours Before Movement of Irradiated
Fuel, Rev. 0
2-SI-68-110, 184 Day Channel Operational Test Pressurizer Level Channel II Loop 2-LPL-68-
320 (L-461), Rev. 0
2-SI-70-62, 18 Month Channel Calibration Remote Shutdown Monitor RHR Heat Exchanger 2B-
B Supply Header Flow Loop 2-LPF-70-165C, Rev. 1
2-SI-72-1-B, Air Test of Containment Spray Nozzles Train B, Rev. 1
2-SI-72-901-B, Containment Spray Pump 2B-B Quarterly Performance Test, Rev. 1
2-SI-74-63-B, 18 Month Channel Calibration Remote Shutdown Control RHR Heat Exchanger B
Outlet Flow Loop 2-LPF-74-28, Rev. 1
2-SI-74-902-A, Quarterly Valve Full Stroke Exercising - RHR System (Train A), Rev. 1
9
2-SI-99-643-B, Response Time Test Containment Spray Slave Relay K643 Train B, Rev. 0
Preventative Maintenance (PMs) and PM Work Instructions
620720020, 2-PI-72-33, Containment Spray Pump '2A-A' Suction Pressure Indicator Calibration
in accordance with 0-IMI-201 and SSD-2-PI-72-33, ACTIVE
620810014, PM 620810014: 2-LPL-081-0001, (Primary Water Storage Tank Level), Perform
Loop Calibration in accordance with SSD-2-LPL-81-1 and IMI-200, ACTIVE
620720019, 2-PI-72-16, Containment Spray Pump '2B-B' Suction Pressure Indicator Calibration
in accordance with 0-IMI-201 and SSD-2-PI-72-16, ACTIVE
620720022, WBN-2-LPF-072-0013-G, Containment Spray Pump '2B' Flow Loop Calibration in
accordance with 2-IMI-72.013 (Channel Calibration Containment Spray Header B Flow Loop
2-LPF-72-13) (F-999), ACTIVE
620720027, 2-LPT-72-31 - Containment Spray Heat Exchanger '2A-A' Outlet Temperature Loop
Calibration, ACTIVE
620610013, 2-TIS-61-99A/B, Temp Ind. Switch on Glycol Supply to Floor Cooler, Perform
Switch Cal per 0-IMI-200, AND SSD 2-TIS-61-99A/B, ACTIVE
IV. OTHER ACTIVITES
OA.1.1 Electrical Issues CAP - Sub-issue: Cable Separation and Electrical Isolation
Miscellaneous:
WB-DC-30-4 Revision R22 WATTS BAR NUCLEAR PLANT UNIT 1/UNIT 2
SEPARATION/ISOLATION, dated: 7/3/2008
Drawing Revision Authorization (DRA) 55125-23, Drawing Number 45W874-4 Rev. 31, dated:
5/16/2014
Drawing Revision Authorization (DRA) 55125-24, Drawing Number 45W874-4 Rev. 31, dated:
4/23/2014
Drawing Revision Authorization (DRA) 55125-29, Drawing Number 45W872-10 Rev. 36, dated:
5/26/2010
Drawing Revision Authorization (DRA) 55125-042, Drawing Number 45W826-9 Rev. 53, dated:
4/23/2014
Drawing Revision Authorization (DRA) 55125-053, Drawing Number 45W826-37 Rev. 31,
dated: 4/23/2014
Drawing Revision Authorization (DRA) 55125-069, Drawing Number 45W826-25 Rev. 7, dated:
4/23/2014
Drawing Revision Authorization (DRA) 55125-121, Drawing Number 45W872-10 Rev. 36,
dated: 5/26/2010
Drawing Revision Authorization (DRA) 55125-139, Drawing Number 45W828-9 Rev. 31, dated:
11/30/2012
Drawing Revision Authorization (DRA) 55125-140, Drawing Number 45W828-9 Rev. 31, dated:
11/30/2012
Drawing Revision Authorization (DRA) 55125-157, Drawing Number 45W826-8 Rev. 57, dated:
2/13/2013
Drawing Revision Authorization (DRA) 55125-158, Drawing Number 45W828-7 Rev. 40, dated:
2/13/2013
Work Orders:
WO# 113325343 - CCE BC COND PER 366694 PER 224892 EDCR2 52938 55125 55233 SYS
030 293 2VC2039A 2VC2041A 2VC2042A, dated: 4/14/2015
WO# 114955552 - CCE BC CONDUIT EDCR2 55125 52938 SYS 03 068 285 293 WBN-2-
MISC-293 2PM6396G, dated: 4/14/2015
10
WO# 113427588 - CCE BC PER 366694 CONDUIT BC0716R56 EDCR 55125 SYSTEM 068
293 WBN-2-MISC-293 2VC4432B, dated: 4/14/2015
WO# 111123610 - CCE EDCR2 55125 SYS 068 001 099 0275 043 003 030 090 070 285 072
067 065 292 2-MISC-292, dated: 4/14/2015
WO# 111504205 - CCE SYS 292 067 070 074 WBN-0-XSW-070-0051-S, dated: 5/28/2014
WO# 114216892 - CCE BC CONDUIT PER 224748 EDCR2 54636 55125 54632 55523 55233
