ML15181A446

IR 05000391/2015604; 05/16/2015; Watts Bar Nuclear Plant Unit 2 Construction - NRC Integrated Report and Notice of Violation

ML15181A446
Person / Time
Site:	Watts Bar
Issue date:	06/29/2015
From:	Haag R C NRC/RGN-II/DCP/CPB3
To:	Skaggs M D 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

EA-15-075 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. O'Dell 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 Commission's 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 NRC's "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 NRC's 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)

M. Skaggs 2 In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRC's "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 NRC's 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) * Previous Concurrence PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE NON-SENSITIVE ADAMS: Yes ACCESSION NUMBER: ML15181A446 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICIAL RECORD COPY DOCUMENT NAME: G:\CCI\DCP\CPB3\WATTS BAR 2\CURRENT DRAFT INSPECTION REPORT\2015\IR 2015-604\Integrated IR 2015604 Final.docx 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: DCIRII:DCI SIGNATURE /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/ /RA via Email/ NAME J. Seat C. Even C. Cheung G. Crespo C. Julian C. Stanberry-SmithDATE 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: DCIRII: DCIRII: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. Gordon P. Arent

Director, Licensing Watts Bar Nuclear Plant Tennessee Valley Authority

P.O. Box 2000

Spring City, Tennessee 37381

Mr. O. J. Zeringue, General Manager Engineering and Construction WBN Unit Two

Watts Bar Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000 Spring City, Tennessee 37381

Mr. Paul Simmons, Vice President

WBN Unit Two Project

Watts Bar Nuclear Plant Tennessee Valley Authority P.O. Box 2000

Spring City Tennessee 37381

Mr. James O'Dell, Manager

Licensing and Industry Affairs WBN Nuclear Plant Tennessee Valley Authority

P.O. Box 2000

Spring City, Tennessee 37381

Mr. Joseph P. Grimes Chief Nuclear Officer

and Executive Vice President

Tennessee Valley Authority

1101 Market Place

3R Lookout Place Chattanooga, Tennessee 37402-2801

County Executive

375 Church Street

Suite 215 Dayton, Tennessee 37321

Mr. Sean Connors

Plant Manager, WBN Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000 Spring City, Tennessee 37381

Mr. R. R. Baron, Senior Manager Nuclear Construction Quality Assurance

WBN Unit Two Watts Bar Nuclear Plant Tennessee Valley Authority

P.O. Box 2000

Spring City, Tennessee 37381

Mr. Joseph Shea, Vice President Nuclear Licensing Tennessee Valley Authority

1101 Market Street

3R Lookout Place

Chattanooga, TN 37402-2801 Mr. E. J. Vigluicci

Assistant General Counsel

Tennessee Valley Authority

400 West Summit Hill Drive 6A West Tower Knoxville, Tennessee 37402

Mr. Lawrence E. Nanney, Director Tennessee Department of Environmental

Health & Conservation Division of Radiological Health 3rd Floor, L&C Annex

401 Church Street

Nashville, TN 37243-1532

Mr. Kevin Walsh Site Vice President

Watts Bar Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Spring City, Tennessee 37381 County Mayor

P.O. Box 156

Decatur, Tennessee 37322

Ms. Ann P. Harris Public

341 Swing Loop

Rockwood, TN 37854

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 J. Nadel, RII WBN Unit 1 SRI L. Chattin, RII

OE Mail

ConE_Resource@nrc.gov PUBLIC

Enclosure 1 NOTICE OF VIOLATION Tennessee Valley Authority Docket No. 50-391 Watts Bar Nuclear Plant - Unit 2 Construction Permit No. CPPR-92 Spring City, TN

EA-15-075

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.

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 NRC's 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

Enclosure 2 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

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 applicant's 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 applicant's 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) * The NRC identified a SL IV violation (VIO) of Title 10 to the Code of Federal Regulations (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

applicant's 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 applicant's 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 applicant's 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 applicant's 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 8'x4' and 4'x4' 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 TVA's 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.

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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 NRC's 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. ML13220A640) * 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. ML14086A063) * 05000391/2014603, Sections C.1.7 and E.1.1, (ADAMS Accession No. ML14129A381) * 05000391/2014604, Sections C.1.3 and OA.1.26, (ADAMS Accession No. ML14177A214) * 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. ML14322A182) * 05000391/2014614, Sections C.1.2 and C.1.3, (ADAMS Accession No. ML14363A315) * 05000391/2014615, Sections C.1.6 and OA.1.7, (ADAMS Accession No. ML15044A424)

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).

