ML102170465: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
 
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257
{{#Wiki_filter:UNITED STATES
      August 5, 2010  
                                NUCLEAR REGULATORY COMMISSION
  Mr. Ashok S. Bhatnagar Senior Vice President  
                                              REGION II
Nuclear Generation Development and Construction Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801  
                            245 PEACHTREE CENTER AVENUE NE, SUITE 1200
                                    ATLANTA, GEORGIA 30303-1257
                                            August 5, 2010
Mr. Ashok S. Bhatnagar
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 05000391/2010603 AND NOTICE OF VIOLATION
Dear Mr. Bhatnagar:
On June 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of
construction activities at your Watts Bar Unit 2 reactor facility. The enclosed integrated
inspection report documents the inspection results, which were discussed on July 13, 2010, with
Mr. Masoud Bajestani and other members of your staff.
This inspection examined activities conducted under your Unit 2 construction permit as they
relate to safety and compliance with the Commissions rules and regulations, with the conditions
of your construction permit, and with fulfillment of Unit 2 regulatory framework commitments.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
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 failure to implement adequate measures to review the suitability
of application of materials, parts, and equipment essential to the safety related functions of
molded case circuit breakers and provide for the verification of checking the adequacy of
design, such as, calculational methods, performing a suitable test program, including
qualifications testing of a prototype unit, under the most adverse conditions. 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, this report documents seven NRC-identified findings which were determined to
involve violations of NRC requirements. However, because these findings were Severity Level
IV violations and were entered into your corrective action program, the NRC is treating them as
non-cited violations consistent with Section VI.A.1 of the NRC Enforcement Policy. If you
contest the non-cited violations in the enclosed report, you should provide a response within 30


SUBJECT: WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED INSPECTION REPORT 05000391/2010603 AND NOTICE OF VIOLATION
TVA                                                2
Dear Mr. Bhatnagar:
days of the date of this inspection report, with the basis for your denial, to the United States
On June 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of construction activities at your Watts Bar Unit 2 reactor facility.  The enclosed integrated inspection report documents the inspection results, which were discussed on July 13, 2010, with Mr. Masoud Bajestani and other members of your staff.
Nuclear Regulatory Commission, ATTENTION: Document Control Desk, Washington, DC
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, with the conditions of your construction permit, and with fulfillment of Unit 2 regulatory framework commitments. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
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
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 failure to implement adequate measures to review the suitability of application of materials, parts, and equipment essential to the safety related functions of molded case circuit breakers and provide for the verification of checking the adequacy of  
the NRC Senior Resident Inspector at the Watts Bar Unit 2 Nuclear Plant. In accordance with
design, such as, calculational methods, performing a suitable test program, including qualifications testing of a prototype unit, under the most adverse conditions. 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
10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your
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.  
response (if any) will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRCs document
system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
                                              Sincerely,
                                              /RA/
                                              Robert C. Haag, Chief
                                              Construction Projects Branch 3
                                              Division of Construction Projects
Docket No. 50-391
Construction Permit No: CPPR-92
Enclosure: 1. Notice of Violation
            2. Inspection Report 05000391/2010603 w/attachment
cc w/encl: (See next page)


Additionally, this report documents seven NRC-identified findings which were determined to involve violations of NRC requirements.  However, because these findings were Severity Level IV violations and were entered into your corrective action program, the NRC is treating them as non-cited violations consistent with Section VI.A.1 of the NRC Enforcement Policy.  If you contest the non-cited violations in the enclosed report, you should provide a response within 30 
TVA 2 days of the date of this inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTENTION: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Senior Resident Inspector at the Watts Bar Unit 2 Nuclear Plant.  In accordance with 10 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 Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
            Sincerely, 
      /RA/   
      Robert C. Haag, Chief      Construction Projects Branch 3
      Division of Construction Projects
  Docket No. 50-391 Construction Permit No: CPPR-92


  Enclosure:  1. Notice of Violation         2. Inspection Report 05000391/2010603 w/attachment
  ML102170465                G SUNSI REVIEW COMPLETE
    
OFFICE            RII: DCP        RII:DCP          RII:DCP          RII:DCP          RII:DCP          RII:DCP          RII:DCP
cc w/encl:  (See next page)
SIGNATURE          *WCB            *TXN            ANI              *KEM              JBB              WRL            Via Email
NAME              WBearden        TNazario        AIssa            KMiller          JBaptist        WLewis          GKhouri
DATE                    8/4/2010        8/4/2010    8/4/2010        8/4/2010        8/4/2010        8/4/2010        7/30/2010
E-MAIL COPY?          YES        NO  YES          NO YES        NO  YES          NO  YES        NO  YES          NO  YES        NO
OFFICE            RII:DCP          RII:DCP          RII:DCP          RII:DCI          RII:DCI          RII:DCI          RII:DCI
SIGNATURE          Via Email        *PH              Via Email        Via Email        CRO              Via Email        *JXL
NAME              GCrespo          PHeher          CJFong          CJones          COgle            JFuller          JLizardi
DATE                    8/3/2010         8/3/2010        8/2/2010        7/30/2010        8/5/2010        7/30/2010        8/4/2010
E-MAIL COPY?          YES        NO  YES          NO  YES        NO  YES          NO YES          NO YES            NO YES          NO
OFFICE            RII:DCI          RII:DCI          RII:DCI          RII:DCI          RII:DCI          RII:DCI          RII:DCI
SIGNATURE          Via Email        Via Email        *CBA            Via Email        Via Email        Via Email        Via Email
NAME              EMichel          TSteadham        CAbbott          TFanelli        LCastelli        AArtayet        CStandberry
DATE                  7/30/2010        7/30/2010        8/4/2010          8/4/2010        8/3/2010        7/30/2010        8/4/2010
E-MAIL COPY?          YES        NO  YES          NO  YES        NO  YES          NO  YES        NO  YES          NO YES          NO
OFFICE            RII:DCI          RII:DCI          RII:EICS
SIGNATURE          Via Email        Via Email        Via Email
NAME              EHeher          JKent            CEvans
DATE              7/30/2010        8/4/2010        8/5/2010
E-MAIL COPY?          YES        NO  YES          NO  YES        NO  YES          NO  YES        NO   YES          NO YES          NO
       
TVA                              3
cc w/encl:
Mr. Gordon P. Arent                Mr. M.J. Hellstern
Manager                            General Manager
New Generation Licensing            NGDC Governance & Oversight
Nuclear Generation Development      Tennessee Valley Authority
and Construction                  3A Blue Ridge Place
WBN Nuclear Plant                  1101 Market Street
P.O. Box 2000                      Chattanooga, Tennessee 37402-2801
Spring City, Tennessee 37381
                                    Mr. R.M Krich
Mr. Masoud Bajestani                Vice President
Vice President                      Nuclear Licensing
WBN Unit Two                        Tennessee Valley Authority
WBN Nuclear Plant                  3R Lookout Place
Tennessee Valley Authority          1101 Market Street
P.O. Box 2000                      Chattanooga, Tennessee 37402-2801
Spring City, Tennessee 37381
                                    Mr. E.J. Vigluicci
Mr. Michael K. Brandon, Manager    Assistant General Counsel
Licensing and Industry Affairs      Tennessee Valley Authority
WBN Nuclear Plant                  6A West Tower
Tennessee Valley Authority          400 West Summit Hill Drive
P.O. Box 2000                      Knoxville, Tennessee 37402
Spring City, Tennessee 37381
                                    Lawrence E. Nanney, Director
Mr. Preston D. Swafford            Tennessee Department of Environmental
Chief Nuclear Officer              Health and Conservation
  and Executive Vice President      Division of Radiological Health
Tennessee Valley Authority          3rd Floor, L&C Annex
3R Lookout Place                    401 Church Street
1101 Market Place                  Nashville, TN 37243-1532
Chattanooga, Tennessee 37402-2801
                                    Mr. D. E. Grissette
County Executive                    Site Vice President
375 Church Street                  WBN Nuclear Plant
Suite 215                          Tennessee Valley Authority
Dayton, Tennessee 37321            P.O. Box 2000
                                    Spring City, Tennessee 37381
W.R. Crouch, Manager
WBN Unit 2 Licensing                County Mayor
Watts Bar Nuclear Plant            P.O. Box 156
Tennessee Valley Authority          Decatur, Tennessee 37322
P.O. Box 2000
Spring City, Tennessee 37381        Senior Resident Inspector
                                    WBN Nuclear Plant
Mr. Gregory A. Boerschig            U.S. NRC
Plant Manager, WBN Nuclear Plant    1260 Nuclear Plant Road
Tennessee Valley Authority          Spring City, Tennessee 37381-2000
P.O. Box 2000
Spring City, Tennessee 37381


TVA                          4
 
cc email distribution w/encl:
   
Greg Scott
     
Tennessee Valley Authority
   
Electronic Mail Distribution
 


  ML102170465
Letter to Ashok S. Bhatnagar from Robert C. Haag dated August 5, 2010.
G  SUNSI REVIEW COMPLETE OFFICE RII: DCP RII:DCP RII:DCP RII:DCP RII:DCP RII:DCP RII:DCP SIGNATURE *WCB *TXN ANI *KEM  JBB  WRL Via Email NAME WBearden TNazario AIssa KMiller JBaptist WLewis GKhouri DATE 8/4/2010 8/4/2010 8/4/2010 8/4/2010 8/4/2010 8/4/2010 7/30/2010 E-MAIL COPY?    YES NO  YES NO  YES NO  YES NO  YES NO  YES NO  YES NO OFFICE RII:DCP RII:DCP RII:DCP RII:DCI RII:DCI RII:DCI RII:DCI SIGNATURE Via Email *PH Via Email Via Email CRO Via Email *JXL NAME GCrespo PHeher CJFong CJones COgle JFuller JLizardi DATE 8/3/2010 8/3/2010 8/2/2010 7/30/2010 8/5/2010 7/30/2010 8/4/2010 E-MAIL COPY?    YES NO  YES NO  YES NO  YES NO YES NO YES NO YES NO OFFICE RII:DCI RII:DCI RII:DCI RII:DCI RII:DCI RII:DCI RII:DCI SIGNATURE Via Email Via Email *CBA Via Email Via Email Via Email Via Email NAME EMichel TSteadham CAbbott TFanelli LCastelli AArtayet CStandberry DATE 7/30/2010 7/30/2010 8/4/2010 8/4/2010 8/3/2010 7/30/2010 8/4/2010 E-MAIL COPY?    YES NO  YES NO  YES NO  YES NO  YES NO  YES NO YES NO OFFICE RII:DCI RII:DCI RII:EICS    SIGNATURE Via Email Via Email Via Email    NAME EHeher JKent CEvans    DATE 7/30/2010 8/4/2010 8/5/2010    E-MAIL COPY?    YES NO  YES NO  YES NO  YES NO  YES NO  YES NO YES NO
SUBJECT:       WBN NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED
 
                INSPECTION REPORT 05000391/2010603
TVA 3   
Distribution w/encl:
cc w/encl:   Mr. Gordon P. Arent Manager New Generation Licensing Nuclear Generation Development  and Construction
L. Raghavan, NRR
WBN Nuclear Plant P.O. Box 2000 Spring City, Tennessee 37381
S. Campbell, NRR
Mr. Masoud Bajestani
P. Milano, NRR
Vice President WBN Unit Two WBN Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381
C. Evans, RII
L. Slack, RII EICS
Mr. Michael K. Brandon, Manager Licensing and Industry Affairs WBN Nuclear Plant Tennessee Valley Authority P.O. Box 2000
E. Guthrie, RII DRP
Spring City, Tennessee 37381
R. Monk, RII WBN Unit 1 SRI
Mr. Preston D. Swafford Chief Nuclear Officer  and Executive Vice President
OE Mail (email address if applicable)
Tennessee Valley Authority 3R Lookout Place 1101 Market Place Chattanooga, Tennessee 37402-2801
PUBLIC
County Executive 375 Church Street Suite 215 Dayton, Tennessee 37321
W.R. Crouch, Manager WBN Unit 2 Licensing  Watts Bar Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381
Mr. Gregory A. Boerschig Plant Manager, WBN Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381


  Mr. M.J. Hellstern General Manager NGDC Governance & Oversight Tennessee Valley Authority 3A Blue Ridge Place
                                        NOTICE OF VIOLATION
1101 Market Street Chattanooga, Tennessee 37402-2801
Tennessee Valley Authority                                                          Docket No. 50-391
Mr. R.M Krich Vice President 
Watts Bar Nuclear Plant - Unit 2                                  Construction Permit No. CPPR-92
Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801
Spring City, TN
Mr. E.J. Vigluicci
During an NRC inspection conducted on April 26-30, 2010, a violation of NRC requirements was
Assistant General Counsel Tennessee Valley Authority 6A West Tower 400 West Summit Hill Drive Knoxville, Tennessee 37402
identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR 50, Appendix B, Criterion III, Design Control, states that measures shall be
established for the review for suitability of application of materials, parts, and equipment that are
essential to the safety-related functions of the structures, systems, and components (SSCs).
The design control measures shall provide for verifying or checking the adequacy of design,
such as by the performance of design reviews, by the use of alternate or simplified calculational
methods, or by the performance of a suitable testing program. Where a test program is used to
verify the adequacy of a specific design feature in lieu of other verifying or checking processes,
it shall include suitable qualifications testing of a prototype unit under the most adverse design
conditions.
Contrary to the above, measures used to review the suitability of application of materials, parts,
and equipment essential to the safety-related functions of molded case circuit breakers and
measures to provide for the verification of checking the adequacy of design, such as,
calculational methods, performing a suitable test program, including qualifications testing of a
prototype unit under the most adverse design conditions, were not adequate in that:
    1. On October 5, 2009, the applicant installed molded case circuit breakers into the
          120VAC vital instrument power boards; however, the test program used to seismically
          qualify a prototype circuit breaker failed to use a suitable mounting method that reflected
          the most adverse mounting condition.
    2. On September 3, 2009, the applicant failed to perform an adequate review for suitability
          of application parts and material used to modify dimensional critical characteristics in
          molded case circuit breakers; further, the applicant failed to verify the adequacy of
          design for the modification and the effects on essential safety related functions of the
          circuit breakers.
This is a Severity Level IV violation (Supplement II)
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
(Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" 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
                                                                                  Enclosure 1


Lawrence E. Nanney, Director Tennessee Department of Environmental Health and Conservation Division of Radiological Health
NOV                                                2
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.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the NRCs document system (ADAMS), accessible from the
NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not
include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that delete such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by 10
CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated this 5th day of August, 2010


3 rd Floor, L&C Annex 401 Church Street Nashville, TN 37243-1532
                        U.S. NUCLEAR REGULATORY COMMISSION
Mr. D. E. Grissette
                                          REGION II
Site Vice President WBN Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381
Docket No.:                  50-391
Construction Permit No.:    CPPR-92
Report No.:                  05000391/2010603
Applicant:                  Tennessee Valley Authority (TVA)
Facility:                    Watts Bar Nuclear Plant, Unit 2
Location:                    1260 Nuclear Plant Rd
                            Spring City TN 37381
Dates:                      April 1 - June 30, 2010
Inspectors:                  W. Bearden, Senior Resident Inspector, Construction Projects
                                Branch 3 (CPB3), Division of Construction Projects (DCP)
                                Region II (RII)
                            T. Nazario, Resident Inspector, CPB3, DCP, RII
                            K. Miller, Resident Inspector, CPB3, DCP, RII
                            W. Lewis, Resident Inspector, CPB3, DCP, RII
                            J. Fuller, Senior Construction Inspector, Construction Inspection
                                Branch 3 (CIB3), Division of Construction Inspection (DCI), RII;
                                Sections C.1.8, C.1.9, C.1.10, C.1.11, C.1.12, C.1.13, C.1.14,
                                C.1.15, C.1.16, C.1.17, C.1.18, C.1.19, C.1.20
                            G. Crespo, Senior Construction Inspector, CIB1, DCI, RII;
                                Sections C.1.2, C.1.6, E.1.1, T.1.1, OA .1.4, OA.1.5, OA.1.6,
                                OA.1.7
                            A. Issa, Construction Inspector, CPB3, DCP, RII, Section Q.1.3
                            E. Michel, Senior Construction Inspector, CIB3, DCI, RII, Sections
                                C.1.9, C.1.11, C.1.12, C.1.13, C.1.14
                            T. Steadham, Construction Inspector, CIB3, DCI , RII, Section
                                C.1.5
                            J. Lizardi, Construction Inspector, CIB2, DCI, RII, Sections C.1.4,
                                C.1.7, C.1.8
                            C. Abbott, Construction Inspector, CIB2, DCI, RII, Section C.1.3
                            C. Jones, Senior Construction Inspector, CIB1, DCI, RII, Sections
                                E.1.2, OA.1.5, OA.1.8, OA.1.12
                            T. Fanelli, Construction Inspector, CIB1, DCI, RII, Sections C.1.2,
                                E.1.1
                                                                            Enclosure 2


County Mayor P.O. Box 156 Decatur, Tennessee 37322
                                2
Senior Resident Inspector WBN Nuclear Plant
            L. Castelli, Senior Construction Inspector, CIB1, DCI, RII Section
U.S. NRC  1260 Nuclear Plant Road Spring City, Tennessee 37381-2000
                C.1.1
 
            A. Artayet, Senior Construction Inspector, CIB3, DCI, RII, Sections
TVA 4  cc email distribution w/encl:
                C.1.15, C.1.16
Greg Scott Tennessee Valley Authority Electronic Mail Distribution
            C. Smith-Standberry, Construction Inspector, CIB1, DCI, RII,
 
                Section OA.1.13
     
            G. Khouri, Senior Construction Inspector, CPB2, DCP, RII, Section
  Letter to Ashok S. Bhatnagar from Robert C. Haag dated August 5, 2010.  
                E.1.2
SUBJECT: WBN NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED INSPECTION REPORT 05000391/2010603
            E. Heher, Construction Inspector, CIB2, DCI, RII, Section E.1.2
Distribution w/encl
            P. Heher, Construction Inspector, CPB2, DCP, RII, Section Q.1.3
: L. Raghavan, NRR S. Campbell, NRR P. Milano, NRR C. Evans, RII L. Slack, RII EICS
            J. Kent, Construction Inspector, CIB1, DCI, RII, Sections OA.1.1,
E. Guthrie, RII DRP R. Monk, RII WBN Unit 1 SRI   
                OA.1.9, OA.1.10, OA.1.11
OE Mail (email address if applicable)
            C. Fong, Construction Inspector, CPB2, DCP, RII, Section C.1.3
PUBLIC   
Approved by: Robert C. Haag, Chief
  Enclosure 1 NOTICE OF VIOLATION
            Construction Projects Branch 3
            Division of Construction Projects
Tennessee Valley Authority Docket No. 50-391  Watts Bar Nuclear Plant - Unit 2        Construction Permit  No. CPPR-92 Spring City, TN         


During an NRC inspection conducted on April 26-30, 2010, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
                                      EXECUTIVE SUMMARY
  10 CFR 50, Appendix B, Criterion III, "Design Control," states that measures shall be
                                  Watts Bar Nuclear Plant, Unit 2
established for the review for suitability of application of materials, parts, and equipment that are essential to the safety-related functions of the structures, systems, and components (SSCs). The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.  Where a test program is used to verify the adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualifications testing of a prototype unit under the most adverse design
This integrated inspection included aspects of engineering and construction activities performed
conditions.
by TVA associated with the Watts Bar Nuclear (WBN) Plant Unit 2 construction project. This
  Contrary to the above, measures used to review the suitability of application of materials, parts, and equipment essential to the safety-related functions of molded case circuit breakers and measures to provide for the verification of checking the adequacy of design, such as,  
report covered a three-month period of inspections in the areas of quality assurance (QA);
calculational methods, performing a suitable test program, including qualifications testing of a prototype unit under the most adverse design conditions, were not adequate in that:
identification and resolution of construction problems; construction activities; training and
1. On October 5, 2009, the applicant installed molded case circuit breakers into the 120VAC vital instrument power boards; however, the test program used to seismically
qualification of plant personnel; fire protection; and follow-up of other activities. The inspection
qualify a prototype circuit breaker failed to use a suitable mounting method that reflected the most adverse mounting condition.
program for Unit 2 construction activities is described in NRC Inspection Manual Chapter (IMC)
2. On September 3, 2009, the applicant failed to perform an adequate review for suitability of application parts and material used to modify dimensional critical characteristics in
2517. Information regarding the WBN Unit 2 Construction Project and NRC inspections can be
molded case circuit breakers; further, the applicant failed to verify the adequacy of design for the modification and the effects on essential safety related functions of the circuit breakers.
found at http://www.nrc.gov/reactors/plant-specific-items/watts-bar.html.
This is a Severity Level IV violation (Supplement II)  
The inspection identified one NRC-identified Severity Level (SL) IV violation (VIO), seven non-
cited violations (NCV), and one Unresolved Item (URI).
Inspection Results
  *  A SL IV NCV of 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion XV,
    Nonconforming Materials, Parts, or Components, was identified by the inspectors for the
    failure to have procedures for identification, documentation and segregation of materials
    identified as nonconforming to Purchase Order (PO) requirements by the kick and count
    inspection. (Section Q.1.3)
*  A SL IV NCV of 10 CFR 50, Appendix B, Criterion VI, Document Control, was identified by
    the inspectors for the failure to establish adequate measures to control the issuance of
    documents stored in the CONEX storage area. (Section Q.1.3)
  *  A SL IV NCV of 10 CFR Part 21 was identified by the inspectors for the failure to invoke
    10 CFR Part 21 requirements on a supplier of safety-related services of basic components.
    (Section Q.1.3)
*    A SL IV NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
    Drawings, was identified by the inspectors for failure to identify improper weld size by the
    welder, field engineer, and quality control (QC) in accordance with applicable instructions,
    procedures, and drawings. (Section C. 1.3)
*    A SL IV NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified
    by the inspectors for inadequate measures to assure that conditions adverse to quality,
    specifically non-conforming safety-related concrete, was promptly identified and corrected.
    (Section C.1.4)
*  The inspectors identified a URI related to the material condition inside of the loop-3 RCS
    crossover piping. The inspectors concluded that in order to properly evaluate and disposition
    this issue, additional inspection would be required to determine (1) whether areas of
    concern (potential pitting) were properly identified and documented at the time by QC and
    Field Engineer (FE) in accordance with applicable instructions and procedures; and (2)
    whether the engineering disposition appropriately addressed the area of concern. (Section
    C.1.8)


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 (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should
                                                  2
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  
* A SL IV, NCV of 10 CFR 50 Appendix B, Criterion XIII, Handling, Storage, and Shipping,
received within the time specified in this Notice, an order or a Demand for Information may be 
  was identified by the inspectors in that the applicant failed to control the storage and
NOV 2   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.  
  preservation of material and equipment in accordance with work and inspection instructions
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
  to prevent damage from nearby construction activities. Specifically, the inspectors identified
Regulatory Commission, Washington, DC 20555-0001.
  multiple locations of weld and paint spatter, arc strikes, and mechanical damage on safety-
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
  related welds, piping, and components. (Section C.1.9)
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.  
* A SL IV VIO of 10 CFR 50, Appendix B, Criterion III, "Design Control," was identified by the
  inspectors in that the applicant failed to implement adequate design control measures in the
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.  Dated this 5th day of August, 2010 
  qualification analysis, testing, and calculational methods used to qualify and analyze safety-
   Enclosure 2  U.S. NUCLEAR REGULATORY COMMISSION
  related components. This is regarding the seismic qualification of circuit breakers in safety-
   REGION II
  related 120VAC Vital Instrument Power Boards. Two examples of design control violation
   Docket No.:  50-391
  are listed in the report details section. The violation did not meet the criteria for a non-cited
   violation in Section VI.A.1 of the NRC Enforcement Policy because the applicants corrective
  action did not adequately address the findings identified and would not ensure that
  compliance was restored in a reasonable timeframe or prevent recurrence. (Section E.1.1)
* A SL IV NCV of 10 CFR 50 Appendix B, Criterion III, Design Control, was identified by the
  inspectors for a failure to correctly translate the design basis, as described in a System
  Description Document, into affected drawings and specifications. Specifically, a design
  basis requirement to provide diverse level measurement systems for the Safety Injection
  System Accumulators was not correctly translated into affected specifications and drawings
  issued for construction. (Section E.1.2)
* The inspectors concluded that concerns pertaining to the cable CAP sub-issue on adhesive
  backed cable mount supports have been appropriately addressed for Watts Bar Unit 2 and
  this item is closed. (Section OA.1.3)
* Other areas inspected were adequate with no findings of significance identified. These
   areas included: response to response Three Mile Island (TMI) Action Items; electrical
   systems and components; nuclear welding; structural welding; nondestructive examination
   and inservice inspection activities; craft training; and fire protection.


Construction Permit No.: CPPR-92
                                                        Table of Contents
Report No.:  05000391/2010603
I. QUALITY ASSURANCE (QA) PROGRAM ............................................................................ 1
Q.1 QA Oversight Activities ................................................................................................. 1
Applicant:  Tennessee Valley Authority (TVA)  
    Q.1.1    Identification and Resolution of Construction Problems (Inspection Procedure (IP) ....
  Facility:  Watts Bar Nuclear Plant, Unit 2
    35007) .................................................................................................................................... 1
 
    Q.1.2    Safety Conscience Work Environment (IP 35007)..................................................... 1
Location:  1260 Nuclear Plant Rd    Spring City TN 37381
    Q.1.3    Procurement, Receiving, and Storage Inspection (IP 35060 and IP 35065) .............. 2
Dates:    April 1 - June 30, 2010
II. MANAGEMENT OVERSIGHT AND CONTROLS .................................................................. 6
        Inspectors: W. Bearden, Senior Resident Inspector, Construction Projects Branch 3 (CPB3), Division of Construction Projects (DCP) Region II (RII)    T. Nazario, Resident Inspector, CPB3, DCP, RII
C.1 Construction Activities .................................................................................................. 6
  K. Miller, Resident Inspector, CPB3, DCP, RII W. Lewis, Resident Inspector, CPB3, DCP, RII J. Fuller, Senior Construction Inspector, Construction Inspection Branch 3 (CIB3), Division of Construction Inspection (DCI), RII; Sections C.1.8, C.1.9, C.1.10, C.1.11, C.1.12, C.1.13, C.1.14, C.1.15, C.1.16, C.1.17, C.1.18, C.1.19, C.1.20  G. Crespo, Senior Construction Inspector, CIB1, DCI, RII; Sections C.1.2, C.1.6, E.1.1, T.1.1, OA .1.4, OA.1.5, OA.1.6, OA.1.7 A. Issa, Construction Inspector, CPB3, DCP, RII, Section Q.1.3
    C.1.1    Instrument Components and Systems - Work Observation (IP 52053) ..................... 6
E. Michel, Senior Construction Inspector, CIB3, DCI, RII, Sections C.1.9, C.1.11, C.1.12, C.1.13, C.1.14 T. Steadham, Construction Inspector, CIB3, DCI , RII, Section C.1.5 J. Lizardi, Construction Inspector, CIB2, DCI, RII, Sections C.1.4, C.1.7, C.1.8 C. Abbott, Construction Inspector, CIB2, DCI, RII, Section C.1.3
    C.1.2      Instrumentation installation activities- Work Observation (IP 52053) ....................... 7
C. Jones, Senior Construction Inspector, CIB1, DCI, RII, Sections E.1.2, OA.1.5, OA.1.8, OA.1.12 T. Fanelli, Construction Inspector, CIB1, DCI, RII, Sections C.1.2, E.1.1
    C.1.3    Pipe Support and Restraint Systems (IP 50090, 46071, and TI 2512/023) ................ 7
2  L. Castelli, Senior Construction Inspector, CIB1, DCI, RII Section C.1.1  A. Artayet, Senior Construction Inspector, CIB3, DCI, RII, Sections C.1.15, C.1.16 C. Smith-Standberry, Construction Inspector, CIB1, DCI, RII, Section OA.1.13 G. Khouri, Senior Construction Inspector, CPB2, DCP, RII, Section E.1.2 E. Heher, Construction Inspector, CIB2, DCI, RII, Section E.1.2 P. Heher, Construction Inspector, CPB2, DCP, RII, Section Q.1.3 J. Kent, Construction Inspector, CIB1, DCI, RII, Sections OA.1.1, OA.1.9, OA.1.10, OA.1.11 C. Fong, Construction Inspector, CPB2, DCP, RII, Section C.1.3 
    C.1.4    Structural Concrete (IP 46053)................................................................................ 10
Approved by:  Robert C. Haag, Chief    Construction Projects Branch 3    Division of Construction Projects 
    C.1.5    Safety-Related and RCS Pressure Boundary Piping Records Review (IPs 49055 ......
EXECUTIVE SUMMARY
    and 49065, TI 2512/024) ....................................................................................................... 11
  Watts Bar Nuclear Plant, Unit 2
    C.1.6 Cable Signal Tracing - Work Observation (TI 2512/016, IP 52053) ........................... 13
This integrated inspection included aspects of engineering and construction activities performed by TVA associated with the Watts Bar Nuclear (WBN) Plant Unit 2 construction project. This
    C.1.7    RPV Internals and Protection of Installed Plan Equipment during Construction ..........
report covered a three-month period of inspections in the areas of quality assurance (QA); identification and resolution of construction problems; construction activities; training and qualification of plant personnel; fire protection; and follow-up of other activities. The inspection program for Unit 2 construction activities is described in NRC Inspection Manual Chapter (IMC) 2517. Information regarding the WBN Unit 2 Construction Project and NRC inspections can be
    Activities (IP 50053) .............................................................................................................. 14
found at http://www.nrc.gov/reactors/plant-specific-items/watts-bar.html.     The inspection identified one NRC-identified Severity Level (SL) IV violation (VIO), seven non-
    C.1.8    Reactor Coolant System (RCS) Piping (IP 49053) .................................................. 14
cited violations (NCV), and one Unresolved Item (URI).  
    C.1.9    Protection of Installed Plant Equipment During Construction Activities - Reactor .......
Inspection Results
    Coolant Pressure Boundary Piping (IP 49053) ...................................................................... 16
  * A SL IV NCV of 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion XV, "Nonconforming Materials, Parts, or Components," was identified by the inspectors for the failure to have procedures for identification, documentation and segregation of materials identified as nonconforming to Purchase Order (PO) requirements by the kick and count inspection. (Section Q.1.3)
    C.1.10. URI 78-05-02, Reactor Vessel - Nozzle Weld Surface Cracking ............................. 18
* A SL IV NCV of 10 CFR 50, Appendix B, Criterion VI, "Document Control," was identified by the inspectors for the failure to establish adequate measures to control the issuance of documents stored in the CONEX storage area. (Section Q.1.3)
    C.1.11 Inservice Inspection - Review of Program (IP 73051) ............................................. 19
* A SL IV NCV of 10 CFR Part 21 was identified by the inspectors for the failure to invoke  10 CFR Part 21 requirements on a supplier of safety-related services of basic components.  (Section Q.1.3)
    C.1.12 Inservice Inspection - Review of Procedures (IP 73052) ........................................ 20
*  A SL IV NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified by the inspectors for failure to identify improper weld size by the welder, field engineer, and quality control (QC) in accordance with applicable instructions, procedures, and drawings. (Section C. 1.3)  
    C.1.13 Preservice Inspection - Observation of Work and Work Activities (IP 73053) ......... 20
*  A SL IV NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," was identified by the inspectors for inadequate measures to assure that conditions adverse to quality, specifically non-conforming safety-related concrete, was promptly identified and corrected. (Section C.1.4)
    C.1.14 Preservice Inspection - Data Review and Evaluation (IP 73055) ............................. 21
* The inspectors identified a URI related to the material condition inside of the loop-3 RCS crossover piping. The inspectors concluded that in order to properly evaluate and disposition this issue, additional inspection would be required to determine (1) whether areas of
    C.1.15 Nuclear Welding General Inspection Procedure (IP 55050) .................................... 23
concern (potential pitting) were properly identified and documented at the time by QC and Field Engineer (FE) in accordance with applicable instructions and procedures; and (2) whether the engineering disposition appropriately addressed the area of concern. (Section C.1.8) 
    C.1.16 Structural Welding General Inspection Procedure (IP 55100) ................................. 26
2  * A SL IV, NCV of 10 CFR 50 Appendix B, Criterion XIII, "Handling, Storage, and Shipping," was identified by the inspectors in that the applicant failed to control the storage and preservation of material and equipment in accordance with work and inspection instructions
    C.1.17 Visual Examination of Safety Related Welds (IP 57050) ......................................... 29
to prevent damage from nearby construction activities. Specifically, the inspectors identified multiple locations of weld and paint spatter, arc strikes, and mechanical damage on safety-related welds, piping, and components. (Section C.1.9)
    C.1.18 Liquid Penetrant Examination of Safety Related Welds (IP 57060) ......................... 30
* A SL IV VIO of 10 CFR 50, Appendix B, Criterion III, "Design Control," was identified by the inspectors in that the applicant failed to implement adequate design control measures in the qualification analysis, testing, and calculational methods used to qualify and analyze safety-related components. This is regarding the seismic qualification of circuit breakers in safety-related 120VAC Vital Instrument Power Boards. Two examples of design control violation are listed in the report details section. The violation did not meet the criteria for a non-cited violation in Section VI.A.1 of the NRC Enforcement Policy because the applicant's corrective action did not adequately address the findings identified and would not ensure that compliance was restored in a reasonable timeframe or prevent recurrence. (Section E.1.1)
    C.1.19 Magnetic Particle Examination of Safety Related Welds (IP57070) ......................... 31
* A SL IV NCV of 10 CFR 50 Appendix B, Criterion III, "Design Control," was identified by the inspectors for a failure to correctly translate the design basis, as described in a System Description Document, into affected drawings and specifications. Specifically, a design basis requirement to provide diverse level measurement systems for the Safety Injection System Accumulators was not correctly translated into affected specifications and drawings issued for construction. (Section E.1.2)
    C.1.20 Ultrasonic Examination of Safety-Related Welds (IP 57080, 73053) ....................... 32
* The inspectors concluded that concerns pertaining to the cable CAP sub-issue on adhesive backed cable mount supports have been appropriately addressed for Watts Bar Unit 2 and this item is closed. (Section OA.1.3)
E.1 ENGINEERING ACTIVITIES ......................................................................................... 32
* Other areas inspected were adequate with no findings of significance identified. These areas included: response to response Three Mile Island (TMI) Action Items; electrical systems and components; nuclear welding; structural welding; nondestructive examination and inservice inspection activities; craft training; and fire protection.  
    E.1.1    Procurement, Receiving, and Storage (IP35065) .................................................... 32
  Table of Contents
    E.1.2    Engineering Design Activities and Design Control (IPs 35100 and 37055) .............. 35
I. QUALITY ASSURANCE (QA) PROGRAM ............................................................................ 1
T.1     TRAINING AND QUALIFICATION OF PLANT PERSONNEL ....................................... 37
Q.1 QA Oversight Activities ................................................................................................. 1
    T.1.1    Craft Training (IPs 51051 and 64051) ..................................................................... 37
Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure (IP) ....
    T.1.2    Engineering Organization Training (IP 35960) ........................................................ 38
35007) ........................................................................................................................
III. OPERATIONAL READINESS ACTIVITIES ........................................................................ 38
............ 1
F.1      Fire Protection (IP 64051) ............................................................................................ 38
Q.1.2 Safety Conscience Work Environment (IP 35007)
..................................................... 1
Q.1.3 Procurement, Receiving, and Storage Inspection (IP 35060 and IP 35065) .............. 2
II. MANAGEMENT OVERSIGHT AND CONTROLS .................................................................. 6
C.1 Construction Activities ..................................................................................................
6 C.1.1 Instrument Components and Systems - Work Observation (IP 52053) ..................... 6
C.1.2  Instrumentation installation activities- Work Observation (IP 52053) ....................... 7
C.1.3 Pipe Support and Restraint Systems (IP 50090, 46071, and TI 2512/023) ................ 7
C.1.4 Structural Concrete (IP 46053) ................................................................................ 10
C.1.5 Safety-Related and RCS Pressure Boundary Piping Records Review (IPs 49055 ...... and 49065, TI
2512/024) ....................................................................................................... 11 C.1.6  Cable Signal Tracing - Work Observation (TI 2512/016, IP 52053) ........................... 13
C.1.7 RPV Internals and Protection of Installed Plan Equipment during Construction ..........
Activities (IP 50053) .............................................................................................................. 14 C.1.8 Reactor Coolant System (RCS) Piping (IP 49053) .................................................. 14
C.1.9 Protection of Installed Plant Equipment During Construction Activities - Reactor .......  
Coolant Pressure Boundary Piping (IP 49053) ...................................................................... 16
C.1.10.   URI 78-05-02, Reactor Vessel - Nozzle Weld Surface Cracking ............................. 18
C.1.11 Inservice Inspection - Review of Program (IP 73051) ............................................. 19
C.1.12 Inservice Inspection - Review of Procedures (IP 73052) ........................................ 20
C.1.13 Preservice Inspection - Observation of Work and Work Activities (IP 73053) ......... 20
C.1.14 Preservice Inspection - Data Review and Evaluation (IP 73055) ............................. 21
C.1.15 Nuclear Welding General Inspection Procedure (IP 55050) .................................... 23
C.1.16 Structural Welding General Inspection Procedure (IP 55100) ................................. 26
C.1.17 Visual Examination of Safety Related Welds (IP 57050) ......................................... 29
C.1.18 Liquid Penetrant Examination of Safety Related Welds (IP 57060) ......................... 30
C.1.19 Magnetic Particle Examination of Safety Related Welds (IP57070) ......................... 31
C.1.20 Ultrasonic Examination of Safety-Related Welds (IP 57080, 73053) ....................... 32
E.1 ENGINEERING ACTIVITIES ......................................................................................... 32
E.1.1 Procurement, Receiving, and Storage (IP35065) .................................................... 32
E.1.2  Engineering Design Activities and Design Control (IPs 35100 and 37055) .............. 35
T.1 TRAINING AND QUALIFICATION OF PLANT PERSONNEL ....................................... 37
T.1.1 Craft Training (IPs 51051 and 64051) ..................................................................... 37
T.1.2 Engineering Organization Training (IP 35960) ........................................................ 38
III. OPERATIONAL READINESS ACTIVITIES ........................................................................ 38
F.1 Fire Protection (IP 64051) ............................................................................................ 38
2  IV. OTHER ACTIVITIES ...................................................................................................... 39
OA.1.1(Discussed) QA Records Corrective Action Program (TI 2512/28, IPs 50075, 51065, ....
51055, 52055) ....................................................................................................................... 39 OA.1.2  Corrective Action Plans and Special Programs Reviews (TI 2512/017, 025) ...... 40
OA.1.3 (Closed) Electrical Issues CAP Sub-issue: Adhesive Backed Cable Support Mount .....
(ABCSM) (TI 2512/020, IP 51063) ........................................................................................ 41
OA.1.4 (Discussed) Cable Issues CAP Sub-Issue: Computerized Cable Routing System ........
(CCRS) Software and Database Verification and Validation (TI 2512/016) ........................... 41
OA.1.5 (Discussed) Station Blackout (SBO) Rule Procedures and Actions (TI 2515/120)
..... 42 OA.1.6 (Discussed) Non-cited Violation NCV-391/2008-010-01 corrective action for failure......
to document a cable raceway separation non-conforming condition. ..................................... 42
OA.1.7 (Closed) NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power ........
Cable Failures that Disable Accident Mitigation Systems or Cause Plant ..................................
Transients. ............................................................................................................................ 43
OA.1.8 (Discussed) Inspection of Watts Bar Nuclear Plant Master Fuse List Special ................
Program (TI 2512/037) .......................................................................................................... 43 OA.1.9 (Discussed) NRC Bulletins 74-15, "Misapplication of Cutler-Hammer Three .................
Position Maintained Switch Model No. 10250T"; 75-03, "Incorrect Lower Disc ..........................
Spring and Clearance Dimension in Series 8300 and 8302 ASCO Solenoid .............................
Valves"; and 75-06, "Defective Westinghouse Type OT-2 Control Switches" ........................ 45
OA.1.10 (Discussed) NRC Bulletin 76-02, Relay Coil Failures - General Electric Type HFA, ...
HGA, HKA, and HMA Relays ................................................................................................ 46
OA.1.11 (Discussed) Violation 391/86-02-01; Failure to Follow Procedures that Resulted in ....
Improperly Installed Solenoid Valves .................................................................................... 47
OA.1.12 (Discussed) Inspection of Watts Bar Nuclear Plant Radiation Monitoring System .......
Special Program (TI 2512/041) ............................................................................................. 47
OA.1.13 (Discussed) Applicant Actions on Three Mile Island (TMI) Action Items .................. 48
V. MANAGEMENT MEETINGS ............................................................................................. 51
X.1 EXIT MEETING SUMMARY .......................................................................................... 51
   
   
     
   
  REPORT DETAILS
Summary of Plant Status
  During the current inspection period, TVA performed pre-service inspection (PSI) activities and construction completion activities on safety-related systems, and continued engineering design
activities.


                                                                    2
I. Quality Assurance (QA) Program  
IV.     OTHER ACTIVITIES ...................................................................................................... 39
  Q.1 QA Oversight Activities
  OA.1.1(Discussed) QA Records Corrective Action Program (TI 2512/28, IPs 50075, 51065, ....
  51055, 52055) ....................................................................................................................... 39
  OA.1.2      Corrective Action Plans and Special Programs Reviews (TI 2512/017, 025) ...... 40
  OA.1.3 (Closed) Electrical Issues CAP Sub-issue: Adhesive Backed Cable Support Mount .....
  (ABCSM) (TI 2512/020, IP 51063) ........................................................................................ 41
  OA.1.4 (Discussed) Cable Issues CAP Sub-Issue: Computerized Cable Routing System ........
  (CCRS) Software and Database Verification and Validation (TI 2512/016) ........................... 41
  OA.1.5 (Discussed) Station Blackout (SBO) Rule Procedures and Actions (TI 2515/120) ..... 42
  OA.1.6 (Discussed) Non-cited Violation NCV-391/2008-010-01 corrective action for failure......
  to document a cable raceway separation non-conforming condition...................................... 42
  OA.1.7 (Closed) NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power ........
  Cable Failures that Disable Accident Mitigation Systems or Cause Plant ..................................
  Transients. ............................................................................................................................ 43
  OA.1.8 (Discussed) Inspection of Watts Bar Nuclear Plant Master Fuse List Special ................
  Program (TI 2512/037) .......................................................................................................... 43
  OA.1.9 (Discussed) NRC Bulletins 74-15, Misapplication of Cutler-Hammer Three .................
  Position Maintained Switch Model No. 10250T; 75-03, Incorrect Lower Disc ..........................
  Spring and Clearance Dimension in Series 8300 and 8302 ASCO Solenoid .............................
  Valves; and 75-06, Defective Westinghouse Type OT-2 Control Switches ........................ 45
  OA.1.10 (Discussed) NRC Bulletin 76-02, Relay Coil Failures - General Electric Type HFA, ...
  HGA, HKA, and HMA Relays ................................................................................................ 46
  OA.1.11 (Discussed) Violation 391/86-02-01; Failure to Follow Procedures that Resulted in ....
  Improperly Installed Solenoid Valves .................................................................................... 47
  OA.1.12 (Discussed) Inspection of Watts Bar Nuclear Plant Radiation Monitoring System .......
  Special Program (TI 2512/041) ............................................................................................. 47
  OA.1.13 (Discussed) Applicant Actions on Three Mile Island (TMI) Action Items .................. 48
V.    MANAGEMENT MEETINGS ............................................................................................. 51
X.1    EXIT MEETING SUMMARY .......................................................................................... 51


Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure (IP)            35007)   
                                        REPORT DETAILS
Summary of Plant Status
During the current inspection period, TVA performed pre-service inspection (PSI) activities and
construction completion activities on safety-related systems, and continued engineering design
activities.
I. Quality Assurance (QA) Program
Q.1      QA Oversight Activities
Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure (IP)
        35007)
  a.    Inspection Scope
        During this inspection period, the inspectors reviewed problem evaluation reports
        (PERs) as part of TVAs corrective action program to verify that issues being identified
        under the corrective action program were being properly identified, addressed, and
        resolved by TVA. Additionally, the inspectors reviewed three recent Bechtel QA
        surveillance reports regarding ongoing nondestructive examination work activities.
  b.    Observations and Findings
        No findings of significance were identified.
  c.    Conclusions
        Generally, the PERs reviewed were properly identified, addressed, and resolved;
        however, as noted in Section C.1.4, Structural Concrete, a violation of regulatory
        requirements was identified for failure to promptly identify and correct a condition
        adverse to quality.
Q.1.2 Safety Conscience Work Environment (IP 35007)
  a.    Inspection Scope
        The inspectors continued routine meetings with the Unit 2 Employee Concerns Program
        (ECP) representative to evaluate the effectiveness of the applicants program for
        resolving employee concerns. The inspectors reviewed existing program requirements
        and all recent safety-related concerns identified by the applicants and contractors ECP
        programs. The inspectors also verified that significant problems were documented
        under the corrective action program and were being properly identified, addressed, and
        resolved by TVA. This included a review of anonymous PERs and trending for the
        months of April and May.
  b.    Observations and Findings
        No findings of significance were identified.
 