SYSTEM 068 099 275 285 292 WBN-2, dated: 5/28/2014
WO# 114955061 - CCE BC CONDUIT EDCR2 55125 SYS 068 292 WBN-2-MISC-292
2PS703E, dated: 4/14/2015
OA.1.2 Construction Deficiency Report (CDR) 05000391/89-08: Kapton Insulated Pigtail
Insulation Damage
Work Orders
WO 115788202, CCE EDCR 54918 PER 766444 SYS 293 2-PENT-293-0008-A (inboard)
WO 115788149, CCE EDCR 54918 PER 766444 SYS 293 2-PENT-293-0038-D (outboard)
WO 115788453, CCE EDCR 54918 PER 766444 SYS 293 2-PENT-293-0038-D (inboard)
OA.1.3 Generic Letter 89-10: Safety Related Motor Operated Valve Testing and
Surveillance
Calculations
MDQ0020632008-0233, Documentation of Design Basis Review, Required Thrust/Torque
Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-63-006,
revision 007
MDQ0020632008-0234, Documentation of Design Basis Review, Required Thrust/Torque
Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-63-007,
revision 006
MDQ0020632008-0235, Documentation of Design Basis Review, Required Thrust/Torque
Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-63-008,
revision 007
MDQ0020632008-0236, Documentation of Design Basis Review, Required Thrust/Torque
Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-63-011,
revision 007
MDQ0020632008-0240, Documentation of Design Basis Review, Required Thrust/Torque
Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-63-0047,
revision 004
Work Orders
114900446
114900454
114900744
114900755
114976204
114976208
Training Records
Selected Personnel Training Records for MOVATS Test Equipment setup/hookup to MOV
Actuator
Crane Nuclear Representative Diagnostic Test Engineer and Diagnostic Test Technician
qualification record
Miscellaneous
0-MI-0.006, MOVATS Testing of Motor Operated Valves, revision 5 dated 09/09/2014
11
2-TI-85.009, Dynamic Test of Safety Injection Pump Suction and Associated ECCS Motor
Operated Valves
OA.1.4 Generic Letter 2004-02 - Potential Impact of Debris Blockage on Emergency
Recirculation during Design Basis Accidents at Pressurized-Water Reactors and
Pressurized Water Reactor Containment Sump Blockage
Work Orders
111606951, Installation of Containment-Sump Strainer Assembly
111083539, Installation of Plenum for Containment-sump Strainer Assembly
111627598, Installation of I-Beam Supports for Containment-Sump Strainer Assembly
Purchase Order
69810
Procedures
MAI-5.1B, Wedge Bolt Anchor Installation
EDCR
53580, Containment Sump Strainer Installation
Drawings
SFS-WB2-GA-00, General Arrangement, Rev. 0
SFS-WB2-GA-01, General Notes, Rev. 2
SFS-WB2-GA-03, General Arrangement, Rev, 0
SFS-WB2-GA-04, General Arrangement, Rev. 0
SFS-WB2-GA-10, General Arrangement - Top Cover, Rev. 3
SFS-WB2-PA-7100, Module Assembly 6 Disk, Rev. 0
SFS-WB2-PA-7101, Module Assembly 7 Disk, Rev. 2
SFS-WB2-PA-7151, Lower Deck, Rev. 0
SFS-WB2-PA-7156, Support Beams-Anchor Mounting Details, Rev. 0
OA.1.7 Three Mile Island Action Item II.D.3 - Direct Indication of Relief-and Safety-Valve
Position and Supplemental Safety Evaluation Report Appendix HH Item 074:
Installation of the Acoustic monitoring system for the Power Operated Relief Valves
Work Orders:
WO#116574299 Start-up Testing for system 068 2 Tank 068 Pressure Relief Tank, Dated:
3/11/2015
WO#113474274 CCE EDCR 55174 SYS 068 PER 595068 CT#2M2762 WBN-2-@W-068-2762,
dated: 11/26/2013
WO#114624225 CCE EDCR 55174, 55006, 54154, 55233 SYS 068 293 BC Cable
Terminations, dated: 2/5/2014
WO#114874716 WIL PER 876407 EDCR2 53760, 55174 SYS 068 293 BC Cable Terminations,
dated: 4/25//2014
WO#114877483 CCE EDCR 55174, 55006 FCR 62387, 59368 SYS 068 293 BC Cable
Terminations, dated: 11/23/2013.