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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. ML13316A776).

In addition, during this inspection period, the inspectors compared final detailed construction drawings and specification requirements with the actual installation for

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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 pump 2B-B steel pedestal - Seismic Category 1 * RHR heat exchanger 2B steel brace - Seismic Category 1 * CS heat exchanger 2B steel brace - Seismic Category 1 * CS pump 2B-B room cooler steel support shelf - 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 applicant's 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 NRC's 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.

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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 applicant's

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 employer's 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

Approval * 05000391/2009604, Section C.1.11 * 05000391/2010602, Section C.1.16 * 05000391/2010604, Section C.1.11 * 05000391/2012602, Section C.1.5 * ML093030479 * ML101230144 * ML103060240 * ML12087A324

18

• 05000391/2013612, Section C.1.12* ML13088A066 02.02 Program Organization * 05000391/2009604, Section C.1.11* ML093030479 02.03 Quality Assurance Program * 05000391/2009604, Section C.1.11 * 05000391/2010602, Section C.1.16 * 05000391/2011608, Section C.1.12* ML093030479 * ML101230144 * ML11311A082 02.04 Repair Program * 05000391/2011605, Section C.1.10* ML112201418 02.05 Replacement Program * 05000391/2011605, Section C.1.10* ML112201418 02.06 Records * 05000391/2009604, Section C.1.11* ML093030479 02.07 Qualification of Personnel * 05000391/2009604, Section C.1.11* ML093030479 02.08 Reporting Requirements * 05000391/2009604, Section C.1.11* ML093030479 02.09 Relief Requests * 05000391/2009604, Section C.1.11 * 05000391/2010603, Section C.1.11* ML093030479 * ML102170465 IP 73052 Section Inspection Reports ADAMS Accession Number 02.01 Program

Requirements * 05000391/2012602, Section C.1.5* ML12087A324 02.02 Procedure Approval * 05000391/2009604, Section C.1.12 * 05000391/2009603, Section C.1.5* ML093030479 * ML092120326 02.03 Non-Destructive Examination (NDE)

Procedure Review * 05000391/2009604, Section C.1.12 * 05000391/2009603, Section C.1.5 * 05000391/2010603, Section C.1.12* ML093030479 * ML092120326 * ML102170465 02.04 Code Repair or Replacement

Procedure Review * 05000391/2011605, Section C.1.10 * ML112201418 IP 73053 Section Inspection Reports ADAMS Accession Number 02.01 Preservice

inspection (PSI) plan

review * 05000391/2012602, Section C.1.6 * ML12087A324

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02.02 Examiner qualification review * 05000391/2010602, Section C.1.17* ML101230144 02.03 Observe four different methods of

examination of components * 05000391/2009604, Section C.1.13 (PT, UT) * 05000391/2009603, Section C.1.5 (UT) * 05000391/2010602, Section C.1.17 (ECT) * 05000391/2010603, Section C.1.13 (UT) * 05000391/2010605, Section OA.1.11 (UT) * 05000391/2013612, Section C.1.9 (MT)* ML093030479 * ML092120326 * ML101230144 * ML102170465 * ML110410680 * ML13088A066 02.04 Pressure Boundary Repair * 05000391/2011605, Section C.1.11 * 05000391/2013612, Section C.1.13 * ML112201418 * ML13088A066 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 applicant's 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 applicant's 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 applicant's 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:

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• 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

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• 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 applicant's 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:

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• 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 inspector's 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:

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• 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 inspector's 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 applicant's 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

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procedures and to verify the adequacy of test program records and preliminary evaluation of test results. The following component's 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 inspector's 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 applicant's 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

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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 inspector's 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 applicant's 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

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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 inspector's observations. During the tests, the inspectors observed important data gathering activities to ensure the data

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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 applicant's 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.

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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 inspector's 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 applicant's 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 component's 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;

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• 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 inspector's 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 applicant's 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 component's 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;

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• 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 inspector's 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 applicant's 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

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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 applicant's 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 applicant's 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

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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 contractor's "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 TVA's 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.

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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

applicant's 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

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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.

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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.

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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.

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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;

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• calculations complied with design standard DS-M18.2.22, TVA Mechanical Design Standard for MOV Design Basis and Joint Owner's 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 applicant's 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

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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 GL 89-10 MOVs.