                                                2
  c.  Conclusions
      The inspectors did not identify any issues or concerns regarding the ability of the
      applicant to provide a safety-conscience work environment.
Q.1.3 Procurement, Receiving, and Storage Inspection (IP 35060 and IP 35065)
  a.  Inspection Scope
      The inspectors performed a procurement, receiving, and storage inspection in
      accordance with IP 35065, Procurement, Receiving, and Storage, and Section 02.04 of
      IP 35060, Applicant management of QA activities. In addition, IP 38703, Commercial
      Grade Dedication, was used for guidance in reviewing commercial grade dedication
      activities. The inspection covered all aspects of procurement and procurement
      interfaces. This included a review of the design bases; material requests; procurement
      data sheets; technical evaluations and commercial dedication plans; purchase orders;
      10 CFR Part 21 provisions; receiving inspection records; storage; corrective action
      program; interfaces between design, procurement engineering, procurement and QA;
      personnel training and qualification; and internal and external oversight. The objectives
      of the inspection were to verify that these activities were performed in accordance with
      the applicable QA programs and NRC requirements.
      Specifically, the inspectors:
      1) Reviewed audit reports of procurement activities at the site.
      2) Independently reviewed material requests, technical specifications in procurement
          data sheets, and procurement documents to determine whether they invoked the
          applicable Quality Assurance (QA) requirements and the applicable codes and
          standards; and whether the specified design parameters were in accordance with
          those listed in the design specifications. This included ASME Code Section III
          requirements and environmental and seismic qualifications.
      3) Reviewed purchasing documents for basic components to determine whether they
          imposed the requirements of 10 CFR 21 and whether the suppliers were on the
          approved suppliers list.
      4) Reviewed two samples of commercial grade dedication, to determine the adequacy
          of the dedication plan including the identification of critical characteristics, and to
          ascertain that the completed dedication activities complied with the dedication plan.
      5) Reviewed for adequacy, the requirements specified in the procurement documents
          for documentation and acceptance of purchased items and sampled certificate of
          conformances (COCs).
      6) Reviewed procurement documents to determine whether source verification was
          specified for complex engineered items when required and whether the appropriate
          receiving inspection organization was aware of the source verification results.
      7) Examined the CONEX trailer to determine the adequacy of implementation for the
          protection, handling and control of purchasing documents.
      8) Examined the system established for conducting receiving inspection including
          facilities and records of acceptance such as COCs to determine whether receiving
          inspection records were available and whether identified discrepancies were
          reviewed by QA and/or engineering, as appropriate, to assure proper disposition.
      9) Examined material receiving inspection records to determine compliance with
          acceptance requirements and to ascertain whether receiving inspections were
          based on acceptable documentation, direct examination, or record of source
          verification.
 
                                              3
  10)    Examined storage facilities for safety-related items to ensure adequate protection
          and compliance with the applicable storage level. The inspectors checked for
          proper segregation and identification of nonconforming items. The warehouses
          examined included warehouse number 6 where the kick and count inspection takes
          place, warehouse number 8 where Quality Control (QC) inspection takes place, and
          warehouse number 7 where items are stored for issue to the field. Warehouse
          number 7 also included storage of items originally intended for warehouses 6 and 8.
  11)    Reviewed purchaser notification points, hold points, and access rights when
          required to be included in procurement documents.
b.  Observations and Findings
    The inspectors identified three violations of regulatory requirements as discussed below:
    Violation 1:
    Introduction: A Severity Level (SL) IV non-cited violation (NCV) of 10 CFR 50, Appendix
    B, Criterion XV, Nonconforming Materials, Parts, or Components, was identified by the
    inspectors for the failure to have procedures for identification, documentation and
    segregation of materials identified as nonconforming to Purchase Order (PO)
    requirements by the kick and count inspection. Specifically, effective measures did not
    exist to segregate or properly identify hydraulic snubbers procured under PO 63534 as
    nonconforming to the PO identification requirements.
    Description: On June 8, 2010, the inspectors conducted a walk-down of warehouse
    facilities at the WBN2 site. In warehouse number 7, the inspectors observed crates
    containing hydraulic snubbers that had not been subjected to QC receipt inspection,
    stored next to receipt inspected materials available for issue. Further review indicated
    that some of these snubbers did not conform to the PO requirements in that they did not
    have all the required identification. The finding was determined to be more than minor
    because it represented an improper and uncontrolled work practice that can impact
    quality or safety, involving nonconforming safety-related hydraulic snubbers, being
    stored without proper identification in close proximity to other materials available for use.
    This condition was documented in PER 234358. The cause of this finding was directly
    related to the resources component of the Human Performance cross-cutting area, as
    defined in IMC 0310, because TVA failed to provide a complete, accurate and up-to-date
    procedure, 25402-000-GPP-0000-N6104, Material Receiving, Revision (Rev.) 4, to
    address the handling of materials identified as nonconforming to PO requirements at the
    kick and count stage of the receiving inspection (H.2(c)).
    Enforcement: 10 CFR, Part 50, Appendix B, Criterion XV, Nonconforming Materials,
    Parts, or Components, states in part that measures shall be established to control
    materials, parts, or components which do not conform to requirements in order to
    prevent their inadvertent use or installation. These measures shall include, as
    appropriate, procedures for identification, documentation, segregation, disposition, and
    notification to affected organizations.
    Contrary to the above, on June 8, 2010, the inspectors observed crates containing
    hydraulic snubbers being stored next to receipt inspected materials available for issue
    even though some of the snubbers did not conform to the PO requirements, in that they
    did not have all the required identification. In addition, the affected snubbers were not
    properly identified as nonconforming. Although procedures SPP-4.3, Rev. 0006, section
    3.5 and 25402-000-GPP-0000-N6104, Rev. 4, section 6.5.12, require the immediate
 
                                            4
segregation or identification of nonconforming material, these requirements apply to the
QC portion of the receiving inspection and not the kick and count portion. This finding
was determined to be a SL IV violation using Supplement II of the Enforcement Policy.
Because this was a SL IV violation and because it was entered into the corrective action
program as PER 234358, it is being treated as a NCV consistent with Section VI.A of the
NRC Enforcement Policy: NCV 5000391/2010603-01, Marking and Segregation of
Nonconforming Materials from Accepted Materials Available for Use.
Violation 2:
Introduction: A SL IV NCV of 10 CFR 50, Appendix B, Criterion VI, Document Control,
was identified by the inspectors for the failure to establish adequate measures to control
the issuance of documents. Specifically, the applicant failed to establish proper storage
and control of documents stored in the CONEX storage area that were used during
performance of safety-related work activities.
Description: On June 8, 2010, the inspectors walked down the CONEX storage area
and interviewed warehouse personnel on its use. The storage area was environmentally
controlled, used fire rated cabinets, and was locked during off shift hours. Files in the
storage area were sometimes removed from storage or copied during performance of
safety-related work activities. A sign-out folder was to be used whenever a file was
removed from the area. The area included a refrigerator that was being used by
personnel to retrieve drinks and food. On June 9, 2010, the inspectors attempted to
retrieve a completed receiving package for PO 31774, I&C Instrument Isolation Valves
ASME Section III, Class 2, Safety-Related. The package had been removed from the
file cabinets without using a sign-out folder. The finding was determined to be more than
minor because it represented an improper and uncontrolled work practice that could
impact quality or safety, involving the use of improperly stored and uncontrolled
documents in safety-related activities. This condition was documented in PER 234281.
The cause of this finding was directly related to the resources component of the Human
Performance cross-cutting area, as defined in IMC 0310, because TVA failed to provide
a complete, accurate and up-to-date procedure, 25402-ADM-001, Document Control,
Rev. 9, that describes what to do with copies of documents once originals have been
transmitted to Document Control and how to control satellite document control facilities
(H.2(c)).
Enforcement: 10 CFR, Part 50, Appendix B, Criterion VI, Document Control, requires
that Measures shall be established to control the issuance of documents, such as
instructions, procedures, and drawings, including changes thereto, which prescribe all
activities affecting quality. These measures shall assure that documents, including
changes, are reviewed for adequacy and approved for release by authorized personnel
and are distributed to and used at the location where the prescribed activity is
performed.
Contrary to the above, some files in the CONEX trailer have been used or copied to
perform safety-related work activities effectively making it a satellite document control
station, and the files in this trailer were not properly protected nor controlled. The area
included a refrigerator containing food and drinks and the receiving records for PO
31774 were missing from the files in the CONEX trailer with no logout folder in place. In
addition, there were no signs in the trailer, on the filing cabinets or on the folders
themselves identifying these records as for information only (FIO). This finding was
determined to be a SL IV violation using Supplement II of the Enforcement Policy.
 
                                          5
Because this was a SL IV violation and because it was entered into the corrective action
program as PER 234281, it is being treated as a NCV consistent with Section VI.A of the
NRC Enforcement Policy: NCV 5000391/2010603-02, Inadequate Storage and Improper
Control of Documents Used in Safety Related Activities.
Violation 3:
Introduction: A SL IV NCV of 10 CFR Part 21 was identified by the inspectors for the
failure to invoke the provisions of 10 CFR Part 21 on a supplier for services of safety-
related components. Specifically, lever arms for limit switches were purchased under
PO 87607. The lever arms were sent to TVA Central Laboratories to perform
commercial grade dedication activities without invoking the provisions of 10 CFR Part
21.
Description: The inspectors reviewed the completed package for PO 87607 and
concluded that it did not invoke the provisions of 10 CFR Part 21 on TVA Central
Laboratories. The inspectors also reviewed intergroup agreement (IGA) -11, Central
Laboratories, Rev. 001. This agreement, which is between TVA Nuclear Power Group
(NPG) and TVA Central Laboratories, establishes the responsibilities and requirements
in providing requested services. The inspectors noted that this agreement did not invoke
the provisions of 10 CFR Part 21. The finding was determined to be more than minor
because it represented an improper and uncontrolled work practice that can impact
quality or safety, involving the issuance of procurement documents that did not invoke
the provisions of 10 CFR Part 21. This condition was documented in PER 235485.
There was no cross-cutting aspect associated with this violation.
Enforcement: 10 CFR Part 21.31 states that each individual, corporation, partnership,
dedicating entity, or other entity subject to the regulations in this part shall ensure that
each procurement document for a facility, or a basic component issued by him, her or it
on or after January 6, 1978, specifies, when applicable, that the provisions of 10 CFR
Part 21 apply.
Contrary to the above, PO 87607 did not specify that the provisions of 10 CFR Part 21
applied to TVA Central Laboratories nor did IGA-11, between TVA (NPG) and TVA
Central Laboratories. This finding was determined to be a SL IV violation using
Supplement II of the Enforcement Policy. Because this was a SL IV violation and
because it was entered into the corrective action program as PER 235485, it is being
treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV
5000391/2010603-03, Failure to Invoke 10 CFR Part 21 in Safety Related Procurement
Documents.
In addition, the inspectors made the following observations as a result of their
inspections:
*        The dedication performed by TVA Central Laboratories for NAMCO limit switch
        lever arms purchased under PO 87607 was accepted even though it did not fully
        meet the dedication plan for verification of manufacturer and part number. This
        condition was documented in PER 234290.
*        Level B Condition Examples on page 14 of CAP procedure 25402-MGT-0003,
        Rev. 7 cover repetitive supplier nonconformances detected during receiving but
        since trending only covers conditions documented in PERs, other
 
                                                  6
                nonconformances detected during the kick and count portion of the receiving
                inspection will not support this trending effort.
    c. Conclusions
        Problems were identified in the areas of equipment storage, document control and
        invoking the provisions of 10 CFR Part 21 as documented above. Other inspected
        procurement, receiving and storage activities were performed in accordance with the
        applicable QA programs and NRC requirements.
II. Management Oversight and Controls
C.1    Construction Activities
C.1.1 Instrument Components and Systems - Work Observation (IP 52053)
    a.  Inspection Scope
        The inspectors reviewed safety-related instrumentation components and systems by
        direct observation of work performance and work in progress to verify related activities
        were performed in accordance with NRC requirements and applicant procedures. Four
        samples were inspected and selected from those associated with the reactor trip system
        and the engineered safety features actuation system. Specifically, the inspectors
        reviewed receiving documents, component identification, controls for potential
        nonconforming components, storage conditions, qualifications of warehouse personnel,
        and physical condition of the components. The inspectors interviewed responsible
        personnel associated with receiving inspection and conducted walk-downs of
        warehouses 7, 8, and the Spring City facility to observe the storage facilities for
        purchased instrument components. The following items were inspected:
            *  2-FT-68-6A (Receipt and Storage)
             *  2-PT-68-340D (Receipt and Storage)
            *  2-FT-68-48A (Receipt and Storage)
            *  Westinghouse Power Range Detector (Storage)
            *  2LT-063-180, 181, 182, 183 (Receipt)
        The following samples were inspected:
            *  IP 52053 Section 02.02.a - four samples
            *  IP 52053 Section 02.02.b - four samples
        Additionally, the inspectors reviewed in-process work orders for containment sump level
        transmitters. The inspectors verified the transmitters were bench calibrated with proper
        control of measuring and test equipment.
    b. Observations and Findings
        No findings of significance were identified.
    c.  Conclusions
        Adequate receipt and storage controls were established for the inspected samples.
 
                                                  7
C.1.2 Instrumentation Installation Activities- Work Observation (IP 52053)
   a. Inspection Scope
   a. Inspection Scope
  During this inspection period, the inspectors reviewed problem evaluation reports
      The inspectors interviewed responsible personnel, reviewed documentation, and
(PERs) as part of TVA's corrective action program to verify that issues being identified under the corrective action program were being properly identified, addressed, and resolved by TVA. Additionally, the inspectors reviewed three recent Bechtel QA surveillance reports regarding ongoing nondestructive examination work activities.  
      evaluated Unit 2 instrument installation activities.
   b. Observations and Findings
      The inspectors interviewed responsible construction oversight personnel to determine
  No findings of significance were identified.  
      the status of installation activities being performed at Unit 2. The inspectors reviewed
      installation procedures MAI-4.4A, Instrument Line Installation and MAI-4.4B,
      Instrument and Instrument Panel Installation to determine the verification, testing and
      documentation requirements for instrument and instrument line installation. The
      inspectors performed walk downs to evaluate the installation activities in the north and
      south fan rooms to determine the progress and quality of installation activities.
      The following items were inspected:
          *    2-LT-003-0094-F - Steam Generator 2 Narrow Range Level
          *    2-LT-003-0156-A - Steam Generator 2 Narrow Range Level
          *    2-RTV-003-0285A - Root Valve for 2-LT-3-42/174
   b. Observations and Findings
      No findings of significance were identified.
   c. Conclusions
   c. Conclusions
   Generally, the PERs reviewed were properly identified, addressed, and resolved; however, as noted in Section C.1.4, Structural Concrete, a violation of regulatory requirements was identified for failure to promptly identify and correct a condition adverse to quality.  
      The inspection results are too limited to support a conclusion at this time.
  Q.1.2 Safety Conscience Work Environment (IP 35007) 
C.1.3 Pipe Support and Restraint Systems (IP 50090, 46071, and TI 2512/023)
   a. Inspection Scope
      The inspectors reviewed procedures and instructions pertaining to pipe support and
      restraint systems to determine if they had been evaluated and approved by appropriate
      applicant personnel. The inspectors also conducted interviews with personnel engaged
      in pipe support installation and performed work observations to confirm adequate
      performance of pre-installation checks, field adjustments, equipment control, and
      calibrations. The inspectors assessed whether that personnel had received the
      appropriate training, had the latest revisions of applicable drawings, and significant
      modifications to supports had been approved by appropriate personnel.
      The inspectors conducted walk-downs of the following installed safety-related pipe
      supports to verify their compliance with NRC requirements and applicant commitments:
          *    H-406-14-23-72 (Chemical and Volume Control System (CVCS))
          *    H-406-14-23-71 (CVCS)
          *    2-47A462-11-172 (Ice Condenser System)
          *    2-47A462-11-173 (Ice Condenser System)
          *    2-47A462-11-174 (Ice Condenser System)
          *    2-47A450-26-304 (Essential Raw Cooling Water (ERCW) System)
      Specifically, the inspectors performed a visual inspection to verify the absence of
      deformation and corrosion. Independent measurements were also performed to
      determine whether the installed configuration of pipe supports was consistent with final
      as-built drawings.
 
                                            8
  The inspectors also observed applicable controls of specific processes and activities
  including torquing of bolts, minimum spacing between bolts, slippage of nut during
  installation, and number of washers used on bolts for the following supports:
  SUPPORT ID # (2 bolts per support)
  110714210-570
  110714210-385
  110714210-386
  110714210-373
  110714210-358
  110714210-413
  110714210-380
  110714210-158
  110714210-304
  110714210-115
  110714210-351
  110714210-329
  995417923-153
  995417923-055
  995417923-170
  SUPPORT ID# (4 bolts per support)
  110714194-084
  110714194-126
  110714194-128
  110714194-129
  The following samples were inspected:
      *    IP 50090 Section 02.02.a - one sample
      *    IP 50090 Section 02.03.a - one sample
      *    IP 50090 Section 02.03.b - two samples
      *    IP 50090 Section 02.03.d.2 - six samples
      *    IP 50090 Section 02.03.d.2 - six samples
      *    IP 50090 Section 02.03.f - six samples
      *    IP 46071 Section 02.02.b - 46 samples
b. Observations and Findings
  The inspectors identified the following NCV:
  Introduction: A SL IV NCV of 10 CFR 50, Appendix B, Criterion V, Instructions,
  Procedures, and Drawings, was identified by the inspectors for failure to identify
  improper weld size by the welder, field engineer, and quality control (QC) in accordance
  with applicable instructions, procedures, and drawings.
  Description: On February 25, 2010, the inspectors performed a walk-down of newly-
  installed pipe supports to determine whether their as-installed configurations matched
  those specified by the applicable drawing revision authorizations (DRAs). The
  inspectors identified an example where the weld throat did not meet the minimum size
  requirements, specified by DRA 52897-005, for a weld joining an embed plate to pipe
  support 2-47A450-26-304 for the safety-related ERCW system.


                                          9
Specifically, the inspectors identified that Weld #1 joining embed plate 48N913-8B to
pipe support 2-47A450-26-304 was (1) not welded in accordance with the drawings; (2)
was verified and signed off by the field engineer (FE) despite the incorrect weld size; and
(3) was accepted by QC despite the fact that the weld size did not meet the acceptance
criteria specified in DRA 52897-005.
On February 26, 2010 the applicant initiated PER 219205 to document the conditions
identified by the inspectors. The applicant concluded that although the weld had been
final accepted by QC, it did not meet the size requirements specified by DRA 52897-005,
and would have to be repaired or reworked. An initial extent of condition evaluation was
performed and included re-inspection of 67 safety-related welds, 18 of which were found
not to meet the acceptance criteria. The applicants review of this issue and follow-up
extent of condition review, which identified the additional 18 undersize weld, extended
into the inspection period covered by this report and is the reason this violation is
documented in this inspection report.
This finding was determined to be more than minor because it represented an
inadequate work activity and inadequate quality oversight function that, if left
uncorrected, could adversely affect the quality of the construction and records of a
safety-related system, the ERCW system. The cause of this finding was directly related
to the work practices component of the Human Performance cross-cutting area, as
defined in IMC 0310, because TVA failed to appropriately communicate human error
prevention techniques, such as self checking, and proper documentation of activities
(H.4 (a)).
Enforcement: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and
Drawings requires in part that activities affecting quality shall be accomplished in
accordance with instructions, procedures, or drawings.
Section 6.1.3 of Bechtel procedure 25402-000-GPP-0000-N3504, Pipe and Instrument
Tubing Supports requires that all materials, work, and services shall fully comply with
the design drawings, specifications, applicable codes and standards. Additionally,
Section 6.3.1 requires that the quality control engineer (QCE) inspect and verify all
inspection attributes for Safety-Related (SR) and Quality Related (QR) activities. These
inspection attributes include orientation, configuration, and dimensions as defined in
attachment B of the procedure. Finally, Section 6.3.7 requires that the FE verify that
hangers and supports are installed in accordance with design output documents,
including drawings.
Contrary to the above, activities affecting quality were not accomplished in accordance
with applicable instructions, procedures, and drawings. Specifically, Weld #1 joining
embed plate 48N913-8B to pipe support 2-47A450-26-304 was (1) not welded in
accordance with the drawings; (2) was verified and signed off by FE despite the incorrect
weld size; and (3) was accepted by QC despite the fact that the weld size did not meet
the acceptance criteria specified in DRA 52897-005.
This finding was determined to be a SL IV violation using Supplement II of the
Enforcement Policy. Because this was a SL IV violation and because it was entered into
the corrective action program as PER 219205, this violation is being treated as a NCV
consistent with Section VI.A of the NRC Enforcement Policy: NCV 5000391/2010603-04,
Undersized Pipe Support Welds.
                                              10
  c. Conclusions
      The inspected activities associated with the installation of pipe supports for those
      discussed above were not performed in accordance with applicant procedures and NRC
      regulations; however, other activities observed were performed in accordance applicable
      procedures.
C.1.4 Structural Concrete (IP 46053)
   a. Inspection Scope
   a. Inspection Scope
  The inspectors continued routine meetings with the Unit 2 Employee Concerns Program (ECP) representative to evaluate the effectiveness of the applicant's program for resolving employee concerns. The inspectors reviewed existing program requirements and all recent safety-related concerns identified by the applicant's and contractor's ECP programs.  The inspectors also verified that significant problems were documented under the corrective action program and were being properly identified, addressed, and resolved by TVA. This included a review of anonymous PERs and trending for the
      The inspectors observed concrete placement activities associated with work order (WO)
months of April and May.  
      09-954333-011. The inspectors interviewed personnel involved with these activities and
  b.  Observations and Findings
      assessed the following conditions prior to and during the placement process:
  No findings of significance were identified.
          *  The pre-placement inspection performed by QC was completed before any
2      c. Conclusions
              concrete was placed.
  The inspectors did not identify any issues or concerns regarding the ability of the applicant to provide a safety-conscience work environment.
          *  The placement area was cleaned and joint preparation was as specified in the
Q.1.3 Procurement, Receiving, and Storage Inspection (IP 35060 and IP 35065)
              construction specification.
a.    Inspection Scope
          *   Records were produced, reviewed, and indicated mix, location, time placed,
   The inspectors performed a procurement, receiving, and storage inspection in accordance with IP 35065, Procurement, Receiving, and Storage, and Section 02.04 of
              water additions, and temperature of the concrete mix and ambient conditions.
IP 35060, Applicant management of QA activities.  In addition, IP 38703, Commercial Grade Dedication, was used for guidance in reviewing commercial grade dedication activities.  The inspection covered all aspects of procurement and procurement interfaces. This included a review of the design bases; material requests; procurement data sheets; technical evaluations and commercial dedication plans; purchase orders; 10 CFR Part 21 provisions; receiving inspection records; storage; corrective action program; interfaces between design, procurement engineering, procurement and QA;
          *   Concrete temperature, slump, air content, and unit weight were determined at the
personnel training and qualification; and internal and external oversight.  The objectives of the inspection were to verify that these activities were performed in accordance with the applicable QA programs and NRC requirements.    
              proper location and frequency.
Specifically, the inspectors:
          *   Sampling and testing techniques conformed to the procedures specified in the
1) Reviewed audit reports of procurement activities at the site. 2) Independently reviewed material requests, technical specifications in procurement data sheets, and procurement documents to determine whether they invoked the applicable Quality Assurance (QA) requirements and the applicable codes and
              applicable American Society for Testing and Materials (ASTM) standards.
standards; and whether the specified design parameters were in accordance with those listed in the design specifications.  This included ASME Code Section III requirements and environmental and seismic qualifications. 3) Reviewed purchasing documents for basic components to determine whether they imposed the requirements of 10 CFR 21 and whether the suppliers were on the
          *  Test specimens, for concrete strength determination, were sampled at the
approved suppliers list.   4) Reviewed two samples of commercial grade dedication, to determine the adequacy of the dedication plan including the identification of critical characteristics, and to ascertain that the completed dedication activities complied with the dedication plan. 5) Reviewed for adequacy, the requirements specified in the procurement documents for documentation and acceptance of purchased items and sampled certificate of conformances (COCs). 6) Reviewed procurement documents to determine whether source verification was specified for complex engineered items when required and whether the appropriate receiving inspection organization was aware of the source verification results. 7) Examined the CONEX trailer to determine the adequacy of implementation for the protection, handling and control of purchasing documents. 8) Examined the system established for conducting receiving inspection including facilities and records of acceptance such as COCs to determine whether receiving inspection records were available and whether identified discrepancies were reviewed by QA and/or engineering, as appropriate, to assure proper disposition. 9) Examined material receiving inspection records to determine compliance with acceptance requirements and to ascertain whether receiving inspections were  
              required location and frequency and were molded and cured in accordance with
based on acceptable documentation, direct examination, or record of source verification.
              specified requirements.
3    10) Examined storage facilities for safety-related items to ensure adequate protection and compliance with the applicable storage level.  The inspectors checked for
      The following samples were inspected:
proper segregation and identification of nonconforming items. The warehouses
          *  IP 46053 Section 02.03.e - one sample
examined included warehouse number 6 where the kick and count inspection takes
          *  IP 46053 Section 02.03.f - one sample
place, warehouse number 8 where Quality Control (QC) inspection takes place, and
          *  IP 46053 Section 02.03.h - two samples
warehouse number 7 where items are stored for issue to the field. Warehouse
  b. Observations and Findings
number 7 also included storage of items originally intended for warehouses 6 and 8. 11) Reviewed purchaser notification points, hold points, and access rights when required to be included in procurement documents.     b.   Observations and Findings
      The inspectors identified the following NCV:
  The inspectors identified three violations of regulatory requirements as discussed below:
          Introduction: A SL IV NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective
Violation 1:
          Action, was identified by the inspectors for inadequate measures to assure that
  Introduction: A Severity Level (SL) IV non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XV, "Nonconforming Materials, Parts, or Components," was identified by the inspectors for the failure to have procedures for identification, documentation and segregation of materials identified as nonconforming to Purchase Order (PO) requirements by the kick and count inspection.  Specifically, effective measures did not
          conditions adverse to quality, specifically non-conforming safety-related concrete,
exist to segregate or properly identify hydraulic snubbers procured under PO 63534 as nonconforming to the PO identification requirements.
          were promptly identified and corrected.
Description:  On June 8, 2010, the inspectors conducted a walk-down of warehouse facilities at the WBN2 site.  In warehouse number 7, the inspectors observed crates containing hydraulic snubbers that had not been subjected to QC receipt inspection, stored next to receipt inspected materials available for issue.  Further review indicated
          Description: On May 17, 2010, the inspectors observed concrete placement activities
that some of these snubbers did not conform to the PO requirements in that they did not have all the required identification.  The finding was determined to be more than minor because it represented an improper and uncontrolled work practice that can impact quality or safety, involving nonconforming safety-related hydraulic snubbers, being stored without proper identification in close proximity to other materials available for use. 
          associated with work order (WO) 09-954333-011. On May 21, 2010, PER 230811,
This condition was documented in PER 234358.  The cause of this finding was directly related to the resources component of the Human Performance cross-cutting area, as defined in IMC 0310, because TVA failed to provide a complete, accurate and up-to-date procedure, 25402-000-GPP-0000-N6104, Material Receiving, Revision (Rev.) 4, to address the handling of materials identified as nonconforming to PO requirements at the
          Concrete Mixing and Placement Violations, was issued to document issues with
kick and count stage of the receiving inspection (H.2(c)).  
          concrete mixing and placement discrepancies identified during the placement of
Enforcement: 10 CFR, Part 50, Appendix B, Criterion XV, "Nonconforming Materials, Parts, or Components," states in part that "measures shall be established to control materials, parts, or components which do not conform to requirements in order to
          concrete into the floor for support No. 2-70-888 in accordance with WO 09-954333-
prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations." 
          011. Prior to placement, QC rejected the safety-related concrete batch; however, the
Contrary to the above, on June 8, 2010, the inspectors observed crates containing
          concrete was placed with known concerns.
hydraulic snubbers being stored next to receipt inspected materials available for issue even though some of the snubbers did not conform to the PO requirements, in that they did not have all the required identification.  In addition, the affected snubbers were not properly identified as nonconforming.  Although procedures SPP-4.3, Rev. 0006, section 3.5 and 25402-000-GPP-0000-N6104, Rev. 4, section 6.5.12, require the immediate 
4    segregation or identification of nonconforming material, these requirements apply to the QC portion of the receiving inspection and not the kick and count portion.  This finding was determined to be a SL IV violation using Supplement II of the Enforcement Policy.  Because this was a SL IV violation and because it was entered into the corrective action program as PER 234358, it is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV 5000391/2010603-01, Marking and Segregation of
Nonconforming Materials from Accepted Materials Available for Use.
Violation 2:
  Introduction:  A SL IV NCV of 10 CFR 50, Appendix B, Criterion VI, "Document Control," was identified by the inspectors for the failure to establish adequate measures to control the issuance of documents.  Specifically, the applicant failed to establish proper storage and control of documents stored in the CONEX storage area that were used during performance of safety-related work activities.
Description:  On June 8, 2010, the inspectors walked down the CONEX storage area and interviewed warehouse personnel on its use.  The storage area was environmentally
controlled, used fire rated cabinets, and was locked during off shift hours.  Files in the storage area were sometimes removed from storage or copied during performance of safety-related work activities.  A sign-out folder was to be used whenever a file was removed from the area. The area included a refrigerator that was being used by personnel to retrieve drinks and food.  On June 9, 2010, the inspectors attempted to
retrieve a completed receiving package for PO 31774, I&C Instrument Isolation Valves ASME Section III, Class 2, Safety-Related.  The package had been removed from the file cabinets without using a sign-out folder.  The finding was determined to be more than minor because it represented an improper and uncontrolled work practice that could impact quality or safety, involving the use of improperly stored and uncontrolled
documents in safety-related activities.  This condition was documented in PER 234281.  The cause of this finding was directly related to the resources component of the Human Performance cross-cutting area, as defined in IMC 0310, because TVA failed to provide a complete, accurate and up-to-date procedure, 25402-ADM-001, Document Control, Rev. 9, that describes what to do with copies of documents once originals have been
transmitted to Document Control and how to control satellite document control facilities (H.2(c)). Enforcement:  10 CFR, Part 50, Appendix B, Criterion VI, "Document Control," requires that "Measures shall be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is
performed." Contrary to the above, some files in the CONEX trailer have been used or copied to perform safety-related work activities effectively making it a satellite document control station, and the files in this trailer were not properly protected nor controlled.  The area included a refrigerator containing food and drinks and the receiving records for PO 31774 were missing from the files in the CONEX trailer with no logout folder in place.  In
addition, there were no signs in the trailer, on the filing cabinets or on the folders themselves identifying these records as for information only (FIO).  This finding was determined to be a SL IV violation using Supplement II of the Enforcement Policy. 
5    Because this was a SL IV violation and because it was entered into the corrective action program as PER 234281, it is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV 5000391/2010603-02, Inadequate Storage and Improper Control of Documents Used in Safety Related Activities.
Violation 3:
  Introduction:  A SL IV NCV of 10 CFR Part 21 was identified by the inspectors for the failure to invoke the provisions of 10 CFR Part 21 on a supplier for services of safety-related components.  Specifically, lever arms for limit switches were purchased under PO 87607.  The lever arms were sent to TVA Central Laboratories to perform
commercial grade dedication activities without invoking the provisions of 10 CFR Part
21.  Description:  The inspectors reviewed the completed package for PO 87607 and concluded that it did not invoke the provisions of 10 CFR Part 21 on TVA Central Laboratories. The inspectors also reviewed intergroup agreement (IGA) -11, Central Laboratories, Rev. 001.  This agreement, which is between TVA Nuclear Power Group
(NPG) and TVA Central Laboratories, establishes the responsibilities and requirements in providing requested services.  The inspectors noted that this agreement did not invoke the provisions of 10 CFR Part 21.  The finding was determined to be more than minor because it represented an improper and uncontrolled work practice that can impact quality or safety, involving the issuance of procurement documents that did not invoke
the provisions of 10 CFR Part 21.  This condition was documented in PER 235485.  There was no cross-cutting aspect associated with this violation.
Enforcement:  10 CFR Part 21.31 states that "each individual, corporation, partnership, dedicating entity, or other entity subject to the regulations in this part shall ensure that
each procurement document for a facility, or a basic component issued by him, her or it on or after January 6, 1978, specifies, when applicable, that the provisions of 10 CFR Part 21 apply." 
Contrary to the above, PO 87607 did not specify that the provisions of 10 CFR Part 21
applied to TVA Central Laboratories nor did IGA-11, between TVA (NPG) and TVA Central Laboratories.  This finding was determined to be a SL IV violation using Supplement II of the Enforcement Policy.  Because this was a SL IV violation and because it was entered into the corrective action program as PER 235485, it is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy:  NCV
5000391/2010603-03, Failure to Invoke 10 CFR Part 21 in Safety Related Procurement Documents.
In addition, the inspectors made the following observations as a result of their inspections:
* The dedication performed by TVA Central Laboratories for NAMCO limit switch lever arms purchased under PO 87607 was accepted even though it did not fully meet the dedication plan for verification of manufacturer and part number.  This
condition was documented in PER 234290.
* Level B Condition Examples on page 14 of CAP procedure 25402-MGT-0003, Rev. 7 cover repetitive supplier nonconformances detected during receiving but since trending only covers conditions documented in PERs, other 
6    nonconformances detected during the kick and count portion of the receiving inspection will not support this trending effort.
c. Conclusions
  Problems were identified in the areas of equipment storage, document control and
invoking the provisions of 10 CFR Part 21 as documented above.  Other inspected procurement, receiving and storage activities were performed in accordance with the applicable QA programs and NRC requirements.
  II. Management Oversight and Controls 


C.1 Construction Activities
                                                11
C.1.1 Instrument Components and Systems - Work Observation (IP 52053)  
          On June 30, 2010 the inspectors reviewed PER 230811 and discovered that the
          PER and associated actions had been closed and archived. The action to address
          the nonconforming condition did not fully address the discrepancies identified during
          placement as stated in PER 230811. On July 1, 2010, the applicant initiated PER
          237820 to document the inappropriate closure of PER 230811.
          This finding was determined to be more than minor because it represented an
          improper or uncontrolled work practice that can impact quality or safety, involving
          safety-related SSCs, in that the failure to appropriately disposition the nonconforming
          condition (concrete rejected by QC) led to the inadvertent use of concrete of
          indeterminate quality in a safety-related application. The cause of this finding was
          directly related to the work practices component of the Human Performance cross-
          cutting area, as defined in IMC 0310, because the applicant failed to ensure
          supervisory and management of oversight of work, including contractors, such that
          nuclear safety is supported (H.4(c)).
          Enforcement: 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires in
          part that measures shall be established to assure that conditions adverse to quality,
          such as deficiencies, deviations, defective materials, and nonconformances are
          promptly identified and corrected.
          Contrary to the above, measures specified in the Corrective Action Program
          procedure 25402-MGT-003 including oversight by responsible organizations, were
          inadequate to assure that conditions adverse to quality, such as deficiencies,
          deviations, defective materials, and nonconformances were corrected. Specifically,
          PER 230811 was closed inappropriately without an adequate engineering disposition
          for non-conforming (as rejected by QC) safety-related concrete and the responsible
          organization did not verify completion of the PER corrective actions.
          This finding was determined to be a SL IV violation using Supplement II of the
          Enforcement Policy. Because this was a SL IV violation and because it was entered
          into the corrective action program as PER 237820, this violation is being treated as a
          non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement
          Policy: NCV 5000391/2010603-05, Inadequate corrective actions for non-conforming
          safety-related concrete.
  c. Conclusions
      The inspected activities associated with the disposition of non-conforming safety-related
      concrete were not performed in accordance with applicant procedures and NRC
      regulations as noted above.
C.1.5 Safety-Related and RCS Pressure Boundary Piping Records Review (IPs 49055
      and 49065, TI 2512/024)
  a. Inspection Scope
      The inspectors reviewed the applicants actions related to the Heat Code Traceability
      Corrective Action Program (CAP) implementation plan (plan) for Unit 2 following the
      guidance in Temporary Instruction (TI) 2512/024. This CAP was designed to resolve
      issues related to traceability problems identified in the mid-1980s with pressure retaining
      loose piping, fittings, and flange bolting (materials) used in American Society of
      Mechanical Engineers (ASME) applications. The overall objective of the CAP was to


a. Inspection Scope
                                        12
The inspectors reviewed safety-related instrumentation components and systems by direct observation of work performance and work in progress to verify related activities were performed in accordance with NRC requirements and applicant procedures. Four samples were inspected and selected from those associated with the reactor trip system and the engineered safety features actuation system.   Specifically, the inspectors reviewed receiving documents, component identification, controls for potential
provide a re-verification of ASME Section III Code compliance of the installed hardware.
nonconforming components, storage conditions, qualifications of warehouse personnel, and physical condition of the components. The inspectors interviewed responsible personnel associated with receiving inspection and conducted walk-downs of warehouses 7, 8, and the Spring City facility to observe the storage facilities for purchased instrument components. The following items were inspected:
The plan for the CAP was designed to address the following identified issues and to
* 2-FT-68-6A (Receipt and Storage)
provide for recurrence control:
* 2-PT-68-340D (Receipt and Storage)
    *  ASME systems containing lower class ASME or ASTM material; and
* 2-FT-68-48A (Receipt and Storage)
    *  ASTM plate material attached to ASME pressure boundaries.
* Westinghouse Power Range Detector (Storage)
The inspectors compared the Unit 2 plan to the Unit 1 plan to evaluate the similarity of
* 2LT-063-180, 181, 182, 183 (Receipt)
approach for both units and to determine whether any differences were appropriate.
The following samples were inspected:  
Overall, the inspectors reviewed records related to ASME Section III, Class 1, 2, and 3
* IP 52053 Section 02.02.a - four samples
pressure retaining materials to determine if the applicant was effectively implementing
* IP 52053 Section 02.02.b - four samples Additionally, the inspectors reviewed in-process work orders for containment sump level transmitters.  The inspectors verified the transmitters were bench calibrated with proper control of measuring and test equipment. b. Observations and Findings
the Unit 2 plan. The inspectors reviewed applicant efforts to resolve unverified non-
No findings of significance were identified.    c. Conclusions
destructive evaluation (NDE) for Class 1, 2, and 3 pressure retaining materials as well as
  Adequate receipt and storage controls were established for the inspected samples.
recurrence control efforts. More specifically, the inspectors:
      
    *  Reviewed records to determine if the required performance tests, nondestructive
7    C.1.2 Instrumentation Installation Activities- Work Observation (IP 52053) a. Inspection Scope
      tests, and other specification requirements were met and if the required
The inspectors interviewed responsible personnel, reviewed documentation, and evaluated Unit 2 instrument installation activities.  The inspectors interviewed responsible construction oversight personnel to determine the status of installation activities being performed at Unit 2. The inspectors reviewed  
      inspections were performed. The inspectors reviewed the applicants efforts to
installation procedures MAI-4.4A, "Instrument Line Installation" and MAI-4.4B, "Instrument and Instrument Panel Installation" to determine the verification, testing and documentation requirements for instrument and instrument line installation. The inspectors performed walk downs to evaluate the installation activities in the north and south fan rooms to determine the progress and quality of installation activities. The following items were inspected: 
      ensure adequate traceability and Code compliance of Class 1, 2, and 3 pressure
  * 2-LT-003-0094-F - Steam Generator 2 Narrow Range Level
      retaining materials to determine if those efforts were being performed in
* 2-LT-003-0156-A - Steam Generator 2 Narrow Range Level
      accordance with the plan;
* 2-RTV-003-0285A - Root Valve for 2-LT-3-42/174
    * Reviewed the applicant/contractor system for reporting and dispositioning
  b. Observations and Findings
      nonconforming materials associated with the reactor coolant pressure boundary
No findings of significance were identified.  c. Conclusions
      piping and other safety-related piping and two nonconforming reports to
  The inspection results are too limited to support a conclusion at this time.   
      determine:
C.1.3 Pipe Support and Restraint Systems (IP 50090, 46071, and TI 2512/023)
            * whether the records adequately documented the status of the
                nonconformances;
            * whether the sample of records was legible and complete; and,
            * whether the records were being properly identified and stored.
     *  Performed field walk-downs on nine Class 1 welds, four Class 2 welds, one
      Class 3 weld, and one Class 2 valve to evaluate the base metal traceability to the
      material certifications and the adequacy of the material certifications compared to
      the relevant Code requirements. This review included 27 loose material pieces
      consisting of 17 separate heat numbers installed in four systems. The nine
      reactor coolant pressure boundary welds reviewed included five 3/4 diameter,
      two 2 diameter, and two 3 diameter parts. These reactor coolant pressure
      boundary parts were located in the reactor coolant, chemical and volume control,
      and safety injection systems. The specific list of welds that were inspected is
      included in the Attachment to this report;
    * Performed field walk-downs of welds 2-068A-T035-27 and 2-068A-T015-27,
      which were annotated in the N-5 database as being removed, to evaluate the
      accuracy of the database; and,
    *  Reviewed Bechtel and TVA procurement and material control procedures to
      determine if the procedures contained appropriate recurrence control elements;
The inspectors interviewed ASME N-5 personnel about TVAs implementation of the
plan. The inspectors also reviewed Boundary Information Transmittals (BIT),
engineering evaluations, work orders, material certification packages (weld map,


a. Inspection Scope
                                                  13
  The inspectors reviewed procedures and instructions pertaining to pipe support and restraint systems to determine if they had been evaluated and approved by appropriate applicant personnel.  The inspectors also conducted interviews with personnel engaged
      certified mill test reports, certificates of compliance, weld fit-up data sheets, and
in pipe support installation and performed work observations to confirm adequate performance of pre-installation checks, field adjustments, equipment control, and calibrations. The inspectors assessed whether that personnel had received the appropriate training, had the latest revisions of applicable drawings, and significant modifications to supports had been approved by appropriate personnel.       
      examination record data sheets), historical condition reports, and the Unit 1 plan to
      evaluate the applicants plan for Unit 2. Other documents reviewed are also included in
      the attachment.
      These inspection activities reviewed a portion of the applicants plan. Therefore, this
      CAP remains open.
  b. Observations and Findings
      No findings of significance were identified.
      During implementation of the Unit 2 plan, the applicant identified numerous traceability
      concerns with installed materials and addressed each issue by writing a BIT. The
      inspectors reviewed two BITs and determined the BITs appropriately characterized the
      nonconformance and the BITs were in conformance with all applicable procedures.
      Additionally, the inspectors reviewed all deviations between the plans for both units and
      determined that they were acceptable because the scope of the Unit 2 plan exceeded
      the scope of the Unit 1 plan. For example, the plan for Unit 1 consisted of a statistical
      sampling of all Class 2 & 3 materials to obtain a 95% confidence level that all materials
      complied with the Code; however, the applicant reviewed all Class 2 & 3 materials for
      Unit 2 and did not rely on a statistical sampling technique to ensure Code compliance.
  c. Conclusions
      The applicants closure plan for the Heat Code Traceability CAP was similar to the plan
      used to close the Unit 1 CAP with no unacceptable deviations identified. The applicant
      was effectively implementing the Unit 2 plan for those activities reviewed during this
      inspection.
C.1.6 Cable Signal Tracing - Work Observation (TI 2512/016, IP 52053)
  a.  Inspection Scope
      The inspectors reviewed calculation EDQ00299920090014, Engineering Document
      Construction Release (EDCR) 54264, and WO 111010149 associated with the signal
      tracing of B-train, safety-related cable 2V1916B. Additionally, the inspectors interviewed
      responsible engineering staff and observed field cable signal tracing activities.
  b. Observations and Findings
      No findings of significance were identified. The inspectors determined that the pre-job
      briefings were adequate, covering staff qualifications, equipment calibration and
      operating conditions, other staff assistance requirements for providing ladders and
      access to spaces inside the Auxiliary Building, operations coordination, and appropriate
      tools. The inspectors verified that the staff performing the tracing were following proper
      peer-to-peer verification procedures. The inspectors observed the signal tracing;
      however, the applicant noted the results did not appear reasonable to accurately identify
      routing. It was identified that the routing picked up by the tracing was different from the
      routing shown on the drawings and Integrated Cable and Raceway Design System
      (ICRDS) data sheets. At the end of the inspection period, the applicant was still
       investigating the tracing anomaly.