Drawings:
FLOW DIAGRAM REACTOR COOLANT SYSTEM, 2-47W813-1 R33, dated: 09/14/09
ELECTRICAL LAYOUT OF CONTROL BOARD PANEL 0-M-4, 2-47W605-53 R3, dated:
04/08/13
12
ELECTRICAL LAYOUT OF CONTROL BOARD PANEL 0-M-25, 0-47W605-162 R0, dated:
03/11/14
NAMEPLATE TABULATION CONTROL PANEL 0-M-25, 1-47W605-164 R2, dated: 06/14/01
ELECTRICAL CONTROL DIAGRAM REACTOR COOLANT SYSTEM, 2-47W610-68-6 R9,
dated: 10/09/08
ELECTRICAL INSTRUMENTS AND CONTROLS, 2-47W600-44 R3, dated: 10/06/08
Miscellaneous:
WBN-VTD-T068-0020 General Description and Specifications for TEC 1414 Valve Flow Monitor
System, Rev. 1, dated: 1/4/1995.
OA.1.8 Generic Letter 79-36, Adequacy of Station Electric Distribution System Voltages
Calculations:
EDQ00099920080014 Rev. 23, Appendix A - Diesel Generator Load List (Loading and Starting
Times)
EDQ00099920070002 Rev. 43, AC Auxiliary Power System Analysis, dated 12/16/2014
EDQ00299920080003 Rev 11, Class 1E MCC Control Circuit Voltage Analysis and Transformer
Sizing, dated: 8/4/2014
WBNEEBMSTI060029 Rev 37, Degarded Voltage Analysis, dated: 10/15/2014
WBPE2119202001 Rev 11, 6.9kV Shutdown & Logic Boards Undervolatge Relays Requirement
/ Demonstrated Accuracy Calculation, Dated: 10/25/2012
MDQ0020032008-0210 Rev 004, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
03-116A, Dated: 3/16/2015
MDQ0020032008-0213 Rev 003, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
03-126B, Dated: 10/31/2014
MDQ0020032008-0215 Rev 003, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
03-136B, Dated: 4/23/2014
MDQ0020622008-0228 Rev 002, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
62-138, Dated: 2/22/2014
MDQ0020632008-0229 Rev 003, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
63-001, Dated: 1/15/2014
MDQ0020632008-0230 Rev 003, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
63-003, Dated: 3/14/2014
MDQ0020632008-0240 Rev 003, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
63-047, Dated: 3/14/2014
MDQ0020672008-0259 Rev 003, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
67-097, Dated: 6/24/2014
MDQ0020672008-0267 Rev 003, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
67-113, Dated: 7/7/2014
MDQ0020722008-0290 Rev 004, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
72-021, Dated: 4/4/2014
13
MDQ0020722008-0295 Rev 004, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
72-41, Dated: 2/11/2015
MDQ0020742008-0300 Rev 003, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
74-003, Dated: 6/24/2014
MDQ0020742008-0304 Rev 003, Documentation of Design Basis Review, Required
Thrust/Torque Calculations and Valve and Actuator Capability Assessment for Valve 2-FCV-
74-021, Dated: 6/24/2014
MDQ0029992009-0310 Rev 007, Generic Letter 89-10 MOV Population for Watts Bar (Unit 2),
Dated: 12/29/2014
Miscellaneous:
TVA Electrical Engineering / Electrical Design Guide DG-E2.4.6, dated: 12/09/1994
TVA Design Criteria WB-DC-30-28 Low and Medium Voltage Power Systems - Unit 1 / Unit 2,
dated: 9/11/2012
Problem Evaluation Report (PER) #1016375 - NRC Identified updates to Unit 1 Calculations,
dated 4/21/2015.
Problem Evaluation Report (PER) #1016464 - NRC Identified updates to Unit 2 Calculations,
dated 5/5/2015.