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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 1's 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.

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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.

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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 TVA's

response to GL 2006-02 for Unit 2. The SER, dated January 20, 2010, concluded that

TVA's response and regulatory commitments made for GL 2006-02 were acceptable.

The report also indicated that prior to closing out the review of TVA's 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 TVA's 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.

ML14322A182).

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 TVA's 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.

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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.

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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 TVA's 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. TVA's

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 TVA's 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.

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The inspection reviewed TVA's 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 Owner's 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 Owner's Group guidelines and that the license condition

was no longer necessary. Inspection Activities: The inspectors reviewed the applicant's 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 Owner's 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 NRC's 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 applicant's 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. O'Dell. 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.

Attachment 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. O'Dell, 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

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-

02

VIO

Failure to Follow Anchor Bolt Installation Procedure

(Section OA.1.12)

Opened and Closed

05000391/2015604-

01

Closed CIF

Failure to Comply with Conduct of Maintenance -

Expectations and Standards (Section C.1.1) 46053 37051

80210

73051

73052

73053

70338

70343

70562

35746

35743

35745

2515/191

IP IP IP IP IP

IP

IP

IP

IP IP

IP IP

TI

Structural Concrete Work Observation (Section C.1.3) Verification of As-Builts (Section C.1.4)

Environmental Inspection-Periodic (Section C.1.5)

Inservice Inspection Review of Program (Section C.1.6)

Inservice Inspection Review of Procedures (Section

C.1.6)

Preservice Inspection - Observation of Work and Work Activities (Section C.1.6)

Auxilliary Feedwater System Test- Preoperational Test

Procedure Review (Section P.1.2)

Containment Spray System Test- Preoperational Test Procedure Review (Section P.1.2)

Reactor Coolant System Hydrostatic Test Results

Evaluation (Section P.1.11) Quality Assurance Program - Procurement Control

(Section O.1.1)

Quality Assurance Program - Maintenance (Section O.1.2) Quality Assurance Program - Surveillance Testing and

Calibration Control (Section O.1.3)

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

II.D.3

Open Item 74

79-36 05000391/2014614-01

I.C.7

05000391/2015603-

04

Discussed 2512/020

391/89-08

1989-10

2515/109

2004-02

2006-02 TMI Action Item SSER Appendix HH GL

URI

TMI Action Item URI

TI

CDR GL

TI GL

GL Preparedness Information Requested in NRC March 12, 2012 (Section OA.1.5)

Direct Indication of Relief-and Safety-Valve Position

(Section OA.1.7)

Installation of the Acoustic Monitoring System for the Power Operated Relief Valves (Section OA.1.7)

Adequacy of Station Electric Distribution System

Voltages (Section OA.1.8)

Potential Failure To Comply With 10 CFR 50.55a and Properly Implement the Scope of the ASME OM Code

(Section OA.1.9)

Nuclear Steam Supply System Vendor Review of Procedures (Section OA.1.10)

Boric Acid Tank C Design Control (Section OA.1.11)

Electrical Issues CAP - Sub-issue: Cable Separation

and Electrical Isolation (Section OA.1.1)

Kapton Insulated Pigtail Insulation Damage (Section OA.1.2)

Safety Related Motor Operated Valve Testing and

Surveillance (Section OA.1.3)

Safety Related Motor Operated Valve Testing and Surveillance (Section OA.1.3)

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)

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

Weld Maps: 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 - DG 1A-A, Rev 000U2 (Draft) Unit 1 Surveillance Instruction 0-SI-82-4, 18 Month Loss of Offsite Power with Safety Injection - DG 1B-B, Rev 000U2 (Draft) Unit 2 Surveillance Instruction 0-SI-82-5, 18 Month Loss of Offsite Power with Safety Injection - DG 2A-A, Rev 000U2 (Draft) Unit 2 Surveillance Instruction 0-SI-82-6, 18 Month Loss of Offsite Power with Safety Injection - DG 2B-B, Rev 000U2 (Draft) 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 AFW Auxiliary Feedwater 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

CS Containment spray 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 Owner's 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 RCS Reactor Coolant System Rev. Revision

RG Regulatory Guide

RHR Residual Heat Removal

ROP Reactor Oversight Process

RWST Refueling Water Storage Tanks SER Safety Evaluation Report SG Steam generator

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