The inspectors conducted walk-downs of the following installed safety-related pipe supports to verify their compliance with NRC requirements and applicant commitments:
                                                    14
* H-406-14-23-72 (Chemical and Volume Control System (CVCS))
  c.    Conclusions
* H-406-14-23-71 (CVCS)
        Further inspection is needed to verify ICRDS is updated with the results from the signal
* 2-47A462-11-172 (Ice Condenser System)
        tracing.
* 2-47A462-11-173 (Ice Condenser System)
C.1.7 RPV Internals and Protection of Installed Plan Equipment during Construction
* 2-47A462-11-174 (Ice Condenser System)
        Activities (IP 50053)
* 2-47A450-26-304 (Essential Raw Cooling Water (ERCW) System)
  a.  Inspection Scope
Specifically, the inspectors performed a visual inspection to verify the absence of  
        During the inspection period, the inspectors conducted observations of the reactor
deformation and corrosion. Independent measurements were also performed to determine whether the installed configuration of pipe supports was consistent with final as-built drawings.      
        pressure vessel (RPV) condition assessment activities. The assessment activities
8    The inspectors also observed applicable controls of specific processes and activities including torquing of bolts, minimum spacing between bolts, slippage of nut during installation, and number of washers used on bolts for the following supports:  
        included walk-downs and non-destructive examinations (NDEs). This inspection was to
        determine whether requirements, work procedures, and inspection (quality control)
SUPPORT ID  # (2 bolts per support)  
        procedures were being met. The inspectors also observed ongoing visual examination
   110714210-570 110714210-385 110714210-386 110714210-373 110714210-358 110714210-413
        activities performed by PCI Energy Services (PCI) inside the RPV. Housekeeping and
110714210-380 110714210-158 110714210-304 110714210-115 110714210-351 110714210-329 995417923-153
        protection controls of the RPV were observed to determine whether procedural
995417923-055 995417923-170
        requirements were being met. These activities are controlled by procedure 25402-000-
SUPPORT ID#  (4 bolts per support)
        GPP-0000-N2102, Housekeeping. Specific documents reviewed are listed in the
   110714194-084 110714194-126 110714194-128 110714194-129
        attachment.
The following samples were inspected:
        The following samples were inspected:
        *       IP 50053 Section 02.01.c - one sample
        *       IP 50053 Section 02.02.a - one sample
        *       IP 50053 Section 02.03.b - one sample
        *       IP 50053 Section 02.03.c - one sample
    b. Observations and Findings
        No findings of significance were identified.
    c. Conclusions
        Adequate controls were in place to protect the RPV during the inspection period.
C.1.8 Reactor Coolant System (RCS) Piping (IP 49053)
   a.      Inspection Scope
        The inspectors observed work activities associated with the reactor coolant system
        including loops 1 through 4 hot legs and cold legs. The inspectors entered and visually
        examined the piping to verify the material condition. The inspectors also verified the
        following:
            *  Inspection (QC) and/or work performance verification, including specified
                frequency of inspections
            *   Utilization of qualified inspection personnel
            *   Control of nonconforming items


* IP 50090 Section 02.02.a - one sample
                                              15
* IP 50090 Section 02.03.a - one sample  
  The following samples were inspected:
* IP 50090 Section 02.03.b - two samples
    *       IP 49053 Section 02.03 - one sample
* IP 50090 Section 02.03.d.2 - six samples
    *       IP 49055 Section 02.02 - one sample
* IP 50090 Section 02.03.d.2 - six samples
b. Observations and Findings
* IP 50090 Section 02.03.f - six samples
  The inspectors identified the following unresolved item:
* IP 46071 Section 02.02.b - 46 samples
  Introduction: The inspectors identified an unresolved item (URI) related to the material
b. Observations and Findings
  condition inside of the loop-3 RCS crossover piping.
  The inspectors identified the following NCV:  
  Description: On June 30, 2010, the inspectors reviewed PER 224434 associated with
Introduction: A SL IV NCV of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was identified by the inspectors for failure to identify improper weld size by the welder, field engineer, and quality control (QC) in accordance with applicable instructions, procedures, and drawings.    
  the material condition of the loop-3 RCS crossover piping. The inspectors had
Description: On February 25, 2010, the inspectors performed a walk-down of newly-installed pipe supports to determine whether their as-installed configurations matched those specified by the applicable drawing revision authorizations (DRAs). The inspectors identified an example where the weld throat did not meet the minimum size requirements, specified by DRA 52897-005, for a weld joining an embed plate to pipe support 2-47A450-26-304 for the safety-related ERCW system.  
  previously entered the loop-3 crossover piping on March 20 and 21 to inspect the
9   Specifically, the inspectors identified that Weld #1 joining embed plate 48N913-8B to pipe support 2-47A450-26-304 was (1) not welded in accordance with the drawings; (2) was verified and signed off by the field engineer (FE) despite the incorrect weld size; and (3) was accepted by QC despite the fact that the weld size did not meet the acceptance criteria specified in DRA 52897-005.  
  material condition of the interior of the piping as documented in inspection report
  05000391/2010602. During that time and after work had been completed and signed off
On February 26, 2010 the applicant initiated PER 219205 to document the conditions identified by the inspectors.  The applicant concluded that although the weld had been final accepted by QC, it did not meet the size requirements specified by DRA 52897-005, and would have to be repaired or reworked.  An initial extent of condition evaluation was performed and included re-inspection of 67 safety-related welds, 18 of which were found
  by QC. The inspectors noted that some potential areas of pitting had not been
not to meet the acceptance criteria. The applicant's review of this issue and follow-up extent of condition review, which identified the additional 18 undersize weld, extended into the inspection period covered by this report and is the reason this violation is documented in this inspection report.
  documented by the applicant as specified in WO 110739214. Specifically, Step 5.5.3.C
This finding was determined to be more than minor because it represented an inadequate work activity and inadequate quality oversight function that, if left
  of WO 110739214, stated the following:
uncorrected, could adversely affect the quality of the construction and records of a safety-related system, the ERCW system. The cause of this finding was directly related to the work practices component of the Human Performance cross-cutting area, as defined in IMC 0310, because TVA failed to appropriately communicate human error prevention techniques, such as self checking, and proper documentation of activities
            After cleaning, the surface of the RCS piping and welds shall be visually
(H.4 (a)).  
            examined to determine if surface pitting has occurred. The pipe interior shall be
Enforcement:  10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings" requires in part that activities affecting quality shall be accomplished in accordance with instructions, procedures, or drawings.
            inspected for any area showing a reduction in wall thickness as PER NDRF
            211911. Any suspect areas shall be forwarded to engineering for inspection and
            further evaluation.
   In addition, Appendix B of the Corrective Action Program procedure 25402-MGT-003
  requires that nonconforming items be dispositioned by engineering and a technical
  justification be included for Accept-As-Is or Repair.
  As result of the NRCs questions, on April 7, 2010 the applicant initiated PER 224434 to
  address the issues identified by the NRC related to the material condition of the
  crossover piping and document the location of these potential areas of concern;
  however, on June 30 after further review of the PER, the inspectors noted that corrective
  action 224434-002 included an engineering disposition unrelated to the issue and
  instead addressed a 3 drain line.
  The inspectors concluded that in order to properly evaluate the applicants disposition of
  this issue, additional inspection would be required to determine (1) whether areas of
  concern (potential pitting) were properly identified and documented at the time by QC
  and FE in accordance with applicable instructions and procedures; and (2) whether the
  engineering disposition appropriately addressed the area of concern. This issue was
  identified as URI 05000391/2010603-06, Material Condition Inside Loop-3 RCS
  Crossover Piping.
c. Conclusions
  The inspectors concluded that additional inspection would be required to resolve
  questions associated with material condition of RCS piping.


Section 6.1.3 of Bechtel procedure 25402-000-GPP-0000-N3504, "Pipe and Instrument Tubing Supports" requires that all materials, work, and services shall fully comply with the design drawings, specifications, applicable codes and standards. Additionally, Section 6.3.1 requires that the quality control engineer (QCE) inspect and verify all
                                              16
inspection attributes for Safety-Related (SR) and Quality Related (QR) activities.   These inspection attributes include orientation, configuration, and dimensions as defined in attachment B of the procedure. Finally, Section 6.3.7 requires that the FE verify that hangers and supports are installed in accordance with design output documents, including drawings.  
C.1.9 Protection of Installed Plant Equipment During Construction Activities - Reactor
      Coolant Pressure Boundary Piping (IP 49053)
  a. Inspection Scope
      The inspectors performed a walk-down of a sample of installed safety-related welds,
      piping, and components to determine whether the applicant and their contractors had
      established adequate controls for the storage and preservation of safety-related, ASME
      materials and equipment. Specifically, the inspectors performed walk-downs of portions
      of the following systems:
      *  Reactor coolant system (pressurizer surge line, pressurizer spray line, pressurizer
          relief and safety valve lines)
      *  Residual heat removal system
      *  Safety injection system
      The inspectors observed housekeeping activities to determine whether quality
      assurance program requirements were adequately implemented by the applicant and
      their contractors. The inspectors compared observations made to the following quality
      assurance program requirements:
      *  Appendix B, Criterion XIII, Handling, Storage, and Shipping, of 10 CFR Part 50
      *  The TVA quality assurance program, TVA-NQA-PLN89-A, Nuclear Quality
          Assurance Program (NQAP), Rev. 23
      *  Watts Bar Unit 2 Construction Completion Project, Bechtel Project Nuclear Quality
          Assurance Manual (PNQAM), Rev. 6
      *  American National Standards Institute (ANSI) N45.2.3-1973, Housekeeping during
          the Construction Phase of Nuclear Plants, (referenced in both NQAP and PNQAM)
      *  ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage, and handling of
          Items for Nuclear Plants. (Referenced in both NQAP and PNQAM)
      *  ANSI N45.2.8-1975, "Supplementary Quality Assurance Requirements for the
          Installation, Inspection, and Testing of Mechanical Equipment and Systems for the
          Construction of Nuclear Power Plants.
  b. Observations and Findings
      The inspectors identified the following NCV:
      Introduction: The inspectors identified a SL IV, NCV of 10 CFR 50, Appendix B,
      Criterion XIII, Handling, Storage, and Shipping, in that, the applicant failed to control
      the storage and preservation of safety-related material (welds, piping, and components)
      to prevent damage from nearby construction activities. Specifically, the inspectors
      identified multiple locations of weld and paint spatter, arc strikes, and mechanical
      damage on safety-related welds, piping, and components.
      Description: On June 23, 2010, while performing a walk-down of the pressurizer safe-
      end to elbow weld (RCF-D144-11), the inspectors identified multiple examples of weld
      and paint spatter, arc strikes, and mechanical damage (e.g., dents, dings, gouges, etc.)
      on adjacent ASME Class 1, safety-related welds, piping, and components. On June 24,
      2010, the inspectors performed another walk-down of piping systems in the reactor
      building and identified additional examples of weld and paint spatter, arc strikes, and
      mechanical damage on ASME Class 1, safety-related welds, piping, and components.


Contrary to the above, activities affecting quality were not accomplished in accordance with applicable instructions, procedures, and drawings. Specifically, Weld #1 joining embed plate 48N913-8B to pipe support 2-47A450-26-304 was (1) not welded in accordance with the drawings; (2) was verified and signed off by FE despite the incorrect weld size; and (3) was accepted by QC despite the fact that the weld size did not meet the acceptance criteria specified in DRA 52897-005.  
                                          17
The inspectors identified approximately 70 locations of damage associated with welds,
piping, and components within the following systems: (1) reactor coolant system, (2)
safety injection system, and (3) residual heat removal system. The specific issues
identified by the inspectors were documented by the applicant in PER 236720.
The inspectors noted that affected welds, piping, and components were fabricated from
stainless steel alloys, and were all ASME Class 1, pressure boundary items. The
inspectors determined that these issues were reasonably within the applicants ability to
foresee and correct, and should have been prevented.
TVAs Nuclear Quality Assurance Program and the Bechtel PNQAM both require the
implementation of ANSI N45.2.8-1975, "Supplementary Quality Assurance
Requirements for the Installation, Inspection, and Testing of Mechanical Equipment and
Systems for the Construction of Nuclear Power Plants. Section 4.6, Care of Items, of
ANSI N45.2.8-1975, states in part:
    Items on which inspection and testing activities are being performed shall be
    protected from personnel traffic, weather, and adjacent construction activities
    such as sandblasting, acid cleaning, welding, jack hammering, chipping,
    burning and stress relieving that would adversely affect the quality of the item
    or test results. Such protection shall be provided through good cleanliness
    and housekeeping practices, temporary packaging, erection of barriers,
    protective covers, and walkways as required in accordance with Subsection
    2.6.
ANSI N45.2.8-1975, Section 2.6 references ANSI N45.2.3-1973, Housekeeping during
the Construction Phase of Nuclear Plants, which both TVA and Bechtel commit to in
their quality assurance programs. This ANSI standard specifically addresses the
protection of materials and equipment from physical damage during the construction
phase. Bechtel implements the requirements of ANSI N45.2.3-1973 through adherence
to Procedure 5402-000-GPP-0000-N2102, Housekeeping. Section 6.11,
Housekeeping During Construction Activities, of this procedure, states in part:
    Barriers, screens, shields, restricted access, or other protection shall be
    provided as necessary for isolation of areas where dust, inclement weather,
    or other conditions exist that may affect the quality of work being performed.
    This protection should be maintained throughout the work cycle.
Based on the applicants preliminary evaluation of the conditions identified, the
inspectors determined that the applicant failed to provide adequate protection of safety-
related welds, piping, and components from adjacent construction activities in
accordance with work and inspection instructions.
The inspectors determined that this finding was more than minor because it represented
an inadequate quality oversight function that, if left uncorrected, could adversely affect
the quality of the construction of safety-related, pressure boundary welds, piping, and
components. Specifically, these conditions could render the quality of the installed items
unacceptable or indeterminate. Additionally, the repairs or rework required to correct the
identified conditions may require additional examinations to verify conformance with the
construction code of record. Furthermore, the applicant had previously completed pre-
service inspections on some of the affected welds, and depending on the repair required
to correct the condition, the pre-service examination results may be invalidated.


This finding was determined to be a SL IV violation using Supplement II of the Enforcement Policy. Because this was a SL IV violation and because it was entered into the corrective action program as PER 219205, this violation is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV 5000391/2010603-04,  
                                                    18
Undersized Pipe Support Welds.  
        This issue was entered into the corrective action program as PER 236720. This PER
 
        stated that some of these issues were likely the result of recent construction activities
10   c. Conclusions
        and others were likely historical issues, in that they were caused by construction and/or
  The inspected activities associated with the installation of pipe supports for those discussed above were not performed in accordance with applicant procedures and NRC regulations; however, other activities observed were performed in accordance applicable procedures.   
        installation activities that occurred prior to 2008. There was no cross-cutting aspect
        associated with this violation.
        Enforcement: 10 CFR 50 Appendix B, Criterion XIII, Handling, Storage, and Shipping,
        requires, in part, that, measures shall be established to control the handling, storage,
        shipping, cleaning and preservation of material and equipment in accordance with work
        and inspection instructions to prevent damage or deterioration.
        TVAs Nuclear Quality Assurance Program and the Bechtel PNQAM both require the
        implementation of ANSI N45.2.8-1975 and ANSI N45.2.3-1973. Section 4.6, Care of
        Items, of ANSI N45.2.8, states in part that, Items on which inspection and testing
        activities are being performed shall be protected from adjacent construction
        activitiesthat would adversely affect the quality of the item or test results.
        Section 6.11, Housekeeping During Construction Activities, of Procedure 5402-000-
        GPP-0000-N2102, Housekeeping, Rev. 8, states in part: Barriers, screens, shields,
        restricted access, or other protection shall be provided as necessary for isolation of
        areas where dust, inclement weather, or other conditions exist that may affect the quality
        of work being performed.
        Contrary to the above, prior to June 24, 2010, the applicant failed to control the storage
        and preservation of material and equipment in accordance with work and inspection
        instructions to prevent damage from adjacent construction activities as evidenced by
        multiple locations of weld and paint spatter, arc strikes, and mechanical damage on
        safety-related welds, piping, and components.
        This finding was determined to be a SL IV violation using Supplement II of the
        Enforcement Policy. Because this was a SL IV violation and because it was entered into
        the corrective action program as PER 236720, it is being treated as a NCV consistent
        with Section VI.A of the NRC Enforcement Policy: NCV 5000391/2010603-07, Failure to
        Protect Safety-Related Welds, Piping, and Components During Construction Activities.
   c.   Conclusions
        The inspectors identified a violation for the applicants failure to control the storage and
        preservation of material and equipment in accordance with work and inspection
        instructions to prevent damage from nearby construction activities.
C.1.10. Unresolved Item 78-05-02, Reactor Vessel - Nozzle Weld Surface Cracking
  a.  Inspection Scope
        The inspectors conducted interviews and reviewed documentation related to URI 78-05-
        02, Reactor Vessel - Nozzle Weld Surface Cracking, to determine whether the cracking
        had been adequately repaired. The inspectors reviewed welding records and NDE
        reports related to repairs completed to loop four, reactor vessel cold leg nozzle weld 2-
        068C-W004-01, to evaluate compliance with the requirements of ASME Section III,
        1971 edition through the summer 1973 addenda. Following all repairs, the final
        radiographic exam (RT) was performed on May 9, 1978, and was accepted by both the


  C.1.4 Structural Concrete (IP 46053)   
                                                19
        Level II reviewer and Authorized Nuclear Inspector (ANI). However, a subsequent May
        19, 1988, review rejected the May 9, 1978, RT due to excessive geometric unsharpness
        and use of the wrong penetrameter. This issue was generic in nature, in that, during an
        NRC conducted review of RT film for both Unit 1 and Unit 2, 683 Class 1 and Class 2
        welds were identified with geometrical unsharpness issues. See NRC inspection report
        50-390, 391/91-23 for additional information on the RT review. A subsequent
        evaluation, and development of a special procedure per the 1971 edition of the ASME
        Section III, Appendix IX, paragraph IX-3110, was performed by the applicant to resolve
        the geometrical unsharpness issue for Watts Bar Unit 1. See NRC inspection report 50-
        390, 391/91-32 for additional details and disposition.
        As these issues relate to Watts Bar Unit 2, the applicant intends to submit a special
        procedure to the NRC as a proposed alternative per the requirements of 10 CFR
        50.55a, Codes and Standards, and to the ANI for review and acceptance. Further
        inspection of URI 78-05-02 will continue, once those reviews or acceptable alternatives,
        have been completed.
  b.  Observations and Findings
      No findings of significance were identified.
  c. Conclusions
      The inspectors determined that URI 78-05-02, Reactor Vessel - Nozzle Weld Surface
      Cracking will remain open.
C.1.11 Inservice Inspection - Review of Program (IP 73051)
  a. Inspection Scope
      The inspectors reviewed a sample of NDE coverage calculations to determine whether
      the applicant adequately calculated the percentage of code-required examination
      volume coverage obtained. The inspectors also performed a walk-down of the following
      welds in order to evaluate the validity of relief requests intended to be submitted for less
      than 90% NDE coverage within the preservice inspection (PSI) program. The inspectors
      also reviewed the following NDE report coverage diagrams:
      *      CVCF-F-T284-06, 2 Class 1 pipe to flange weld
      *      RCF-G1-4, 31 Class 1 pipe to reactor coolant pump bowl weld
      *      SIF-B-T090-06, 2 Class 2 pipe to flange weld
      *      SIF-D198-06, 6 Class 1 elbow to check valve weld
      The following samples were inspected:
      *      IP 73051 Section 02.09 - 4 samples
  b.  Observations and Findings
      No findings of significance were identified.


  a. Inspection Scope
                                                20
  The inspectors observed concrete placement activities associated with work order (WO) 09-954333-011.  The inspectors interviewed personnel involved with these activities and assessed the following conditions prior to and during the placement process:
  c. Conclusions
* The pre-placement inspection performed by QC was completed before any concrete was placed.  
      The inspectors determined that the observed NDE activities met the requirements
* The placement area was cleaned and joint preparation was as specified in the construction specification.  
      established by the applicants PSI program and the ASME Code.
* Records were produced, reviewed, and indicated mix, location, time placed, water additions, and temperature of the concrete mix and ambient conditions.
C.1.12 Inservice Inspection - Review of Procedures (IP 73052)
* Concrete temperature, slump, air content, and unit weight were determined at the proper location and frequency.
  a.  Inspection Scope
* Sampling and testing techniques conformed to the procedures specified in the applicable American Society for Testing and Materials (ASTM) standards.
      The inspectors reviewed N-UT-78, PDI Generic Procedure for the Manual Ultrasonic
* Test specimens, for concrete strength determination, were sampled at the required location and frequency and were molded and cured in accordance with specified requirements.  
      Examination of Reactor Pressure Vessel Welds PDI-UT-6, Rev. 0005 to determine the
The following samples were inspected:  
      adequacy of both the scope and technical content in meeting the requirements of the 10
* IP 46053 Section 02.03.e - one sample  
      CFR 50.55a Codes and Standards, and Section XI of the ASME Boiler and Pressure
* IP 46053 Section 02.03.f - one sample
      Vessel Code, 2001 edition through 2003 addenda. The inspectors also observed the
* IP 46053 Section 02.03.h - two samples
      procedure in use during the examination of W09-10, reactor pressure vessel head
  b. Observations and Findings
      circumferential weld.
  The inspectors identified the following NCV:
      The following samples were inspected:
Introduction: A SL IV NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action", was identified by the inspectors for inadequate measures to assure that conditions adverse to quality, specifically non-conforming safety-related concrete, were promptly identified and corrected.      
      *       IP 73052 Section 02.03 - 1 sample
Description: On May 17, 2010, the inspectors observed concrete placement activities associated with work order (WO) 09-954333-011. On May 21, 2010, PER 230811,
  b.  Observations and Findings
"Concrete Mixing and Placement Violations," was issued to document issues with concrete mixing and placement discrepancies identified during the placement of concrete into the floor for support No. 2-70-888 in accordance with WO 09-954333-011.  Prior to placement, QC rejected the safety-related concrete batch; however, the concrete was placed with known concerns.  
      No findings of significance were identified.
  c.  Conclusions
      The inspectors determined that the ultrasonic examination procedure reviewed met
      applicable ASME code and 10 CFR 50.55a requirements.
C.1.13 Preservice Inspection - Observation of Work and Work Activities (IP 73053)
  a. Inspection Scope
      The inspectors observed a selected sample of PSI related activities to determine
      whether the onsite preservice inspection of ASME Class 1, 2 and 3 pressure retaining
      components was performed in accordance with the applicants PSI program, Preservice
      Inspection Program Plan, Watts Bar Nuclear Plant Unit 2, Rev 3. Specifically, the
      inspectors observed the ultrasonic (UT) PSI examination of reactor pressure vessel
      head Circumferential Weld W09-10.
      The inspectors observed portions of the examination and reviewed associated NDE
      reports to determine whether the examinations were performed in accordance with
      approved procedures and consistent with the ASME Code of Record for the PSI
      program (ASME, Boiler and Pressure Vessel Code, 2001 edition including 2003
      addenda, Section XI, Division 1, Inservice Inspection of Nuclear Power Plant
      Components). Examination records were reviewed to determine whether they were
      prepared, evaluated, and maintained in accordance with the applicants QA program
      requirements (TVA-NQA-PLN89-A, Rev. 23) and the requirements specified in ASME
      Section XI.


 
                                                21
11    On June 30, 2010 the inspectors reviewed
      Qualification and certification records for examiners, inspection equipment, and
PER 230811 and discovered that
      consumables along with the applicable NDE procedures for the pre-service examination
the PER and associated actions had been closed and archived.  The action to address the nonconforming condition did not fully address the discrepancies identified during placement as stated in PER 230811.  On July 1, 2010, the applicant initiated PER 237820 to document the inappropriate closure of PER 230811. 
      activities were reviewed to determine whether they met the requirements established by
      the applicants PSI program and the ASME Code.
This finding was determined to be more than minor because it represented an improper or uncontrolled work practice that can impact quality or safety, involving safety-related SSCs, in that the failure to appropriately disposition the nonconforming condition (concrete rejected by QC) led to the inadvertent use of concrete of indeterminate quality in a safety-related application. The cause of this finding was
      The following samples were inspected:
directly related to the work practices component of the Human Performance cross-cutting area, as defined in IMC 0310, because the applicant failed to ensure supervisory and management of oversight of work, including contractors, such that nuclear safety is supported (H.4(c)). 
      *        IP 73053 Section 02.03 - 1 sample
Enforcement: 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires in part that measures shall be established to assure that conditions adverse to quality,
  b.  Observations and Findings
such as deficiencies, deviations, defective materials, and nonconformances are promptly identified and corrected.  
      No findings of significance were identified.
Contrary to the above, measures specified in the Corrective Action Program procedure 25402-MGT-003 including oversight by responsible organizations, were
  c.  Conclusions
inadequate to assure that conditions adverse to quality, such as deficiencies, deviations, defective materials, and nonconformances were corrected.  Specifically, PER 230811 was closed inappropriately without an adequate engineering disposition for non-conforming (as rejected by QC) safety-related concrete and the responsible organization did not verify completion of the PER corrective actions.   
      The inspectors determined that the observed NDE activities and qualification records for
 
      examination personnel met the requirements established by the applicants PSI program
This finding was determined to be a SL IV violation using Supplement II of the Enforcement Policy.  Because this was a SL IV violation and because it was entered into the corrective action program as PER 237820, this violation is being treated as a non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement
      and the ASME Code.
Policy: NCV 5000391/2010603-05, Inadequate corrective actions for non-conforming safety-related concrete.  
C.1.14 Preservice Inspection - Data Review and Evaluation (IP 73055)
  c. Conclusions
  a. Inspection Scope
  The inspected activities associated with the disposition of non-conforming safety-related concrete were not performed in accordance with applicant procedures and NRC regulations as noted above.
      The inspectors reviewed a sample of recently completed PSI examination records (NDE
C.1.5 Safety-Related and RCS Pressure Boundary Piping Records Review (IPs 49055            and 49065, TI 2512/024)  
      records) for safety-related systems. The inspectors reviewed these records to determine
a. Inspection Scope
      whether they met the requirements the ASME Code, the associated NDE procedure,
The inspectors reviewed the applicant's actions related to the Heat Code Traceability Corrective Action Program (CAP) implementation plan ("plan") for Unit 2 following the guidance in Temporary Instruction (TI) 2512/024.  This CAP was designed to resolve issues related to traceability problems identified in the mid-1980s with pressure retaining
      and the applicants quality assurance program. Specifically, the inspectors reviewed the
loose piping, fittings, and flange bolting (materials) used in American Society of Mechanical Engineers (ASME) applications.  The overall objective of the CAP was to 
      records to determine whether they contained or referenced the following information:
12    provide a re-verification of ASME Section III Code compliance of the installed hardware.  The plan for the CAP was designed to address the following identified issues and to provide for recurrence control:
      *       Examination results and data sheets
* ASME systems containing lower class ASME or ASTM material; and
      *        Examination equipment data
* ASTM plate material attached to ASME pressure boundaries.  
      *       Calibration data sheets (as applicable)
The inspectors compared the Unit 2 plan to the Unit 1 plan to evaluate the similarity of approach for both units and to determine whether any differences were appropriate.  Overall, the inspectors reviewed records related to ASME Section III, Class 1, 2, and 3 pressure retaining materials to determine if the applicant was effectively implementing
      *       Extent of examination
the Unit 2 plan.  The inspectors reviewed applicant efforts to resolve unverified non-destructive evaluation (NDE) for Class 1, 2, and 3 pressure retaining materials as well as recurrence control efforts. More specifically, the inspectors:
      *       Records on disposition of findings (if applicable)
* Reviewed records to determine if the required performance tests, nondestructive tests, and other specification requirements were met and if the required inspections were performed.  The inspectors reviewed the applicant's efforts to ensure adequate traceability and Code compliance of  Class 1, 2, and 3 pressure
      *        Identification of NDE material such as penetrant, penetrant cleaner, couplant,
retaining materials to determine if those efforts were being performed in accordance with the plan;
                films, tapes, etc.
* Reviewed the applicant/contractor system for reporting and dispositioning nonconforming materials associated with the reactor coolant pressure boundary piping and other safety-related piping and two nonconforming reports to determine:
      The inspectors also reviewed these records to determine whether:
* whether the records adequately documented the status of the nonconformances;
      *        Collected examination data and any recordable indications were properly
* whether the sample of records was legible and complete; and, * whether the records were being properly identified and stored.
                recorded to permit accurate evaluation and documentation.
* Performed field walk-downs on nine Class 1 welds, four Class 2 welds, one Class 3 weld, and one Class 2 valve to evaluate the base metal traceability to the material certifications and the adequacy of the material certifications compared to
      *        Evaluation of examination data was performed by a Level II or Level III
the relevant Code requirements.  This review included 27 loose material pieces consisting of 17 separate heat numbers installed in four systems.  The nine reactor coolant pressure boundary welds reviewed included five 3/4" diameter, two 2" diameter, and two 3" diameter parts.  These reactor coolant pressure boundary parts were located in the reactor coolant, chemical and volume control,  
                examiner.
and safety injection systems.  The specific list of welds that were inspected is included in the Attachment to this report;
      *        Evaluation of examination data was consistent with the procedure.
* Performed field walk-downs of welds 2-068A-T035-27 and 2-068A-T015-27, which were annotated in the N-5 database as being removed, to evaluate the accuracy of the database; and,  * Reviewed Bechtel and TVA procurement and material control procedures to determine if the procedures contained appropriate recurrence control elements;
      *        Evaluation of indications (if applicable) complied with the criteria of the NDE
The inspectors interviewed ASME N-5 personnel about TVA's implementation of the
                procedure and ASME Section XI.
plan.  The inspectors also reviewed Boundary Information Transmittals (BIT), engineering evaluations, work orders, material certification packages (weld map, 
      *       Incomplete examinations and results were repeated to permit full evaluation (if
13    certified mill test reports, certificates of compliance, weld fit-up data sheets, and examination record data sheets), historical condition reports, and the Unit 1 plan to evaluate the applicant's plan for Unit 2.  Other documents reviewed are also included in the attachment. 
                applicable).
These inspection activities reviewed a portion of the applicant's plan.  Therefore, this
CAP remains open.
b. Observations and Findings
No findings of significance were identified. During implementation of the Unit 2 plan, the applicant identified numerous traceability concerns with installed materials and addressed each issue by writing a BIT.  The inspectors reviewed two BITs and determined the BITs appropriately characterized the nonconformance and the BITs were in conformance with all applicable procedures.  Additionally, the inspectors reviewed all deviations between the plans for both units and determined that they were acceptable because the scope of the Unit 2 plan exceeded the scope of the Unit 1 plan.  For example, the plan for Unit 1 consisted of a statistical sampling of all Class 2 & 3 materials to obtain a 95% confidence level that all materials
complied with the Code; however, the applicant reviewed all Class 2 & 3 materials for Unit 2 and did not rely on a statistical sampling technique to ensure Code compliance. c. Conclusions
The applicant's closure plan for the Heat Code Traceability CAP was similar to the plan used to close the Unit 1 CAP with no unacceptable deviations identified.  The applicant
was effectively implementing the Unit 2 plan for those activities reviewed during this inspection.
C.1.6  Cable Signal Tracing - Work Observation (TI 2512/016, IP 52053) a. Inspection Scope
The inspectors reviewed calculation EDQ00299920090014, Engineering Document Construction Release (EDCR) 54264, and WO 111010149 associated with the signal tracing of B-train, safety-related cable 2V1916B. Additionally, the inspectors interviewed responsible engineering staff and observed field cable signal tracing activities.  b. Observations and Findings
No findings of significance were identified. The inspectors determined that the pre-job briefings were adequate, covering staff qualifications, equipment calibration and operating conditions, other staff assistance requirements for providing ladders and access to spaces inside the Auxiliary Building, operations coordination, and appropriate tools.  The inspectors verified that the staff performing the tracing were following proper
peer-to-peer verification procedures.  The inspectors observed the signal tracing; however, the applicant noted the results did not appear reasonable to accurately identify routing.  It was identified that the routing picked up by the tracing was different from the routing shown on the drawings and Integrated Cable and Raceway Design System (ICRDS) data sheets.  At the end of the inspection period, the applicant was still investigating the tracing anomaly.
 
14    c. Conclusions
Further inspection is needed to verify ICRDS is updated with the results from the signal tracing.  
C.1.7 RPV Internals and Protection of Installed Plan Equipment during Construction 
            Activities (IP 50053)  
a. Inspection Scope
  During the inspection period, the inspectors conducted observations of the reactor pressure vessel (RPV) condition assessment activities.  The assessment activities
included walk-downs and non-destructive examinations (NDEs).  This inspection was to determine whether requirements, work procedures, and inspection (quality control) procedures were being met.  The inspectors also observed ongoing visual examination activities performed by PCI Energy Services (PCI) inside the RPV.  Housekeeping and protection controls of the RPV were observed to determine whether procedural requirements were being met.  These activities are controlled by procedure 25402-000-GPP-0000-N2102, Housekeeping.  Specific documents reviewed are listed in the
attachment.
The following samples were inspected:
* IP 50053 Section 02.01.c - one sample
* IP 50053 Section 02.02.a - one sample
* IP 50053 Section 02.03.b - one sample
* IP 50053 Section 02.03.c - one sample
  b. Observations and Findings
  No findings of significance were identified.
  c. Conclusions
  Adequate controls were in place to protect the RPV during the inspection period.  


                                        22
C.1.8 Reactor Coolant System (RCS) Piping (IP 49053)
The inspectors reviewed the following PSI examinations:
a. Inspection Scope
  Report #          NDE          Weld # /       System        Description    ASME
  The inspectors observed work activities associated with the reactor coolant system including loops 1 through 4 hot legs and cold legs.  The inspectors entered and visually
                  Method        Component                                      Class
examined the piping to verify the material condition.  The inspectors also verified the following:  
                                      #
* Inspection (QC) and/or work performance verification, including specified frequency of inspections
  R-P0240          Liquid      RCF-D144-11        Reactor      Safe End to        1
* Utilization of qualified inspection personnel
                  Penetrant                        Coolant      Elbow Weld
* Control of nonconforming items
  R-P0970          Liquid        SIS-163          Safety     Elbow to Pipe      2
      
                  Penetrant                        Injection        Weld
15   The following samples were inspected:
  R-P0972          Liquid      SIF-D123-07        Safety        Valve to        2
* IP 49053 Section 02.03 - one sample 
                  Penetrant                        Injection      Reducer
* IP 49055 Section 02.02 - one sample 
                                                                    Weld
b. Observations and Findings
   R-P0992        Visual        RCP3FLG          Reactor          Flange          1
  The inspectors identified the following unresolved item:
                                                  Coolant
Introduction: The inspectors identified an unresolved item (URI) related to the material condition inside of the loop-3 RCS crossover piping.  
  R-P0993        Magnetic      FWF-D002-03     Feed Water      Valve to Pipe      2
Description: On June 30, 2010, the inspectors reviewed PER 224434 associated with the material condition of the loop-3 RCS crossover piping. The inspectors had previously entered the loop-3 crossover piping on March 20 and 21 to inspect the  
                  Particle                                          Weld
material condition of the interior of the piping as documented in inspection report 05000391/2010602. During that time and after work had been completed and signed off by QC. The inspectors noted that some potential areas of pitting had not been documented by the applicant as specified in WO 110739214. Specifically, Step 5.5.3.C of WO 110739214, stated the following:
  R-P0994        Magnetic        FWS-015        Feed Water        Pipe to        2
"After cleaning, the surface of the RCS piping and welds shall be visually
                  Particle                                        Reducer
examined to determine if surface pitting has occurred.  The pipe interior shall be inspected for any area showing a reduction in wall thickness as PER NDRF 211911. Any suspect areas shall be forwarded to engineering for inspection and further evaluation."
                                                                    Weld
In addition, Appendix B of the Corrective Action Program procedure 25402-MGT-003 requires that nonconforming items be dispositioned by engineering and a technical justification be included for Accept-As-Is or Repair.  
  R-P0996        Magnetic        MSS-052        Main Steam      Cap to Pipe        2
As result of the NRC's questions, on April 7, 2010 the applicant initiated PER 224434 to  
                  Particle                                          Weld
address the issues identified by the NRC related to the material condition of the crossover piping and document the location of these potential areas of concern; however, on June 30 after further review of the PER, the inspectors noted that corrective action 224434-002 included an engineering disposition unrelated to the issue and instead addressed a 3" drain line.  
For PSI examinations that identified unsatisfactory examination results, the inspectors
reviewed the applicants actions to determine whether indications were dispositioned in
accordance with approved procedures, and the ASME Code. Specifically, for PSI report
R-P0240 (weld number RCF-D144-11), the inspectors reviewed the associated
corrective action documents (PER 166624) that the applicant used to correct an
unsatisfactory linear indication. The inspectors reviewed WO 10-951028-000 and
supplemental examination reports (PT-019 and UT-019) to determine whether the
indication was adequately corrected. The inspectors also performed an independent
visual inspection of the repair area to determine whether the weld conformed to contour
and surface finish requirements. For the other PSI reports that documented
unacceptable indications, the inspectors were unable to review the corrective actions
because the conditions had not been corrected at the time of the inspection. The
inspectors reviewed the PERs that were generated for the unacceptable indications.
The inspectors reviewed records related to the PSI ultrasonic examination of the reactor
pressure vessel head circumferential weld, W09-10, to determine whether the
examination was performed in accordance with N-UT-78, Rev. 5. The inspectors also
reviewed these records to determine whether the records provided documentary
evidence that the examination met the prescribed acceptance criteria and other technical
and quality requirements. Specifically, the inspectors reviewed records to determine
whether:
*      The method, extent and technique complied with the requirements of the PSI
        program and ASME Section XI.
*      Exam data were within the ASME Section XI and NDE procedure acceptance
        criteria.
*      Recording, evaluation and disposition of findings were in compliance with Section
        XI and the NDE procedure.
*      The method used was sufficient to determine the full extent of an indication or its
        acceptance.


The inspectors concluded that in order to properly evaluate the applicant's disposition of this issue, additional inspection would be required to determine (1) whether areas of concern (potential pitting) were properly identified and documented at the time by QC and FE in accordance with applicable instructions and procedures; and (2) whether the
                                                23
engineering disposition appropriately addressed the area of concern. This issue was identified as URI 05000391/2010603-06, "Material Condition Inside Loop-3 RCS Crossover Piping."
      The inspectors performed the following samples:
c. Conclusions
      *      IP 73055 Section 02.02 and 02.04 - seven NDE records
  The inspectors concluded that additional inspection would be required to resolve
      *      IP 73055 Section 02.03 - one NDE record for the RPV head circumferential weld
questions associated with material condition of RCS piping.  
  b.  Observations and Findings
 
      No findings of significance were identified.
16    C.1.9 Protection of Installed Plant Equipment During Construction Activities - Reactor              Coolant Pressure Boundary Piping (IP 49053)  
  c. Conclusions
a. Inspection Scope
      The inspectors determined that the PSI data reviewed met applicable ASME Code
  The inspectors performed a walk-down of a sample of installed safety-related welds,
      Sections, the applicant quality assurance program, and PSI Program requirements. The
piping, and components to determine whether the applicant and their contractors had established adequate controls for the storage and preservation of safety-related, ASME materials and equipment. Specifically, the inspectors performed walk-downs of portions of the following systems:
      inspectors also determined that the PSI data was complete and was either within the
* Reactor coolant system (pressurizer surge line, pressurizer spray line, pressurizer relief and safety valve lines)
      prescribed acceptance criteria or documented in a corrective action document to restore
* Residual heat removal system
      compliance with acceptance criteria.
* Safety injection system
C.1.15 Nuclear Welding General Inspection Procedure (IP 55050)
The inspectors observed housekeeping activities to determine whether quality
  a. Inspection Scope
assurance program requirements were adequately implemented by the applicant and their contractors.  The inspectors compared observations made to the following quality assurance program requirements:  
      The inspectors performed an inspection of applicant activities associated with the
  * Appendix B, Criterion XIII, "Handling, Storage, and Shipping," of 10 CFR Part 50
      fabrication and repair of safety-related piping welds at Watts Bar Unit 2. The inspectors
* The TVA quality assurance program, TVA-NQA-PLN89-A, "Nuclear Quality Assurance Program (NQAP)," Rev. 23  
      reviewed the contractors welding program controls for welding fabrication and weld
* Watts Bar Unit 2 Construction Completion Project, Bechtel Project Nuclear Quality Assurance Manual (PNQAM), Rev. 6
      repair of safety-related piping welds.
* American National Standards Institute (ANSI) N45.2.3-1973, "Housekeeping during the Construction Phase of Nuclear Plants," (referenced in both NQAP and PNQAM)  
      The inspectors compared safety-related welding activities and records reviewed to the
* ANSI N45.2.2-1972, "Packaging, Shipping, Receiving, Storage, and handling of Items for Nuclear Plants." (Referenced in both NQAP and PNQAM)
      following technical and quality requirements:
* ANSI N45.2.8-1975, "Supplementary Quality Assurance Requirements for the Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction of Nuclear Power Plants." 
            * Bechtel Quality Assurance Manual, Rev. 3 (Section 9, Control of Special
  b. Observations and Findings
              Processes)
  The inspectors identified the following NCV:
            * The applicants quality assurance manual TVA-NQA-PLN89-A, Rev. 23 (Section
Introduction:  The inspectors identified a SL IV, NCV of 10 CFR 50, Appendix B, Criterion XIII, "Handling, Storage, and Shipping," in that, the applicant failed to control the storage and preservation of safety-related material (welds, piping, and components) to prevent damage from nearby construction activities.  Specifically, the inspectors identified multiple locations of weld and paint spatter, arc strikes, and mechanical damage on safety-related welds, piping, and components. 
              9.3, Control of Special Processes)
Description:  On June 23, 2010, while performing a walk-down of the pressurizer safe-end to elbow weld (RCF-D144-11), the inspectors identified multiple examples of weld and paint spatter, arc strikes, and mechanical damage (e.g., dents, dings, gouges, etc.) on adjacent ASME Class 1, safety-related welds, piping, and components.  On June 24, 2010, the inspectors performed another walk-down of piping systems in the reactor building and identified additional examples of weld and paint spatter, arc strikes, and  
            *  Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B,
mechanical damage on ASME Class 1, safety-related welds, piping, and components. 
              Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing
17    The inspectors identified approximately 70 locations of damage associated with welds, piping, and components within the following systems:  (1) reactor coolant system, (2) safety injection system, and (3) residual heat removal system.  The specific issues identified by the inspectors were documented by the applicant in PER 236720. 
              Plants
The inspectors noted that affected welds, piping, and components were fabricated from
            *  The Watts Bar Unit 2 piping code of record (American Society of Mechanical
stainless steel alloys, and were all ASME Class 1, pressure boundary items.  The inspectors determined that these issues were reasonably within the applicant's ability to foresee and correct, and should have been prevented. 
              Engineers [ASME] Boiler and Pressure Vessel Code, 1971 Edition with addenda
TVA's Nuclear Quality Assurance Program and the Bechtel PNQAM both require the
              through summer 1973, Section III, Division 1, Rules for Construction of Nuclear
implementation of ANSI N45.2.8-1975, "Supplementary Quality Assurance Requirements for the Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction of Nuclear Power Plants."  Section 4.6, Care of Items, of ANSI N45.2.8-1975, states in part: 
              Facility Components).
"Items on which inspection and testing activities are being performed shall be protected from personnel traffic, weather, and adjacent construction activities
      The inspectors reviewed portions of the contractors Special Processes Manual (SPM),
such as sandblasting, acid cleaning, welding, jack hammering, chipping, burning and stress relieving that would adversely affect the quality of the item or test results.  Such protection shall be provided through good cleanliness and housekeeping practices, temporary packaging, erection of barriers, protective covers, and walkways as required in accordance with Subsection
      Rev. 1, to determine whether the contractor had established an adequate program to
2.6."  ANSI N45.2.8-1975, Section 2.6 references ANSI N45.2.3-1973, "Housekeeping during the Construction Phase of Nuclear Plants," which both TVA and Bechtel commit to in their quality assurance programs.  This ANSI standard specifically addresses the
      implement the above quality and technical requirements. The SPM included program
protection of materials and equipment from physical damage during the construction phase.  Bechtel implements the requirements of ANSI N45.2.3-1973 through adherence to Procedure 5402-000-GPP-0000-N2102, "Housekeeping."  Section 6.11, "Housekeeping During Construction Activities," of this procedure, states in part:
      documents such as: welding procedure specifications (WPSs) with supporting
"Barriers, screens, shields, restricted access, or other protection shall be provided as necessary for isolation of areas where dust, inclement weather, or other conditions exist that may affect the quality of work being performed.  This protection should be maintained throughout the work cycle."
      procedure qualification records (PQRs); welding filler metal control procedures; welder
      performance qualification procedures; general welding standards; general purging
Based on the applicant's preliminary evaluation of the conditions identified, the inspectors determined that the applicant failed to provide adequate protection of safety- related welds, piping, and components from adjacent construction activities in accordance with work and inspection instructions.
      specification; various NDE procedures; postweld heat treatment (PWHT) procedures;
The inspectors determined that this finding was more than minor because it represented
      and weld documentation procedures.
an inadequate quality oversight function that, if left uncorrected, could adversely affect the quality of the construction of safety-related, pressure boundary welds, piping, and
components. Specifically, these conditions could render the quality of the installed items unacceptable or indeterminate.  Additionally, the repairs or rework required to correct the identified conditions may require additional examinations to verify conformance with the construction code of record.  Furthermore, the applicant had previously completed pre-service inspections on some of the affected welds, and depending on the repair required
to correct the condition, the pre-service examination results may be invalidated.   
18    This issue was entered into the corrective action program as PER 236720.  This PER stated that some of these issues were likely the result of recent construction activities and others were likely historical issues, in that they were caused by construction and/or installation activities that occurred prior to 2008. There was no cross-cutting aspect associated with this violation. 
Enforcement: 10 CFR 50 Appendix B, Criterion XIII, "Handling, Storage, and Shipping," requires, in part, that, "measures shall be established to control the handling, storage, shipping, cleaning and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration."
TVA's Nuclear Quality Assurance Program and the Bechtel PNQAM both require the implementation of ANSI N45.2.8-1975 and ANSI N45.2.3-1973.  Section 4.6, "Care of Items," of ANSI N45.2.8, states in part that, "Items on which inspection and testing activities are being performed shall be protected from -adjacent construction activities-that would adversely affect the quality of the item or test results." 
Section 6.11, "Housekeeping During Construction Activities," of Procedure 5402-000-
GPP-0000-N2102, "Housekeeping," Rev. 8, states in part:  "Barriers, screens, shields, restricted access, or other protection shall be provided as necessary for isolation of areas where dust, inclement weather, or other conditions exist that may affect the quality of work being performed."
Contrary to the above, prior to June 24, 2010, the applicant failed to control the storage and preservation of material and equipment in accordance with work and inspection instructions to prevent damage from adjacent construction activities as evidenced by multiple locations of weld and paint spatter, arc strikes, and mechanical damage on safety-related welds, piping, and components.  