Limitorque Maintenance Update 92-01 (NER No. 92 0380), dated: 10/15/1992
Limitorque Maintenance Update 92-02, transmitted on date: 1/13/1993
Unit 0 Surveillance Instruction 0-SI-82-3, 18 Month Loss of Offsite Power with Safety Injection -
Unit 1 Surveillance Instruction 0-SI-82-4, 18 Month Loss of Offsite Power with Safety Injection -
Unit 2 Surveillance Instruction 0-SI-82-5, 18 Month Loss of Offsite Power with Safety Injection -
Unit 2 Surveillance Instruction 0-SI-82-6, 18 Month Loss of Offsite Power with Safety Injection -
Service Request SR#1013555 - NRC Identified updates to Unit 1 and Unit 2 Calculations, dated
4/16/2015.
Limitorque Technical Update 93-03, Reliance 3-phase Limitorque Corporation Actuator Motors
(Starting Torque @ Elevated Temperature), dated: 9/17/1993
Analysis Print of test for valve 2-063-0001-A (14 Gate Valve), dated 4/8/2015
Limitorque Motors Bulletin - calc. no. EDQO-248-2002-0042, Rev. 0
TVA Branch Technical Instruction - Setpoint Calculations BTI-EEB-TI-28 Rev. 0011, dated:
12/31/2014
TVA Electrical Design Guide DG-E2.4.6 R2 Equipment Typical Data, dated: 12/9/1994
Engineering and Materials Setpoint and Scaling Document SSD Number: 2-27-211-DAT-A Rev.
1 dated: 3/15/2002.
Engineering and Materials Setpoint and Scaling Document SSD Number: 2-27-211-DAT-B Rev.
1 dated: 3/15/2002.
Engineering and Materials Setpoint and Scaling Document SSD Number: 2-27-211-DBT-A Rev.
1 dated: 3/15/2002.
Engineering and Materials Setpoint and Scaling Document SSD Number: 2-27-211-DBT-B Rev.
1 dated: 3/15/2002.
Engineering and Materials Setpoint and Scaling Document SSD Number: 2-27-211-DCT-A Rev.
1 dated: 3/15/2002.
Engineering and Materials Setpoint and Scaling Document SSD Number: 2-27-211-DCT-B Rev.
1 dated: 3/15/2002.
Drawings:
14
1-45W760-212-4, R24 Unit 1 & 2, Wiring Diagrams 480V Shutdown Power Schematic
Diagrams, date: 2-11-93.
1-45W760-212-4A, R10 Unit 1, Wiring Diagrams 480V Shutdown Power Schematic Diagrams,
date: 8-13-94.
2-45W760-212-4, R1 Unit 2, Wiring Diagrams 480V Shutdown Power Schematic Diagrams,
date: 1-29-13.
2-45W760-212-4A, R3 Unit 2, Wiring Diagrams 480V Shutdown Power Schematic Diagrams,
date: 5-11-15.
1-45W724-1, R28 Units 1 & 2, Wiring Diagrams 6900V Shutdowwn Board 1A-A Single Line,
original release date: 9-21-90.
1-45W751-1, R51, Unit 1, Wiring Diagrams 480V REAC MOV BDS 1A1-A Single Line SH-1,
original release date: 9-22-90.
1-45W751-7, R56, Unti 1, Wiring Diagrams 480V REAC MOV BDS 1B1-B Single Line SH-1,
original release date: 9-22-90.
2-45W751-1, R13, Unit 2, Wiring Diagrams 480V REAC MOV BD 2A1-A Single line SH-1,
dated: 3-17-15.
2-45W751-7, R13, Unit 2, Wiring Diagrams 480V REAC MOV BD 2B1-B Single line SH-1,
dated: 12-15-08.
1-45W756-1, R65, Unit 1, Wiring Diagrams 480V CONT & AUX BLDG VT BD 1A1-A Single Line
SH-1, original release date: 9-22-90.
1-45W756-1A, R2, Unit 2, Wiring Diagrams 480V CONT & AUX BLDG VT BD 2A1-A Single
Line SH-1, original release date: 8-8-11.
1-45W756-6, R78, Unit 1, Wiring Diagrams 480V CONT & AUX BLDG VT BD 1B1-B Single Line
SH-2, original release date: 9-22-90.
2-45W756-5, R2, Unit 2, Wiring Diagrams 480V CONT & AUX BLDG VT BD 2B1-B Single Line
SH-1, dated: 8-4-14.