This finding was determined to be a SL IV violation using Supplement II of the Enforcement Policy.  Because this was a SL IV violation and because it was entered into the corrective action program as PER 236720, it is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV 5000391/2010603-07, Failure to
                                          24
Protect Safety-Related Welds, Piping, and Components During Construction Activities. 
Base Material and Weld Filler Material Compatibility for Welding
c. Conclusions
The inspectors reviewed WFMC-1, Bechtel Welding Specification - Welding Filler
  The inspectors identified a violation for the applicant's failure to control the storage and  
Material Control, Rev. 1, to verify that the contractor had established procedures and
preservation of material and equipment in accordance with work and inspection instructions to prevent damage from nearby construction activities.
instructions for the purchasing, receiving, storing, identifying, disbursing, and handling of
  C.1.10. Unresolved Item 78-05-02, Reactor Vessel - Nozzle Weld Surface Cracking
welding filler metals. The inspectors reviewed the contractors procedures to determine
a. Inspection Scope
whether they had established procedural controls for the following: (1) environmental
 
(moisture) control; (2) holding and baking temperatures and out-of-oven exposure times
The inspectors conducted interviews and reviewed documentation related to URI 78-05-02, Reactor Vessel - Nozzle Weld Surface Cracking, to determine whether the cracking had been adequately repaired. The inspectors reviewed welding records and NDE reports related to repairs completed to loop four, reactor vessel cold leg nozzle weld 2-068C-W004-01, to evaluate compliance with the requirements of ASME Section III,
for covered electrodes; (3) filler metal identification and control; and (4) filler metal
1971 edition through the summer 1973 addenda.  Following all repairs, the final radiographic exam (RT) was performed on May 9, 1978, and was accepted by both the
disbursement. The inspectors compared WFMC-1 to the applicable quality requirements
19    Level II reviewer and Authorized Nuclear Inspector (ANI). However, a subsequent May 19, 1988, review rejected the May 9, 1978, RT due to excessive geometric unsharpness and use of the wrong penetrameter.  This issue was generic in nature, in that, during an NRC conducted review of RT film for both Unit 1 and Unit 2, 683 Class 1 and Class 2 welds were identified with geometrical unsharpness issues.  See NRC inspection report 50-390, 391/91-23 for additional information on the RT review. A subsequent
of 10 CFR Part 50, Appendix B; and technical requirements of the ASME Section III
evaluation, and development of a special procedure per the 1971 edition of the ASME Section III, Appendix IX, paragraph IX-3110, was performed by the applicant to resolve the geometrical unsharpness issue for Watts Bar Unit 1.  See NRC inspection report 50-390, 391/91-32 for additional details and disposition.
piping code of record.
The inspectors reviewed a sample of welding material purchasing and receiving records
As these issues relate to Watts Bar Unit 2, the applicant intends to submit a special procedure to the NRC as a proposed alternative per the requirements of 10 CFR 50.55a, "Codes and Standards," and to the ANI for review and acceptance.  Further inspection of URI 78-05-02 will continue, once those reviews or acceptable alternatives, have been completed.
to verify conformance with the applicable quality and technical requirements. The
b. Observations and Findings
inspectors reviewed the certified material test reports (CMTRs) for 17 heat/lot numbers
  No findings of significance were identified.  
of welding filler metals to determine whether they met the requirements of the ASME
c. Conclusions
code (ASME Section II - Part C) and the applicable technical requirements prescribed by
  The inspectors determined that URI 78-05-02, Reactor Vessel - Nozzle Weld Surface Cracking will remain open. 
the contractors specifications. The inspectors also reviewed these records to determine
C.1.11 Inservice Inspection - Review of Program (IP 73051)
whether the traceability of heat/lot numbers for weld filler metals and base materials
a. Inspection Scope
were properly recorded on production weld records.
  The inspectors reviewed a sample of NDE coverage calculations to determine whether the applicant adequately calculated the percentage of code-required examination volume coverage obtained. The inspectors also performed a walk-down of the following
The inspectors observed the issuance of weld filler material from the weld rod issue
welds in order to evaluate the validity of relief requests intended to be submitted for less than 90% NDE coverage within the preservice inspection (PSI) program. The inspectors also reviewed the following NDE report coverage diagrams:  
room and observed the identification, storage, and handling of welding filler materials.
* CVCF-F-T284-06, 2" Class 1 pipe to flange weld
The inspectors observed these activities to determine whether they were performed in
* RCF-G1-4, 31" Class 1 pipe to reactor coolant pump bowl weld
accordance with WFMC-1.
* SIF-B-T090-06, 2" Class 2 pipe to flange weld
Welding Procedures
* SIF-D198-06, 6" Class 1 elbow to check valve weld
The inspectors reviewed the contractors welding program to determine whether they
The following samples were inspected:
had established adequate procedures for the preparation, qualification, distribution, and
* IP 73051 Section 02.09 - 4 samples
revision of WPSs. Specifically, the inspectors reviewed the contractors general welding
b. Observations and Findings
requirements for pressure retaining components GWS-1, Bechtel General Welding
  No findings of significance were identified.
Standard, Rev. 2, along with the following four welding procedures:
   
    *   P1-AT-Lh (CVN+10)
20    c. Conclusions
    *   P1-AT-Lh
  The inspectors determined that the observed NDE activities met the requirements established by the applicant's PSI program and the ASME Code.
    *   P8-AT-Ag
    *   P8, P1-AT-Ag
C.1.12 Inservice Inspection - Review of Procedures (IP 73052)  
The inspectors reviewed the above welding procedures to determine whether they met
a. Inspection Scope
the requirements of ASME Section IX, Welding and Brazing Qualification. The
  The inspectors reviewed N-UT-78, "PDI Generic Procedure for the Manual Ultrasonic Examination of Reactor Pressure Vessel Welds PDI-UT-6," Rev. 0005 to determine  the
inspectors reviewed these procedures to determine whether they adequately defined the
adequacy of both the scope and technical content in meeting the requirements of the 10 CFR 50.55a "Codes and Standards," and Section XI of the ASME Boiler and Pressure Vessel Code, 2001 edition through 2003 addenda.  The inspectors also observed the procedure in use during the examination of W09-10, reactor pressure vessel head circumferential weld.
essential, supplementary essential (for impact toughness), and nonessential variables
The following samples were inspected:
for each welding process, as prescribed by ASME Section IX.
* IP 73052 Section 02.03 - 1 sample
For the above welding procedures, the inspectors also reviewed the supporting PQRs
b. Observations and Findings
for conformance to ASME Section IX requirements to verify that the procedures were
  No findings of significance were identified.
properly qualified. The inspectors verified that the PQRs were certified by the contractor
c. Conclusions
and properly listed the essential variables. For each PQR, the inspectors: (1) verified
  The inspectors determined that the ultrasonic examination procedure reviewed met applicable ASME code and 10 CFR 50.55a requirements.
that the ranges of the essential variables were consistent with those permitted by the
C.1.13 Preservice Inspection - Observation of Work and Work Activities (IP 73053)  
WPS and were within the limits of ASME Section IX; and (2) reviewed the mechanical
a. Inspection Scope
  The inspectors observed a selected sample of PSI related activities to determine
whether the onsite preservice inspection of ASME Class 1, 2 and 3 pressure retaining components was performed in accordance with the applicant's PSI program, "Preservice Inspection Program Plan, Watts Bar Nuclear Plant Unit 2," Rev 3.  Specifically, the inspectors observed the ultrasonic (UT) PSI examination of reactor pressure vessel head Circumferential Weld W09-10. 


The inspectors observed portions of the examination and reviewed associated NDE reports to determine whether the examinations were performed in accordance with approved procedures and consistent with the ASME Code of Record for the PSI program (ASME, Boiler and Pressure Vessel Code, 2001 edition including 2003 addenda, Section XI, Division 1, Inservice Inspection of Nuclear Power Plant Components).  Examination records were reviewed to determine whether they were  
                                          25
prepared, evaluated, and maintained in accordance with the applicant's QA program requirements (TVA-NQA-PLN89-A, Rev. 23) and the requirements specified in ASME Section XI.  
testing results to verify that they were completed and properly documented in the PQR,
 
and that the test results met or exceeded the minimum technical requirements.
21    Qualification and certification records for examiners, inspection equipment, and consumables along with the applicable NDE procedures for the pre-service examination activities were reviewed to determine whether they met the requirements established by the applicant's PSI program and the ASME Code.  
During the review of the above WPSs, the inspectors verified that any changes or
The following samples were inspected:
revisions to the essential or nonessential variables were properly identified, documented,
* IP 73053 Section 02.03 - 1 sample
and supported by requalification (if necessary).
b. Observations and Findings
Welder Performance Qualifications
  No findings of significance were identified.
The inspectors reviewed the contractors welding program to determine whether: (1) the
c. Conclusions
contractor had established adequate procedures for the qualification of welders and
  The inspectors determined that the observed NDE activities and qualification records for examination personnel met the requirements established by the applicant's PSI program and the ASME Code. 
welding operators; and (2) the contractor had established an adequate system to control
the qualification status of welding personnel. Specifically, the inspectors reviewed the
C.1.14 Preservice Inspection - Data Review and Evaluation (IP 73055)
contractors procedure, WQ-1, Welding Performance Qualification Specification [ASME
a. Inspection Scope
Section IX], Rev. 2, for conformance to welder qualification requirements prescribed by
  The inspectors reviewed a sample of recently completed PSI examination records (NDE records) for safety-related systems.  The inspectors reviewed these records to determine
ASME Section III and Section IX. The inspectors reviewed six welder performance
whether they met the requirements the ASME Code, the associated NDE procedure, and the applicant's quality assurance program. Specifically, the inspectors reviewed the records to determine whether they contained or referenced the following information:
qualification records, and compared these records to procedure WQ-1 and ASME
* Examination results and data sheets
Section IX.
* Examination equipment data
Production Welding
* Calibration data sheets (as applicable)  
The inspectors reviewed three work packages containing completed weld records for
* Extent of examination
compliance with the contractors welding program requirements, the applicants ASME
* Records on disposition of findings (if applicable)
Section III code of record, and 10 CFR Part 50, Appendix B. Specifically, the inspectors
* Identification of NDE material such as penetrant, penetrant cleaner, couplant, films, tapes, etc.
reviewed Field Weld Checklists (WR-5) and associated fabrication and installation
The inspectors also reviewed these records to determine whether:
drawings, material traceability documents, ASME code data reports, and NDE reports on
* Collected examination data and any recordable indications were properly recorded to permit accurate evaluation and documentation.
the following welds:
* Evaluation of examination data was performed by a Level II or Level III examiner.
    *  Weld Number 2-068A-D145-02 C1R0; safety-related ASME Section III, Class 1
* Evaluation of examination data was consistent with the procedure.
    *  Weld Number 2-061B-T023-1, C0R0; safety-related ASME Section III, Class 3
* Evaluation of indications (if applicable) complied with the criteria of the NDE procedure and ASME Section XI.
    *  Weld Number 2-061B-T023-2, C0R0; safety-related ASME Section III, Class 3
* Incomplete examinations and results were repeated to permit full evaluation (if applicable).
The inspectors reviewed the weld records for the above welds to determine whether: (1)
   
the welding activity was properly documented on the weld traveler; (2) the weld traveler
22    The inspectors reviewed the following PSI examinations:  
appropriately referenced the correct welding procedure; (3) the welding technique and
Report # NDE Method Weld # / Component
sequence requirements were specified; (4) the weld traveler established quality control
# SystemDescription ASME Class R-P0240 Liquid Penetrant RCF-D144-11Reactor Coolant Safe End to Elbow Weld
and authorized nuclear inspector hold points; and (5) the base materials and welding
1 R-P0970 Liquid Penetrant SIS-163 Safety Injection Elbow to Pipe Weld 2 R-P0972 Liquid Penetrant SIF-D123-07 Safety Injection Valve to Reducer Weld 2 R-P0992 Visual  RCP3FLG Reactor Coolant Flange 1 R-P0993 Magnetic Particle FWF-D002-03Feed Water Valve to Pipe Weld 2 R-P0994 Magnetic Particle FWS-015 Feed Water Pipe to Reducer Weld 2 R-P0996 Magnetic Particle MSS-052 Main Steam Cap to Pipe Weld 2  For PSI examinations that identified unsatisfactory examination results, the inspectors reviewed the applicant's actions to determine whether indications were dispositioned in accordance with approved procedures, and the ASME Code.  Specifically, for PSI report R-P0240 (weld number RCF-D144-11), the inspectors reviewed the associated corrective action documents (PER 166624) that the applicant used to correct an unsatisfactory linear indication.  The inspectors reviewed WO 10-951028-000 and supplemental examination reports (PT-019 and UT-019) to determine whether the  
filler materials were properly identified and traceable to the required test reports and
indication was adequately corrected.  The inspectors also performed an independent visual inspection of the repair area to determine whether the weld conformed to contour and surface finish requirements.  For the other PSI reports that documented unacceptable indications, the inspectors were unable to review the corrective actions because the conditions had not been corrected at the time of the inspection. The
certifications.
inspectors reviewed the PERs that were generated for the unacceptable indications. 
Preheat and Postweld Heat Treatment
The inspectors reviewed records related to the PSI ultrasonic examination of the reactor pressure vessel head circumferential weld, W09-10, to determine whether the examination was performed in accordance with N-UT-78, Rev. 5.  The inspectors also
The inspectors reviewed the contractors welding program to determine whether the
reviewed these records to determine whether the records provided documentary evidence that the examination met the prescribed acceptance criteria and other technical and quality requirements. Specifically, the inspectors reviewed records to determine whether:  * The method, extent and technique complied with the requirements of the PSI program and ASME Section XI.
contractor had established adequate procedures for weld joint preheating and PWHT.
* Exam data were within the ASME Section XI and NDE procedure acceptance criteria.
Specifically, the inspectors reviewed the contractors procedure; PHT-1, Bechtel
* Recording, evaluation and disposition of findings were in compliance with Section XI and the NDE procedure.  
General Welding Standard, Rev. 2; for the process of localized PWHT. The inspectors
* The method used was sufficient to determine the full extent of an indication or its acceptance.
verified that PHT-1 contained requirements for the monitoring and recording of the time
23    The inspectors performed the following samples:
and temperature of the weld joint. The inspectors reviewed this procedure to determine
* IP 73055 Section 02.02 and 02.04 - seven NDE records 
whether it implemented the applicable ASME Section III requirements for PWHT.
* IP 73055 Section 02.03 - one NDE record for the RPV head circumferential weld
b. Observations and Findings
  No findings of significance were identified.
c. Conclusions
  The inspectors determined that the PSI data reviewed met applicable ASME Code Sections, the applicant quality assurance program, and PSI Program requirements.  The inspectors also determined that the PSI data was complete and was either within the prescribed acceptance criteria or documented in a corrective action document to restore compliance with acceptance criteria.
C.1.15 Nuclear Welding General Inspection Procedure (IP 55050)
a. Inspection Scope
  The inspectors performed an inspection of applicant activities associated with the fabrication and repair of safety-related piping welds at Watts Bar Unit 2.  The inspectors
reviewed the contractor's welding program controls for welding fabrication and weld repair of safety-related piping welds.  
The inspectors compared safety-related welding activities and records reviewed to the following technical and quality requirements: 


  * Bechtel Quality Assurance Manual, Rev. 3 (Section 9, "Control of Special Processes")  
                                                  26
* The applicant's quality assurance manual TVA-NQA-PLN89-A, Rev. 23 (Section 9.3, "Control of Special Processes")  
      The inspectors performed the following samples:
* Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants * The Watts Bar Unit 2 piping code of record (American Society of Mechanical Engineers [ASME] Boiler and Pressure Vessel Code, 1971 Edition with addenda through summer 1973, Section III, Division 1, Rules for Construction of Nuclear Facility Components). 
            *  IP 55050 Section 02.01 - seventeen heat/lot numbers for welding filler metals
            *  IP 55050 Section 02.02 - four welding procedures, with supporting PQRs
The inspectors reviewed portions of the contractor's Special Processes Manual (SPM), Rev. 1, to determine whether the contractor had established an adequate program to implement the above quality and technical requirements. The SPM included program documents such as:  welding procedure specifications (WPSs) with supporting procedure qualification records (PQRs); welding filler metal control procedures; welder
            *  IP 55050 Section 02.03 - six welder performance qualification records
performance qualification procedures; general welding standards; general purging specification; various NDE procedures; postweld heat treatment (PWHT) procedures; and weld documentation procedures. 
            *  IP 55050 Section 02.04 - three field welding document packages
 
            *  IP 55050 Section 02.05 - one PWHT procedure
 
  b.  Observations and Findings
24    Base Material and Weld Filler Material Compatibility for Welding  
      No findings of significance were identified.
  The inspectors reviewed WFMC-1, "Bechtel Welding Specification - Welding Filler Material Control," Rev. 1, to verify that the contractor had established procedures and instructions for the purchasing, receiving, storing, identifying, disbursing, and handling of welding filler metals. The inspectors reviewed the contractor's procedures to determine  
  c. Conclusions
whether they had established procedural controls for the following: (1) environmental (moisture) control; (2) holding and baking temperatures and out-of-oven exposure times for covered electrodes; (3) filler metal identification and control; and (4) filler metal disbursement. The inspectors compared WFMC-1 to the applicable quality requirements of 10 CFR Part 50, Appendix B; and technical requirements of the ASME Section III
      The welding program documents reviewed met the requirements of 10 CFR Part 50,
piping code of record.
      Appendix B; the contractors quality assurance manual; the applicants quality assurance
The inspectors reviewed a sample of welding material purchasing and receiving records to verify conformance with the applicable quality and technical requirements.  The inspectors reviewed the certified material test reports (CMTRs) for 17 heat/lot numbers of welding filler metals to determine whether they met the requirements of the ASME code (ASME Section II - Part C) and the applicable technical requirements prescribed by
      manual; and the applicants ASME Section III code of record.
the contractor's specifications.  The inspectors also reviewed these records to determine whether the traceability of heat/lot numbers for weld filler metals and base materials were properly recorded on production weld records.
C.1.16 Structural Welding General Inspection Procedure (IP 55100)
The inspectors observed the issuance of weld filler material from the weld rod issue
  a.  Inspection Scope
room and observed the identification, storage, and handling of welding filler materials.  The inspectors observed these activities to determine whether they were performed in accordance with WFMC-1. 
      The inspectors performed an inspection of applicant activities associated with the
Welding Procedures
      fabrication and repair of safety-related structural steel welds at Watts Bar Unit 2. The
  The inspectors reviewed the contractor's welding program to determine whether they had established adequate procedures for the preparation, qualification, distribution, and revision of WPSs.  Specifically, the inspectors reviewed the contractor's general welding requirements for pressure retaining components GWS-1, "Bechtel General Welding
      inspectors reviewed the contractors welding program controls for welding fabrication
Standard," Rev. 2, along with the following four welding procedures: 
      and weld repair of safety-related structural steel.
* P1-AT-Lh (CVN+10)
      The inspectors observed in-process welding, inspected completed structural steel welds,
* P1-AT-Lh
      and reviewed completed weld records. The inspectors compared safety-related welding
* P8-AT-Ag
      activities and records reviewed to the following technical and quality requirements:
* P8, P1-AT-Ag
            *   Bechtel Quality Assurance Manual, Rev. 3 (Section 9, Control of Special
The inspectors reviewed the above welding procedures to determine whether they met
                Processes)
the requirements of ASME Section IX, Welding and Brazing Qualification.  The inspectors reviewed these procedures to determine whether they adequately defined the essential, supplementary essential (for impact toughness), and nonessential variables for each welding process, as prescribed by ASME Section IX. 
            *   The applicants quality assurance manual, TVA-NQA-PLN89-A, Rev. 23 (Section
                9.3, Control of Special Processes)
For the above welding procedures, the inspectors also reviewed the supporting PQRs for conformance to ASME Section IX requirements to verify that the procedures were properly qualified.  The inspectors verified that the PQRs were certified by the contractor and properly listed the essential variables.  For each PQR, the inspectors: (1) verified that the ranges of the essential variables were consistent with those permitted by the WPS and were within the limits of ASME Section IX; and (2) reviewed the mechanical 
            *   10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power
25    testing results to verify that they were completed and properly documented in the PQR, and that the test results met or exceeded the minimum technical requirements. 
                Plants and Fuel Reprocessing Plants
During the review of the above WPSs, the inspectors verified that any changes or revisions to the essential or nonessential variables were properly identified, documented, and supported by requalification (if necessary). 
            *   Watts Bar Unit 2 structural steel welding code of record (American Welding
Welder Performance Qualifications
                Society [AWS] D1.1, Structural Welding Code, 1972 edition with Rev. 1-73 and 1-
  The inspectors reviewed the contractor's welding program to determine whether: (1) the contractor had established adequate procedures for the qualification of welders and
                73.)
welding operators; and (2) the contractor had established an adequate system to control the qualification status of welding personnel.  Specifically, the inspectors reviewed the contractor's procedure, WQ-1, "Welding Performance Qualification Specification [ASME Section IX]," Rev. 2, for conformance to welder qualification requirements prescribed by ASME Section III and Section IX.  The inspectors reviewed six welder performance qualification records, and compared these records to procedure WQ-1 and ASME Section IX.
      Base Material and Filler Material Compatibility for Welding
      The inspectors reviewed WFMC-1, Bechtel Welding Specification - Welding Filler
      Material Control, Rev. 1, to verify that the contractor had established procedures and
      instructions for the purchasing, receiving, storing, identifying, disbursing, and handling of
      welding filler metals. The inspectors reviewed the contractors procedures to determine
      whether the contractor had established procedural controls for the following: (1)
      environmental (moisture) control; (2) holding and baking temperatures and out-of-oven
      exposure times for covered electrodes; (3) filler metal identification and control; and (4)
      filler metal disbursement. The inspectors compared WFMC-1 to the applicable quality


Production Welding
                                        27
  The inspectors reviewed three work packages containing completed weld records for compliance with the contractor's welding program requirements, the applicant's ASME
requirements of 10 CFR Part 50, Appendix B; and technical requirements of the AWS
Section III code of record, and 10 CFR Part 50, Appendix B.  Specifically, the inspectors reviewed "Field Weld Checklists (WR-5)" and associated fabrication and installation drawings, material traceability documents, ASME code data reports, and NDE reports on the following welds:
D1.1.
* Weld Number 2-068A-D145-02 C1R0; safety-related ASME Section III, Class 1
The inspectors reviewed a sample of welding material purchasing and receiving records
* Weld Number 2-061B-T023-1, C0R0; safety-related ASME Section III, Class 3
to verify conformance with the applicable quality and technical requirements. The
* Weld Number 2-061B-T023-2, C0R0; safety-related ASME Section III, Class 3
inspectors reviewed the CMTRs for two heat/lot numbers of welding filler metals to
The inspectors reviewed the weld records for the above welds to determine whether:  (1) the welding activity was properly documented on the weld traveler; (2) the weld traveler
determine whether they met applicable quality and technical requirements. The
appropriately referenced the correct welding procedure; (3) the welding technique and sequence requirements were specified; (4) the weld traveler established quality control and authorized nuclear inspector hold points; and (5) the base materials and welding filler materials were properly identified and traceable to the required test reports and certifications.
inspectors also reviewed these records to determine whether the traceability of heat/lot
Preheat and Postweld Heat Treatment
numbers for weld filler metals and base materials were properly recorded on production
  The inspectors reviewed the contractor's welding program to determine whether the contractor had established adequate procedures for weld joint preheating and PWHT. 
weld records.
Specifically, the inspectors reviewed the contractor's procedure; PHT-1, "Bechtel General Welding Standard," Rev. 2; for the process of localized PWHT.  The inspectors verified that PHT-1 contained requirements for the monitoring and recording of the time and temperature of the weld joint.  The inspectors reviewed this procedure to determine whether it implemented the applicable ASME Section III requirements for PWHT.
The inspectors observed the issuance of weld filler material from the weld rod issue
 
room and observed the identification, storage, and handling of welding filler materials.
 
The inspectors observed these activities to determine whether they were performed in
26    The inspectors performed the following samples:
accordance with WFMC-1. The inspectors also observed the control and handling of
* IP 55050 Section 02.01 - seventeen heat/lot numbers for welding filler metals
welding material during the welding of safety-related conduit supports to determine
* IP 55050 Section 02.02 - four welding procedures, with supporting PQRs
whether they met the requirements of procedure WFMC-1.
* IP 55050 Section 02.03 - six welder performance qualification records
Welding Procedures
* IP 55050 Section 02.04 - three field welding document packages
The inspectors reviewed the contractors welding program to determine whether the
* IP 55050 Section 02.05 - one PWHT procedure
contractor had established adequate procedures for the preparation, qualification,
b. Observations and Findings
distribution, and revision of WPSs. The inspectors reviewed the contractors general
  No findings of significance were identified.
welding standard, GWS-Structural, Rev. 1, and a prequalified structural steel welding
c. Conclusions
procedure for conformance with the AWS D1.1 code of record. Specifically, the
  The welding program documents reviewed met the requirements of 10 CFR Part 50, Appendix B; the contractor's quality assurance manual; the applicant's quality assurance manual; and the applicant's ASME Section III code of record. 
inspectors reviewed the prequalified welding procedure P1-A-Lh (Structural) for
C.1.16 Structural Welding General Inspection Procedure (IP 55100)
conformance with AWS D1.1.
a. Inspection Scope
  The inspectors performed an inspection of applicant activities associated with the fabrication and repair of safety-related structural steel welds at Watts Bar Unit 2.  The inspectors reviewed the contractor's welding program controls for welding fabrication
and weld repair of safety-related structural steel. 
The inspectors observed in-process welding, inspected completed structural steel welds, and reviewed completed weld records.  The inspectors compared safety-related welding activities and records reviewed to the following technical and quality requirements: 
* Bechtel Quality Assurance Manual, Rev. 3 (Section 9, "Control of Special Processes")
* The applicant's quality assurance manual, TVA-NQA-PLN89-A, Rev. 23 (Section 9.3, "Control of Special Processes")
* 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants
* Watts Bar Unit 2 structural steel welding code of record (American Welding Society [AWS] D1.1, Structural Welding Code, 1972 edition with Rev. 1-73 and 1-73.)  Base Material and Filler Material Compatibility for Welding
  The inspectors reviewed WFMC-1, "Bechtel Welding Specification - Welding Filler Material Control," Rev. 1, to verify that the contractor had established procedures and
instructions for the purchasing, receiving, storing, identifying, disbursing, and handling of welding filler metals.  The inspectors reviewed the contractor's procedures to determine whether the contractor had established procedural controls for the following:  (1) environmental (moisture) control; (2) holding and baking temperatures and out-of-oven exposure times for covered electrodes; (3) filler metal identification and control; and (4)
filler metal disbursement.  The inspectors compared WFMC-1 to the applicable quality 
27    requirements of 10 CFR Part 50, Appendix B; and technical requirements of the AWS D1.1.  The inspectors reviewed a sample of welding material purchasing and receiving records to verify conformance with the applicable quality and technical requirements. The inspectors reviewed the CMTRs for two heat/lot numbers of welding filler metals to  
determine whether they met applicable quality and technical requirements. The inspectors also reviewed these records to determine whether the traceability of heat/lot numbers for weld filler metals and base materials were properly recorded on production weld records.  
The inspectors observed the issuance of weld filler material from the weld rod issue room and observed the identification, storage, and handling of welding filler materials. The inspectors observed these activities to determine whether they were performed in accordance with WFMC-1. The inspectors also observed the control and handling of welding material during the welding of safety-related conduit supports to determine whether they met the requirements of procedure WFMC-1.
Welding Procedures
  The inspectors reviewed the contractor's welding program to determine whether the contractor had established adequate procedures for the preparation, qualification, distribution, and revision of WPSs. The inspectors reviewed the contractor's general  
welding standard, GWS-Structural, Rev. 1, and a prequalified structural steel welding procedure for conformance with the AWS D1.1 code of record. Specifically, the inspectors reviewed the prequalified welding procedure P1-A-Lh (Structural) for conformance with AWS D1.1.  
Welder Performance Qualification
Welder Performance Qualification
  The inspectors reviewed the contractor's welding program to determine whether: (1) the contractor had established adequate procedures for the qualification of welders and welding operators; and (2) the contractor had established an adequate system to control  
The inspectors reviewed the contractors welding program to determine whether: (1) the
the qualification status of welding personnel.  
contractor had established adequate procedures for the qualification of welders and
The inspectors reviewed the contractor's procedure WQ-2, "Bechtel Welding Performance Qualification Specification [D1.1]," Rev. 0, for the qualification of welders, and compared the procedure to the Watts Bar Unit 2 AWS D1.1 code of record. The  
welding operators; and (2) the contractor had established an adequate system to control
inspectors reviewed three welder performance qualification records to determine whether welding personnel were qualified in accordance with procedure WQ-2, ASME Section IX, and AWS D1.1.  
the qualification status of welding personnel.
Production Welding
The inspectors reviewed the contractors procedure WQ-2, Bechtel Welding
  The inspectors observed a sample of in-process welding activities associated with  
Performance Qualification Specification [D1.1], Rev. 0, for the qualification of welders,
safety-related conduit supports to determine whether: (1) welding procedures, detailed drawings and instructions, and weld data sheets were readily available to the welder; (2) the WPS used was appropriate for the weld joint; (3) the welding technique and sequence requirements were specified; (4) base materials and welding filler materials were properly inspected, tested, and identified, and were traceable to test reports and certifications; (5) weld joint geometry was specified and the weld joint surfaces were properly prepared, cleaned, and inspected; (6) weld fit-up was as specified on the design
and compared the procedure to the Watts Bar Unit 2 AWS D1.1 code of record. The
28    drawing; (7) welding was performed in accordance with approved welding procedures; and (8) welders were properly qualified.
inspectors reviewed three welder performance qualification records to determine
The inspectors also reviewed portions of WO 09-954179-023, "Fabricate Typical Supports in the Fabrication Shop to be Installed in WOs under EDCR 54633."  During the review of this WO, the inspectors reviewed a sample of completed weld records to
whether welding personnel were qualified in accordance with procedure WQ-2, ASME
determine whether the welds met applicable quality and technical requirements. 
Section IX, and AWS D1.1.
The inspectors reviewed weld records for the following safety-related conduit support welds:  * 995417923-001
Production Welding
* 995417923-002
The inspectors observed a sample of in-process welding activities associated with
* 995417923-003
safety-related conduit supports to determine whether: (1) welding procedures, detailed
* 995417923-031
drawings and instructions, and weld data sheets were readily available to the welder; (2)
* 995417923-036
the WPS used was appropriate for the weld joint; (3) the welding technique and
* 995417923-040
sequence requirements were specified; (4) base materials and welding filler materials
* 995417923-066
were properly inspected, tested, and identified, and were traceable to test reports and
* 995417923-155 FW-2
certifications; (5) weld joint geometry was specified and the weld joint surfaces were
* 995417923-156 FW-3
properly prepared, cleaned, and inspected; (6) weld fit-up was as specified on the design
* 995417923-157 FW-4
* 995417923-160 FW 7
* Four support welds (WO 09-954333-01)
The inspectors reviewed the weld records for the above welds to determine whether:  (1) the welding activity was properly documented on the weld traveler; (2) the weld traveler appropriately referenced the correct welding procedure; (3) the welding technique and sequence requirements were specified; (4) the weld traveler established quality control hold points; and (5) the base materials and welding filler materials were properly identified and traceable to the required test reports and certifications.


Examination and Inspection of Welds
                                          28
  The inspectors independently inspected a sample of safety-related conduit support welds fabricated on-site by the contractor to determine whether these welds met the  
drawing; (7) welding was performed in accordance with approved welding procedures;
acceptance criteria specified in the AWS-D1.1 code of record. During the inspection of a sample of fillet welds, the inspectors also compared the following attributes to the AWS D1.1 code or record: weld surface finish; shape and size of fillet welds; and the absence of surface defects including cracks, lack of fusion, porosity, and slag. Specifically, the inspectors observed the following safety-related conduit support welds:  
and (8) welders were properly qualified.
The inspectors also reviewed portions of WO 09-954179-023, Fabricate Typical
Supports in the Fabrication Shop to be Installed in WOs under EDCR 54633. During
the review of this WO, the inspectors reviewed a sample of completed weld records to
determine whether the welds met applicable quality and technical requirements.
The inspectors reviewed weld records for the following safety-related conduit support
welds:
    *    995417923-001
    *    995417923-002
    *    995417923-003
    *    995417923-031
    *    995417923-036
    *    995417923-040
    *    995417923-066
    *    995417923-155 FW-2
    *    995417923-156 FW-3
    *    995417923-157 FW-4
    *    995417923-160 FW 7
    *    Four support welds (WO 09-954333-01)
The inspectors reviewed the weld records for the above welds to determine whether: (1)
the welding activity was properly documented on the weld traveler; (2) the weld traveler
appropriately referenced the correct welding procedure; (3) the welding technique and
sequence requirements were specified; (4) the weld traveler established quality control
hold points; and (5) the base materials and welding filler materials were properly
identified and traceable to the required test reports and certifications.
Examination and Inspection of Welds
The inspectors independently inspected a sample of safety-related conduit support
welds fabricated on-site by the contractor to determine whether these welds met the
acceptance criteria specified in the AWS-D1.1 code of record. During the inspection of a
sample of fillet welds, the inspectors also compared the following attributes to the AWS
D1.1 code or record: weld surface finish; shape and size of fillet welds; and the absence
of surface defects including cracks, lack of fusion, porosity, and slag.
Specifically, the inspectors observed the following safety-related conduit support welds:
    *    995417923-124
    *    995417923-125
    *    995417923-126
    *    995417923-155
    *    995417923-157
    *    995417923-160
    *    995417923-163
    *    995417923-164
    *    995417923-165


* 995417923-124
                                                29
* 995417923-125
          *  995417923-166
* 995417923-126
          *   995417923-167
* 995417923-155
      The inspectors performed the following samples:
* 995417923-157
          *   IP 55100 Section 02.01 - two samples of lot numbers for welding filler metals
* 995417923-160
          *   IP 55100 Section 02.02 - one sample for a prequalified welding procedure
* 995417923-163
          *   IP 55100 Section 02.03 - three samples of welder performance qualification
* 995417923-164
              records
* 995417923-165
          *   IP 55100 Section 02.04 - seventeen samples (2 in-process welds, 15 completed
    
              weld records)
29    * 995417923-166  
          *   IP 55100 Section 02.06 - eleven samples
* 995417923-167  
  b. Observations and Findings
The inspectors performed the following samples:  
      No findings of significance were identified.
* IP 55100 Section 02.01 - two samples of lot numbers for welding filler metals  
  c. Conclusions
* IP 55100 Section 02.02 - one sample for a prequalified welding procedure  
      The welding program documents reviewed met the requirements of 10 CFR Part 50,
* IP 55100 Section 02.03 - three samples of welder performance qualification records * IP 55100 Section 02.04 - seventeen samples (2 in-process welds, 15 completed weld records)  
      Appendix B; the contractors quality assurance manual; the applicants quality assurance
* IP 55100 Section 02.06 - eleven samples  
      manual; and the applicants AWS D1.1 code of record. Welding activities observed were
b. Observations and Findings
      performed in accordance with approved welding procedures. With the exception of
  No findings of significance were identified.  
      undersized welds identified in Section C.1.3, the completed welds observed by the
c. Conclusions
      inspectors met the acceptance criteria of the contractors inspection procedures and the
  The welding program documents reviewed met the requirements of 10 CFR Part 50, Appendix B; the contractor's quality assurance manual; the applicant's quality assurance  
      AWS D1.1 code of record.
manual; and the applicant's AWS D1.1 code of record. Welding activities observed were performed in accordance with approved welding procedures. With the exception of undersized welds identified in Section C.1.3, the completed welds observed by the inspectors met the acceptance criteria of the contractor's inspection procedures and the AWS D1.1 code of record.  
C.1.17 Visual Examination of Safety Related Welds (IP 57050)
  a.  Inspection Scope
      The inspectors reviewed the contractors NDE procedure; VT-ASME III Piping, Bechtel
      Nondestructive Examination Standard, Visual Examination, Rev. 1. The inspectors
      compared this procedure to the ASME Section III code of record and ASME Section V,
      Nondestructive Examination, 1971 edition with addenda through summer 1973.
      The inspectors also reviewed the contractors visual examination procedure for safety-
      related structural steel VT-AWS D1.1, Bechtel Nondestructive Examination Standard,
      Visual Examination, Rev. 1. The inspectors compared this procedure to the AWS code
      of record.
      The inspectors also reviewed the above procedures to determine whether they were
      issued and qualified in accordance with the contractors quality assurance program, and
      were reviewed and approved by the authorized nuclear inspector (if required).
      The inspectors reviewed the contractors written practice NEPQ, Bechtel Construction
      Operations Inc. Nondestructive Examination Standard, NDE Personnel Qualification and
      Certification, Rev. 1. The inspectors compared the written practice to the NDE
      personnel qualification requirements specified in the ASME Section III code of record.
      The inspectors also reviewed the personnel qualification records (visual examination) for
      one Level III inspector, for conformance with the requirements of the contractors written
      practice.


  C.1.17 Visual Examination of Safety Related Welds (IP 57050)  
                                                30
      The inspectors performed the following samples:
          *  IP 57050 Section 02.01 - one sample
          *  IP 57050 Section 02.03 - one sample
  b. Observations and Findings
      No findings of significance were identified.
  c.  Conclusions
      The visual examination procedures and NDE personnel qualification records reviewed
      by the inspectors met the requirements of 10 CFR Part 50, Appendix B, and the
      applicants ASME Section III and AWS codes of record.
C.1.18 Liquid Penetrant Examination of Safety Related Welds (IP 57060)
  a.  Inspection Scope
      The inspectors reviewed the contractors NDE procedure PT (SR)-ASME III Piping,
      Bechtel Nondestructive Examination Standard, Liquid Penetrant Examination, Rev. 5.
      The inspectors compared this procedure to the ASME Section III code of record and
      ASME Section V, Nondestructive Examination, 1971 edition with addenda through
      summer 1973.
      The inspectors also reviewed the above procedure to determine whether it was issued
      and qualified in accordance with the contractors quality assurance program and
      approved by the authorized nuclear inspector.
      The inspectors also reviewed the personnel qualification records (liquid penetrant
      examination) of one Level III inspector for conformance with the requirements of the
      contractors written practice.
      The inspectors reviewed the following liquid penetrant examination reports to determine
      whether they met the requirements of the applicants procedure PT (SR)-ASME III
      Piping: PT-022, ASME Section III Class 1, pressurizer spray line, pipe to fitting.
      The inspectors performed the following samples:
          *    IP 57060 Section 02.01 - one sample
          *    IP 57060 Section 02.03 - two samples (one personnel and one examination
                record)
  b.  Observations and Findings
      No findings of significance were identified.
  c.  Conclusions
      The liquid penetrant examination procedure and NDE personnel qualification records
      reviewed by the inspectors met the requirements of 10 CFR Part 50, Appendix B, and
      the applicants ASME Section III code of record.


a. Inspection Scope
                                                31
  The inspectors reviewed the contractor's NDE procedure; VT-ASME III Piping, "Bechtel Nondestructive Examination Standard, Visual Examination," Rev. 1. The inspectors compared this procedure to the ASME Section III code of record and ASME Section V, Nondestructive Examination, 1971 edition with addenda through summer 1973.  
C.1.19 Magnetic Particle Examination of Safety Related Welds (IP57070)
The inspectors also reviewed the contractor's visual examination procedure for safety-related structural steel VT-AWS D1.1, "Bechtel Nondestructive Examination Standard,
  a. Inspection Scope
Visual Examination," Rev. 1.  The inspectors compared this procedure to the AWS code of record.
      The inspectors reviewed the contractors NDE procedure MT-ASME, Bechtel
The inspectors also reviewed the above procedures to determine whether they were issued and qualified in accordance with the contractor's quality assurance program, and  
      Nondestructive Examination Standard, Magnetic Particle Examination, Rev. 5. The
were reviewed and approved by the authorized nuclear inspector (if required).  
      inspectors compared this procedure to the ASME Section III code of record and ASME
The inspectors reviewed the contractor's written practice NEPQ, "Bechtel Construction Operations Inc. Nondestructive Examination Standard, NDE Personnel Qualification and Certification," Rev. 1.  The inspectors compared the written practice to the NDE
      Section V, Nondestructive Examination, 1971 edition with addenda through summer
personnel qualification requirements specified in the ASME Section III code of record.  The inspectors also reviewed the personnel qualification records (visual examination) for one Level III inspector, for conformance with the requirements of the contractor's written practice. 
      1973.
30    The inspectors performed the following samples:  
      The inspectors reviewed the above procedure to determine whether it was issued and
* IP 57050 Section 02.01 - one sample  
      qualified in accordance with the contractors quality assurance program and was
* IP 57050 Section 02.03 - one sample b. Observations and Findings
      approved by the authorized nuclear inspector.
  No findings of significance were identified.  
      The inspectors also reviewed the personnel qualification records (magnetic particle
c. Conclusions
      examination) of one Level III inspector for conformance with the requirements of the
  The visual examination procedures and NDE personnel qualification records reviewed
      contractors written practice.
by the inspectors met the requirements of 10 CFR Part 50, Appendix B, and the applicant's ASME Section III and AWS codes of record. 
      The inspectors reviewed the following magnetic particle examination reports to
C.1.18 Liquid Penetrant Examination of Safety Related Welds (IP 57060)
      determine whether they met the requirements of the applicants procedure MT-ASME:
          *    MT-058, ASME Section II Class 3, Ice condenser drain piping, pipe to elbow
          *    MT-064, ASME Section II Class 3, Ice condenser drain piping, pipe to elbow
      In addition to the document review, the inspectors observed magnetic particle (MT)
      examination for the completed pipe welds listed below, including review of the
      qualification records of examination personnel and review of the applicable measuring
      and test equipment calibration records. These welds were on safety-related piping and
      part of the ongoing ice condenser drain piping modification activities performed under
      WOs 08-956218-025 and 08-956218-038. These welds were ASME Section III Class III
      piping welds associated with EDCR 52813, Redesign and Reinstall Ice Condenser Drain
      Piping. MT examinations were observed to determine whether they were performed in
      accordance with the applicable ASME Boiler and Pressure Vessel Code, Section III.
      Specific MT examinations observed included the following:
      Weld ID                        Component
      2-061B-T018-09                12-inch diameter pipe weld
      2-061B-T028-04                12-inch diameter pipe weld
      The inspectors performed the following samples:
          *   IP 57070 Section 02.01 - one sample
          *   IP 57070 Sections 02.02 - one sample
          *    IP 57070 Section 02.03 - three samples (one personnel and two examination
                records)
  b. Observations and Findings
      No findings of significance were identified.


  a. Inspection Scope
                                                32
  The inspectors reviewed the contractor's NDE procedure PT (SR)-ASME III Piping, "Bechtel Nondestructive Examination Standard, Liquid Penetrant Examination," Rev. 5.  The inspectors compared this procedure to the ASME Section III code of record and ASME Section V, Nondestructive Examination, 1971 edition with addenda through  
  c. Conclusions
summer 1973.  
      The magnetic particle examination procedure and NDE personnel qualification records
The inspectors also reviewed the above procedure to determine whether it was issued and qualified in accordance with the contractor's quality assurance program and approved by the authorized nuclear inspector.
      reviewed by the inspectors and the magnetic particle examinations observed by the
The inspectors also reviewed the personnel qualification records (liquid penetrant examination) of one Level III inspector for conformance with the requirements of the contractor's written practice.  
      inspectors met the requirements of 10 CFR Part 50, Appendix B, and the applicants
   
      ASME Section III code of record.
The inspectors reviewed the following liquid penetrant examination reports to determine whether they met the requirements of the applicant's procedure PT (SR)-ASME III Piping:  PT-022, ASME Section III Class 1, pressurizer spray line, pipe to fitting.  
C.1.20 Ultrasonic Examination (UT) of Safety-Related Welds (IP 57080, 73053)
The inspectors performed the following samples:
  a.  Inspection Scope
      The inspectors observed phased array UT examination for completed dissimilar metal
      welds on nine safety-related control rod drive mechanism (CRDM). A circumferential
      and axial scan was performed with both the shear and refracted longitudinal waves. UT
      examinations were observed to determine whether they were performed in accordance
      with ASME Boiler and Pressure Vessel Code, Section III, 1971 Edition with Addenda
      through summer 1973 to verify compliance.
      The inspectors reviewed applicant NDE procedure N-UT-87, Generic Procedure for the
      Phased Array Ultrasonic Examination of Dissimilar Metal Welds, Rev. 0. For the
      examination, the inspectors reviewed the completed NDE reports, the qualification
      records of the examination personnel, and observed calibration checks of the UT
      equipment. The observed examinations and completed examination reports were
      compared with the contractors procedures for UT examination of ASME Code welds.
      Specific UT examination was observed for dissimilar metal welds on CRDMs 54, 60, 64,
      65, 66, 67, 71, 72, and 73.
      Additionally, the inspectors reviewed records of completed observation reports for QA
      oversight activities of contractor NDE activities. A list of QA observation reports is
      included in the attachment.
      The following samples were inspected:
          *  IP 57080 Section 02.02 - one sample
          *  IP 73053 Section 02.03 - one sample
  b. Observations and Findings
      No findings of significance were identified.
  c. Conclusions
      The inspectors determined that the observed/reviewed UT examinations met applicable
      Code requirements and other regulatory requirements.
E.1    Engineering Activities
E.1.1 Procurement, Receiving, and Storage (IP35065)
  a.  Inspection Scope
      The inspectors reviewed the applicants actions to resolve Bulletin 88-10 for non-
      conforming molded case circuit breakers (breakers). The inspectors reviewed the


* IP 57060 Section 02.01 - one sample
                                              33
* IP 57060 Section 02.03 - two samples (one personnel and one examination record) b. Observations and Findings
  applicants program for commercial grade molded case breakers dedicated under the
  No findings of significance were identified.
  QA plan. The inspectors compared observations to references in the Final Safety
c. Conclusions
  Analysis Report, Chapter 3.10 Seismic Design of Category I Instrumentation and
  The liquid penetrant examination procedure and NDE personnel qualification records reviewed by the inspectors met the requirements of 10 CFR Part 50, Appendix B, and the applicant's ASME Section III code of record. 
  Electrical Equipment, paragraph 3.10.1 Seismic Qualification Criteria based on IEEE
31   C.1.19 Magnetic Particle Examination of Safety Related Welds (IP57070)
  344-1971 or IEEE 344-1975 and IEEE 323-1974 requiring the capability of Class 1E
a. Inspection Scope
  power equipment to withstand seismic disturbances to be established by seismic
  The inspectors reviewed the contractor's NDE procedure MT-ASME, "Bechtel Nondestructive Examination Standard, Magnetic Particle Examination," Rev. 5.  The  
  analysis and/or testing of each system component.
inspectors compared this procedure to the ASME Section III code of record and ASME Section V, Nondestructive Examination, 1971 edition with addenda through summer 1973.   The inspectors reviewed the above procedure to determine whether it was issued and  
b. Observations and Findings
qualified in accordance with the contractor's quality assurance program and was approved by the authorized nuclear inspector.
  The inspectors identified the following VIO:
The inspectors also reviewed the personnel qualification records (magnetic particle examination) of one Level III inspector for conformance with the requirements of the contractor's written practice.  
  Introduction: On April 30, 2010, the inspectors identified a violation with two examples of
  10 CFR 50, Appendix B, Criterion III, Design Control, for failure to implement design
The inspectors reviewed the following magnetic particle examination reports to determine whether they met the requirements of the applicant's procedure MT-ASME:
  control measures that provided for design reviews, calculational methods, and
* MT-058, ASME Section II Class 3, Ice condenser drain piping, pipe to elbow
   qualification testing of a prototype unit under the most adverse design conditions and to
* MT-064, ASME Section II Class 3, Ice condenser drain piping, pipe to elbow
  review for suitability of application of materials, parts, and equipment.
In addition to the document review, the inspectors observed magnetic particle (MT) examination for the completed pipe welds listed below, including review of the qualification records of examination personnel and review of the applicable measuring
  Description: The applicant installed breakers into the 4 divisions of 120VAC Vital
and test equipment calibration records. These welds were on safety-related piping and part of the ongoing ice condenser drain piping modification activities performed under  WOs 08-956218-025 and 08-956218-038.   These welds were ASME Section III Class III piping welds associated with EDCR 52813, Redesign and Reinstall Ice Condenser Drain Piping.  MT examinations were observed to determine whether they were performed in  
  Instrument Power Boards. The electrical loads in the power boards are safety related
accordance with the applicable ASME Boiler and Pressure Vessel Code, Section III. Specific MT examinations observed included the following:
  and necessary to shut down and maintain the plant in a safe condition. The following
Weld ID  Component
  describes the violation with two examples resulting from the inspectors observations
  2-061B-T018-09  12-inch diameter pipe weld 2-061B-T028-04  12-inch diameter pipe weld 
  and review of the records and time line involved in the installation of the breakers.
The inspectors performed the following samples:
  Example 1: The inspectors found that significant differences existed between the
* IP 57070 Section 02.01 - one sample
  original qualification mounting and the actual mounting method of the breakers in the
* IP 57070 Sections 02.02 - one sample
  power boards. During the 1992 qualifications testing, (report S522-RP-02) the breakers
* IP 57070 Section 02.03 - three samples (one personnel and two examination records) b. Observations and Findings
  were individually mounted to a plate with screws and no front cover. The actual
  No findings of significance were identified.  
  breakers are mounted in the power boards by clamping 12 breakers with a 36 front
 
  cover against two horizontal angle iron supports in the rear and without additional
32   c. Conclusions
  screws. The actual mounting method used introduces different shock and random
  The magnetic particle examination procedure and NDE personnel qualification records reviewed by the inspectors and the magnetic particle examinations observed by the inspectors met the requirements of 10 CFR Part 50, Appendix B, and the applicant's ASME Section III code of record. 
  frequency impacts during a postulated seismic event to the breakers that were not
C.1.20 Ultrasonic  Examination (UT) of Safety-Related Welds (IP 57080, 73053)
  simulated nor analyzed in the tested mounting method. Additionally, the actual mounting
a. Inspection Scope
  method exposes the bus bar to additional seismic loading not simulated in the
  The inspectors observed phased array UT examination for completed dissimilar metal welds on nine safety-related control rod drive mechanism (CRDM).  A circumferential and axial scan was performed with both the shear and refracted longitudinal waves.  UT
  qualification testing. The front cover plate is held in place with one screw in each corner
examinations were observed to determine whether they were performed in accordance with ASME Boiler and Pressure Vessel Code, Section III, 1971 Edition with Addenda through summer 1973 to verify compliance.  
  and introduces an uncertain clamping pressure across the 12 breakers. The inspectors
The inspectors reviewed applicant NDE procedure N-UT-87, "Generic Procedure for the  
  determined that the tested breaker mounting did not envelope the mounted condition of
Phased Array Ultrasonic Examination of Dissimilar Metal Welds," Rev. 0.  For the examination, the inspectors reviewed the completed NDE reports, the qualification records of the examination personnel, and observed calibration checks of the UT equipment. The observed examinations and completed examination reports were compared with the contractor's procedures for UT examination of ASME Code welds. Specific UT examination was observed for dissimilar metal welds on CRDMs 54, 60, 64, 65, 66, 67, 71, 72, and 73.  
  the breakers in the power boards.
  Example 2: The inspectors reviewed WO 08-816370-000 used to replace old and add
  new breakers into the WBN-2-BD-235-0003 120VAC vital instrument power board. The
  inspectors determined the applicant received breakers in which two attributes had been
  changed. The depth (Z dimension), a critical characteristic, was reduced and the
  auxiliary contact was moved from the outside to the inside of the breakers. The 1992
   qualification report indicated a Z dimension of 3.75 and the manufacturers catalog now
  indicates 2.609 for the critical characteristic. The applicant recognized that the breaker
  with the smaller Z dimension would not mount into the power board. The inspectors
  determined that the applicant modified the breaker by attaching a Micarta plate to the
  rear of the breaker using 4 nuts and bolts to fit them in the power boards as described in
  example 1 without updating the qualification package. The inspectors determined the
  applicant did not analyze if any detrimental effects may have been introduced by the
  modification, demonstrate an adequate review for suitability of application, or the impact
  on other components.


Additionally, the inspectors reviewed records of completed observation reports for QA oversight activities of contractor NDE activities.  A list of QA observation reports is included in the attachment.
                                          34
The inspectors reviewed calculation WCG-ACQ-1004, Rev. 1, used by the applicant to
The following samples were inspected:
demonstrate qualification by analysis. The inspectors verified the calculations purpose
* IP 57080 Section 02.02 - one sample
was to qualify the breakers and the calculation concluded the breakers were qualified.
* IP 73053 Section 02.03 - one sample
The calculation only determined the power board weight change and the shift in natural
b. Observations and Findings
frequency of the power board and its effect on the power board floor anchor bolts.
  No findings of significance were identified. 
However, the calculation did not address the breaker performance during a seismic
c. Conclusions
event. The inspectors determined that the conclusion that the breakers were qualified
  The inspectors determined that the observed/reviewed UT examinations met applicable Code requirements and other regulatory requirements.
was not validated by the calculation.
E.1 Engineering Activities
The inspectors reviewed problem evaluation report (PER) 227786 dated May 10, 2010
E.1.1 Procurement, Receiving, and Storage (IP35065)  a. Inspection Scope
for the qualification findings identified by the inspectors. The inspectors determined that
The inspectors reviewed the applicant's actions to resolve Bulletin 88-10 for non-conforming molded case circuit breakers (breakers).  The inspectors reviewed the 
the PER was inadequate. The PER characterized the seismic evaluation calculation
33    applicant's program for commercial grade molded case breakers dedicated under the QA plan.  The inspectors compared observations to references in the Final Safety Analysis Report, Chapter 3.10 Seismic Design of Category I Instrumentation and Electrical Equipment, paragraph 3.10.1 Seismic Qualification Criteria based on IEEE 344-1971 or IEEE 344-1975 and IEEE 323-1974 requiring the capability of Class 1E power equipment to withstand seismic disturbances to be established by seismic
WCG-ACQ-1004, Rev. 1 as having evaluated and addressed the seismic qualification of
analysis and/or testing of each system component. b. Observations and Findings
the breakers. The inspectors determined the calculation did not address the qualification
The inspectors identified the following VIO:
of the breakers but rather the qualification of the floor anchor bolts of the power boards.
Introduction:  On April 30, 2010, the inspectors identified a violation with two examples of 10 CFR 50, Appendix B, Criterion III, "Design Control," for failure to implement design control measures that provided for design reviews, calculational methods, and qualification testing of a prototype unit under the most adverse design conditions and to review for suitability of application of materials, parts, and equipment. 
The PER further stated that the breaker installation was in compliance with the 1992
Description:  The applicant installed breakers into the 4 divisions of 120VAC Vital Instrument Power Boards. The electrical loads in the power boards are safety related
qualification report S522-RP-02. The inspectors determined that the 1992 seismic
and necessary to shut down and maintain the plant in a safe condition.  The following describes the violation with two examples resulting from the inspectors' observations and review of the records and time line involved in the installation of the breakers.
qualification of the breakers did not envelope the breaker mounting method used for the
Example 1:  The inspectors found that significant differences existed between the
breakers in the power boards. The 1992 seismic qualification report did not envelope
original qualification mounting and the actual mounting method of the breakers in the power boards.  During the 1992 qualifications testing, (report S522-RP-02) the breakers were individually mounted to a plate with screws and no front cover.  The actual breakers are mounted in the power boards by clamping 12 breakers with a 36" front cover against two horizontal angle iron supports in the rear and without additional
the breaker mounting method used either before or after the attribute changes imposed
screws.  The actual mounting method used introduces different shock and random frequency impacts during a postulated seismic event to the breakers that were not simulated nor analyzed in the tested mounting method.  Additionally, the actual mounting method exposes the bus bar to additional seismic loading not simulated in the qualification testing.  The front cover plate is held in place with one screw in each corner
by the manufacturer occurred. The PER stated that the breakers are acceptable and the
and introduces an uncertain clamping pressure across the 12 breakers.  The inspectors determined that the tested breaker mounting did not envelope the mounted condition of the breakers in the power boards.
integrity of the breakers in the power boards is maintained. No further action was
Example 2:  The inspectors reviewed WO 08-816370-000 used to replace old and add
required by the applicant in the corrective actions of the PER. The inspectors
new breakers into the WBN-2-BD-235-0003 120VAC vital instrument power board.  The inspectors determined the applicant received breakers in which two attributes had been changed.  The depth (Z dimension), a critical characteristic, was reduced and the auxiliary contact was moved from the outside to the inside of the  breakers.  The 1992 qualification report indicated a Z dimension of 3.75" and the manufacturer's catalog now indicates 2.609" for the critical characteristic.  The applicant recognized that the breaker with the smaller Z dimension would not mount into the power board.  The inspectors
determined the PER did not address the effects that changes in attributes may impose
determined that the applicant modified the breaker by attaching a Micarta plate to the rear of the breaker using 4 nuts and bolts to fit them in the power boards as described in example 1 without updating the qualification package. The inspectors determined the applicant did not analyze if any detrimental effects may have been introduced by the modification, demonstrate an adequate review for suitability of application, or the impact
on safety, verify the conclusions made in the above calculation, address the qualification
on other components.
of the breakers, or the different mounting method in the 1992 qualification report. The
 
inspectors determined the PER failed to adequately address the findings identified and
34    The inspectors reviewed calculation WCG-ACQ-1004, Rev. 1, used by the applicant to demonstrate qualification by analysis. The inspectors verified the calculation's purpose was to qualify the breakers and the calculation concluded the breakers were qualified. The calculation only determined the power board weight change and the shift in natural frequency of the power board and its effect on the power board floor anchor bolts. However, the calculation did not address the breaker performance during a seismic  
would not ensure that compliance was restored in a reasonable timeframe or prevent
event. The inspectors determined that the conclusion that the breakers were qualified was not validated by the calculation.  
recurrence in accordance with the enforcement policy. Therefore, the criterion for a non-
The inspectors reviewed problem evaluation report (PER) 227786 dated May 10, 2010 for the qualification findings identified by the inspectors. The inspectors determined that  
cited violation was not met and a Notice of Violation is warranted, requiring a formal
the PER was inadequate. The PER characterized the seismic evaluation calculation WCG-ACQ-1004, Rev. 1 as having evaluated and addressed the seismic qualification of the breakers. The inspectors determined the calculation did not address the qualification of the breakers but rather the qualification of the floor anchor bolts of the power boards. The PER further stated that the breaker installation was in compliance with the 1992 qualification report S522-RP-02. The inspectors determined that the 1992 seismic qualification of the breakers did not envelope the breaker mounting method used for the  
response from the applicant.
breakers in the power boards. The 1992 seismic qualification report did not envelope the breaker mounting method used either before or after the attribute changes imposed by the manufacturer occurred. The PER stated that the breakers are acceptable and the integrity of the breakers in the power boards is maintained. No further action was required by the applicant in the corrective actions of the PER. The inspectors  
Example 1 is more than minor because the finding represents a deviation that, if left
determined the PER did not address the effects that changes in attributes may impose on safety, verify the conclusions made in the above calculation, address the qualification of the breakers, or the different mounting method in the 1992 qualification report. The inspectors determined the PER failed to adequately address the findings identified and would not ensure that compliance was restored in a reasonable timeframe or prevent  
uncorrected, could adversely affect the environmental or seismic qualification of a
recurrence in accordance with the enforcement policy.
component. Example 2 is more than minor because the violation represents an
  Therefore, the criterion for a non-cited violation was not met and a Notice of Violation is warranted, requiring a formal response from the applicant.  
inadequate process, procedure, or quality oversight function that, if left uncorrected,
Example 1 is more than minor because the finding represents a deviation that, if left  
could adversely affect the quality of the fabrication, construction, testing, analysis, or
uncorrected, could adversely affect the environmental or seismic qualification of a component. Example 2 is more than minor because the violation represents an inadequate process, procedure, or quality oversight function that, if left uncorrected, could adversely affect the quality of the fabrication, construction, testing, analysis, or records of a safety-related component. The cause of this finding was directly related to  
records of a safety-related component. The cause of this finding was directly related to
the decision-making component of the Human Performance cross-cutting area because the applicant failed to appropriately review safety significant decisions to verify the validity of the underlying assumptions and identify possible unintended consequences. H.1 (b) An unresolved item, URI-05000390/2009002-03, was identified on Unit 1 related to the adequacy of the same seismic qualification report for breakers associated with station 120VAC Vital Instrumentation Boards.  
the decision-making component of the Human Performance cross-cutting area because
the applicant failed to appropriately review safety significant decisions to verify the
Enforcement: 10 CFR 50, Appendix B, Criterion III, "Design Control," states that measures shall be established for the review for suitability of application of materials, parts, and equipment that are essential to the safety-related functions of the structures, systems, and components (SSCs). The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design  
validity of the underlying assumptions and identify possible unintended consequences.
reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Where a test program is used to verify the
H.1 (b) An unresolved item, URI-05000390/2009002-03, was identified on Unit 1 related
35    adequacy of a specific design feature in lieu of other verifying or checking processes, it shall include suitable qualifications testing of a prototype unit under the most adverse design conditions. 
to the adequacy of the same seismic qualification report for breakers associated with
Contrary to the above, measures used to review for the suitability of application of materials, parts, and equipment essential to the safety related functions of molded case
station 120VAC Vital Instrumentation Boards.
circuit breakers and measures to provide for the verification of checking the adequacy of design, such as, calculational methods, performing a suitable test program, including qualifications testing of a prototype unit under the most adverse conditions were not adequate in that:
Enforcement: 10 CFR 50, Appendix B, Criterion III, Design Control, states that
measures shall be established for the review for suitability of application of materials,
1. On October 5, 2009, the applicant installed molded case breakers into the 120VAC vital instrument power boards, however, the test program used to qualify a prototype  breaker failed to use a suitable mounting method that reflected the most adverse mounting condition.
parts, and equipment that are essential to the safety-related functions of the structures,
2. On September 3, 2009, the applicant failed to perform an adequate review for suitability of application parts and material used to modify dimensional critical
systems, and components (SSCs). The design control measures shall provide for
characteristic in molded case breakers, and further, the applicant failed to verify the adequacy of design for the modification and the effects on essential safety related functions of the breakers. 
verifying or checking the adequacy of design, such as by the performance of design
This is identified as violation (VIO) 005000391/2010603-08, Failure to Adequately
reviews, by the use of alternate or simplified calculational methods, or by the
Evaluate and Qualify Molded Case Circuit Breakers.
performance of a suitable testing program. Where a test program is used to verify the
c. Conclusions
  The applicant failed to verify the validity of the underlying assumptions and identify
possible unintended consequences resulting from inadequate qualification testing and a modification to a critical characteristic of the molded case circuit breakers used for safety related 120VAC power applications.
E.1.2  Engineering Design Activities and Design Control (IPs 35100 and 37055) a. Inspection Scope
The inspectors reviewed the implementation of design controls and the content of drawings, specifications, and instructions that had been verified, approved, and issued for construction.  The reviews consisted of document reviews and interviews with responsible engineering personnel.  The inspectors' reviews were conducted to verify the design documents were correctly incorporated into applicable design inputs, including a site-specific commitment to maintain fidelity to the associated Unit 1 designs.  Inspectors evaluated whether designs were technically adequate, and that they had been reviewed, verified, approved, and controlled in accordance with NRC requirements and applicant's procedures.  b. Observations and Findings
  The inspectors identified the following NCV associated with EDCR 52424, Rev. B, Replace Level Transmitters for the Safety Injection System Cold Leg Accumulators: 
Introduction:  A SL IV NCV of 10 CFR 50 Appendix B, Criterion III, "Design Control," was identified by the inspectors for a failure to correctly translate the design basis, as 
36    described in a System Description Document, into affected drawings and specifications.  Specifically, a design basis requirement to provide diverse level measurement systems for the Safety Injection System Accumulators was not correctly translated into affected specifications and drawings issued for construction.  Description:  The inspectors identified that Section 3.3.1 of System Description Document WBN2-63-4001, Rev.1, Safety Injection System, stated "Each CLA
[i.e. Cold Leg Accumulator] is provided with two diverse level measurement systems.  Both systems are used to determine the operational readiness of the accumulators during steady state operations."  TVA Nuclear Standard Department procedure NEDP-1, Rev. 5, "Design Basis and Design Input Control," Appendix D, identified System Description Documents as a
primary source for defining design inputs.  The drawings and specifications released for construction under EDCR 52424 did not provide diverse level measurement systems for the Cold Leg Accumulators.  Instead, the design documents provided duplicate level measurement systems.  This configuration also differed from the Unit 1 design which contained diverse level measurement systems.  The inspectors identified that the level measurement systems were required to implement Technical Specification Surveillance 3.5.1.2, and were classified as Quality-
Related and non-Safety Related.  EDCR 52424 identified that differences existed between Unit 1 and Unit 2 on Attachment E, EDCR Unit Difference Form.  Specifically, the EDCR stated that each accumulator on Unit 1 was provided a Rosemount Model 1152 DP level transmitter and an FCI Thermal Dispersion level element; whereas each accumulator on Unit 2 was provided two
Rosemount Model 1153 DD3RB transmitters.  Although the EDCR documentation provided a justification for using a different model Rosemount transmitter on Unit 2 than installed on Unit 1, it did not provide a basis for specifying a different form and function of level sensor in comparison to the thermal dispersion devices provided for Unit 1.  The inspectors noted this omission did not comply with a requirement in procedure 25402-
3DPG04G-00081, Engineering Document Construction Release, Section 7.2.4, which states that every unit difference must contain an evaluation which addresses differences in form, fit, or function.    The inspectors also noted the EDCR contained a draft Revision to WBN-63-4001, System Description for Safety Injection System; however, neither the description of the
revision contained in the document nor the marked changes in Section 3.3.1 identified any intent to change the requirement for diverse level measurement systems.  The violation was determined to be more than minor because the failure to correctly translate the design requirement from the System Description Document and the failure to properly evaluate the difference created with the Unit 1 design represented an
improper work practice which could impact the proper functioning of the Safety Injection System Accumulator level measurement system.  A cross-cutting aspect was identified for this violation which was related to Human Performance - Work Practices (H.4 (b)).  This aspect is applicable in that the applicant did not effectively communicate expectations regarding procedural compliance and personnel following procedures.
  The applicant issued PER 226246 to address this condition and other concerns with discrepancies in EDCR Technical Evaluations. Enforcement:  10 CFR 50 Appendix B, Criterion III, Design Control, requires, in part, that measures are to be established to correctly translate the design basis into affected 
37    drawings and specifications. TVA Nuclear Standard Department procedure NEDP-1,  "Design Basis and Design Input Control," identifies System Description Documents as a primary source for defining design inputs.  Contrary to the above, on May 21, 2010, the inspectors identified that the applicant failed to correctly translate a requirement for a diverse level measurement system into design drawings and specifications issued for construction under EDCR 52424, as specified in
System Description Document WBN2-63-4001, Safety Injection System.  This finding was determined to be a SL IV violation using Supplement II of the Enforcement Policy.  Because this was a SL IV violation, and because it was entered into the corrective action program under PER 226246, this violation is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV
5000391/2010603-09, Failure to Correctly Translate the Design Basis into Affected Specifications and Drawings Issued for Construction. c. Conclusions
  The inspectors determined that, in most cases, design drawings, specifications, and instructions were developed in accordance with NRC and applicant requirements.  Design documents were provided specific approvals for differences that were created
between the Unit 2 design and the Unit 1 design.  However, one violation was identified where a requirement to provide diverse level measurement systems for Safety Injection System Cold Leg Accumulators was not correctly translated into design documents.
T.1 Training and Qualification of Plant Personnel 
T.1.1 Craft Training (IPs 51051 and 64051) 


                                                35
      adequacy of a specific design feature in lieu of other verifying or checking processes, it
      shall include suitable qualifications testing of a prototype unit under the most adverse
      design conditions.
      Contrary to the above, measures used to review for the suitability of application of
      materials, parts, and equipment essential to the safety related functions of molded case
      circuit breakers and measures to provide for the verification of checking the adequacy of
      design, such as, calculational methods, performing a suitable test program, including
      qualifications testing of a prototype unit under the most adverse conditions were not
      adequate in that:
      1. On October 5, 2009, the applicant installed molded case breakers into the 120VAC
          vital instrument power boards, however, the test program used to qualify a prototype
          breaker failed to use a suitable mounting method that reflected the most adverse
          mounting condition.
      2. On September 3, 2009, the applicant failed to perform an adequate review for
          suitability of application parts and material used to modify dimensional critical
          characteristic in molded case breakers, and further, the applicant failed to verify the
          adequacy of design for the modification and the effects on essential safety related
          functions of the breakers.
      This is identified as violation (VIO) 005000391/2010603-08, Failure to Adequately
      Evaluate and Qualify Molded Case Circuit Breakers.
  c. Conclusions
      The applicant failed to verify the validity of the underlying assumptions and identify
      possible unintended consequences resulting from inadequate qualification testing and a
      modification to a critical characteristic of the molded case circuit breakers used for safety
      related 120VAC power applications.
E.1.2 Engineering Design Activities and Design Control (IPs 35100 and 37055)
   a. Inspection Scope
   a. Inspection Scope
  The inspectors observed a classroom training session for electrical craft personnel. 
      The inspectors reviewed the implementation of design controls and the content of
Specifically, the inspectors observed containment CONEX penetration and Kapton insulated conductor familiarization in accordance with vendor technical document WBN-VTD-C515-0060, Installation Manual for CONEX Electrical Conductor Seal Assemblies. The training session included discussions on installation and repair of
      drawings, specifications, and instructions that had been verified, approved, and issued
Kapton insulated conductors.
      for construction. The reviews consisted of document reviews and interviews with
The inspectors also observed classroom fire watch training.  The inspectors reviewed
      responsible engineering personnel.
the associated procedures and lesson plans, and held discussions with the instructors.  The training highlighted selected portions of TVA procedure SPP-10.11, Control of
      The inspectors reviews were conducted to verify the design documents were correctly
Ignition Sources (Hot Work).
      incorporated into applicable design inputs, including a site-specific commitment to
Samples inspected are as follows:
      maintain fidelity to the associated Unit 1 designs. Inspectors evaluated whether designs
* IP 51051 Section 02.03 - one sample
      were technically adequate, and that they had been reviewed, verified, approved, and
* IP 64051 Section 02.04 - one sample
      controlled in accordance with NRC requirements and applicants procedures.
   b. Observations and Findings
   b. Observations and Findings
   No findings of significance were identified.  
      The inspectors identified the following NCV associated with EDCR 52424, Rev. B,
      Replace Level Transmitters for the Safety Injection System Cold Leg Accumulators:
 
      Introduction: A SL IV NCV of 10 CFR 50 Appendix B, Criterion III, Design Control, was
38      c. Conclusions
      identified by the inspectors for a failure to correctly translate the design basis, as
  TVA's program for training of newly hired personnel relating to repair or installation of CONEX Penetration Seals and Kapton Insulated Conductors and training for hot work fire watches was adequate for the current level of construction activities being performed.  
 
 
                                          36
T.1.2 Engineering Organization Training (IP 35960)  
described in a System Description Document, into affected drawings and specifications.
  a. Inspection Scope
Specifically, a design basis requirement to provide diverse level measurement systems
  The inspectors observed a classroom training session for engineering personnel. Specifically, the inspectors observed Introduction to ASME Code for Design Engineers. The training session was intended to be an introduction on use of the ASME Class III Code by engineering design personnel. Additional future training on ASME Code requirements would be required. Samples inspected are as follows:  
for the Safety Injection System Accumulators was not correctly translated into affected
* IP 35960 Section 02.01 - one sample     b. Observations and Findings
specifications and drawings issued for construction.
  No findings of significance were identified.  
Description: The inspectors identified that Section 3.3.1 of System Description
  c. Conclusions
Document WBN2-63-4001, Rev.1, Safety Injection System, stated Each CLA [i.e. Cold
  The inspection results are too limited to support a conclusion at this time.  
Leg Accumulator] is provided with two diverse level measurement systems. Both
III. Operational Readiness Activities  
systems are used to determine the operational readiness of the accumulators during
F.1 Fire Protection (IP 64051)  
steady state operations.
TVA Nuclear Standard Department procedure NEDP-1, Rev. 5, Design Basis and
Design Input Control, Appendix D, identified System Description Documents as a
primary source for defining design inputs.
The drawings and specifications released for construction under EDCR 52424 did not
provide diverse level measurement systems for the Cold Leg Accumulators. Instead, the
design documents provided duplicate level measurement systems. This configuration
also differed from the Unit 1 design which contained diverse level measurement
systems. The inspectors identified that the level measurement systems were required to
implement Technical Specification Surveillance 3.5.1.2, and were classified as Quality-
Related and non-Safety Related.
EDCR 52424 identified that differences existed between Unit 1 and Unit 2 on Attachment
E, EDCR Unit Difference Form. Specifically, the EDCR stated that each accumulator on
Unit 1 was provided a Rosemount Model 1152 DP level transmitter and an FCI Thermal
Dispersion level element; whereas each accumulator on Unit 2 was provided two
Rosemount Model 1153 DD3RB transmitters. Although the EDCR documentation
provided a justification for using a different model Rosemount transmitter on Unit 2 than
installed on Unit 1, it did not provide a basis for specifying a different form and function
of level sensor in comparison to the thermal dispersion devices provided for Unit 1. The
inspectors noted this omission did not comply with a requirement in procedure 25402-
3DPG04G-00081, Engineering Document Construction Release, Section 7.2.4, which
states that every unit difference must contain an evaluation which addresses differences
in form, fit, or function.
The inspectors also noted the EDCR contained a draft Revision to WBN-63-4001,
System Description for Safety Injection System; however, neither the description of the
revision contained in the document nor the marked changes in Section 3.3.1 identified
any intent to change the requirement for diverse level measurement systems.
The violation was determined to be more than minor because the failure to correctly
translate the design requirement from the System Description Document and the failure
to properly evaluate the difference created with the Unit 1 design represented an
improper work practice which could impact the proper functioning of the Safety Injection
System Accumulator level measurement system.
A cross-cutting aspect was identified for this violation which was related to Human
Performance - Work Practices (H.4 (b)). This aspect is applicable in that the applicant
did not effectively communicate expectations regarding procedural compliance and
personnel following procedures.
The applicant issued PER 226246 to address this condition and other concerns with
discrepancies in EDCR Technical Evaluations.
Enforcement: 10 CFR 50 Appendix B, Criterion III, Design Control, requires, in part, that
measures are to be established to correctly translate the design basis into affected
 
                                                37
      drawings and specifications. TVA Nuclear Standard Department procedure NEDP-1,
      Design Basis and Design Input Control, identifies System Description Documents as a
      primary source for defining design inputs.
      Contrary to the above, on May 21, 2010, the inspectors identified that the applicant failed
      to correctly translate a requirement for a diverse level measurement system into design
      drawings and specifications issued for construction under EDCR 52424, as specified in
      System Description Document WBN2-63-4001, Safety Injection System.
      This finding was determined to be a SL IV violation using Supplement II of the
      Enforcement Policy. Because this was a SL IV violation, and because it was entered
      into the corrective action program under PER 226246, this violation is being treated as a
      NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV
      5000391/2010603-09, Failure to Correctly Translate the Design Basis into Affected
      Specifications and Drawings Issued for Construction.
  c.  Conclusions
      The inspectors determined that, in most cases, design drawings, specifications, and
      instructions were developed in accordance with NRC and applicant requirements.
      Design documents were provided specific approvals for differences that were created
      between the Unit 2 design and the Unit 1 design. However, one violation was identified
      where a requirement to provide diverse level measurement systems for Safety Injection
      System Cold Leg Accumulators was not correctly translated into design documents.
T.1    Training and Qualification of Plant Personnel
T.1.1 Craft Training (IPs 51051 and 64051)
    a. Inspection Scope
      The inspectors observed a classroom training session for electrical craft personnel.
      Specifically, the inspectors observed containment CONEX penetration and Kapton
      insulated conductor familiarization in accordance with vendor technical document
      WBN-VTD-C515-0060, Installation Manual for CONEX Electrical Conductor Seal
      Assemblies. The training session included discussions on installation and repair of
      Kapton insulated conductors.
      The inspectors also observed classroom fire watch training. The inspectors reviewed
      the associated procedures and lesson plans, and held discussions with the instructors.
      The training highlighted selected portions of TVA procedure SPP-10.11, Control of
      Ignition Sources (Hot Work).
      Samples inspected are as follows:
          *   IP 51051 Section 02.03 - one sample
          *  IP 64051 Section 02.04 - one sample
    b. Observations and Findings
      No findings of significance were identified.
 
                                                    38
      c. Conclusions
          TVAs program for training of newly hired personnel relating to repair or installation of
          CONEX Penetration Seals and Kapton Insulated Conductors and training for hot work
          fire watches was adequate for the current level of construction activities being
          performed.
T.1.2 Engineering Organization Training (IP 35960)
      a. Inspection Scope
        The inspectors observed a classroom training session for engineering personnel.
        Specifically, the inspectors observed Introduction to ASME Code for Design Engineers.
        The training session was intended to be an introduction on use of the ASME Class III
        Code by engineering design personnel. Additional future training on ASME Code
        requirements would be required.
          Samples inspected are as follows:
              *   IP 35960 Section 02.01 - one sample
      b. Observations and Findings
          No findings of significance were identified.
      c. Conclusions
          The inspection results are too limited to support a conclusion at this time.
III. Operational Readiness Activities
F.1       Fire Protection (IP 64051)
      a. Inspection Scope
          The inspectors conducted a walk-down of TVAs established fire protection/prevention
          controls for Unit 2 and inspected hot work activities inside the Unit 2 reactor building.
          Inspectors observed fire watches and verified that fire suppression devices were
          available at or near the location of the hot work activities. The inspectors interviewed fire
          watch personnel to verify knowledge of responsibilities as fire watches. The inspectors
          also verified that hot work permits were posted at the location of any hot work and that
          appropriate signoffs had been completed in the associated work control documents.
          The inspectors also verified that the assigned fire watches had current training and
          appropriate qualifications. The inspectors observed fire prevention aspects associated
          with welding activities. Specific documents reviewed are listed in the attachment.
          The following samples were inspected:
          *    IP 64051 Section 02.07 - one sample
          *    IP 64051 Section 02.08 - one sample
 
                                                  39
    b. Observations and Findings
        No findings of significance were identified.
    c. Conclusions
        TVA implemented adequate fire protection measures and controls to support Unit 2
        construction activities and minimize impact on Unit 1 operation activities.
IV.    Other Activities
OA.1.1 (Discussed) Quality Assurance Corrective Action Program (TI 2512/28, IPs 50075,
        51065, 51055, 52055)
     a. Inspection Scope
     a. Inspection Scope
  The inspectors conducted a walk-down of TVA's established fire protection/prevention controls for Unit 2 and inspected hot work activities inside the Unit 2 reactor building. Inspectors observed fire watches and verified that fire suppression devices were available at or near the location of the hot work activities. The inspectors interviewed fire watch personnel to verify knowledge of responsibilities as fire watches. The inspectors also verified that hot work permits were posted at the location of any hot work and that
        Background: The QA Records Corrective Action Program (CAP) was developed in the
appropriate signoffs had been completed in the associated work control documents. The inspectors also verified that the assigned fire watches had current training and appropriate qualifications. The inspectors observed fire prevention aspects associated with welding activities. Specific documents reviewed are listed in the attachment.  
        mid-1980s after TVA determined that required QA records were:
The following samples were inspected:  
            *  Not retrievable in a timely manner or were missing
* IP 64051 Section 02.07 - one sample  
            *  Not maintained in proper storage
* IP 64051 Section 02.08 - one sample  
            *  Incomplete, technically, or administratively deficient
    
        The applicant has taken various actions to correct previously identified records
    
        deficiencies. These actions included:
39      b. Observations and Findings
            *  Ensuring adequate storage and retrievability
  No findings of significance were identified.  
            *  Resolving quality and technical problems
            *  Ensuring programs were established to prevent recurrence of previous record
                problems
        TVA selected a sample size of 124 records for each of the ANSI/ASME N45.2.9, 1974,
        Appendix record types for Unit 2 and utilized an accepted statistical sampling
        methodology (95/95). NRC Safety Evaluation Reports (SERs) dated June 9, 1992, and
        September 8, 2009, approved the sampling methodology used by the applicant.
        The inspectors reviewed the applicants implementation of the QA Records CAP.
        Specifically, the inspectors reviewed the results of sample assessments performed by
        the applicant in several areas to verify resolution of previously identified problems with
        retrievability, storage, and completeness and to resolve quality and technical problems.
        Additionally, the inspectors performed an independent sample selection of 47 records
        which were shown on the applicants Engineering Construction Monitoring and
        Documentation (ECM&D) database as active records for the following QA record types:
        Mechanical Records (23 records)
            *  Valves (7 records)
            * Mechanical Equipment (5 records)
            * Piping (5 records)
            * Ductwork (6 records)
 
                                              40
      Electrical/Instrument Records (24 records)
          *  Cables (6 records)
          *  Electrical Equipment (8 records)
          *  Instrument Subassemblies (4 records)
          *  Electrical Instruments (6 records)
      Specific QA records and applicant sample assessment reports reviewed are listed in the
      attachment.
      The following samples were inspected:
          *  IP 50075 Section 02.02 - one sample
          *  IP 51055 Section 02.01 - one sample
          *  IP 51055 Section 02.04 - one sample
          *  IP 51055 Section 02.06 - one sample
          *  IP 51065 Section 02.01 - one sample
          *  IP 51065 Section 02.05 - one sample
          *   IP 51065 Section 02.07 - one sample
          *   IP 52055 Section 02.01 - one sample
          *   IP 52055 Section 02.04 - one sample
          *   IP 52055 Section 02.06 - one sample
  b. Observations and Findings
      No findings of significance were identified. The applicant was able to produce each of
      the above requested QA records from the Unit 2 records vault. The inspectors reviewed
      the original records and determined that the records were legible and complete.
      The inspectors verified that TVA had adequately reviewed an appropriate size sample of
      each record type for mechanical and electrical/instrument records. Record-related
      discrepancies were properly identified and entered into the Corrective Action Program as
      appropriate. The applicant had not yet completed all planned QA record sample
      assessments at the end of the inspection period. Future QA record sample
      assessments are planned for various civil, welding and system cleanliness record types.
   c. Conclusions
   c. Conclusions
 
      The actions performed to resolve the issues associated with the QA Records CAP for
TVA implemented adequate fire protection measures and controls to support Unit 2 construction activities and minimize impact on Unit 1 operation activities.  
      Unit 2 mechanical and electrical/instrument records were found to be adequately
IV. Other Activities
      planned and implemented. Additional NRC review of future applicant QA record
      assessments will be needed prior to closure of this CAP.
OA.1.2 Corrective Action Plans and Special Programs Reviews (TI 2512/017, 025)
      The inspectors held discussions with both TVA and Bechtel engineering and licensing
      personnel regarding the actions planned to resolve the issues associated with the Cable
      Tray and Cable Tray Supports CAP, TI 2512/017, and HVAC Duct and Supports, CAP TI
      2512/025. The initial meeting associated with these CAPs was held during previous
      inspection periods; however, the inspectors reviewed applicable documentation to plan
      future inspections in these areas.


OA.1.1 (Discussed) Quality Assurance Corrective Action Program (TI 2512/28, IPs 50075,             51065, 51055, 52055)  
                                                41
   
      The actions discussed covered the following areas as applicable:
  a. Inspection Scope
          *  Walk-downs
  Background:  The QA Records Corrective Action Program (CAP) was developed in the mid-1980s after TVA determined that required QA records were:
          *  Engineering
          *  Construction
          *  Testing
      The purpose of these discussions was for the inspectors to gain an understanding of the
      actions required to close the subject CAPs, in order to help them develop inspection
      plans and preliminary inspection schedules. Actual inspection activities associated with
      CAPs and SPs performed during this reporting period are discussed elsewhere in this
      report and contain the appropriate observations and findings.
OA.1.3 (Closed) Electrical Issues CAP Sub-issue: Adhesive Backed Cable Support Mount
        (TI 2512/020, IP 51063)
  a.  Inspection Scope
      The inspectors reviewed the applicants actions to resolve the Electrical CAP Sub-Issue,
      Adhesive Backed Cable Support Mount, to confirm that the applicants program complies
      with all commitments and NRC requirements. The inspectors reviewed calculations,
      specification (G-38), EDCR, drawings, documentation of walk downs, and inspected a
      number of control panels in the Unit 2 Control Room.
  b. Observations and Findings
      No findings of significance were identified. The inspectors determined that all adhesive
      backed cable support mounts have been removed and replaced with cable ties and Ty-
      rap clamps to maintain separation inside panels and control cabinets to provide the
      physical restraint required by the specifications. The inspectors verified that redundant
      divisional train safety-related cables inside selected Main Control Room cabinets were
      placed in braided sleeves as called out in the specifications.
  c. Conclusions
      This inspection concluded that concerns pertaining to the electrical CAP sub-issue, on
      adhesive backed cable mount supports, have been appropriately addressed for Watts
      Bar Unit 2.
OA.1.4 (Discussed) Cable Issues CAP Sub-Issue: Computerized Cable Routing System
      Software and Database Verification and Validation (TI 2512/016)
  a. Inspection Scope
      The inspectors reviewed the applicants actions to resolve the Cable CAP Sub-Issue,
      Computerized Cable Routing System (CCRS) software and database verification and
      validation and to evaluate related activities to confirm that the applicants program
      complies with all commitments and NRC requirements. The inspectors reviewed
      documentation and scheduling to inspect signal tracing field activities associated with
      this sub-issue. The inspectors interviewed responsible design personnel and reviewed
      the Environmental Qualification Cable Walkthroughs that establishes the schedule for
      signal tracing field activities. Anomaly tables and action listings were reviewed to
      establish reasonable assurance that data transfer from CCRS to ICRDS has been
      verified.


* Not retrievable in a timely manner or were missing
                                              42
* Not maintained in proper storage
  b. Observations and Findings
* Incomplete, technically, or administratively deficient
      No findings of significance were identified. The applicant replaced CCRS with ICRDS
The applicant has taken various actions to correct previously identified records
      and transferred the data, which included Unit 1 and 2 cables, to the new system. The
deficiencies. These actions included:
      inspectors determined that the applicant verified and validated the transfer of data into
* Ensuring adequate storage and retrievability
      ICRDS in accordance with TVA QA procedures. Part of the Unit 2 verification
* Resolving quality and technical problems
      methodology will be to signal trace all Environmental Qualification (EQ) and Appendix R
* Ensuring programs were established to prevent recurrence of previous record problems  TVA selected a sample size of 124 records for each of the ANSI/ASME N45.2.9, 1974, Appendix record types for Unit 2 and utilized an accepted statistical sampling methodology (95/95).  NRC Safety Evaluation Reports (SERs) dated June 9, 1992, and September 8, 2009, approved the sampling methodology used by the applicant.
      cables that are shown as installed in ICRDS, but do not have pull cards available
The inspectors reviewed the applicant's implementation of the QA Records CAP. Specifically, the inspectors reviewed the results of sample assessments performed by the applicant in several areas to verify resolution of previously identified problems with retrievability, storage, and completeness and to resolve quality and technical problems.   
      (missing QA records). The purpose of the signal trace is to verify the routing and lengths
Additionally, the inspectors performed an independent sample selection of 47 records which were shown on the applicant's Engineering Construction Monitoring and Documentation (ECM&D) database as active records for the following QA record types:
      of cables for comparison with information in ICRDS. Observations of signal tracing
Mechanical Records (23 records)
      activities are discussed in Section C.1.6.
      Conclusions
      The inspectors determined that further inspection will be required to verify acceptable
      completion of the CAP Sub-Issue, ICRDS software and database verification and
      validation.
OA.1.5 (Discussed) Station Blackout (SBO) Rule Procedures and Actions (TI 2515/120)
  a.  Inspection Scope
      The inspectors reviewed design activities associated with implementation of the SBO
      requirements for Unit 2. The inspectors examined planned and in-process actions to
      confirm Unit 2 actions paralleled the actions implemented on Unit 1 and to determine
      whether the Unit 2 actions were technically valid, and were implemented in accordance
      with NRC and applicant requirements.
      The inspectors interviewed the responsible engineering representatives to determine the
      applicants status toward completion of the SBO rule requirements. The inspectors
      reviewed design calculations EPMMA041592 Rev. 10, SBO Coping Evaluation, to
      determine the applicants required SBO time period and actions necessary to cope with
      an the event. Additionally, the inspectors reviewed EDQ00023620070003 Rev. 5, 125V
      DC Vital Battery System Analysis, to determine the adequacy of the applicants 125V
      DC batteries and chargers.
  b.  Observations and Findings
      No findings of significance were identified. The inspectors interviews and reviews of
      design calculations determined that the applicant has not completed the as-built design
      calculations, procedures, and action requirements. The applicants intent is to parallel
      Unit 1 SBO requirements.
  c.  Conclusions
      The inspectors determined that further inspection will be required to verify acceptable
      completion of SBO procedures and processes.
OA.1.6 (Discussed) Non-cited Violation NCV-391/2008-010-01 Corrective Action for
        Failure to Document a Cable Raceway Separation Non-conforming Condition.
  a.  Inspection Scope
      The inspectors reviewed documentation, performed an independent walk down, and
      interviewed responsible personnel related to the Unit 2 corrective action plan associated
      with NCV-391/2008-010-01 for failure to document non-conforming cable raceways.
      The inspectors reviewed PER 158979 to determine the corrective action plan taken by
      the applicant. The inspectors reviewed walk down procedure WDP-GEN-1 package


* Valves (7 records)
                                                  43
* Mechanical Equipment (5 records)
      number LSWDP-430 to determine the extent of condition found by the applicant. The
* Piping (5 records)
      inspectors performed an independent walk down of a portion of the facility to verify the
* Ductwork (6 records)
      adequacy of the applicant findings. The inspectors interviewed engineering personnel
 
      responsible for implementing the extent of condition walk down to determine the
40    Electrical/Instrument Records (24 records)
      synthesis of the corrective action plan and extent of condition.
  * Cables (6 records)
  b. Observations and Findings
* Electrical Equipment (8 records)
      No findings of significance were identified.
* Instrument Subassemblies (4 records)
      The inspectors independent walk down and interviews with applicant personnel
* Electrical Instruments (6 records)
      determined that corrective actions were adequate with the exception of non safety
Specific QA records and applicant sample assessment reports reviewed are listed in the attachment.  The following samples were inspected:
      raceways associated with safety race ways and conduits and their traceability between
* IP 50075 Section 02.02 - one sample
      divisions, which could not be verified.
* IP 51055 Section 02.01 - one sample
  c. Conclusions
* IP 51055 Section 02.04 - one sample
      The inspectors determined that further inspection will be required to verify acceptable
* IP 51055 Section 02.06 - one sample
      closure of the NCV. The inspection of the associated raceways could not be completed
* IP 51065 Section 02.01 - one sample
      during this inspection.
* IP 51065 Section 02.05 - one sample
OA.1.7 (Closed) NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power
* IP 51065 Section 02.07 - one sample
        Cable Failures that Disable Accident Mitigation Systems or Cause Plant
* IP 52055 Section 02.01 - one sample
        Transients.
* IP 52055 Section 02.04 - one sample
  a. Inspection Scope
* IP 52055 Section 02.06 - one sample
      The inspectors reviewed the TVAs actions in response to GL 07-01 including Response
    b. Observations and Findings
      Letter dated September 7, 2007 - Attachment 22 identifying the extent of the scope
  No findings of significance were identified.  The applicant was able to produce each of the above requested QA records from the Unit 2 records vault. The inspectors reviewed the original records and determined that the records were legible and complete.  
      covering 24 pump feeder cables. The inspectors reviewed ICRDS cable reports on
The inspectors verified that TVA had adequately reviewed an appropriate size sample of each record type for mechanical and electrical/instrument records.  Record-related discrepancies were properly identified and entered into the Corrective Action Program as appropriate. The applicant had not yet completed all planned QA record sample assessments at the end of the inspection period.  Future QA record sample
      safety-related control cables running underground to address similar concerns of
assessments are planned for various civil, welding and system cleanliness record types.  
      disabling accident mitigating systems. The inspectors reviewed wiring diagram drawings
  c. Conclusions
      and conduit & grounding detail drawings associated with the underground control cables.
  The actions performed to resolve the issues associated with the QA Records CAP for Unit 2 mechanical and electrical/instrument records were found to be adequately planned and implemented.  Additional NRC review of future applicant QA record
  b.  Observations and Findings
assessments will be needed prior to closure of this CAP.
      This generic issue identified that cables, qualified for 40 years through the equipment
OA.1.2  Corrective Action Plans and Special Programs Reviews (TI 2512/017, 025)  
      qualification program, were failing at several nuclear stations prior to the end of their
  The inspectors held discussions with both TVA and Bechtel engineering and licensing
      qualified life. In an effort to address this issue, the NRC published Generic Letter 2007-
personnel regarding the actions planned to resolve the issues associated with the Cable Tray and Cable Tray Supports CAP, TI 2512/017, and HVAC Duct and Supports, CAP TI 2512/025. The initial meeting associated with these CAPs was held during previous inspection periods; however, the inspectors reviewed applicable documentation to plan future inspections in these areas.
      01. At Watts Bar Nuclear Plant, twenty of the 24 feeders that fall under this category are
 
      either Unit 1 or are common to both units and are already in service. The remaining four
41   The actions discussed covered the following areas as applicable:
      feeders are the Unit 2 Condenser Circulation Water (CCW) pump non safety-related
* Walk-downs
      cables that the applicant has scheduled for testing prior to fuel load. Based on the
* Engineering
      results of this inspection, this GL is closed for Unit 2.
* Construction
  c.  Conclusions
* Testing  The purpose of these discussions was for the inspectors to gain an understanding of the actions required to close the subject CAPs, in order to help them develop inspection
      Based on the results of this inspection, Generic Letter 2007-01 is closed for Unit 2. The
plans and preliminary inspection schedules.  Actual inspection activities associated with CAPs and SPs performed during this reporting period are discussed elsewhere in this report and contain the appropriate observations and findings.
      only four remaining feeder cables left as part of the response to the generic letter are the
OA.1.3 (Closed) Electrical Issues CAP Sub-issue: Adhesive Backed Cable Support Mount              (TI 2512/020, IP 51063)
      Unit 2 CCW pump feeders, which are non safety-related and are scheduled to be tested.
a. Inspection Scope
OA.1.8 (Discussed) Inspection of Watts Bar Nuclear Plant Master Fuse List Special
The inspectors reviewed the applicant's actions to resolve the Electrical CAP Sub-Issue, Adhesive Backed Cable Support Mount, to confirm that the applicant's program complies
        Program (TI 2512/037)
with all commitments and NRC requirements. The inspectors reviewed calculations, specification (G-38), EDCR, drawings, documentation of walk downs, and inspected a number of control panels in the Unit 2 Control Room.  b. Observations and Findings
  a. Inspection Scope
No findings of significance were identified. The inspectors determined that all adhesive backed cable support mounts have been removed and replaced with cable ties and Ty-rap clamps to maintain separation inside panels and control cabinets to provide the physical restraint required by the specifications. The inspectors verified that redundant divisional train safety-related cables inside selected Main Control Room cabinets were placed in braided sleeves as called out in the specifications.  c. Conclusions
      The inspectors reviewed design activities associated with implementation of the Master
This inspection concluded that concerns pertaining to the electrical CAP sub-issue, on adhesive backed cable mount supports, have been appropriately addressed for Watts Bar Unit 2.
      Fuse List (MFL) Special Program for Unit 2. The inspectors evaluated planned and in-
 
      process activities to confirm Unit 2 actions paralleled the actions implemented on Unit 1;
OA.1.4 (Discussed) Cable Issues CAP Sub-Issue: Computerized Cable Routing System 
 
            Software and Database Verification and Validation (TI 2512/016)
                                              44
  and to determine whether the Unit 2 actions were technically valid and were
  implemented in accordance with NRC and applicant requirements. The inspectors
  interviewed responsible design personnel and reviewed documents related to the Unit 2
  implementation plan. The information was compared to actions taken on Unit 1 as
  described in the Watts Bar SER (NUREG 0847), the Watts Bar Nuclear Performance
   Plan, and the Watts Bar Unit 1 CAPs/SPs Closure Book.
b. Observations and Findings
  The Unit 2 implementation plans were found to be generally consistent with the scope of
  the Unit 1 MFL Special Program.
  The inspectors made the following observations about the key elements of the Unit 2
  Special Program:
  1)      Establishment and maintenance of a field-verified Master Fuse List
          Consistent with the Unit 1 Special Program, the inspectors found that
          requirements for Unit 2 fuses were formally defined in Design Criteria WB-DC-30-
          05, WB-DC-30-27, and WB-DC-30-28. The design criteria were applicable to
          both units and were controlled according to TVA Nuclear procedure NEDP-1,
          Design Basis and Design Input Control.
          A review of EDCRs 52324, 54796, and 54798 determined that design
          engineering had developed coordinated fuse applications and had specified fuse
          types, fuse sizes, and fuse ratings. The requirements were formally input into a
          master list of fuses (i.e. Fuse Tabulations) in the Master Equipment List (MEL).
          The inspectors review of EDCR 52324 verified that, consistent with Unit 1,
          vendor-supplied fuses were controlled in the MEL for those instances where the
          fuses were credited for protection of safety-related items. A review of TVA
          procedure SPP-9.6, Master Equipment List, verified the control of the MEL
          information system was guided by a written procedure, and was applicable to
          both Unit 1 and Unit 2.
          A review of TVA Operations procedure OPDP-7, Fuse Control, verified that
          controls had been established to maintain correct fuse configurations after
          equipment turnover from construction. The controls were applicable to both Unit
          1 and Unit 2.
          The inspectors noted that the Unit 1 program called for field walk-downs by the
          applicant to verify correct installations of Special Program fuses; however,
          interviews with responsible applicant personnel indicated that the construction
          project had not yet progressed to the point where the fuses have been installed.
          Thus, the applicant had not yet implemented plans to field-verify the correct
          installation of fuses on Unit 2. Further, interviews with responsible applicant
          personnel indicated the fuse tabulations in the MEL will not be appended to the
          permanent equipment information system (MAXIMO) until after the as-installed
          fuse configurations are verified.
  2)      Correction of deficiencies with misapplication of Bussmann KAZ actuators
          The inspectors review of electrical calculations WBNEEBEDQ00299920080019
          and WBNEEBMSTI0070005 verified that the applicant has identified applications
          using KAZ actuators and, consistent with Unit 1, has specified replacement fuses
          that were electrically coordinated with the associated distribution systems.
          Requirements for the replacement fuses were formally input to the Fuse
          Tabulations of the MEL as documented in EDCR 54798.
 