OA.1.10 (Closed) Three Mile Island Action Item I.C.7 Nuclear Steam Supply System
Vendor Review of Procedures
Miscellaneous
Final Closure Package; Tracking Number: 114961176
Procedure
2-TI-439; Test Review Group (PORC Subcommittee Charter); Rev. 2
OA.1.11 URI 05000391/2015603-4, Boric Acid Tank C Design Control
Surveillances
1-IMI-62.242, Calibration of Boric Acid Tank C Level Loop 1-LPL-62-242-G (L-106), Rev. 06
2-IMI-62.242, Calibration of Boric Acid Tank C Level Loop 2-LPL-62-242-G (2L-106), Rev. 01
Calculations
CN-SUA-10-7, Watts Bar Unit 2 Boric Acid Tank Level SSD Supporting Calculation, Rev. 002
EPMPDM071197, Boric Acid Concentration Analysis for BAT and RWST, Rev. 008
ETNSLSSLWAT110, Eagle 21 Setpoint and Scaling Supporting Calculation Demonstrated
Accuracy Calculation, Rev. 40
Drawing
0-47W600-1006, Units 1 and 2 Electrical Instruments and Controls, Rev. 2
1682C30, Watts Bar Units 1 and 2 Boric Acid Tank, Sheet B7, Rev. 4
2-47W600-16, Unit 2 Electrical Instruments and Controls, Rev. 1
2-47W600-18, Unit 2 Electrical Instruments and Controls, Rev. 1
15
Specifications
SSD-2-L-62-242, NE Setpoint and Scaling Document, Rev. 3
SSD-1-L-62-242, NE Setpoint and Scaling Document, Rev. 4
Misc.
FSAR, Chapter 3, Reactivity Holddown Capability, dated 04/17/13
FSAR, Chapter 9, Boric Acid Tanks, dated 04/17/13
Technical Requirements (TR) 3.1.5, Borated Water Sources, Shutdown, Unit 1, Rev. 9, 33, 37
TR 3.1.6, Borated Water Sources, Operating, Unit 1, Rev. 9, 33
LIST OF ACRONYMS
ABSCE Auxiliary Building Secondary Containment Enclosure
ACL Acceptable Supplier List
ADAMS Agencywide Documents Access and Management System
ANII Authorized Nuclear Inservice Inspector
ASME American Society of Mechanical Engineers
B&PV Boiler and Pressure Vessel
BPVC Boiler and Pressure Vessel Code
CAP Corrective Action Program
CAQR Condition Adverse to Quality Report
CCS Component cooling system
CPSI Containment preservice inspection
CRI Control Room Isolation
CSS Containment spray system
CVCS Chemical and volume control system
ECCS Emergency core cooling system
EDCR Engineering Document Construction Releases
EOP Emergency Operating Procedure
ERCW Essential Raw Cooling Water
FSAR Final Safety Analysis Report
GL Generic Letter
HRRA High Radiation in Refueling Area
IEEE Institute of Electrical and Electronics Engineers
IR Inspection Report
IIR Integrated Inspection Report
IMC Inspection Manual Chapter (NRC)
IP Inspection Procedure (NRC)
IST In-Service Testing
JOG Joint Owners Group
LCO Limiting Condition of Operation
MOV Motor Operated Valve
NDE Non-Destructive Examination
NOV Notice of Violation
No. Number
NPG Nuclear Power Group
NPP Nuclear Performance Plan
NRC Nuclear Regulatory Commission
NSSS Nuclear Steam System Supply
OI Office of Investigations
OM Operation and Maintenance
PER Problem Evaluation Report
PMs Preventive maintenance activities
PORV Power Operated Relief Valve
PRT Pressurizer Relief Tank
PSI Preservice Inspection
PSO Power System Operator
PTI Preoperational Test Instruction
PTS Pressurized thermal shock
QA Quality Assurance
2
QC Quality Control
Rev. Revision
RG Regulatory Guide
ROP Reactor Oversight Process
RWST Refueling Water Storage Tanks
SER Safety Evaluation Report
SI Safety Injection
SIS Safety Injection System
SL Severity Level
SR Surveillance Requirement
SSC Structures, Systems, and Components
SSD Setpoint and Scaling Document
SSER Supplemental Safety Evaluation Report
TI Temporary Instruction (NRC)
TMI Three Mile Island (Nuclear Plant)
TRG Test review group
TS Technical Specifications
TVA Tennessee Valley Authority
URI Unresolved Item
U2 Unit 2
VIO Violation
WBN Watts Bar Nuclear Plant
WO Work Order 10 CFR Title 10 to the Code of Federal Regulations