                                                  45
                The inspectors interviews with responsible applicant personnel indicated that the
                construction project had not progressed to the point where replacement fuses for
                KAZ actuators could be physically installed on Unit 2. Accordingly, the applicant
                was not ready to field-verify the correct installations of replacement fuses as
                done under the Unit 1 Special Program.
      3)        Correction of deficiencies with redundant protection for electrical penetration
                assemblies.
                The inspectors review of calculation WBNEEBEDQ00299920080019 verified the
                calculation specified redundant protection for electrical penetration assemblies to
                prevent damage from fault currents or overload conditions. The calculation
                documented that the analyzed configurations were based upon reviews of as-
                designed drawings and ultimately were to be compared to as-constructed or
                configuration controlled drawings. The inspectors determined that the analyzed
                capabilities of the penetration assemblies were documented and demonstrated to
                be able to withstand the analyzed fault currents. Also, the calculation
                demonstrated the coordination of electrical protection devices associated with the
                penetration assemblies. The inspectors determined that the requirements for the
                electrical penetration assembly fuses were formally input to the Fuse Tabulations
                of the MEL as documented in EDCR 54798.
                Because the construction project had not progressed to the point where the new
                fuse configurations have been installed, inspectors did not perform a verification
                of correct installation.
  c.  Conclusions
      The inspectors determined that the activities committed for the MFL Special Program are
      still in process and will require further inspection to verify acceptable completion. In this
      inspection, the inspectors obtained sufficient samples to verify that a master list of fuses
      was being configured in the MEL; however, the permanent fuse list had not been
      updated. Inspectors verified that provisions have been made to replace KAZ actuators,
      and that design requirements have been developed to provide redundant protection of
      electrical penetration assemblies. However, the applicant had not yet installed the
      Special Program fuses on Unit 2, and had not conducted field verifications of the as-
      installed configurations. Further inspection will be required to verify effective
      implementation and completion of the Special Program.
OA.1.9 (Discussed) NRC Bulletins 74-15, Misapplication of Cutler-Hammer Three
        Position Maintained Switch Model No. 10250T; 75-03, Incorrect Lower Disc
        Spring and Clearance Dimension in Series 8300 and 8302 ASCO Solenoid
        Valves; and 75-06, Defective Westinghouse Type OT-2 Control Switches
  a.  Inspection Scope
      The inspectors reviewed the responses from the applicant regarding all three NRC
      Bulletins. The inspectors reviewed historical NRC inspection reports, response letters,
      and tracking records. The inspectors interviewed TVA engineers responsible for
      compliance with the individual bulletins to understand what activities had been
      performed. The documents reviewed in response to each of the NRC Bulletins were:
      1) Bulletin 74-15; the inspectors reviewed NRC inspection reports 50-390/75-5 and 50-
            391/75-5, response letter T90 080128 001, and tracking record NCO080008070.
      2) Bulletin 75-03; the inspectors reviewed NRC inspection reports 50-390/75-6 and 50-
            391/75-6, response letter T90 080128 001, and tracking record NCO080008030.
 
                                                46
      3) Bulletin 75-06; the inspectors reviewed NRC inspection reports 50-390/85-25 and
          50-391/85-20, response letter T02 080320 001, and tracking record 10187136.
  b.  Observations and Findings
      No findings of significance were identified.
      The inspectors made the following observations about each electrical component and
      system:
      1) Interviews conducted by the inspectors with TVA and Bechtel engineers, responsible
          for compliance with this bulletin, revealed that TVA plans to replace existing Cutler-
          Hammer model 10250T switch with the new Eaton 10250T switch and to
          environmentally qualify existing Eaton 10250T switches.
      2) Discussions with licensing and engineering personnel overseeing compliance to
          Bulletin 75-03 revealed that the intent was to replace all associated valves instead of
          modification.
      3) The original applicant response letter for Bulletin 75-06 stated that the only action
          would be to inspect these switches. Licensing and engineering personnel indicated
          that the applicant will be refurbishing functional control switches and replacing
          inadequate control switches.
      In all three cases the applicant has not yet prepared design modification packages for
      this work.
  c.  Conclusions
      The inspectors determined that the activities committed to correct the misapplication of
      the Cutler-Hammer three position switches, incorrect lower disc spring and clearance
      dimension in Series 8300 and 8302 ASCO solenoid valves, and defective Westinghouse
      Type OT-2 control switches are still in process and will require further inspection to verify
      acceptable completion.
OA.1.10 (Discussed) NRC Bulletin 76-02, Relay Coil Failures - General Electric Type HFA,
        HGA, HKA, and HMA Relays
  a.  Inspection Scope
      The inspectors reviewed the response from the applicant regarding NRC Bulletin 76-02,
      Relay Coil Failures - GE Type HFA, HGA, HKA, and HMA Relays. The inspectors
      reviewed the applicants response letter T02 080320 001 and tracking record 10187197.
      The inspectors interviewed the TVA and Bechtel engineers responsible for compliance
      with this bulletin to understand what activities had been achieved.
  b.  Observations and Findings
      No findings of significance were identified. The responsible engineer for this effort
      informed the inspectors that 14 of these relays were safety-related and that the entire
      population would be replaced with the current version of the same relay.
  c.  Conclusions
      The inspectors determined that the activities committed to correct relay coil failures for
      GE type HFA, HGA, HKA, HMA relays are still in process and will require further
      inspection to verify acceptable completion.
 
                                                47
OA.1.11 (Discussed) Violation 391/86-02-01; Failure to Follow Procedures that Resulted in
        Improperly Installed Solenoid Valves
  a.  Inspection Scope
      The inspectors reviewed the response from the applicant regarding NRC Violation 86-
      02-01, 10 CFR 50, Appendix B, Criterion V, Failure to Follow Procedures. The
      inspectors reviewed the historical NRC reports 50-390/86-02 and 50-391/86-02, as well
      as the applicants response letter to Violation 86-02-01, tracking record NCO860152003,
      and PER 143711. The inspectors interviewed the TVA and Bechtel engineers
      responsible for resolution of this violation to understand what activities had been
      achieved.
  b.  Observations and Findings
      No findings of significance were identified.
      Actions required to resolve this violation for Unit 2 have not been completed. An
      updated response to the violation dated June 12, 1995 sent to the NRC (Applicant
      tracking number T04950612145 - WATTS BAR NUCLEAR PLANT (WBN) - REVISED
      RESPONSE TO VIOLATION 50-390, 391/86-02-01, FAILURE TO FOLLOW
      PROCEDURE AND REVISED FINAL REPORT FOR CDRs 50-390/85-52 AND 50-
      391/86-14) outlined the proposed solution to modify the solenoid valve mounts to
      become compliant through vendor-approved instructions or justification to use as-is.
  c.  Conclusions
      The inspectors determined that the activities committed to correct this violation have not
      been performed and will require further inspection to verify acceptable completion.
OA.1.12 (Discussed) Inspection of Watts Bar Nuclear Plant Radiation Monitoring System
        Special Program (TI 2512/041)
  a.  Inspection Scope
      The inspectors reviewed design activities associated with implementation of the
      Radiation Monitoring System (RMS) Special Program for Unit 2. The inspectors
      examined planned and in-process actions to confirm Unit 2 actions paralleled the actions
      implemented on Unit 1; and to determine whether the Unit 2 actions results were
      technically valid, and were implemented in accordance with NRC and applicant
      requirements. The inspectors interviewed responsible design personnel and reviewed
      program documentation related to the Unit 2 implementation plan. The information was
      compared to actions taken on Unit 1 as described in the Watts Bar SER (NUREG 0847),
      the Watts Bar Nuclear Performance Plan, and the Watts Bar Unit 1 CAPs/SPs Closure
      Book.
  b.  Observations and Findings
      The Unit 2 activities were found to be generally consistent with the scope of the Unit 1
      RMS Special Program.
      The inspectors made the following determinations about the key elements of the Unit 2
      Special Program:
      1)      Establishment and maintenance of formally defined design criteria
              The inspectors review of RMS Design Criteria, WB-DC-40-24, determined the
              document implemented the Special Program commitment to formally define RMS
              design requirements and to incorporate the requirements of NRC Regulatory
              Guide 1.97. The design criteria were applicable to both units. In addition,
 
                                                48
                inspectors found that design criteria documents were controlled according to TVA
                Nuclear procedure NEDP-1, Design Basis and Design Input Control.
      2)      Correction of deficiencies with RMS sample lines
                Design actions to correct deficiencies with radiation monitoring system sampling
                lines were still in process. No samples were yet available for NRC inspection.
      3)      Correction of deficiencies with RMS hardware
                The inspectors evaluated design measures for the Main Steam Line Radiation
                Monitors as defined in EDCR 2-52342. Consistent with the Special Program
                actions implemented for Unit 1, the Unit 2 EDCR and its supporting calculations
                were found to define range and accuracy requirements in accordance with the
                specifications for Type E variables contained in NRC Regulatory Guide 1.97.
                The EDCR documented that the Unit 2 design had no equipment differences or
                operating differences with Unit 1. Inspectors noted a companion design change,
                Design Change Notice (DCN) 51154, was incorporated into the EDCR that
                changed the radiation monitors reset logic following loss of power to the
                monitors. The design change was appropriately justified, was reviewed and
                approved by designated authority, and was applied to both units.
                Interviews with responsible management indicated the procurement of the Main
                Steam Line Radiation Monitors was still in process, and the monitors have not yet
                been received or installed.
                No other designs for Special Program radiation monitors were issued at the time
                of this inspection.
      4)        Correction of omissions in documenting calibrations of RMS devices
                Actions to correct deficiencies with documenting primary calibrations of radiation
                monitor were still in process. No samples were available for NRC inspection.
  c.  Conclusions
      The inspectors determined that the activities committed for the RMS Special Program
      were still in process and will require further inspection to verify acceptable completion.
      The inspectors verified that formal design criteria had been established for the Unit 2
      radiation monitoring system. The inspectors reviewed one of the Special Program
      measures to correct hardware deficiencies. No significant issues were identified;
      however, further inspection will be required to evaluate correct installation of design
      features. Also, additional reviews of hardware designs will be required to determine
      acceptable implementation of this element of the RMS Special Program. The Special
      Program elements associated with deficient sample lines and primary calibrations were
      still in process and not available for inspection. Further inspection will be required to
      verify effective implementation of the Special Program.
OA.1.13 (Discussed) Applicant Actions on Three Mile Island (TMI) Action Items
  a.  Inspection Scope
      The inspectors reviewed Unit 2 design activities associated with TMI Action Items and
      for the following electrical components and systems: 1) Acoustic Monitoring Valve
      position indication, 2) emergency power for pressurizer heaters, 3) power supplies for
      pressurizer relief valves, block valves, level indicators, and 4) emergency power
      associated with coolant pump seals. Unit 2 design activities associated with hydrogen
      igniter backup power were also reviewed for consistency with Generic Safety Issue-189
 
                                            49
  (GI-189) requirements. The inspectors assessed whether TMI or GI-189 actions
  including NRC requirements and SAR commitments were properly translated into
  drawings, design change packages, procedures, and other electrical component design
  documentation and whether the design was adequately controlled.
  The inspectors observed and evaluated storage activities and conditions for electrical
  components to determine whether components were stored in the proper storage level
  designation, properly identified, and that storage environmental conditions and
  requirements were controlled and monitored as specified by the applicable manufacturer
  specification. The inspectors reviewed applicant and contractor monitoring activities to
  determine if they were being performed in accordance with procedural requirements.
  The inspectors reviewed documentation received with components relative to quality
  requirements to assure manufacturer requirements were met.
  The inspectors reviewed storage procedure, Bechtel Field Material Storage Control No.
  25402-PRO-0007, to determine if it provided a means to assure that proper storage
  environments were established for various types of electrical components and met
  applicable storage classification levels regardless of location of stored component.
  The inspectors reviewed design drawings and documents and interviewed responsible
  design personnel related to this inspection scope. The design information was reviewed
  for actions taken on Unit 2 required in NUREG 0737, Clarification of TMI Action Plan
  Requirements. The Unit 2 planned or in-process activities were also compared to
  actions taken on Unit 1 as a result of the TMI requirements to determine whether the
  Unit 2 actions were technically valid and were implemented in accordance with NRC and
  applicant requirements.
  Additionally, the inspectors evaluated actions planned or in-process for the following TMI
  Action Items: Noble Gas Monitors (TMI II.F.1.2.A), Iodine Particulate Sampling (TMI
  II.F.1.2.A), Containment High Range Monitoring (TMI II.F.1.2.C), and In-Plant Radiation
  Monitoring (TMI III.D.3.3).
b. Observations and Findings
  No findings of significance were identified.
  The inspectors made the following observations about each electrical component and
  system:
  1)      Valve Position Indication of Acoustic Monitoring on PORVs (TMI Action Item
          II.D.3)
          The inspectors reviewed EDCR 52409, Replacement of Equipment required for
          Unit 2 Acoustic Monitoring system. Since Unit 1 has already completed the
          required TMI Actions, the Unit 2 design parallels Unit 1. Types of new
          components that were installed in Unit 1 are planned to be installed in Unit 2 per
          EDCR 52409. The inspectors determined that the design change package was in
          accordance with Procedure SPP-9.3, Plant Modification & Engineering Change
          Control, and design changes were technically valid.
          The design had not progressed to the point of installation of the Acoustic
          Monitors on Unit 2. Therefore, the inspectors were unable to verify the correct
          installation of Acoustic Monitor level indication components on Unit 2.
          Procurement documentation for Acoustic Monitors and electrical components
          (PO#: 00049277) was reviewed for adherence to manufacturers storage
          specifications and applicant requirements. Five samples of electrical
          components were inspected for proper storage in the warehouse. The electrical
          components were stored in the proper storage level designation and were
 
                                              50
          properly identified by the correct labels, part numbers, and serial numbers on the
          receipt inspection label. Storage conditions and requirements were controlled
          and monitored as specified by the applicable specification and manufacturer, and
          in-place storage requirements were satisfied.
  2)      Emergency Power for Pressurizer (PZR) Heaters (TMI Action Item: II.E.3.1) /
          Power Supplies for PZR Relief Valves, Block Valves, & Level Indicators (TMI
          Action Item: II.G.1) / Power from Emergency Diesel Generator on Reactor
          Coolant Pump seals (TMI Action Item: II.K.3.25)
          According to the drawings, the design for Unit 2 PZR heater emergency power,
          power supplies for PZR relief and block valves, level indicators, and power from
          emergency diesel generator for reactor coolant pump seals is identical to the Unit
          1 design. TMI actions, NRC requirements and SAR commitments were properly
          translated into design drawings for adequate control and installation of electrical
          components. Through interviews with responsible applicant personnel, the
          inspectors determined that there was no other design documentation to review
          because there were no planned design change activities taking place on the Unit
          2, and the design had not progressed to the point of installation on Unit 2.
          Therefore, the inspectors were unable to verify the correct installation of the PZR
          heater components on Unit 2.
  3)      Back-up Power for Hydrogen Igniters (GI-189 and TI 2515/174)
          The inspectors reviewed EDCR 52348, complete installation/refurbish of
          Hydrogen Mitigation System in Unit 2. The inspectors determined that the design
          change package was in accordance with Procedure SPP-9.3, design changes
          were technically valid, and the Unit 2 design of hydrogen igniters parallels Unit 1.
          New hydrogen igniters will be installed on Unit 2 per EDCR 52348.
          Procurement documentation for Hydrogen Igniters and electrical components
          (PO#: 00070570) was reviewed for adherence to manufacturers storage
          specifications and applicant requirements. Two samples of electrical
          components were inspected for proper storage in the warehouse. The electrical
          components were stored in the proper storage level designation and were
          properly identified by the correct labels, part numbers, and serial numbers on the
          receipt inspection label. Storage conditions and requirements were controlled
          and monitored as specified by the applicable specification and manufacturer, and
          in-place storage requirements were satisfied.
          The design of the backup power supply for hydrogen igniters per GI-189 and TI
          2515/174 commitments could not be verified from design documentation
          reviewed for Unit 2. The inspectors determined, from interviews with the
          applicant, that Unit 1 has developed procedures to support the temporary
          connection of a backup power supply to hydrogen igniters; however, the Unit 2
          design activities have not progressed to incorporate any of the GI-189
          requirements into the Unit 2 design, or to the point of installation of the hydrogen
          igniters.
c. Conclusions
  The inspectors determined that the activities committed to for the previously mentioned
  TMI actions and GI-189 requirements are still in process or not available for review, and
  will require further inspection to verify acceptable completion. Inspectors were able to
  obtain sufficient samples of electrical components to verify that storage requirements
  were met and manufacturer specifications were followed. Design packages and/or
 
                                          51
    drawings were also verified for adherence to SAR commitments and requirements. On
    each system, the applicant had not yet installed the necessary components on Unit 2 in
    accordance with TMI actions and GI-189, so further inspection will be required to verify
    effective implementation and completion of the TMI Action Items and GI-189
    commitments.
V.  Management Meetings
X.1 Exit Meeting Summary
    On July 13, 2010, the resident inspectors presented the inspection results to Mr. Masoud
    Bajestani and other members of his staff. Although some proprietary information may
    have been reviewed during the inspection, no proprietary information was included in
    this inspection report..


a. Inspection Scope
                              SUPPLEMENTAL INFORMATION
The inspectors reviewed the applicant's actions to resolve the Cable CAP Sub-Issue, Computerized Cable Routing System (CCRS) software and database verification and validation and to evaluate related activities to confirm that the applicant's program
                                  KEY POINTS OF CONTACT
complies with all commitments and NRC requirements.  The inspectors reviewed documentation and scheduling to inspect signal tracing field activities associated with this sub-issue.  The inspectors interviewed responsible design personnel and reviewed the "Environmental Qualification Cable Walkthroughs" that establishes the schedule for signal tracing field activities.  Anomaly tables and action listings were reviewed to
Applicant personnel
establish reasonable assurance that data transfer from CCRS to ICRDS has been verified.
C. Ankeny, Quality Assurance Manager, PCI Energy Services
 
G. Arent, Licensing Manager, Unit 2
42    b. Observations and Findings
M. Bajestani, Vice President, Unit 2
No findings of significance were identified. The applicant replaced CCRS with ICRDS and transferred the data, which included Unit 1 and 2 cables, to the new system. The inspectors determined that the applicant verified and validated the transfer of data into ICRDS in accordance with TVA QA procedures.  Part of the Unit 2 verification methodology will be to signal trace all Environmental Qualification (EQ) and Appendix R
M. Bali, Electrical Design Manager, Bechtel
cables that are shown as installed in ICRDS, but do not have pull cards available (missing QA records).  The purpose of the signal trace is to verify the routing and lengths of cables for comparison with information in ICRDS. Observations of signal tracing activities are discussed in Section C.1.6.
R. Baron, Nuclear Assurance Project Manager, TVA, Unit 2
Conclusions
D. Beckley, Electrical Design Manager, Bechtel
The inspectors determined that further inspection will be required to verify acceptable completion of the CAP Sub-Issue, ICRDS software and database verification and validation.    OA.1.5 (Discussed) Station Blackout (SBO) Rule Procedures and Actions (TI 2515/120)
T. Moran, MELB and MIC Special Program Owner
a. Inspection Scope
B. Briody, Maintenance and Modifications Manager, TVA, Unit 2
The inspectors reviewed design activities associated with implementation of the SBO requirements for Unit 2. The inspectors examined planned and in-process actions to confirm Unit 2 actions paralleled the actions implemented on Unit 1 and to determine whether the Unit 2 actions were technically valid, and were implemented in accordance with NRC and applicant requirements. The inspectors interviewed the responsible engineering representatives to determine the applicant's status toward completion of the SBO rule requirements.  The inspectors reviewed design calculations EPMMA041592 Rev. 10, "SBO Coping Evaluation," to determine the applicant's required SBO time period and actions necessary to cope with an the event. Additionally, the inspectors reviewed EDQ00023620070003 Rev. 5, "125V
B. Crouch, Lead Mechanical Engineer, TVA, Unit 2
DC Vital Battery System Analysis," to determine the adequacy of the applicant's 125V DC batteries and chargers. b. Observations and Findings
M. Das, Principal Engineer, Bechtel
No findings of significance were identified. The inspectors' interviews and reviews of design calculations determined that the applicant has not completed the as-built design
L. Davenport, Contracts/Procurement Manager, TVA, Unit 2
calculations, procedures, and action requirements.  The applicant's intent is to parallel Unit 1 SBO requirements.  c. Conclusions
M. Easter, Westinghouse Joint Test Team Manager
  The inspectors determined that further inspection will be required to verify acceptable completion of SBO procedures and processes.  
R. Esnes, Engineering Manager, Washington Group, Inc
OA.1.6 (Discussed) Non-cited Violation NCV-391/2008-010-01 Corrective Action for 
T. Franchuk, Quality Manager, Bechtel
            Failure to Document a Cable Raceway Separation Non-conforming Condition. a. Inspection Scope
E. Freeman, Engineering Manager, TVA, Unit 2
The inspectors reviewed documentation, performed an independent walk down, and interviewed responsible personnel related to the Unit 2 corrective action plan associated with NCV-391/2008-010-01 for failure to document non-conforming cable raceways.  The inspectors reviewed PER 158979 to determine the corrective action plan taken by the applicant.  The inspectors reviewed walk down procedure WDP-GEN-1 package 
W. Goodman, Procurement Manager, Bechtel
43    number LSWDP-430 to determine the extent of condition found by the applicant.  The inspectors performed an independent walk down of a portion of the facility to verify the adequacy of the applicant findings.  The inspectors interviewed engineering personnel responsible for implementing the extent of condition walk down to determine the synthesis of the corrective action plan and extent of condition.  
J. Hannah, Corrective Action Coordinator, Bechtel
b. Observations and Findings
D. Helms, Lead Engineer CAPs & SPs, TVA, Unit 2
No findings of significance were identified.
S. Hilmes, Lead Electrical Engineer, TVA, Unit 2
The inspectors' independent walk down and interviews with applicant personnel determined that corrective actions were adequate with the exception of non safety raceways associated with safety race ways and conduits and their traceability between
M. Lackey, ECP Rep, TVA, Unit 2
divisions, which could not be verified.  c. Conclusions
I. Khan, Electrical Engineer, Bechtel Design
The inspectors determined that further inspection will be required to verify acceptable closure of the NCV. The inspection of the associated raceways could not be completed during this inspection.
R. Kuhn, Quality Assurance Manager, Bechtel
OA.1.7 (Closed) NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power              Cable Failures that Disable Accident Mitigation Systems or Cause Plant              Transients.  a. Inspection Scope
D. Malone, Quality Assurance, TVA, Unit 2
The inspectors reviewed the TVA's actions in response to GL 07-01 including Response Letter dated September 7, 2007 - Attachment 22 identifying the extent of the scope
J. Mitchell, Field Procurement Manager, Bechtel
covering 24 pump feeder cables.  The inspectors reviewed ICRDS cable reports on safety-related control cables running underground to address similar concerns of disabling accident mitigating systems.  The inspectors reviewed wiring diagram drawings and conduit & grounding detail drawings associated with the underground control cables. b. Observations and Findings
J. Moseley, Westinghouse Site Director
This generic issue identified that cables, qualified for 40 years through the equipment qualification program, were failing at several nuclear stations prior to the end of their qualified life. In an effort to address this issue, the NRC published Generic Letter 2007-01.  At Watts Bar Nuclear Plant, twenty of the 24 feeders that fall under this category are either Unit 1 or are common to both units and are already in service.  The remaining four
D. Myers, Quality Assurance Manager, TVA, Unit 2
feeders are the Unit 2 Condenser Circulation Water (CCW) pump non safety-related cables that the applicant has scheduled for testing prior to fuel load. Based on the results of this inspection, this GL is closed for Unit 2.  c. Conclusions
B. Newton, General Manager- Welding Technology and Programs, PCI Energy Services
Based on the results of this inspection, Generic Letter 2007-01 is closed for Unit 2.  The only four remaining feeder cables left as part of the response to the generic letter are the Unit 2 CCW pump feeders, which are non safety-related and are scheduled to be tested. 
J. Robertson, Engineering Manager, Bechtel
  OA.1.8 (Discussed) Inspection of Watts Bar Nuclear Plant Master Fuse List Special              Program (TI 2512/037) a. Inspection Scope
S. Sawa, Training Manager, Bechtel
The inspectors reviewed design activities associated with implementation of the Master Fuse List (MFL) Special Program for Unit 2.  The inspectors evaluated planned and in-process activities to confirm Unit 2 actions paralleled the actions implemented on Unit 1; 
J. Schlessel, Construction Manager, TVA, Unit 2
44    and to determine whether the Unit 2 actions were technically valid and were implemented in accordance with NRC and applicant requirements. The inspectors interviewed responsible design personnel and reviewed documents related to the Unit 2 implementation plan.  The information was compared to actions taken on Unit 1 as described in the Watts Bar SER (NUREG 0847), the Watts Bar Nuclear Performance Plan, and the Watts Bar Unit 1 CAPs/SPs Closure Book.  b. Observations and Findings
P. Theobold, Radcon Supervisor, TVA, Unit 2
The Unit 2 implementation plans were found to be generally consistent with the scope of the Unit 1 MFL Special Program. The inspectors made the following observations about the key elements of the Unit 2 Special Program: 1) Establishment and maintenance of a field-verified Master Fuse List
D. Tinley, Quality Assurance, TVA, Unit 2
Consistent with the Unit 1 Special Program, the inspectors found that requirements for Unit 2 fuses were formally defined in Design Criteria WB-DC-30-05, WB-DC-30-27, and WB-DC-30-28.  The design criteria were applicable to both units and were controlled according to TVA Nuclear procedure NEDP-1, "Design Basis and Design Input Control."  A review of EDCRs 52324, 54796, and 54798 determined that design engineering had developed coordinated fuse applications and had specified fuse types, fuse sizes, and fuse ratings. The requirements were formally input into a master list of fuses (i.e. Fuse Tabulations) in the Master Equipment List (MEL).  The inspectors' review of EDCR 52324 verified that, consistent with Unit 1, vendor-supplied fuses were controlled in the MEL for those instances where the
R. White, Radiography Level III
fuses were credited for protection of safety-related items.  A review of TVA procedure SPP-9.6, "Master Equipment List," verified the control of the MEL information system was guided by a written procedure, and was applicable to both Unit 1 and Unit 2. A review of TVA Operations procedure OPDP-7, "Fuse Control," verified that controls had been established to maintain correct fuse configurations after equipment turnover from construction.  The controls were applicable to both Unit 1 and Unit 2. The inspectors noted that the Unit 1 program called for field walk-downs by the applicant to verify correct installations of Special Program fuses; however,  
                                                                    Attachment
interviews with responsible applicant personnel indicated that the construction project had not yet progressed to the point where the fuses have been installed. Thus, the applicant had not yet implemented plans to field-verify the correct installation of fuses on Unit 2. Further, interviews with responsible applicant personnel indicated the fuse tabulations in the MEL will not be appended to the
permanent equipment information system (MAXIMO) until after the as-installed fuse configurations are verified. 2) Correction of deficiencies with misapplication of Bussmann KAZ actuators
The inspectors' review of electrical calculations WBNEEBEDQ00299920080019 and WBNEEBMSTI0070005 verified that the applicant has identified applications using KAZ actuators and, consistent with Unit 1, has specified replacement fuses that were electrically coordinated with the associated distribution systems.  Requirements for the replacement fuses were formally input to the Fuse Tabulations of the MEL as documented in EDCR 54798. 
45    The inspectors' interviews with responsible applicant personnel indicated that the construction project had not progressed to the point where replacement fuses for KAZ actuators could be physically installed on Unit 2. Accordingly, the applicant was not ready to field-verify the correct installations of replacement fuses as done under the Unit 1 Special Program. 3) Correction of deficiencies with redundant protection for electrical penetration
assemblies.
The inspectors' review of calculation WBNEEBEDQ00299920080019 verified the calculation specified redundant protection for electrical penetration assemblies to prevent damage from fault currents or overload conditions. The calculation documented that the analyzed configurations were based upon reviews of as-
designed drawings and ultimately were to be compared to as-constructed or configuration controlled drawings.  The inspectors determined that the analyzed capabilities of the penetration assemblies were documented and demonstrated to be able to withstand the analyzed fault currents.  Also, the calculation demonstrated the coordination of electrical protection devices associated with the penetration assemblies.  The inspectors determined that the requirements for the electrical penetration assembly fuses were formally input to the Fuse Tabulations
of the MEL as documented in EDCR 54798. Because the construction project had not progressed to the point where the new fuse configurations have been installed, inspectors did not perform a verification of correct installation.  c. Conclusions
The inspectors determined that the activities committed for the MFL Special Program are still in process and will require further inspection to verify acceptable completion. In this inspection, the inspectors obtained sufficient samples to verify that a master list of fuses was being configured in the MEL; however, the permanent fuse list had not been updated.  Inspectors verified that provisions have been made to replace KAZ actuators,  
and that design requirements have been developed to provide redundant protection of electrical penetration assemblies. However, the applicant had not yet installed the Special Program fuses on Unit 2, and had not conducted field verifications of the as-installed configurations.  Further inspection will be required to verify effective implementation and completion of the Special Program.


  OA.1.9 (Discussed) NRC Bulletins 74-15, "Misapplication of Cutler-Hammer Three 
                                              2
            Position Maintained Switch Model No. 10250T"; 75-03, "Incorrect Lower Disc              Spring and Clearance Dimension in Series 8300 and 8302 ASCO Solenoid              Valves"; and 75-06, "Defective Westinghouse Type OT-2 Control Switches"  a. Inspection Scope
                          INSPECTION PROCEDURES USED
The inspectors reviewed the responses from the applicant regarding all three NRC Bulletins.  The inspectors reviewed historical NRC inspection reports, response letters, and tracking records.  The inspectors interviewed TVA engineers responsible for compliance with the individual bulletins to understand what activities had been performed.  The documents reviewed in response to each of the NRC Bulletins were: 1) Bulletin 74-15; the inspectors reviewed NRC inspection reports 50-390/75-5 and 50-391/75-5, response letter T90 080128 001, and tracking record NCO080008070. 2) Bulletin 75-03; the inspectors reviewed NRC inspection reports 50-390/75-6 and 50-391/75-6, response letter T90 080128 001, and tracking record NCO080008030.   
IP 35007    Quality Assurance Program Implementation During Construction
46   3) Bulletin 75-06; the inspectors reviewed NRC inspection reports 50-390/85-25 and 50-391/85-20, response letter T02 080320 001, and tracking record 10187136. b. Observations and Findings
IP 35060    Licensee Management of QA Activities
No findings of significance were identified. The inspectors made the following observations about each electrical component and system: 1) Interviews conducted by the inspectors with TVA and Bechtel engineers, responsible for compliance with this bulletin, revealed that TVA plans to replace existing Cutler-Hammer model 10250T switch with the new Eaton 10250T switch and to environmentally qualify existing Eaton 10250T switches.  2) Discussions with licensing and engineering personnel overseeing compliance to Bulletin 75-03 revealed that the intent was to replace all associated valves instead of modification. 3) The original applicant response letter for Bulletin 75-06 stated that the only action would be to inspect these switches.  Licensing and engineering personnel indicated that the applicant will be refurbishing functional control switches and replacing inadequate control switches.  In all three cases the applicant has not yet prepared design modification packages for this work. c. Conclusions
IP 35065   Procurement, Receiving, and Storage
The inspectors determined that the activities committed to correct the misapplication of the Cutler-Hammer three position switches, incorrect lower disc spring and clearance dimension in Series 8300 and 8302 ASCO solenoid valves, and defective Westinghouse
IP 35100    Review of QA Manual
Type OT-2 control switches are still in process and will require further inspection to verify acceptable completion.   OA.1.10 (Discussed) NRC Bulletin 76-02, Relay Coil Failures - General Electric Type HFA, 
IP 35960    QA Program Evaluation of Engineering Organization
              HGA, HKA, and HMA Relays a. Inspection Scope
IP 37002    Construction Refurbishment Process - Watts Bar Unit 2
The inspectors reviewed the response from the applicant regarding NRC Bulletin 76-02, "Relay Coil Failures - GE Type HFA, HGA, HKA, and HMA Relays."  The inspectors reviewed the applicant's response letter T02 080320 001 and tracking record 10187197.  The inspectors interviewed the TVA and Bechtel engineers responsible for compliance
IP 37055   Onsite Design Activities
with this bulletin to understand what activities had been achieved. b. Observations and Findings
IP 46053    Structural Concrete - Work Observation
No findings of significance were identified. The responsible engineer for this effort informed the inspectors that 14 of these relays were safety-related and that the entire population would be replaced with the current version of the same relay. c. Conclusions
IP 48053    Structural Steel and Supports Work Observation
The inspectors determined that the activities committed to correct relay coil failures for GE type HFA, HGA, HKA, HMA relays are still in process and will require further inspection to verify acceptable completion.
IP 49053    Reactor Coolant Pressure Boundary Piping - Work Observation
   
IP 49055    Reactor Coolant Pressure Boundary Piping Record Review
47   OA.1.11 (Discussed) Violation 391/86-02-01; Failure to Follow Procedures that Resulted in                Improperly Installed Solenoid Valves a. Inspection Scope
IP 49061   Safety-Related Piping - QA Review
The inspectors reviewed the response from the applicant regarding NRC Violation 86-02-01, "10 CFR 50, Appendix B, Criterion V, Failure to Follow Procedures."  The inspectors reviewed the historical NRC reports 50-390/86-02 and 50-391/86-02, as well
IP 49063    Safety-Related Piping - Work Observation
as the applicant's response letter to Violation 86-02-01, tracking record NCO860152003, and PER 143711.  The inspectors interviewed the TVA and Bechtel engineers responsible for resolution of this violation to understand what activities had been achieved. b. Observations and Findings
IP 50075    Safety-Related Components - Records Review
No findings of significance were identified.  Actions required to resolve this violation for Unit 2 have not been completed.  An updated response to the violation dated June 12, 1995 sent to the NRC (Applicant tracking number T04950612145 - WATTS BAR NUCLEAR PLANT (WBN) - REVISED RESPONSE TO VIOLATION 50-390, 391/86-02-01, FAILURE TO FOLLOW PROCEDURE AND REVISED FINAL REPORT FOR CDRs 50-390/85-52 AND 50-391/86-14) outlined the proposed solution to modify the solenoid valve mounts to
IP 50090    Pipe Support and Restrain Systems
become compliant through vendor-approved instructions or justification to use "as-is". c. Conclusions
IP 51051   Electrical Components and Systems - Procedure Review
The inspectors determined that the activities committed to correct this violation have not been performed and will require further inspection to verify acceptable completion.   OA.1.12 (Discussed) Inspection of Watts Bar Nuclear Plant Radiation Monitoring System                Special Program (TI 2512/041) a. Inspection Scope
IP 50053    Reactor Vessel and Internals Work Observation
The inspectors reviewed design activities associated with implementation of the Radiation Monitoring System (RMS) Special Program for Unit 2.  The inspectors
IP 51055    Electrical Components and Systems - Record Review
examined planned and in-process actions to confirm Unit 2 actions paralleled the actions implemented on Unit 1; and to determine whether the Unit 2 actions results were technically valid, and were implemented in accordance with NRC and applicant requirements. The inspectors interviewed responsible design personnel and reviewed program documentation related to the Unit 2 implementation plan.  The information was
IP 51061    Electrical Cable - Procedure Review
compared to actions taken on Unit 1 as described in the Watts Bar SER (NUREG 0847), the Watts Bar Nuclear Performance Plan, and the Watts Bar Unit 1 CAPs/SPs Closure Book.  b. Observations and Findings
IP 51063   Electric Cable - Work Observation
The Unit 2 activities were found to be generally consistent with the scope of the Unit 1 RMS Special Program.  The inspectors made the following determinations about the key elements of the Unit 2 Special Program: 1) Establishment and maintenance of formally defined design criteria
IP 51065    Electric Cable - Record Review
The inspectors' review of RMS Design Criteria, WB-DC-40-24, determined the document implemented the Special Program commitment to formally define RMS design requirements and to incorporate the requirements of NRC Regulatory
IP 52051    Instrument Components and Systems - Procedure Review
Guide 1.97.  The design criteria were applicable to both units.  In addition, 
IP 52053    Instrument Components and Systems - Work Observation
48   inspectors found that design criteria documents were controlled according to TVA Nuclear procedure NEDP-1, "Design Basis and Design Input Control."  2) Correction of deficiencies with RMS sample lines
IP 52055   Instrument Components and Systems - Record Review
Design actions to correct deficiencies with radiation monitoring system sampling lines were still in process.  No samples were yet available for NRC inspection. 3) Correction of deficiencies with RMS hardware
IP 51053    Electrical Components and Systems Work Observation
The inspectors evaluated design measures for the Main Steam Line Radiation Monitors as defined in EDCR 2-52342.  Consistent with the Special Program actions implemented for Unit 1, the Unit 2 EDCR and its supporting calculations were found to define range and accuracy requirements in accordance with the specifications for Type "E" variables contained in NRC Regulatory Guide 1.97. The EDCR documented that the Unit 2 design had no equipment differences or operating differences with Unit 1.  Inspectors noted a companion design change, Design Change Notice (DCN) 51154, was incorporated into the EDCR that changed the radiation monitors' reset logic following loss of power to the monitors.  The design change was appropriately justified, was reviewed and approved by designated authority, and was applied to both units. Interviews with responsible management indicated the procurement of the Main Steam Line Radiation Monitors was still in process, and the monitors have not yet been received or installed. No other designs for Special Program radiation monitors were issued at the time of this inspection. 4) Correction of omissions in documenting calibrations of RMS devices
IP 55050    Nuclear Welding General Inspection Procedure
Actions to correct deficiencies with documenting primary calibrations of radiation monitor were still in process.  No samples were available for NRC inspection. c. Conclusions
IP 55100    Structural Welding General Inspection Procedure
The inspectors determined that the activities committed for the RMS Special Program were still in process and will require further inspection to verify acceptable completion. 
IP 57050    Visual Testing Examination
The inspectors verified that formal design criteria had been established for the Unit 2 radiation monitoring system.  The inspectors reviewed one of the Special Program measures to correct hardware deficiencies.  No significant issues were identified; however, further inspection will be required to evaluate correct installation of design features.  Also, additional reviews of hardware designs will be required to determine
IP 57060   Liquid Penetrant Testing Examination
acceptable implementation of this element of the RMS Special Program.  The Special Program elements associated with deficient sample lines and primary calibrations were still in process and not available for inspection.  Further inspection will be required to verify effective implementation of the Special Program.
IP 57070   Nondestructive Examination Procedure Magnetic Particle Examination Procedure
OA.1.13 (Discussed) Applicant Actions on Three Mile Island (TMI) Action Items a. Inspection Scope
            Review/Work Observation/Record Review
The inspectors reviewed Unit 2 design activities associated with TMI Action Items and for the following electrical components and systems: 1) Acoustic Monitoring Valve position indication, 2) emergency power for pressurizer heaters, 3) power supplies for pressurizer relief valves, block valves, level indicators, and 4) emergency power associated with coolant pump seals.  Unit 2 design activities associated with hydrogen
IP 57080    Nondestructive Examination Procedure Ultrasonic Examination Procedure
igniter backup power were also reviewed for consistency with Generic Safety Issue-189 
            Review/Work Observation/Record Review
49   (GI-189) requirements.  The inspectors assessed whether TMI or GI-189 actions including NRC requirements and SAR commitments were properly translated into drawings, design change packages, procedures, and other electrical component design documentation and whether the design was adequately controlled.  The inspectors observed and evaluated storage activities and conditions for electrical components to determine whether components were stored in the proper storage level
IP 57090    Nondestructive Examination - RT
designation, properly identified, and that storage environmental conditions and requirements were controlled and monitored as specified by the applicable manufacturer specification.  The inspectors reviewed applicant and contractor monitoring activities to determine if they were being performed in accordance with procedural requirements.  The inspectors reviewed documentation received with components relative to quality
IP 64051   Procedures - Fire Prevention/Protection
requirements to assure manufacturer requirements were met. The inspectors reviewed storage procedure, "Bechtel Field Material Storage Control No. 25402-PRO-0007," to determine if it provided a means to assure that proper storage environments were established for various types of electrical components and met applicable storage classification levels regardless of location of stored component.  The inspectors reviewed design drawings and documents and interviewed responsible design personnel related to this inspection scope.  The design information was reviewed
IP 73051    Inservice Inspection - Review of Program
for actions taken on Unit 2 required in NUREG 0737, "Clarification of TMI Action Plan Requirements."  The Unit 2 planned or in-process activities were also compared to actions taken on Unit 1 as a result of the TMI requirements to determine whether the Unit 2 actions were technically valid and were implemented in accordance with NRC and applicant requirements. Additionally, the inspectors evaluated actions planned or in-process for the following TMI Action Items: Noble Gas Monitors (TMI II.F.1.2.A), Iodine Particulate Sampling (TMI II.F.1.2.A), Containment High Range Monitoring (TMI II.F.1.2.C), and In-Plant Radiation Monitoring (TMI III.D.3.3).  b. Observations and Findings
IP 73052    Inservice Inspection - Review of Procedures
No findings of significance were identified.  The inspectors made the following observations about each electrical component and system: 1) Valve Position Indication of Acoustic Monitoring on PORVs (TMI Action Item II.D.3) The inspectors reviewed EDCR 52409, "Replacement of Equipment required for Unit 2 Acoustic Monitoring system."  Since Unit 1 has already completed the required TMI Actions, the Unit 2 design parallels Unit 1.  Types of new components that were installed in Unit 1 are planned to be installed in Unit 2 per EDCR 52409. The inspectors determined that the design change package was in
IP 73053   Preservice Inspection - Observation of Work and Work Activities
accordance with Procedure SPP-9.3, "Plant Modification & Engineering Change Control," and design changes were technically valid. The design had not progressed to the point of installation of the Acoustic Monitors on Unit 2.  Therefore, the inspectors were unable to verify the correct installation of Acoustic Monitor level indication components on Unit 2. Procurement documentation for Acoustic Monitors and electrical components (PO#: 00049277) was reviewed for adherence to manufacturer's storage
IP 73055    Preservice Inspection Data Review and Evaluation
specifications and applicant requirements.  Five samples of electrical components were inspected for proper storage in the warehouse.  The electrical components were stored in the proper storage level designation and were 
IP 92701   Followup
50   properly identified by the correct labels, part numbers, and serial numbers on the receipt inspection label.  Storage conditions and requirements were controlled and monitored as specified by the applicable specification and manufacturer, and in-place storage requirements were satisfied.   2) Emergency Power for Pressurizer (PZR) Heaters (TMI Action Item: II.E.3.1) / Power Supplies for PZR Relief Valves, Block Valves, & Level Indicators (TMI Action Item: II.G.1) / Power from Emergency Diesel Generator on Reactor Coolant Pump seals (TMI Action Item: II.K.3.25)
TI 2512/015 Inspection of Watts Bar Nuclear Plant Employee Concerns Program
According to the drawings, the design for Unit 2 PZR heater emergency power, power supplies for PZR relief and block valves, level indicators, and power from emergency diesel generator for reactor coolant pump seals is identical to the Unit
TI 2512/016 Plant Cable Issues Corrective Action Program
1 design.  TMI actions, NRC requirements and SAR commitments were properly translated into design drawings for adequate control and installation of electrical components. Through interviews with responsible applicant personnel, the inspectors determined that there was no other design documentation to review because there were no planned design change activities taking place on the Unit 2, and the design had not progressed to the point of installation on Unit 2.  Therefore, the inspectors were unable to verify the correct installation of the PZR
TI 2512/018 Inspection of Watts Bar Nuclear Plant Electrical Conduit and Supports Corrective
heater components on Unit 2. 3) Back-up Power for Hydrogen Igniters (GI-189 and TI 2515/174)
            Action Program Plan
The inspectors reviewed EDCR 52348, complete installation/refurbish of Hydrogen Mitigation System in Unit 2. The inspectors determined that the design change package was in accordance with Procedure SPP-9.3, design changes
TI 2512/020 Plant Electrical Issues Corrective Action Program
were technically valid, and the Unit 2 design of hydrogen igniters parallels Unit 1.  New hydrogen igniters will be installed on Unit 2 per EDCR 52348. 
TI 2512/024 Inspection of Watts Bar Nuclear Plant Heat Code Traceability Corrective Action
Procurement documentation for Hydrogen Igniters and electrical components (PO#: 00070570) was reviewed for adherence to manufacturer's storage
            Program Plan
specifications and applicant requirements.  Two samples of electrical components were inspected for proper storage in the warehouse.  The electrical components were stored in the proper storage level designation and were properly identified by the correct labels, part numbers, and serial numbers on the receipt inspection label.  Storage conditions and requirements were controlled
TI 2512/025 Inspection of Watts Bar Nuclear Plant HVAC Duct and Supports Corrective
and monitored as specified by the applicable specification and manufacturer, and in-place storage requirements were satisfied.   The design of the backup power supply for hydrogen igniters per GI-189 and TI 2515/174 commitments could not be verified from design documentation reviewed for Unit 2.  The inspectors determined, from interviews with the
            Action Program Plan
applicant, that Unit 1 has developed procedures to support the temporary connection of a backup power supply to hydrogen igniters; however, the Unit 2 design activities have not progressed to incorporate any of the GI-189 requirements into the Unit 2 design, or to the point of installation of the hydrogen igniters.  c. Conclusions
The inspectors determined that the activities committed to for the previously mentioned TMI actions and GI-189 requirements are still in process or not available for review, and will require further inspection to verify acceptable completion.  Inspectors were able to obtain sufficient samples of electrical components to verify that storage requirements were met and manufacturer specifications were followed.  Design packages and/or 
51   drawings were also verified for adherence to SAR commitments and requirements.  On each system, the applicant had not yet installed the necessary components on Unit 2 in accordance with TMI actions and GI-189, so further inspection will be required to verify effective implementation and completion of the TMI Action Items and GI-189 commitments.
V. Management Meetings
X.1 Exit Meeting Summary
On July 13, 2010, the resident inspectors presented the inspection results to Mr. Masoud
Bajestani and other members of his staff.  Although some proprietary information may have been reviewed during the inspection, no proprietary information was included in this inspection report.. 
   Attachment SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Applicant personnel
  C. Ankeny, Quality Assurance Manager, PCI Energy Services
G. Arent, Licensing Manager, Unit 2 M. Bajestani, Vice President, Unit 2 M. Bali, Electrical Design Manager, Bechtel R. Baron, Nuclear Assurance Project Manager, TVA, Unit 2
D. Beckley, Electrical Design Manager, Bechtel T. Moran, MELB and MIC Special Program Owner B. Briody, Maintenance and Modifications Manager, TVA, Unit 2 B. Crouch, Lead Mechanical Engineer, TVA, Unit 2 M. Das, Principal Engineer, Bechtel L. Davenport, Contracts/Procurement Manager, TVA, Unit 2 M. Easter, Westinghouse Joint Test Team Manager
R. Esnes, Engineering Manager, Washington Group, Inc T. Franchuk, Quality Manager, Bechtel E. Freeman, Engineering Manager, TVA, Unit 2 W. Goodman, Procurement Manager, Bechtel J. Hannah, Corrective Action Coordinator, Bechtel
D. Helms, Lead Engineer CAPs & SPs, TVA, Unit 2 S. Hilmes, Lead Electrical Engineer, TVA, Unit 2 M. Lackey, ECP Rep, TVA, Unit 2 I. Khan, Electrical Engineer, Bechtel Design  R. Kuhn, Quality Assurance Manager, Bechtel 
D. Malone, Quality Assurance, TVA, Unit 2 J. Mitchell, Field Procurement Manager, Bechtel J. Moseley, Westinghouse Site Director D. Myers, Quality Assurance Manager, TVA, Unit 2 B. Newton, General Manager- Welding Technology and Programs, PCI Energy Services
J. Robertson, Engineering Manager, Bechtel S. Sawa, Training Manager, Bechtel J. Schlessel, Construction Manager, TVA, Unit 2 P. Theobold, Radcon Supervisor, TVA, Unit 2 D. Tinley, Quality Assurance, TVA, Unit 2
R. White, Radiography Level III


                                            3
 
TI 2512/028 QA Records Corrective Action Program
    2INSPECTION PROCEDURES USED
TI 2512/037 Inspection of Watts Bar Nuclear Plant Master Fuse List Special Program
TI 2512/041 Inspection of Watts Bar Nuclear Plant Radiation Monitoring System Special
IP 35007 Quality Assurance Program Implementation During Construction IP 35060 Licensee Management of QA Activities IP 35065 Procurement, Receiving, and Storage IP 35100 Review of QA Manual
            Program
IP 35960 QA Program Evaluation of Engineering Organization
TI 2515/174 Hydrogen Igniter Backup Power Verification
IP 37002 Construction Refurbishment Process - Watts Bar Unit 2
                LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
IP 37055 Onsite Design Activities IP 46053 Structural Concrete - Work Observation IP 48053 Structural Steel and Supports Work Observation
Opened
IP 49053 Reactor Coolant Pressure Boundary Piping - Work Observation IP 49055 Reactor Coolant Pressure Boundary Piping Record Review  IP 49061 Safety-Related Piping - QA Review  IP 49063 Safety-Related Piping - Work Observation IP 50075 Safety-Related Components - Records Review IP 50090 Pipe Support and Restrain Systems IP 51051 Electrical Components and Systems - Procedure Review
2010603-01                       NCV Marking and Segregation of nonconforming
IP 50053 Reactor Vessel and Internals Work Observation IP 51055 Electrical Components and Systems - Record Review IP 51061 Electrical Cable - Procedure Review IP 51063 Electric Cable - Work Observation IP 51065 Electric Cable - Record Review
                                  materials from accepted materials available for use
IP 52051 Instrument Components and Systems - Procedure Review IP 52053 Instrument Components and Systems - Work Observation IP 52055 Instrument Components and Systems - Record Review IP 51053 Electrical Components and Systems Work Observation IP 55050 Nuclear Welding General Inspection Procedure
                                  (Section Q.1.3)
IP 55100 Structural Welding General Inspection Procedure IP 57050 Visual Testing Examination IP 57060 Liquid Penetrant Testing Examination  IP 57070 Nondestructive Examination Procedure Magnetic Particle Examination Procedure  Review/Work Observation/Record Review
2010603-02                       NCV Inadequate storage and improper control of
IP 57080 Nondestructive Examination Procedure Ultrasonic Examination Procedure Review/Work Observation/Record Review IP 57090 Nondestructive Examination - RT IP 64051 Procedures - Fire Prevention/Protection IP 73051  Inservice Inspection - Review of Program
                                  documents used in safety related activities (Section Q.1.3)
IP 73052  Inservice Inspection - Review of Procedures IP 73053  Preservice Inspection - Observation of Work and Work Activities IP 73055  Preservice Inspection Data Review and Evaluation IP 92701 Followup TI 2512/015 Inspection of Watts Bar Nuclear Plant Employee Concerns Program TI 2512/016 Plant Cable Issues Corrective Action Program  TI 2512/018 Inspection of Watts Bar Nuclear Plant Electrical Conduit and Supports Corrective Action Program Plan
2010603-03                       NCV Failure to invoke 10 CFR Part 21 in safety related
TI 2512/020 Plant Electrical Issues Corrective Action Program  TI 2512/024 Inspection of Watts Bar Nuclear Plant Heat Code Traceability Corrective Action Program Plan TI 2512/025 Inspection of Watts Bar Nuclear Plant HVAC Duct and Supports Corrective Action Program Plan 
                                  procurement documents (Section Q.1.3)
    3TI 2512/028 QA Records Corrective Action Program TI 2512/037 Inspection of Watts Bar Nuclear Plant Master Fuse List Special Program TI 2512/041 Inspection of Watts Bar Nuclear Plant Radiation Monitoring System Special Program TI 2515/174 Hydrogen Igniter Backup Power Verification
2010603-04                       NCV     Undersized pipe support welds (Section C.1.3)
  LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
2010603-05                       NCV Inadequate corrective actions for non-conforming
Opened   2010603-01 NCV Marking and Segregation of nonconforming materials from accepted materials available for use (Section Q.1.3)  
                                  safety-related concrete (Section C.1.4)
2010603-02 NCV Inadequate storage and improper control of documents used in safety related activities (Section Q.1.3)  
2010603-06                       URI Material Condition inside loop-3 RCS crossover
                                  piping (Section C.1.8)
2010603-03 NCV Failure to invoke 10 CFR Part 21 in safety related procurement documents (Section Q.1.3)  
2010603-07                       NCV Failure to Protect Safety-Related Welds, Piping,
2010603-04 NCV Undersized pipe support welds (Section C.1.3)  
                                  and Components During Construction Activities (Section
                                  C.1.9)
2010603-05 NCV Inadequate corrective actions for non-conforming safety-related concrete (Section C.1.4)
2010603-08                       VIO Failure to adequately evaluate and qualify molded
  2010603-06 URI Material Condition inside loop-3 RCS crossover piping (Section C.1.8)  
                                  case circuit breakers (Section E.1.1)
2010603-07 NCV Failure to Protect Safety-Related Welds, Piping, and Components During Construction Activities (Section C.1.9) 2010603-08 VIO Failure to adequately evaluate and qualify molded case circuit breakers (Section E.1.1)
2010603-09                       NCV Failure to correctly translate the design basis into
  2010603-09 NCV Failure to correctly translate the design basis into affected specifications and drawings issued for  
                                  affected specifications and drawings issued for
construction (Section E.1.2)
                                  construction (Section E.1.2)
 
Discussed
Discussed
2512/018                         TI     QA Records CAP (Section OA.1.1)
2512/018 TI QA Records CAP (Section OA.1.1)  
2512/016                          TI      Cable Issues CAP Sub-Issue: Computerized Cable
                                  Routing System (CCRS) Software and Database
                                  Verification and Validation (Section OA.1.4)
2515/120                          TI      Station Blackout (SBO) Rule Procedures and
                                  Actions (Section OA.1.5)


2512/016 TI Cable Issues CAP Sub-Issue: Computerized Cable Routing System (CCRS) Software and Database Verification and Validation (Section OA.1.4)
                              4
2515/120 TI Station Blackout (SBO) Rule Procedures and Actions (Section OA.1.5) 
2008-010-01       NCV Corrective action for failure to document a cable
    42008-010-01 NCV Corrective action for failure to document a cable raceway separation non-conforming condition (Section OA.1.6) 2512/037 TI Inspection of Watts Bar Nuclear Plant Master Fuse List Special Program (Section OA.1.8)  
                  raceway separation non-conforming condition (Section
                  OA.1.6)
74-15 BL Misapplication of Cutler-Hammer Three Position Maintained Switch Model No. 10250T (Section OA.1.9)  
2512/037           TI     Inspection of Watts Bar Nuclear Plant Master Fuse
75-03 BL Incorrect Lower Disc Spring and Clearance Dimension in Series 8300 and 8302 ASCO Solenoid  
                    List Special Program (Section OA.1.8)
Valves (Section OA.1.9)  
74-15             BL     Misapplication of Cutler-Hammer Three Position
75-06 BL Defective Westinghouse Type OT-2 Control Switches (Section OA.1.9)  
                    Maintained Switch Model No. 10250T (Section OA.1.9)
76-02 BL Relay Coil Failures - General Electric Type HFA, HGA, HKA, and HMA Relays (Section OA.1.10)  
75-03             BL     Incorrect Lower Disc Spring and Clearance
86-02-01 VIO Failure to Follow Procedures that Resulted in Improperly Installed Solenoid Valves (Section OA.1.11) 2512/041 TI Inspection of Watts Bar Nuclear Plant Radiation Monitoring System Special Program (Section OA.1.12)  
                    Dimension in Series 8300 and 8302 ASCO Solenoid
Closed  
                    Valves (Section OA.1.9)
2512/020 (Partial) TI Electrical Issues Corrective Action Program - Sub-issue Adhesive Backed Cable Mount Supports CAP Electrical Sub-issue (Section OA.1.3)  
75-06             BL     Defective Westinghouse Type OT-2 Control
2007-01 GL Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant  
                    Switches (Section OA.1.9)
Transients (Section OA.1.7)  
76-02             BL     Relay Coil Failures - General Electric Type HFA,
                    HGA, HKA, and HMA Relays (Section OA.1.10)
 
86-02-01           VIO     Failure to Follow Procedures that Resulted in
5    LIST OF DOCUMENTS REVIEWED
                  Improperly Installed Solenoid Valves (Section OA.1.11)
I. Quality Assurance Program
2512/041           TI     Inspection of Watts Bar Nuclear Plant Radiation
Q.1.1 Identification and Resolution of Construction Problems
                    Monitoring System Special Program (Section OA.1.12)
  Procedures/Programs
Closed
  25402-MGT-0003, Corrective Action Program, Rev. 5
2512/020 (Partial) TI     Electrical Issues Corrective Action Program - Sub-
Bechtel Oversight/Self-Assessment Documents
                  issue Adhesive Backed Cable Mount Supports CAP
  QA Surveillance Report 25402-WBN-SR-10-0932, NDE - Liquid Penetrant (PT) by Ivey Cooper QA Surveillance Report 25402-WBN-SR-10-0958, NDE - Magnetic Particle (MT) by Ivey Cooper QA Surveillance Report 25402-WBN-SR-10-0960, Eye exam records of project QC personnel
                  Electrical Sub-issue (Section OA.1.3)
2007-01           GL       Inaccessible or Underground Power Cable Failures
                  that Disable Accident Mitigation Systems or Cause Plant
                  Transients (Section OA.1.7)


                                              5
                            LIST OF DOCUMENTS REVIEWED
I. Quality Assurance Program
Q.1.1 Identification and Resolution of Construction Problems
Procedures/Programs
25402-MGT-0003, Corrective Action Program, Rev. 5
Bechtel Oversight/Self-Assessment Documents
QA Surveillance Report 25402-WBN-SR-10-0932, NDE - Liquid Penetrant (PT) by Ivey Cooper
QA Surveillance Report 25402-WBN-SR-10-0958, NDE - Magnetic Particle (MT) by Ivey
Cooper
QA Surveillance Report 25402-WBN-SR-10-0960, Eye exam records of project QC personnel
Q.1.3 Procurement, Receiving, and Storage Inspection
Q.1.3 Procurement, Receiving, and Storage Inspection
 
Procedures/Programs
Procedures/Programs
  25402-000-GPP-0000-N6104, Materials Receiving, Rev. 4 25402-MGT-0003, Corrective Action Program, Rev. 7  
25402-000-GPP-0000-N6104, Materials Receiving, Rev. 4
CLS.QPP.03.001, TVA Central Laboratories Services, Corrective Action, Rev. 1 CLS.QPP.03.002, TVA Central Laboratories Services, 10 CFR Part 21 Reporting Requirements, Rev. 1 IGA-2, Intergroup Agreement TVA Nuclear and Fossil Power Group, Rev. 4 IGA-11, Intergroup Agreement with Central Laboratories Services, Rev. 0001  
25402-MGT-0003, Corrective Action Program, Rev. 7
SPP-4.3, Material Storage and Handling, Rev. 0006 Watts Bar Unit 2 Construction Completion Project, Project Nuclear Quality Assurance Manual, Rev. 5 Audits 25402-WBN-AR-09-0004, Bechtel's Internal Audit of Procurement, Supplier Quality, and Subcontractors, Rev. 0  
CLS.QPP.03.001, TVA Central Laboratories Services, Corrective Action, Rev. 1
Procurement Documents
CLS.QPP.03.002, TVA Central Laboratories Services, 10 CFR Part 21 Reporting Requirements,
  25402-000-FMR-JV01-00071, Field Material Requisition (FMR) for Diaphragm, Actuator, QA 1for Valve WBN-2-PCV-003-0183, Rev. 0 MEL Package No. 10EMC3072, Component Update Request for EDCR 53276, dated 04/06/2010 PEG PKG No. FMR-JV01-00011 M0, Technical Evaluation for Diaphragm, Aux Feedwater Turbine Pressure Reducing Valve WBN-2-PCV-003-0183, Rev. 0 PEG PKG No. CPT802W, Procurement Data Sheet (PDS) for Diaphragm, Actuator, QA 1for Valve WBN-2-PCV-003-0183, Rev. 0 PO 28498, Welding Consumables, Tape, Insulation, QA 2, Rev. 0 PO 22993-1, Pipe and Fittings, ASME III, for Auxiliary Feedwater System, Rev. 1 PO 32815 -1, Valve, Solenoid (Nuclear), Rev. 1
                  Rev. 1
6   PO 33205, Breakdown Orifices for Aux Feedwater, Orifice Assembly, ASME Section III, Class 3, QA 1, Rev. 0 PO 37189, Relay, QA 1, Order Date: 10/29/2010 PO 42199-2, Main Steam Safety Valves, Refurb., ASME Section III, Rev. 2 PO 54795, Fuses, Holder, QA 2, Order Date: 12/08/2009 PO 59120, Valves, Fittings, Bolt Studs, QA 2, Rev. 0  
IGA-2, Intergroup Agreement TVA Nuclear and Fossil Power Group, Rev. 4
PO 63534, Snubber, Hydraulic, QA 1, for Steam Generators, Rev. 0 PO 80513, Diaphragm, QA 1, Order Date: 02/24/2010 PO 87607, Limit Switch, ARMS, for Actuator, QA 2, Rev. 0 PO 87844, Electrical, Push Buttons, Etc., QA 1, Rev. 0 PO 92806, Valve, Fittings, ASME, QA 1, Rev. 0  
IGA-11, Intergroup Agreement with Central Laboratories Services, Rev. 0001
SPP-4.3, Material Storage and Handling, Rev. 0006
Watts Bar Unit 2 Construction Completion Project, Project Nuclear Quality Assurance Manual,
Rev. 5
Audits
25402-WBN-AR-09-0004, Bechtels Internal Audit of Procurement, Supplier Quality, and
                          Subcontractors, Rev. 0
Procurement Documents
25402-000-FMR-JV01-00071, Field Material Requisition (FMR) for Diaphragm, Actuator, QA
            1for Valve WBN-2-PCV-003-0183, Rev. 0
MEL Package No. 10EMC3072, Component Update Request for EDCR 53276, dated
            04/06/2010
PEG PKG No. FMR-JV01-00011 M0, Technical Evaluation for Diaphragm, Aux Feedwater
            Turbine Pressure Reducing Valve WBN-2-PCV-003-0183, Rev. 0
PEG PKG No. CPT802W, Procurement Data Sheet (PDS) for Diaphragm, Actuator, QA 1for
            Valve WBN-2-PCV-003-0183, Rev. 0
PO 28498, Welding Consumables, Tape, Insulation, QA 2, Rev. 0
PO 22993-1, Pipe and Fittings, ASME III, for Auxiliary Feedwater System, Rev. 1
PO 32815 -1, Valve, Solenoid (Nuclear), Rev. 1
 
                                              6
PO 33205, Breakdown Orifices for Aux Feedwater, Orifice Assembly, ASME Section III, Class 3,
          QA 1, Rev. 0
PO 37189, Relay, QA 1, Order Date: 10/29/2010
PO 42199-2, Main Steam Safety Valves, Refurb., ASME Section III, Rev. 2
PO 54795, Fuses, Holder, QA 2, Order Date: 12/08/2009
PO 59120, Valves, Fittings, Bolt Studs, QA 2, Rev. 0
PO 63534, Snubber, Hydraulic, QA 1, for Steam Generators, Rev. 0
PO 80513, Diaphragm, QA 1, Order Date: 02/24/2010
PO 87607, Limit Switch, ARMS, for Actuator, QA 2, Rev. 0
PO 87844, Electrical, Push Buttons, Etc., QA 1, Rev. 0
PO 92806, Valve, Fittings, ASME, QA 1, Rev. 0
Problem Evaluation Reports
PER 224697, New MRs Generated for Issued EDCRs, Reported Date: 04/12/2010
PER 225712, Increased Activity in Project Trend Code M.1 - Procurement of Material, Reported
              Date: 04/19/2010
II. Management Oversight and Controls
C.1.3 Pipe Support and Restraint Systems (IP 50090, 46071, and TI 2512/023 )
TVA Work Order 08-957282-001
Drawing Rev. Authorization 52897-005
C.1.4 Structural Concrete (IP 46053)
TVA Procedure MAI-5.10 Concrete Placement, Surface Preparation, Placing, Finishing, Curing,
and Testing, Rev. 5
TVA Procedure MAI-5.4 Concrete Removal, Repair, Grouting, and Dry Packing, Rev. 11
TVA Walk-down Procedure WDP-GEN-1 General Walk-down Requirements, Rev. 13
Service Request 180764, Concrete Mixing and Placement Violations
C.1.5 Safety-Related and RCS Pressure Boundary Piping Records Review (IPs 49055
      and 49065, TI 2515/024)
Procedures/Programs
Bechtel Procedure 25402-3DP-G06G-00001, Material Requisitions, Rev. 6
Bechtel Procedure 25402-000-GPP-0000-N6204, Field Material Control and Traceability, Rev. 7
Bechtel Procedure 25402-3DP-G06G-00010, Specifying and Evaluating Supplier Quality
Management System or Quality Assurance Program Requirements, Rev. 2
Bechtel Procedure 25402-PRO-0002, Purchase Order Formation, Rev. 3
Bechtel Procedure 25402-3DP-G06G-00012, Supplier Deviation Disposition Requests, Rev. 3
Bechtel Procedure 25402-3DP-G04G-00082, Interface with the TVA Boundary Information
Transmittal Process, Rev. 3
TVA procedure SPP-4.1, Procurement of Material, Labor, and Services, Rev. 23
TVA Procedure NEDP-8, Technical Evaluation for Procurement of Materials and Services, Rev.
14
TVA Procedure NGDC-PP-6, Completion of TVA Partial ASME Section III N-5 Data Reports,
Rev. 5


Problem Evaluation Reports
                                                7
  PER 224697, New MRs Generated for Issued EDCRs, Reported Date: 04/12/2010 PER 225712, Increased Activity in Project Trend Code M.1 - Procurement of Material, Reported Date: 04/19/2010
Purchase Orders
II. Management Oversight and Controls
Contract 74C38-83015, Principal Piping Systems, 11/19/1975
C.1.3  Pipe Support and Restraint Systems (IP 50090, 46071, and TI 2512/023 )
Corrective Action Documents
  TVA Work Order 08-957282-001
PER 228857, ASME Code Class Not Properly Recorded in WO 08-952876-000, 05/11/2010
Drawing Rev. Authorization 52897-005
PER 228824, Missing FME Cover, 05/11/2010
C.1.4  Structural Concrete (IP 46053)
PER 228845, Procedure Enhancement Regarding Requirements for CMTRs, 05/11/2010
  TVA Procedure MAI-5.10 "Concrete Placement, Surface Preparation, Placing, Finishing, Curing,
Miscellaneous
and Testing," Rev. 5 TVA Procedure MAI-5.4 "Concrete Removal, Repair, Grouting, and Dry Packing," Rev. 11 TVA Walk-down Procedure WDP-GEN-1 "General Walk-down Requirements," Rev. 13 Service Request 180764, "Concrete Mixing and Placement Violations" 
Watts Bar Unit 2 ASME N-5 Database
C.1.5 Safety-Related and RCS Pressure Boundary Piping Records Review (IPs 49055 and 49065, TI 2515/024)
Watts Bar Unit 2 Heat Code Traceability Closure Implementation Plan
  Procedures/Programs
25402-011-YDA-PB02-00002-001, Evaluation of Flange Supplied to 1995 Code Edition,
Bechtel Procedure 25402-3DP-G06G-00001, Material Requisitions, Rev. 6
08/05/2009
Bechtel Procedure 25402-000-GPP-0000-N6204, Field Material Control and Traceability, Rev. 7 Bechtel Procedure 25402-3DP-G06G-00010, Specifying and Evaluating Supplier Quality Management System or Quality Assurance Program Requirements, Rev. 2 Bechtel Procedure 25402-PRO-0002, Purchase Order Formation, Rev. 3 Bechtel Procedure 25402-3DP-G06G-00012, Supplier Deviation Disposition Requests, Rev. 3 Bechtel Procedure 25402-3DP-G04G-00082, Interface with the TVA Boundary Information Transmittal Process, Rev. 3
25402-011-YDA-JXF0-00002-001, Evaluation of Fittings Supplied to 1995 Code Edition,
TVA procedure SPP-4.1, Procurement of Material, Labor, and Services, Rev. 23 TVA Procedure NEDP-8, Technical Evaluation for Procurement of Materials and Services, Rev.
08/13/2009
14 TVA Procedure NGDC-PP-6, Completion of TVA Partial ASME Section III N-5 Data Reports, Rev. 5
WO 08-952876-000, Remove Non-Code Pipe and Replace with Code Pipe, 01/07/2009
 
BIT 371 for TVA Partial N-5 No. TVA-2-62-1-P9, Rev. 2
7    Purchase Orders
BIT 841 for TVA Partial N-5 No. TVA-2-03-2-P6, Rev. 0
Contract 74C38-83015, Principal Piping Systems, 11/19/1975  
Weld No. 2-068A-T037-05 ASME Material Certification Package
Corrective Action Documents
Weld No. 2-068A-T037-06 ASME Material Certification Package
PER 228857, ASME Code Class Not Properly Recorded in WO 08-952876-000, 05/11/2010 PER 228824, Missing FME Cover, 05/11/2010  
Weld No. 2-068A-T037-07 ASME Material Certification Package
PER 228845, Procedure Enhancement Regarding Requirements for CMTRs, 05/11/2010  
Weld No. 2-068A-T037-08 ASME Material Certification Package
Miscellaneous
Weld No. 2-068A-T037-16 ASME Material Certification Package
Watts Bar Unit 2 ASME N-5 Database Watts Bar Unit 2 Heat Code Traceability Closure Implementation Plan  
Weld No. 2-062B-T342-10 ASME Material Certification Package
25402-011-YDA-PB02-00002-001, Evaluation of Flange Supplied to 1995 Code Edition, 08/05/2009 25402-011-YDA-JXF0-00002-001, Evaluation of Fittings Supplied to 1995 Code Edition, 08/13/2009 WO 08-952876-000, Remove Non-Code Pipe and Replace with Code Pipe, 01/07/2009 BIT 371 for TVA Partial N-5 No. TVA-2-62-1-P9, Rev. 2 BIT 841 for TVA Partial N-5 No. TVA-2-03-2-P6, Rev. 0  
Weld No. 2-062B-D136-11 ASME Material Certification Package
Weld No. 2-068A-T037-05 ASME Material Certification Package Weld No. 2-068A-T037-06 ASME Material Certification Package Weld No. 2-068A-T037-07 ASME Material Certification Package Weld No. 2-068A-T037-08 ASME Material Certification Package Weld No. 2-068A-T037-16 ASME Material Certification Package  
Weld No. 2-062B-D136-11B ASME Material Certification Package
Weld No. 2-062B-T342-10 ASME Material Certification Package Weld No. 2-062B-D136-11 ASME Material Certification Package Weld No. 2-062B-D136-11B ASME Material Certification Package Weld No. 2-063A-T013-02 ASME Material Certification Package Weld No. 2-063B-T082-06 ASME Material Certification Package  
Weld No. 2-063A-T013-02 ASME Material Certification Package
Weld No. 2-068G-T013-02 ASME Material Certification Package Weld No. 2-062B-T328-01 ASME Material Certification Package Weld No. 2-062A-T019-04A ASME Material Certification Package Weld No. 2-062A-T036-03 ASME Material Certification Package Valve 2-3-845 ASME Material Certification Package  
Weld No. 2-063B-T082-06 ASME Material Certification Package
Weld No. 2-068G-T013-02 ASME Material Certification Package
Weld No. 2-062B-T328-01 ASME Material Certification Package
Weld No. 2-062A-T019-04A ASME Material Certification Package
Weld No. 2-062A-T036-03 ASME Material Certification Package
Valve 2-3-845 ASME Material Certification Package
C.1.7 RPV Internals and Protection of Installed Plant Equipment during Construction
Activities (IP 50053)
Service Request 180764, Concrete Mixing and Placement Violations
Service Request 182224, Liquid Penetrant Exam in Reactor Vessel
C.1.8, C.1.9, C.1.10, C.1.11, C.1.12, C.1.13, C.1.14, C.1.15, C.1.16, C.1.17, C.1.18, C.1.19,
C.1.20 Collective section documentation)
Procedures
TVA-NQA-PLN89-A, Tennessee Valley Authority Nuclear Quality Assurance Program, Rev. 23
25402-000-GPP-0000-N3701, Unit 2 Construction Completion Project Procedure (CCPP),
        Welding Program, Rev. 3
25402-000-GPP-0000-N3705, Welding and NDE Documentation and Records Management,
        Rev. 2
25402-000-GMX-GCE-00001, Watts Bar Unit 2 Construction Completion Project, Special


                                              8
C.1.7  RPV Internals and Protection of Installed Plant Equipment during Construction
      Processes Manual, Rev. 1
Activities (IP 50053)
25402-000-4MP-T040-S0036, Bechtel Welding Standard, Documentation of Welds, WD-1, Rev.
Service Request 180764, "Concrete Mixing and Placement Violations" 
      6
Service Request 182224, "Liquid Penetrant Exam in Reactor Vessel"
25402-000-4MP-T040-S0012, Bechtel General Purging Standard, GPS-1, Rev. 1
C.1.8, C.1.9, C.1.10, C.1.11, C.1.12, C.1.13, C.1.14, C.1.15, C.1.16, C.1.17, C.1.18, C.1.19, C.1.20  Collective section documentation)  
25402-000-4MP-T040-S0013, Bechtel General Welding Standard, GWS-1, Rev. 2
25402-000-4MP-T040-S0021, Bechtel General Welding Standard, GWS-Structural, Rev. 1
25402-000-4MP-T040-S00038, WFMC-1, Bechtel Welding Specification - Welding Filler
      Material Control, Rev. 1
25402-000-4MP-T040-S0078, WQ-1, Bechtel Welding Performance Qualification Specification
      [ASME Section IX], Rev. 2
25402-000-4MP-T040-S0079, WQ-2, Bechtel Welding Performance Qualification Specification
      [D1.1], Rev. 0
25402-000-4MP-T040-S0030, PHT-1, Bechtel General Welding Standard, Rev. 2
25402-000-4MP-T040-S0165, NEPQ, Bechtel Construction Operations Inc. Nondestructive
      Examination Standard, NDE Personnel Qualification and Certification, Rev. 1
25402-000-4MP-T040-S0131, VT-ASME III Piping, Bechtel Nondestructive Examination
      Standard, Visual Examination, Rev. 1
25402-000-4MP-T040-S0133, VT-AWS D1.1, Bechtel Nondestructive Examination Standard,
      Visual Examination, Rev. 1
25402-000-4MP-T040-S0125, PT (SR)-ASME, Bechtel Nondestructive Examination Standard,
      Liquid Penetrant Examination, Rev. 5
25402-000-4MP-T040-S0124, MT-ASME, Bechtel Nondestructive Examination Standard,
      Magnetic Particle Examination, Rev. 5
25402-000-4MP-T040-S0049, Bechtel Technical Specification for Welding Filler Metal, WM-
      E7018(CVN), Rev. 1
25402-000-4MP-T040-S0066, Bechtel Technical Specification for Welding Filler Metal, WM-
      ER70S-2(CVN), Rev. 1
25402-000-4MP-T040-S0068, Bechtel Technical Specification for Welding Filler Metal, WM-
      ER70S-6 (CVN), Rev. 1
TVA-NQA-PLN89-A, Tennessee Valley Authority Nuclear Quality Assurance Program, Rev. 23
25402-PRO-0007, Field Material Storage Control, Rev. 2
Bechtel Project Nuclear Quality Assurance Manual, Rev. 6
N-UT-78, PDI Generic Procedure for the Manual Ultrasonic Examination of Reactor Pressure
    Vessel Welds PDI-UT-6, Rev 0005
N-PT-9, Liquid Penetrant Examination of ASME and ANSI Code Components and Welds, Rev
    0033
EPRI-DMW-PA-1, Procedure for Manual Phased Array Ultrasonic Examination of Dissimilar
Metal Welds, Rev. 1
NPG Nondestructive Examination Procedure N-UT-87, Generic Procedure for the Phased Array
Ultrasonic Examination of Dissimilar Metal Welds, Rev. 0
Work Orders (WOs)
WO 10-951203-000, Cut-Out and Remake Weld 2-068A-D145-02 C0R0
WO 09-954333-001, Modification of Pipe Supports on the Component Cooling System in the
      Reactor Building under EDCR 52526
WO 09-954179-023, Fabricate Typical Supports in the Fabrication Shop to be Installed in Work
      Orders under EDCR 54633
WO 08-956218-021, Install New Drain Piping and Fittings for Lower Ice Condenser Bay #1 and
      Reinstall Flapper Valve 2-CKV-61-913 System 061 under EDCR 52813


                                            9
Procedures
WO 10-951028-000, Rework weld by removing linear indication and have inspected and
 
  accepted.
TVA-NQA-PLN89-A, Tennessee Valley Authority Nuclear Quality Assurance Program, Rev. 23 25402-000-GPP-0000-N3701, Unit 2 Construction Completion Project Procedure (CCPP), Welding Program, Rev. 3 25402-000-GPP-0000-N3705, Welding and NDE Documentation and Records Management, Rev. 2 25402-000-GMX-GCE-00001, Watts Bar Unit 2 Construction Completion Project, Special 
Bechtel Welding Procedure Specification
8              Processes Manual, Rev. 1  25402-000-4MP-T040-S0036, Bechtel Welding Standard, Documentation of Welds, WD-1, Rev.
P1-AT-Lh (CVN+10)
6 25402-000-4MP-T040-S0012, Bechtel General Purging Standard, GPS-1, Rev. 1 25402-000-4MP-T040-S0013, Bechtel General Welding Standard, GWS-1, Rev. 2 25402-000-4MP-T040-S0021, Bechtel General Welding Standard, GWS-Structural, Rev. 1
P1-AT-Lh
25402-000-4MP-T040-S00038, WFMC-1, Bechtel Welding Specification - Welding Filler Material Control, Rev. 1 25402-000-4MP-T040-S0078, WQ-1, Bechtel Welding Performance Qualification Specification [ASME Section IX], Rev. 2 25402-000-4MP-T040-S0079, WQ-2, Bechtel Welding Performance Qualification Specification [D1.1], Rev. 0 25402-000-4MP-T040-S0030, PHT-1, Bechtel General Welding Standard, Rev. 2 25402-000-4MP-T040-S0165, NEPQ, Bechtel Construction Operations Inc. Nondestructive Examination Standard, NDE Personnel Qualification and Certification, Rev. 1 25402-000-4MP-T040-S0131, VT-ASME III Piping, Bechtel Nondestructive Examination Standard, Visual Examination, Rev. 1 25402-000-4MP-T040-S0133, VT-AWS D1.1, Bechtel Nondestructive Examination Standard, Visual Examination, Rev. 1 25402-000-4MP-T040-S0125, PT (SR)-ASME, Bechtel Nondestructive Examination Standard, Liquid Penetrant Examination, Rev. 5 25402-000-4MP-T040-S0124, MT-ASME, Bechtel Nondestructive Examination Standard, Magnetic Particle Examination, Rev. 5 25402-000-4MP-T040-S0049, Bechtel Technical Specification for Welding Filler Metal, WM-E7018(CVN), Rev. 1 25402-000-4MP-T040-S0066, Bechtel Technical Specification for Welding Filler Metal, WM-ER70S-2(CVN), Rev. 1 25402-000-4MP-T040-S0068, Bechtel Technical Specification for Welding Filler Metal, WM-ER70S-6 (CVN), Rev. 1 TVA-NQA-PLN89-A, Tennessee Valley Authority Nuclear Quality Assurance Program, Rev. 23 25402-PRO-0007, Field Material Storage Control, Rev. 2 Bechtel Project Nuclear Quality Assurance Manual, Rev. 6 N-UT-78, PDI Generic Procedure for the Manual Ultrasonic Examination of Reactor Pressure Vessel Welds PDI-UT-6, Rev 0005 N-PT-9, Liquid Penetrant Examination of ASME and ANSI Code Components and Welds, Rev
P8-AT-Ag
0033 EPRI-DMW-PA-1, Procedure for Manual Phased Array Ultrasonic Examination of Dissimilar Metal Welds, Rev. 1
P8-P1-AT-Ag
NPG Nondestructive Examination Procedure N-UT-87, Generic Procedure for the Phased Array Ultrasonic Examination of Dissimilar Metal Welds, Rev. 0
P1-A-Lh (Structural)
Work Orders (WOs)
  WO 10-951203-000, Cut-Out and Remake Weld 2-068A-D145-02 C0R0 WO 09-954333-001, Modification of Pipe Supports on the Component Cooling System in the Reactor Building under EDCR 52526  WO 09-954179-023, Fabricate Typical Supports in the Fabrication Shop to be Installed in Work Orders under EDCR 54633 WO 08-956218-021, Install New Drain Piping and Fittings for Lower Ice Condenser Bay #1 and Reinstall Flapper Valve 2-CKV-61-913 System 061 under EDCR 52813 
9    WO 10-951028-000, Rework weld by removing linear indication and have inspected and accepted.  
Bechtel Welding Procedure Specification
  P1-AT-Lh (CVN+10)  
P1-AT-Lh P8-AT-Ag P8-P1-AT-Ag P1-A-Lh (Structural)  
NDE Reports
NDE Reports
  MT-058, ASME Class III MT-064, ASME Class III PT-022, ASME Class 1 R-P0240, Penetrant - ASME Class 1 R-P0970, Penetrant - ASME Class 2  
MT-058, ASME Class III
R-P0992, Visual - ASME Class 1 R-P0993, Magnetic Particle - ASME Class 2 R-P0994, Magnetic Particle - ASME Class 2 R-P0996, Magnetic Particle - ASME Class 2 TVA Radiographic Examination Report for acceptance of weld 2-068C-W004-01, 10/28/08 TVA-WPNP NDE Evaluation Data Sheet Radiographic No. 2-1228, 5/19/88  
MT-064, ASME Class III
PERs and Service Requests
PT-022, ASME Class 1
  PER 212696  
R-P0240, Penetrant - ASME Class 1
PER 219039 PER 222093 PER 222236 PER 214589 PER 166624  
R-P0970, Penetrant - ASME Class 2
PER 236720 PER 236733 Service Request 166386 Service Request 167044  
R-P0992, Visual - ASME Class 1
R-P0993, Magnetic Particle - ASME Class 2
Other  NRC Inspection Report 50-390/91-32 NRC Inspection Report 50-390, 391/91-23 NRC Inspection Report 50-390/78-05 and 50-391/78-04 Preservice Inspection Program Plan Watts Bar Nuclear Plan Unit 2, WBN-2 PSI Rev. 3 NGDC PP-15, Watts Bar Unit 2 ASME Section XI, Rev 0  
R-P0994, Magnetic Particle - ASME Class 2
Watts Bar Unit 2 "Red Lined" FSAR Sections 5.2.8, 5.4.4.4, and 6.6 PDI RPV Manual Detection PDI-UT-06 Table 1 and Table 2, Rev 15 Performance Demonstration Qualification Summary No. 621, PDI-UT-06, Rev G, Addenda 0 NDE UT Examination Report R-P1028, Welds CRDW-60, CRDW-64, CRDW-65, CRDW-72, CRDW-73 
R-P0996, Magnetic Particle - ASME Class 2
10    NDE UT Examination Report R-P1029, Welds CRDW-54, CRDW-60, CRDW-62, CRDW-64, CRDW-65, CRDW-66, CRDW-67, CRDW-72, CRDW-73  
TVA Radiographic Examination Report for acceptance of weld 2-068C-W004-01, 10/28/08
TVA-WPNP NDE Evaluation Data Sheet Radiographic No. 2-1228, 5/19/88
PERs and Service Requests
PER 212696
PER 219039
PER 222093
PER 222236
PER 214589
PER 166624
PER 236720
PER 236733
Service Request 166386
Service Request 167044
Other
NRC Inspection Report 50-390/91-32
NRC Inspection Report 50-390, 391/91-23
NRC Inspection Report 50-390/78-05 and 50-391/78-04
Preservice Inspection Program Plan Watts Bar Nuclear Plan Unit 2, WBN-2 PSI Rev. 3
NGDC PP-15, Watts Bar Unit 2 ASME Section XI, Rev 0
Watts Bar Unit 2 Red Lined FSAR Sections 5.2.8, 5.4.4.4, and 6.6
PDI RPV Manual Detection PDI-UT-06 Table 1 and Table 2, Rev 15
Performance Demonstration Qualification Summary No. 621, PDI-UT-06, Rev G, Addenda 0
NDE UT Examination Report R-P1028, Welds CRDW-60, CRDW-64, CRDW-65, CRDW-72,
CRDW-73


                                              10
III. Operational Readiness Activities  
NDE UT Examination Report R-P1029, Welds CRDW-54, CRDW-60, CRDW-62, CRDW-64,
F.1 Fire Protection  
CRDW-65, CRDW-66, CRDW-67, CRDW-72, CRDW-73
 
III. Operational Readiness Activities
F.1     Fire Protection
Procedures and Standards
Procedures and Standards
  SPP-10.9, Control of Fire Protection Impairments, Rev. 3   SPP-10.11, Control of Ignition Sources (Hot Work), Rev. 3  
SPP-10.9, Control of Fire Protection Impairments, Rev. 3
IV. Other Activities  
SPP-10.11, Control of Ignition Sources (Hot Work), Rev. 3
OA.1.1   QA Records CAP  
IV.     Other Activities
Procedures
OA.1.1 QA Records CAP
  TVA Construction Engineering Procedure CEP-1.40-3, Universal System Program, Rev. 2  
Procedures
TVA QA Record Sample Assessment Reports
TVA Construction Engineering Procedure CEP-1.40-3, Universal System Program, Rev. 2
  Records Assessment, Mechanical Valves, April 2010  
TVA QA Record Sample Assessment Reports
Records Assessment, Mechanical Equipment, April 2010 Records Assessment, Mechanical Ductwork, April 2010 Records Assessment, Mechanical Piping, April 2010 Records Assessment, Electrical Cables, April 2010 Records Assessment, Electrical Equipment, April 2010  
Records Assessment, Mechanical Valves, April 2010
Records Assessment, Electrical Instrument Subassemblies, April 2010 Records Assessment, Electrical Instruments, April 2010  
Records Assessment, Mechanical Equipment, April 2010
Corrective Action Documents
Records Assessment, Mechanical Ductwork, April 2010
 
Records Assessment, Mechanical Piping, April 2010
PER 233454, ASME/Hanger inspection records cannot be retrieved in timely manner  
Records Assessment, Electrical Cables, April 2010
Records Assessment, Electrical Equipment, April 2010
Records Assessment, Electrical Instrument Subassemblies, April 2010
Records Assessment, Electrical Instruments, April 2010
Corrective Action Documents
PER 233454, ASME/Hanger inspection records cannot be retrieved in timely manner
Other
Engineering Construction Monitoring and Documentation (ECM&D) database
Mechanical Records
Valve, 0-067-DA-V-RTV-825B, Test 70A
Valve, 2-001-NV-V-RTV-290A, Test 70A
Valve, 2-030-RB-V-TV-555, Test 70A
Valve, 2-062-AB-V-FCV-128, Test 73B
Valve, 2-062-AB-V-ISV-537, Test 70A
Valve, 2-063-AB-V-FCV-175, Test 70A
Valve, 2-067-AB-V-TCV-132, Test 70A
Mechanical Equipment, 0-03B-AB-SL-0786A, Test 35A
Mechanical Equipment, 0-041-AB-SL-2014A, Test 01A
 
                                              11
Mechanical Equipment, 0-082-DIEG-0C1, Test 34A
Mechanical Equipment, 2-I&C-RB-SL-0005, Test 01A
Mechanical Equipment, 2-081-PMP-81-7, Test 33A
Duct, 0-030-DA-D-029, Test 12A
Duct, 2-030-AB-D-141C, Test 11A
Duct, 2-030-RB-BKD-572, Test 13A
Duct, 2-030-RB-BT-TVA4, Test 91A
Duct, 2-030-RB-CT-005, Test 15A
Pipe Segment, 0-018-DA-L-840-2-018, Test 23A
Pipe Segment, 0-067-FB-F-0041, Test 02A
Pipe Segment, 0-067-YD-P-845-5-12, Test 79A
Pipe Segment, 0-067-47W845-5-6-18, Test 50A
Pipe Segment, 2-003-NV-P-803-1-14, Test 23A
Pipe Segment, 2-003-PT-F-0009, Test 28A
Pipe Segment, 2-03B-AB-P-803-3-50, Test 18A
Electrical Records
Cable, 2-2A-62-3624, Test 77A
Cable, 2-2NM-92-100-D, Test 55A
Cable, 2-2NM-92-243-E, Test 77A
Cable, 2-2NM-92-416-F, Test 64A
Cable, 2-3V-1-7611-A,Test 77A
Cable, 2-3V-74-1938-A,Test 77B
Electrical Component, 2-BKR-212-B2/3B-B, Test 67A
Electrical Component, 2-JB-290-2875-D, Test 25B
Electrical Component, 2-JB-293-692-A, Test 61A
Electrical Component, 2-MCCC-213-A1/17E-A, Test 70A
Electrical Component, 2-MTR-61-AHU/07, Test 25A
Electrical Component, 2-PENT-293-14-A, Tests 04A and 64A
Electrical Component, 2-PENT-293-31-G, Test 25A
Instrument Subassembly, 0032JN-042, Test 59A
Instrument Subassembly, 0032LA-A, Test 52A
Instrument Subassembly, 2001AO-001, Test 04A
Instrument Subassembly, 2032BC-042, Test 41A
Electrical Instrument, 2-FCV-62-90-A, Test 47A
Electrical Instrument, 2-FCV-63-118-A, Test 75A
Electrical Instrument, 2-FCV-67-146-A, Test 61A
Electrical Instrument, 2-HS-1-18A-B, Test 61D
Electrical Instrument, 2-HS-3-164A-A, Test 61B
Electrical Instrument, 2-TM-68-65B-E, Test 25A


Other  Engineering Construction Monitoring and Documentation (ECM&D) database
                                                12
Mechanical Records
OA.1.6 Non-cited Violation NCV-391/2008-010-01 corrective action for failure to
  Valve, 0-067-DA-V-RTV-825B, Test 70A Valve, 2-001-NV-V-RTV-290A, Test 70A Valve, 2-030-RB-V-TV-555, Test 70A Valve, 2-062-AB-V-FCV-128, Test 73B
        document a cable raceway separation non-conforming condition.
Valve, 2-062-AB-V-ISV-537, Test 70A Valve, 2-063-AB-V-FCV-175, Test 70A Valve, 2-067-AB-V-TCV-132, Test 70A
Walk Down Package
Mechanical Equipment, 0-03B-AB-SL-0786A, Test 35A
LSWDP-430 Cable Trays for Electrical External Separation Baseline Calculation Program:
Mechanical Equipment, 0-041-AB-SL-2014A, Test 01A 
        Corrective Action for PER 158979
11    Mechanical Equipment, 0-082-DIEG-0C1, Test 34A Mechanical Equipment, 2-I&C-RB-SL-0005, Test 01A Mechanical Equipment, 2-081-PMP-81-7, Test 33A
Others
Duct, 0-030-DA-D-029, Test 12A Duct, 2-030-AB-D-141C, Test 11A
ICRDS QA Report, Cable ID 2PM3870D, 2PM3877E, 2PM3882F, and 2PM3887G; Conduits
Duct, 2-030-RB-BKD-572, Test 13A Duct, 2-030-RB-BT-TVA4, Test 91A Duct, 2-030-RB-CT-005, Test 15A
        2PLC29D, 2PLC62E, 2PLC31E, 2-2PLC-299-23F, and 2-2PLC-299-39G.
 
OA.1.7 NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable
Pipe Segment, 0-018-DA-L-840-2-018, Test 23A Pipe Segment, 0-067-FB-F-0041, Test 02A Pipe Segment, 0-067-YD-P-845-5-12, Test 79A Pipe Segment, 0-067-47W845-5-6-18, Test 50A Pipe Segment, 2-003-NV-P-803-1-14, Test 23A Pipe Segment, 2-003-PT-F-0009, Test 28A Pipe Segment, 2-03B-AB-P-803-3-50, Test 18A
        Failures that Disable Accident Mitigation Systems or Cause Plant Transients.
Others
T90 070911 002, TVA - Watts Bar Nuclear Plant Unit 2 Initial Responses to Bulletins and
Generic Letters dated September 7, 2007.
OA.1.8 Inspection of Watts Bar Nuclear Plant Master Fuse List Special Program
        (TI 2512/037)
Design Change Documents
EDCR 52324, Rev. A, Refurbish Solid State Rod Control System Cabinets
EDCR 54796, Rev. A, Install Fuses for Radiation Monitoring System, etc.
EDCR 54798, Rev. A, Install Fuses for 120 VAC Vital AC, etc.
Procedures
SPP 4.1 - Rev. 21
NEDP-1, Rev. 5, (TVA Procedure) Design Basis and Design Input Control
OPDP-7, Rev. 3, (TVA Procedure) Fuse Control
SPP-9.3, Rev. 22, (TVA Procedure) Plant Modifications and Engineering Change Control
SPP-9.6, Rev. 9, (TVA Procedure) Master Equipment List (MEL)
25402-3DP-G04G-0081, Rev. 007, (Bechtel Procedure) Engineering Document Construction
Release
WB-DC-30-5, Rev. 022, (Design Criteria) Power, Control, and Signal Cables For Use in
Category I Structures -- (Unit 1 / Unit 2)
WB-DC-30-27, Rev. 030, (Design Criteria) AC and DC Control Power Systems - (Unit 1 / Unit 2)
WB-DC-30-28, Rev. 20, (Design Criteria) Low and Medium Voltage Power Systems
Others
WBNEEBMSTI070005, Rev. 53, (Calculation) 125V DC Protection and Coordination Calculation
EDQ00299920080019, Rev. 001, (Calculation) Electrical Penetration Protection Study Voltage
Level V3 - Unit 2
CATD 20103-WBN-02, (Concern) Discrepancies Have Been Identified for Electrical Design
Criteria
CATD 23702-WBN-04, (Concern) No Calculations could be found to demonstrate that fuses
provided adequate full range short circuit protection
CATD 23702-WBN-05, (Concern) Circuit breakers with trip settings higher than permitted by
criteria
NCO850160001, (Commitment) Provide redundant tripping devices to protect containment
penetrations


Electrical Records
                                                13
  Cable, 2-2A-62-3624, Test 77A Cable, 2-2NM-92-100-D, Test 55A
OA.1.9 NRC Bulletins 74-15, Misapplication of Cutler-Hammer Three Position
Cable, 2-2NM-92-243-E, Test 77A Cable, 2-2NM-92-416-F, Test 64A Cable, 2-3V-1-7611-A,Test 77A Cable, 2-3V-74-1938-A,Test 77B
        Maintained Switch Model No. 10250T; 75-03, Incorrect Lower Disc Spring and
        Clearance Dimension in Series 8300 and 8302 ASCO Solenoid Valves; and 75-06,
Electrical Component,  2-BKR-212-B2/3B-B, Test 67A Electrical Component, 2-JB-290-2875-D, Test 25B Electrical Component, 2-JB-293-692-A, Test 61A Electrical Component, 2-MCCC-213-A1/17E-A, Test 70A Electrical Component, 2-MTR-61-AHU/07, Test 25A
        Defective Westinghouse Type OT-2 Control Switches
Electrical Component, 2-PENT-293-14-A, Tests 04A and 64A Electrical Component, 2-PENT-293-31-G, Test 25A 
Others
Instrument Subassembly, 0032JN-042, Test 59A Instrument Subassembly, 0032LA-A, Test 52A
10187136, B 1975-06, Defective Westinghouse Type OT-2 Control Switches Inspect
Instrument Subassembly, 2001AO-001, Test 04A Instrument Subassembly, 2032BC-042, Test 41A
Westinghouse Type OT-2 control switches, 6 October 2009
Electrical Instrument, 2-FCV-62-90-A, Test 47A Electrical Instrument, 2-FCV-63-118-A, Test 75A Electrical Instrument, 2-FCV-67-146-A, Test 61A Electrical Instrument, 2-HS-1-18A-B, Test 61D
T02 080320 001, Dated 20 March 2008
Electrical Instrument, 2-HS-3-164A-A, Test 61B Electrical Instrument, 2-TM-68-65B-E, Test 25A
T90 080128 001, Dated 29 January 2008
 
NCO080008030 (Commitment), B 75-03, Incorrect Lower Disc Spring and Clearance
12    OA.1.6  Non-cited Violation NCV-391/2008-010-01 corrective action for failure to document a cable raceway separation non-conforming condition.
Dimension in Series 8300 8302 ASCO Solenoid Valves-Modify Valves Not Modified At
Walk Down Package
Factory, initiated 27 March 2008
LSWDP-430 Cable Trays for Electrical External Separation Baseline Calculation Program: Corrective Action for PER 158979
NCO080008070 (Commitment), Misapplication of Cutler-Hammer Three Position Maintained
Others ICRDS QA Report, Cable ID 2PM3870D, 2PM3877E, 2PM3882F, and 2PM3887G; Conduits 2PLC29D, 2PLC62E, 2PLC31E, 2-2PLC-299-23F, and 2-2PLC-299-39G.
Switch Model No. 10250T, initiated 31 March 2008
OA.1.7  NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients.
OA.1.10 NRC Bulletin 76-02, Relay Coil Failures - General Electric Type HFA, HGA, HKA,
  Others T90 070911 002, TVA - Watts Bar Nuclear Plant Unit 2 Initial Responses to Bulletins and Generic Letters dated September 7, 2007. OA.1.8  Inspection of Watts Bar Nuclear Plant Master Fuse List Special Program (TI 2512/037)
        and HMA Relays
Design Change Documents
Others
EDCR 52324, Rev. A, Refurbish Solid State Rod Control System Cabinets EDCR 54796, Rev. A, Install Fuses for Radiation Monitoring System, etc.
T02 080320 001, Dated 20 March 2008
EDCR 54798, Rev. A, Install Fuses for 120 VAC Vital AC, etc.
10187197, B 1976-02, Relay Coil Failures - GE Type HFA, HGA, HKA, HMA Relays; Repair
Procedures
or replace relays before preoperational tests., 6 October 2009
SPP 4.1 - Rev. 21  NEDP-1, Rev. 5, (TVA Procedure) Design Basis and Design Input Control
OA.1.11 Violation 391/86-02-01, Failure to Follow Procedures that Resulted in Improperly
OPDP-7, Rev. 3, (TVA Procedure) Fuse Control SPP-9.3, Rev. 22, (TVA Procedure) Plant Modifications and Engineering Change Control SPP-9.6, Rev. 9, (TVA Procedure) Master Equipment List (MEL) 25402-3DP-G04G-0081, Rev. 007, (Bechtel Procedure) Engineering Document Construction
Installed Solenoid Valves
Release
Others
WB-DC-30-5, Rev. 022, (Design Criteria) Power, Control, and Signal Cables For Use in Category I Structures -- (Unit 1 / Unit 2) WB-DC-30-27, Rev. 030, (Design Criteria) AC and DC Control Power Systems - (Unit 1 / Unit 2) WB-DC-30-28, Rev. 20, (Design Criteria) Low and Medium Voltage Power Systems
NCO860152003 (Commitment), Modify Existing ASCO 8315 Series Valves or Ensure
Justification for Use As-Is is provided
Others WBNEEBMSTI070005, Rev. 53, (Calculation) 125V DC Protection and Coordination Calculation EDQ00299920080019, Rev. 001, (Calculation) Electrical Penetration Protection Study Voltage Level V3 - Unit 2 CATD 20103-WBN-02, (Concern) Discrepancies Have Been Identified for Electrical Design
OA.1.12 Inspection of Watts Bar Nuclear Plant Radiation Monitoring System Special
Criteria CATD 23702-WBN-04, (Concern) No Calculations could be found to demonstrate that fuses provided adequate full range short circuit protection  CATD 23702-WBN-05, (Concern) Circuit breakers with trip settings higher than permitted by criteria NCO850160001, (Commitment) Provide redundant tripping devices to protect containment penetrations 
        Program (TI 2512/041)
13    OA.1.9 NRC Bulletins 74-15, "Misapplication of Cutler-Hammer Three Position Maintained Switch Model No. 10250T"; 75-03, "Incorrect Lower Disc Spring and Clearance Dimension in Series 8300 and 8302 ASCO Solenoid Valves"; and 75-06, "Defective Westinghouse Type OT-2 Control Switches"
Design Change Documents
Others 10187136, "B 1975-06, 'Defective Westinghouse Type OT-2 Control Switches' Inspect  
EDCR 2-52342, Rev. A, Install Radiation Monitoring Loops in the Unit 2 Auxiliary Building
Westinghouse Type OT-2 control switches," 6 October 2009 T02 080320 001, Dated 20 March 2008 T90 080128 001, Dated 29 January 2008 NCO080008030 (Commitment), "B 75-03, 'Incorrect Lower Disc Spring and Clearance Dimension in Series 8300 8302 ASCO Solenoid Valves'-Modify Valves Not Modified At  
Procurement Documents
Factory," initiated 27 March 2008 NCO080008070 (Commitment), Misapplication of Cutler-Hammer Three Position Maintained Switch Model No. 10250T, initiated 31 March 2008  
25402-011-MRA-HARA-00001, Rev. 4, (Purchase Requisition) Radiation Monitoring System
OA.1.10 NRC Bulletin 76-02, Relay Coil Failures - General Electric Type HFA, HGA, HKA, and HMA Relays
(System 90)
Others T02 080320 001, Dated 20 March 2008 10187197, "B 1976-02, 'Relay Coil Failures - GE Type HFA, HGA, HKA, HMA Relays'; Repair or replace relays before preoperational tests.," 6 October 2009  
Procedures
OA.1.11 Violation 391/86-02-01, Failure to Follow Procedures that Resulted in Improperly Installed Solenoid Valves
WB-DC-40-24, Rev. 021, (Design Criteria) Radiation Monitoring (Unit 1/ Unit 2)
  Others NCO860152003 (Commitment), Modify Existing ASCO 8315 Series Valves or Ensure Justification for Use "As-Is" is provided  
Others
WBNAPS3047, Rev. 4, (Calculation) Calibration Factors for the Main Steam Line Radiation
Monitors
WO 08-813772-000 - Field Change
WBNAPS3048, Rev. 19, (Calculation) Instrument Range and Accuracy for Measurement of
Regulatory Guide 1.97 Type E Variables


                                            14
OA.1.12  Inspection of Watts Bar Nuclear Plant Radiation Monitoring System Special Program (TI 2512/041)
OA.1.13 Applicant Actions on Three Mile Island (TMI) Action Items
 
Design Change Documents
Design Change Documents
EDCR 2-52342, Rev. A, Install Radiation Monitoring Loops in the Unit 2 Auxiliary Building
EDCR 52409, Rev. A, Replacement of Equipment required for Unit 2 Acoustic Monitoring
Procurement Documents
system
25402-011-MRA-HARA-00001, Rev. 4, (Purchase Requisition) Radiation Monitoring System (System 90)
EDCR 52348, Rev. A, Complete installation/refurbish of Hydrogen Mitigation System in Unit 2
EDCR-2 # 55127, Rev. A, - Resolves physical internal cable separation and electrical isolation
breakages identified by Calc EDQ0029992009002 Rev. 0. - dated: 4/20/10
Drawings
2-45W724-3 Rev. 0, Unit 2 6900 Shutdown Board 2A-A Single Line, 12/15/08
2-45W724-4 Rev. 0, Unit 2 6900 Shutdown Board 2B-B Single Line, 12/15/08
2-45W760-68-3 Rev. 1, Unit 2 Reactor Coolant System Schematic Diagrams, 12/15/08
2-45W760-68-4 Rev. 1, Unit 2 Reactor Coolant System Schematic Diagrams, 12/15/08
1-45W724-3 Rev. 23, Units 1& 2 6900 Shutdown Board 2A-A Single Line, 9/22/90
1-45W724-4 Rev. 20, Units 1& 2 6900 Shutdown Board 2B-B Single Line, 9/22/90
1-45W760-68-3 Rev. 12, Unit 1 Reactor Coolant System Schematic Diagrams, 9/22/90
1-45W760-68-4 Rev. 8, Unit 1 Reactor Coolant System Schematic Diagrams, 9/17/90
2-45W751-8 Rev. 1, Unit 2 480V Reactor MOV Bds 2B1-B Single Line SH-2, 12/15/08
2-45W751-3 Rev. 1, Unit 2 480V Reactor MOVE Bds 2A1-A Single Line SH-3, 12/15/08
2-45W760-68-5 Rev. 0, Unit 2 Reactor Coolant System Schematic Diagrams, 12/15/08
2-45W600-68-1 Rev. 1, Unit 2 Reactor Coolant System Schematic Diagrams, 12/11/08
1-45W600-68-1 Rev. 12, Unit 1 Reactor Coolant System Schematic Diagrams, 9/22/90
1-45W760-68-5 Rev. 18, Unit 2 Reactor Coolant System Schematic Diagrams, 9/21/90
1-45W751-3 Rev. 42, Units 1& 2 480V Reactor MOVE Bds 1A1-A & 2A1-A Single Line SH-3,
9/22/90
1-45W751-8 Rev. 26, Units 1& 2 480V Reactor MOV Bds 1B1-B & 2B1-B Single Line SH-2,
9/22/90
1-45W703-1 Rev. 47, Units 1&2 125V Vital Battery Board I Single Line Sh-1, 9/22/90
1-45W703-2 Rev. 36, Units 1&2 125V Vital Battery Board II Single Line Sh-2, 9/22/90
1-45W703-3 Rev. 40, Units 1&2 125V Vital Battery Board III Single Line Sh-3, 9/22/90
1-45W703-4 Rev. 32, Units 1&2 125V Vital Battery Board IV Single Line Sh-4, 9/22/90
2-45W760-68-4 Rev.1, Unit 2 RCS Schematic Diagram, 12/15/08
2-45W760-68-3 Rev.1, Unit 2 RCS Schematic Diagram, 12/15/08
1-45N709-4 Rev.2, Units 1&2 Chargers Inverters and Misc Equip Connections Diagram, SH-4,
6/14/76
1-45W756-2 Rev.69, Units 1&2 480V Cont and Aux Bldg VT BD 1A1-A & 2A1-A Single Line,
SH-2, 9/22/90
1-45W756-6 Rev.74, Units 1&2 480V Cont and Aux Bldg VT BD 1B1-B & 2B1-B Single Line,
SH-2, 9/22/90
2-45W756-2 Rev.0, Unit 2 480V Cont and Aux Bldg VT BD 2A1-A & 2B1-B Single Line, SH-2,
12/15/08
1-45W749-4A Rev.40, Units 2 480V 2B2-B Single Line, 1/29/93
1-45W749-1A, Rev.37, Units 2 480V 2A1-A Single Line, 2/1/93
1-45W749-3A, Rev.38, Units 2 480V 2B1-B Single Line, 1/29/93
2-45W749-4, Rev.2, Units 2 480V 2B2-B Single Line, 12/15/08
2-45W749-1, Rev.1, Units 2 480V 2A1-A Single Line, 12/15/08
2-45W749-3, Rev.1, Units 2 480V 2B1-B Single Line, 12/15/08
2-45W2640, Rev. 1, Unit 2 Wiring Diagram Control Boards Critical Wiring Braid Installation,
08/14/09


  Procedures
                                            15
WB-DC-40-24, Rev. 021, (Design Criteria) Radiation Monitoring (Unit 1/ Unit 2)
2-45W2640-1, Rev. 0, Unit 2 Wiring Diagram Control Boards Critical Wiring Braid Installation,
Others WBNAPS3047, Rev. 4, (Calculation) Calibration Factors for the Main Steam Line Radiation Monitors
07/14/09
WO 08-813772-000 - Field Change  WBNAPS3048, Rev. 19, (Calculation) Instrument Range and Accuracy for Measurement of Regulatory Guide 1.97 Type E Variables 
Procurement Documents
14    OA.1.13  Applicant Actions on Three Mile Island (TMI) Action Items
25402-011-MRA-HAYS-00001, Acoustic Monitoring Material Requisition
Design Change Documents
PO# 00070570, Hydrogen Igniter Purchase Order
EDCR 52409, Rev. A, Replacement of Equipment required for Unit 2 Acoustic Monitoring system EDCR 52348, Rev. A, Complete installation/refurbish of Hydrogen Mitigation System in Unit 2 EDCR-2 # 55127, Rev. A, - Resolves physical internal cable separation and electrical isolation breakages identified by Calc EDQ0029992009002 Rev. 0. - dated: 4/20/10
PO# 00049277, Acoustic Monitoring Purchase Order
Drawings 2-45W724-3 Rev. 0, Unit 2 6900 Shutdown Board 2A-A Single Line, 12/15/08 2-45W724-4 Rev. 0, Unit 2 6900 Shutdown Board 2B-B Single Line, 12/15/08
25402-011-MRA-EWE2-00012, Hydrogen Igniters Material Requisition
2-45W760-68-3 Rev. 1, Unit 2 Reactor Coolant System Schematic Diagrams, 12/15/08 2-45W760-68-4 Rev. 1, Unit 2 Reactor Coolant System Schematic Diagrams, 12/15/08 1-45W724-3 Rev. 23, Units 1& 2 6900 Shutdown Board 2A-A Single Line, 9/22/90 1-45W724-4 Rev. 20, Units 1& 2 6900 Shutdown Board 2B-B Single Line, 9/22/90 1-45W760-68-3 Rev. 12, Unit 1 Reactor Coolant System Schematic Diagrams, 9/22/90 1-45W760-68-4 Rev. 8, Unit 1 Reactor Coolant System Schematic Diagrams, 9/17/90 2-45W751-8 Rev. 1, Unit 2 480V Reactor MOV Bds 2B1-B Single Line SH-2, 12/15/08
QAR-2375, Qualification Summary Report, Tayco Engineering Inc, Hydrogen Igniter Assembly
2-45W751-3 Rev. 1, Unit 2 480V Reactor MOVE Bds 2A1-A Single Line SH-3, 12/15/08 2-45W760-68-5 Rev. 0, Unit 2 Reactor Coolant System Schematic Diagrams, 12/15/08 2-45W600-68-1 Rev. 1, Unit 2 Reactor Coolant System Schematic Diagrams, 12/11/08 1-45W600-68-1 Rev. 12, Unit 1 Reactor Coolant System Schematic Diagrams, 9/22/90 1-45W760-68-5 Rev. 18, Unit 2 Reactor Coolant System Schematic Diagrams, 9/21/90
Procedures
1-45W751-3 Rev. 42, Units 1& 2 480V Reactor MOVE Bds 1A1-A & 2A1-A Single Line SH-3, 9/22/90 1-45W751-8 Rev. 26, Units 1& 2 480V Reactor MOV Bds 1B1-B & 2B1-B Single Line SH-2, 9/22/90 1-45W703-1 Rev. 47, Units 1&2 125V Vital Battery Board I Single Line Sh-1, 9/22/90
25402-PRO-0007 Rev.1, Bechtel Field Material Storage Control, 10/9/08
1-45W703-2 Rev. 36, Units 1&2 125V Vital Battery Board II Single Line Sh-2, 9/22/90 1-45W703-3 Rev. 40, Units 1&2 125V Vital Battery Board III Single Line Sh-3, 9/22/90 1-45W703-4 Rev. 32, Units 1&2 125V Vital Battery Board IV Single Line Sh-4, 9/22/90 2-45W760-68-4 Rev.1, Unit 2 RCS Schematic Diagram, 12/15/08 2-45W760-68-3 Rev.1, Unit 2 RCS Schematic Diagram, 12/15/08
MAI-4.4B Instrument and Instrument panel Installation
1-45N709-4 Rev.2, Units 1&2 Chargers Inverters and Misc Equip Connections Diagram, SH-4, 6/14/76 1-45W756-2 Rev.69, Units 1&2 480V Cont and Aux Bldg VT BD 1A1-A & 2A1-A Single Line, SH-2, 9/22/90 1-45W756-6 Rev.74, Units 1&2 480V Cont and Aux Bldg VT BD 1B1-B & 2B1-B Single Line,
Walk Down Package
SH-2, 9/22/90 2-45W756-2 Rev.0, Unit 2 480V Cont and Aux Bldg VT BD 2A1-A & 2B1-B Single Line, SH-2, 12/15/08 1-45W749-4A Rev.40, Units 2 480V 2B2-B Single Line, 1/29/93 1-45W749-1A, Rev.37, Units 2 480V 2A1-A Single Line, 2/1/93 1-45W749-3A, Rev.38, Units 2 480V 2B1-B Single Line, 1/29/93 2-45W749-4, Rev.2, Units 2 480V 2B2-B Single Line, 12/15/08
LSWDP-404 Rev. 0, 2-PNL-99-L116 Internal Separation Walk-down
2-45W749-1, Rev.1, Units 2 480V 2A1-A Single Line, 12/15/08 2-45W749-3, Rev.1, Units 2 480V 2B1-B Single Line, 12/15/08 2-45W2640, Rev. 1, Unit 2 Wiring Diagram Control Boards Critical Wiring Braid Installation, 08/14/09 
LSWDP-409 Rev. 0, 0-PNL-278-M26 Internal Separation Walk-down
15    2-45W2640-1, Rev. 0, Unit 2 Wiring Diagram Control Boards Critical Wiring Braid Installation, 07/14/09 Procurement Documents
LSWDP-422 Rev. 0, 2-PNL-278-M9 Internal Separation Walk-down
25402-011-MRA-HAYS-00001, Acoustic Monitoring Material Requisition PO# 00070570, Hydrogen Igniter Purchase Order  
Others
PO# 00049277, Acoustic Monitoring Purchase Order 25402-011-MRA-EWE2-00012, Hydrogen Igniters Material Requisition QAR-2375, Qualification Summary Report, Tayco Engineering Inc, Hydrogen Igniter Assembly  
N3-68-4001, Rev. 0028, TVA, Reactor Coolant System, 8/27/09
Procedures
WBN2-68-4001, Rev. 0000, TVA, Reactor Coolant System, 7/23/08
25402-PRO-0007 Rev.1, Bechtel Field Material Storage Control, 10/9/08 MAI-4.4B Instrument and Instrument panel Installation  
PER Service Request # 170923, Drawing Deviation, NRC Identified 1-45W760-68-5, 2-
Walk Down Package
45W760-68-5, 4/29/10
LSWDP-404 Rev. 0, 2-PNL-99-L116 Internal Separation Walk-down LSWDP-409 Rev. 0, 0-PNL-278-M26 Internal Separation Walk-down LSWDP-422 Rev. 0, 2-PNL-278-M9 Internal Separation Walk-down  
Problem Evaluation Report (PER) 158979, Cable separation issues not identified during walk
down.
WO 08-951069-001 - CRDR EDCR2 52366 (U1RG Approved) PHASE III, PANEL 2-M-9, WILL
PROCURE, MOUNT, & WIRE ONLY T, June 15, 2010.


  Others N3-68-4001, Rev. 0028, TVA, Reactor Coolant System, 8/27/09 WBN2-68-4001, Rev. 0000, TVA, Reactor Coolant System, 7/23/08 PER Service Request # 170923, Drawing Deviation, NRC Identified 1-45W760-68-5, 2-
                                  16
45W760-68-5, 4/29/10 Problem Evaluation Report (PER) 158979, Cable separation issues not identified during walk down. WO 08-951069-001 - CRDR EDCR2 52366 (U1RG Approved) PHASE III, PANEL 2-M-9, WILL PROCURE, MOUNT, & WIRE ONLY T, June 15, 2010.
                        LIST OF ACRONYMS
10 CFR Title 10 of the Code of Federal Regulations
ANSI  American National Standards Institute
ASME  American Society of Mechanical Engineers
ASTM  American Society for Testing and Materials
AWS    American Welding Society
BIT    Boundary Information Transmittals
CAP    Corrective Action Program
CAQ    condition adverse to quality
CCRS  Computerized Cable Routing System
CET    core exit thermocouple
CFR    Code of Federal Regulations
CMTR  certified material test report
CRDM  control rod drive mechanism
DCN    design change notice
ECM&D Engineering construction monitoring & documentation
ECP    Employee Concerns Program
EDCR  engineering document construction release
FE    Field Engineer
FPIP  fire protection impairment permit
HDR    Historical Document Review
IMC    Inspection Manual Chapter (NRC)
ICRDS  Integrated Cables Raceway Design System
IP    Inspection Procedure (NRC)
IR    inspection report
MT    magnetic particle
NA    Nuclear Assurance
NCV    non-cited violation
NDE    non-destructive examination
NRC    Nuclear Regulatory Commission
NRR    Nuclear Reactor Regulation (NRC)
NUREG  (NRC) technical report designation
PCI    PCI Energy Services
PER    Problem Evaluation Report
PO    purchase order
PSI    Pre-Service Inspection
PT    Liquid Penetrant Testing (examination)
QA    quality assurance
QC    quality control
RCP    reactor coolant pump
RCS    reactor coolant system
RHR    residual heat removal
RMS    radiation monitoring system
RPV    reactor pressure vessel
RT    radiograph test (examination)
SCWE  safety conscience work environment
SL    Severity Level
SP    Special Program
SSC    structures, systems, and components
SWBP  sidewall bearing pressure


                              17
TI   Temporary Instruction (NRC)
 
TVA  Tennessee Valley Authority
 
UHI  upper head injection
16   LIST OF ACRONYMS
URI  unresolved item
10 CFR Title 10 of the Code of Federal Regulations ANSI  American National Standards Institute ASME  American Society of Mechanical Engineers ASTM  American Society for Testing and Materials
UT   Ultrasonic test
AWS  American Welding Society BIT  Boundary Information Transmittals CAP  Corrective Action Program CAQ  condition adverse to quality CCRS  Computerized Cable Routing System
VIO  Violation
CET  core exit thermocouple CFR  Code of Federal Regulations CMTR  certified material test report CRDM  control rod drive mechanism DCN  design change notice ECM&D  Engineering construction monitoring & documentation ECP  Employee Concerns Program
WBN  WBN Nuclear Plant
EDCR  engineering document construction release FE  Field Engineer FPIP  fire protection impairment permit HDR  Historical Document Review IMC  Inspection Manual Chapter (NRC)
WBNPP Watts Bar Nuclear Performance Plan
ICRDS  Integrated Cables Raceway Design System IP  Inspection Procedure (NRC) IR  inspection report MT  magnetic particle NA  Nuclear Assurance
WO   work order
NCV  non-cited violation NDE  non-destructive examination NRC  Nuclear Regulatory Commission NRR  Nuclear Reactor Regulation (NRC) NUREG  (NRC) technical report designation
PCI  PCI Energy Services PER  Problem Evaluation Report PO  purchase order PSI  Pre-Service Inspection PT  Liquid Penetrant Testing (examination)
QA  quality assurance QC  quality control RCP  reactor coolant pump RCS  reactor coolant system RHR  residual heat removal RMS  radiation monitoring system RPV  reactor pressure vessel
RT  radiograph test (examination) SCWE  safety conscience work environment SL  Severity Level SP  Special Program SSC  structures, systems, and components
SWBP  sidewall bearing pressure 
17    TI  Temporary Instruction (NRC) TVA  Tennessee Valley Authority UHI  upper head injection URI  unresolved item UT   Ultrasonic test VIO  Violation  
WBN  WBN Nuclear Plant WBNPP Watts Bar Nuclear Performance Plan WO   work order
}}
}}

Latest revision as of 15:00, 13 November 2019

IR 05000391-10-603; 04/01/2010 - 06/30/2010; Tennessee Valley Authority; Watts Bar Nuclear Plant, Unit 2, NRC Integrated Inspection Report
ML102170465
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 08/05/2010
From: Haag R
NRC/RGN-II/DCP/CPB3
To: Bhatnagar A
Tennessee Valley Authority
References
FOIA/PA-2013-0030, FOIA/PA-2013-0139 IR-10-603
Download: ML102170465 (82)
v • d • e


See also: IR 05000391/2010603

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

August 5, 2010

Mr. Ashok S. Bhatnagar

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 05000391/2010603 AND NOTICE OF VIOLATION

Dear Mr. Bhatnagar:

On June 30, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of

construction activities at your Watts Bar Unit 2 reactor facility. The enclosed integrated

inspection report documents the inspection results, which were discussed on July 13, 2010, with

Mr. Masoud Bajestani and other members of your staff.

This inspection examined activities conducted under your Unit 2 construction permit as they

relate to safety and compliance with the Commissions rules and regulations, with the conditions

of your construction permit, and with fulfillment of Unit 2 regulatory framework commitments.

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

personnel.

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 failure to implement adequate measures to review the suitability

of application of materials, parts, and equipment essential to the safety related functions of

molded case circuit breakers and provide for the verification of checking the adequacy of

design, such as, calculational methods, performing a suitable test program, including

qualifications testing of a prototype unit, under the most adverse conditions. 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, this report documents seven NRC-identified findings which were determined to

involve violations of NRC requirements. However, because these findings were Severity Level

IV violations and were entered into your corrective action program, the NRC is treating them as

non-cited violations consistent with Section VI.A.1 of the NRC Enforcement Policy. If you

contest the non-cited violations in the enclosed report, you should provide a response within 30

TVA 2

days of the date of this inspection report, with the basis for your denial, to the United States

Nuclear Regulatory Commission, ATTENTION: Document Control Desk, Washington, DC

20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of

Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and

the NRC Senior Resident Inspector at the Watts Bar Unit 2 Nuclear Plant. In accordance with

10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, and your

response (if any) will be available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRCs document

system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Robert C. Haag, Chief

Construction Projects Branch 3

Division of Construction Projects

Docket No. 50-391

Construction Permit No: CPPR-92

Enclosure: 1. Notice of Violation

2. Inspection Report 05000391/2010603 w/attachment

cc w/encl: (See next page)

ML102170465 G SUNSI REVIEW COMPLETE

OFFICE RII: DCP RII:DCP RII:DCP RII:DCP RII:DCP RII:DCP RII:DCP

SIGNATURE *WCB *TXN ANI *KEM JBB WRL Via Email

NAME WBearden TNazario AIssa KMiller JBaptist WLewis GKhouri

DATE 8/4/2010 8/4/2010 8/4/2010 8/4/2010 8/4/2010 8/4/2010 7/30/2010

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

OFFICE RII:DCP RII:DCP RII:DCP RII:DCI RII:DCI RII:DCI RII:DCI

SIGNATURE Via Email *PH Via Email Via Email CRO Via Email *JXL

NAME GCrespo PHeher CJFong CJones COgle JFuller JLizardi

DATE 8/3/2010 8/3/2010 8/2/2010 7/30/2010 8/5/2010 7/30/2010 8/4/2010

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

OFFICE RII:DCI RII:DCI RII:DCI RII:DCI RII:DCI RII:DCI RII:DCI

SIGNATURE Via Email Via Email *CBA Via Email Via Email Via Email Via Email

NAME EMichel TSteadham CAbbott TFanelli LCastelli AArtayet CStandberry

DATE 7/30/2010 7/30/2010 8/4/2010 8/4/2010 8/3/2010 7/30/2010 8/4/2010

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

OFFICE RII:DCI RII:DCI RII:EICS

SIGNATURE Via Email Via Email Via Email

NAME EHeher JKent CEvans

DATE 7/30/2010 8/4/2010 8/5/2010

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

TVA 3

cc w/encl:

Mr. Gordon P. Arent Mr. M.J. Hellstern

Manager General Manager

New Generation Licensing NGDC Governance & Oversight

Nuclear Generation Development Tennessee Valley Authority

and Construction 3A Blue Ridge Place

WBN Nuclear Plant 1101 Market Street

P.O. Box 2000 Chattanooga, Tennessee 37402-2801

Spring City, Tennessee 37381

Mr. R.M Krich

Mr. Masoud Bajestani Vice President

Vice President Nuclear Licensing

WBN Unit Two Tennessee Valley Authority

WBN Nuclear Plant 3R Lookout Place

Tennessee Valley Authority 1101 Market Street

P.O. Box 2000 Chattanooga, Tennessee 37402-2801

Spring City, Tennessee 37381

Mr. E.J. Vigluicci

Mr. Michael K. Brandon, Manager Assistant General Counsel

Licensing and Industry Affairs Tennessee Valley Authority

WBN Nuclear Plant 6A West Tower

Tennessee Valley Authority 400 West Summit Hill Drive

P.O. Box 2000 Knoxville, Tennessee 37402

Spring City, Tennessee 37381

Lawrence E. Nanney, Director

Mr. Preston D. Swafford Tennessee Department of Environmental

Chief Nuclear Officer Health and Conservation

and Executive Vice President Division of Radiological Health

Tennessee Valley Authority 3rd Floor, L&C Annex

3R Lookout Place 401 Church Street

1101 Market Place Nashville, TN 37243-1532

Chattanooga, Tennessee 37402-2801

Mr. D. E. Grissette

County Executive Site Vice President

375 Church Street WBN Nuclear Plant

Suite 215 Tennessee Valley Authority

Dayton, Tennessee 37321 P.O. Box 2000

Spring City, Tennessee 37381

W.R. Crouch, Manager

WBN Unit 2 Licensing County Mayor

Watts Bar Nuclear Plant P.O. Box 156

Tennessee Valley Authority Decatur, Tennessee 37322

P.O. Box 2000

Spring City, Tennessee 37381 Senior Resident Inspector

WBN Nuclear Plant

Mr. Gregory A. Boerschig U.S. NRC

Plant Manager, WBN Nuclear Plant 1260 Nuclear Plant Road

Tennessee Valley Authority Spring City, Tennessee 37381-2000

P.O. Box 2000

Spring City, Tennessee 37381

TVA 4

cc email distribution w/encl:

Greg Scott

Tennessee Valley Authority

Electronic Mail Distribution

Letter to Ashok S. Bhatnagar from Robert C. Haag dated August 5, 2010.

SUBJECT: WBN NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED

INSPECTION REPORT 05000391/2010603

Distribution w/encl:

L. Raghavan, NRR

S. Campbell, NRR

P. Milano, NRR

C. Evans, RII

L. Slack, RII EICS

E. Guthrie, RII DRP

R. Monk, RII WBN Unit 1 SRI

OE Mail (email address if applicable)

PUBLIC

NOTICE OF VIOLATION

Tennessee Valley Authority Docket No. 50-391

Watts Bar Nuclear Plant - Unit 2 Construction Permit No. CPPR-92

Spring City, TN

During an NRC inspection conducted on April 26-30, 2010, a violation of NRC requirements was

identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

10 CFR 50, Appendix B, Criterion III, Design Control, states that measures shall be

established for the review for suitability of application of materials, parts, and equipment that are

essential to the safety-related functions of the structures, systems, and components (SSCs).

The design control measures shall provide for verifying or checking the adequacy of design,

such as by the performance of design reviews, by the use of alternate or simplified calculational

methods, or by the performance of a suitable testing program. Where a test program is used to

verify the adequacy of a specific design feature in lieu of other verifying or checking processes,

it shall include suitable qualifications testing of a prototype unit under the most adverse design

conditions.

Contrary to the above, measures used to review the suitability of application of materials, parts,

and equipment essential to the safety-related functions of molded case circuit breakers and

measures to provide for the verification of checking the adequacy of design, such as,

calculational methods, performing a suitable test program, including qualifications testing of a

prototype unit under the most adverse design conditions, were not adequate in that:

1. On October 5, 2009, the applicant installed molded case circuit breakers into the

120VAC vital instrument power boards; however, the test program used to seismically

qualify a prototype circuit breaker failed to use a suitable mounting method that reflected

the most adverse mounting condition.

2. On September 3, 2009, the applicant failed to perform an adequate review for suitability

of application parts and material used to modify dimensional critical characteristics in

molded case circuit breakers; further, the applicant failed to verify the adequacy of

design for the modification and the effects on essential safety related functions of the

circuit breakers.

This is a Severity Level IV violation (Supplement II)

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

(Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" 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

Enclosure 1

NOV 2

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.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the NRCs document system (ADAMS), accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the public without redaction. If personal privacy or proprietary information is

necessary to provide an acceptable response, then please provide a bracketed copy of your

response that identifies the information that should be protected and a redacted copy of your

response that delete such information. If you request withholding of such material, you must

specifically identify the portions of your response that you seek to have withheld and provide in

detail the bases for your claim of withholding (e.g., explain why the disclosure of information will

create an unwarranted invasion of personal privacy or provide the information required by 10

CFR 2.390(b) to support a request for withholding confidential commercial or financial

information). If safeguards information is necessary to provide an acceptable response, please

provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days.

Dated this 5th day of August, 2010

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No.: 50-391

Construction Permit No.: CPPR-92

Report No.: 05000391/2010603

Applicant: Tennessee Valley Authority (TVA)

Facility: Watts Bar Nuclear Plant, Unit 2

Location: 1260 Nuclear Plant Rd

Spring City TN 37381

Dates: April 1 - June 30, 2010

Inspectors: W. Bearden, Senior Resident Inspector, Construction Projects

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

Region II (RII)

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

K. Miller, Resident Inspector, CPB3, DCP, RII

W. Lewis, Resident Inspector, CPB3, DCP, RII

J. Fuller, Senior Construction Inspector, Construction Inspection

Branch 3 (CIB3), Division of Construction Inspection (DCI), RII;

Sections C.1.8, C.1.9, C.1.10, C.1.11, C.1.12, C.1.13, C.1.14,

C.1.15, C.1.16, C.1.17, C.1.18, C.1.19, C.1.20

G. Crespo, Senior Construction Inspector, CIB1, DCI, RII;

Sections C.1.2, C.1.6, E.1.1, T.1.1, OA .1.4, OA.1.5, OA.1.6,

OA.1.7

A. Issa, Construction Inspector, CPB3, DCP, RII, Section Q.1.3

E. Michel, Senior Construction Inspector, CIB3, DCI, RII, Sections

C.1.9, C.1.11, C.1.12, C.1.13, C.1.14

T. Steadham, Construction Inspector, CIB3, DCI , RII, Section

C.1.5

J. Lizardi, Construction Inspector, CIB2, DCI, RII, Sections C.1.4,

C.1.7, C.1.8

C. Abbott, Construction Inspector, CIB2, DCI, RII, Section C.1.3

C. Jones, Senior Construction Inspector, CIB1, DCI, RII, Sections

E.1.2, OA.1.5, OA.1.8, OA.1.12

T. Fanelli, Construction Inspector, CIB1, DCI, RII, Sections C.1.2,

E.1.1

Enclosure 2

2

L. Castelli, Senior Construction Inspector, CIB1, DCI, RII Section

C.1.1

A. Artayet, Senior Construction Inspector, CIB3, DCI, RII, Sections

C.1.15, C.1.16

C. Smith-Standberry, Construction Inspector, CIB1, DCI, RII,

Section OA.1.13

G. Khouri, Senior Construction Inspector, CPB2, DCP, RII, Section

E.1.2

E. Heher, Construction Inspector, CIB2, DCI, RII, Section E.1.2

P. Heher, Construction Inspector, CPB2, DCP, RII, Section Q.1.3

J. Kent, Construction Inspector, CIB1, DCI, RII, Sections OA.1.1,

OA.1.9, OA.1.10, OA.1.11

C. Fong, Construction Inspector, CPB2, DCP, RII, Section C.1.3

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 TVA associated with the Watts Bar Nuclear (WBN) Plant Unit 2 construction project. This

report covered a three-month period of inspections in the areas of quality assurance (QA);

identification and resolution of construction problems; construction activities; training and

qualification of plant personnel; fire protection; and follow-up of other activities. The inspection

program for Unit 2 construction activities is described in NRC Inspection Manual Chapter (IMC)

2517. Information regarding the WBN Unit 2 Construction Project and NRC inspections can be

found at http://www.nrc.gov/reactors/plant-specific-items/watts-bar.html.

The inspection identified one NRC-identified Severity Level (SL) IV violation (VIO), seven non-

cited violations (NCV), and one Unresolved Item (URI).

Inspection Results

  • A SL IV NCV of 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion XV,

Nonconforming Materials, Parts, or Components, was identified by the inspectors for the

failure to have procedures for identification, documentation and segregation of materials

identified as nonconforming to Purchase Order (PO) requirements by the kick and count

inspection. (Section Q.1.3)

the inspectors for the failure to establish adequate measures to control the issuance of

documents stored in the CONEX storage area. (Section Q.1.3)

10 CFR Part 21 requirements on a supplier of safety-related services of basic components.

(Section Q.1.3)

Drawings, was identified by the inspectors for failure to identify improper weld size by the

welder, field engineer, and quality control (QC) in accordance with applicable instructions,

procedures, and drawings. (Section C. 1.3)

by the inspectors for inadequate measures to assure that conditions adverse to quality,

specifically non-conforming safety-related concrete, was promptly identified and corrected.

(Section C.1.4)

  • The inspectors identified a URI related to the material condition inside of the loop-3 RCS

crossover piping. The inspectors concluded that in order to properly evaluate and disposition

this issue, additional inspection would be required to determine (1) whether areas of

concern (potential pitting) were properly identified and documented at the time by QC and

Field Engineer (FE) in accordance with applicable instructions and procedures; and (2)

whether the engineering disposition appropriately addressed the area of concern. (Section

C.1.8)

2

was identified by the inspectors in that the applicant failed to control the storage and

preservation of material and equipment in accordance with work and inspection instructions

to prevent damage from nearby construction activities. Specifically, the inspectors identified

multiple locations of weld and paint spatter, arc strikes, and mechanical damage on safety-

related welds, piping, and components. (Section C.1.9)

inspectors in that the applicant failed to implement adequate design control measures in the

qualification analysis, testing, and calculational methods used to qualify and analyze safety-

related components. This is regarding the seismic qualification of circuit breakers in safety-

related 120VAC Vital Instrument Power Boards. Two examples of design control violation

are listed in the report details section. The violation did not meet the criteria for a non-cited

violation in Section VI.A.1 of the NRC Enforcement Policy because the applicants corrective

action did not adequately address the findings identified and would not ensure that

compliance was restored in a reasonable timeframe or prevent recurrence. (Section E.1.1)

inspectors for a failure to correctly translate the design basis, as described in a System

Description Document, into affected drawings and specifications. Specifically, a design

basis requirement to provide diverse level measurement systems for the Safety Injection

System Accumulators was not correctly translated into affected specifications and drawings

issued for construction. (Section E.1.2)

  • The inspectors concluded that concerns pertaining to the cable CAP sub-issue on adhesive

backed cable mount supports have been appropriately addressed for Watts Bar Unit 2 and

this item is closed. (Section OA.1.3)

  • Other areas inspected were adequate with no findings of significance identified. These

areas included: response to response Three Mile Island (TMI) Action Items; electrical

systems and components; nuclear welding; structural welding; nondestructive examination

and inservice inspection activities; craft training; and fire protection.

Table of Contents

I. QUALITY ASSURANCE (QA) PROGRAM ............................................................................ 1

Q.1 QA Oversight Activities ................................................................................................. 1

Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure (IP) ....

35007) .................................................................................................................................... 1

Q.1.2 Safety Conscience Work Environment (IP 35007)..................................................... 1

Q.1.3 Procurement, Receiving, and Storage Inspection (IP 35060 and IP 35065) .............. 2

II. MANAGEMENT OVERSIGHT AND CONTROLS .................................................................. 6

C.1 Construction Activities .................................................................................................. 6

C.1.1 Instrument Components and Systems - Work Observation (IP 52053) ..................... 6

C.1.2 Instrumentation installation activities- Work Observation (IP 52053) ....................... 7

C.1.3 Pipe Support and Restraint Systems (IP 50090, 46071, and TI 2512/023) ................ 7

C.1.4 Structural Concrete (IP 46053)................................................................................ 10

C.1.5 Safety-Related and RCS Pressure Boundary Piping Records Review (IPs 49055 ......

and 49065, TI 2512/024) ....................................................................................................... 11

C.1.6 Cable Signal Tracing - Work Observation (TI 2512/016, IP 52053) ........................... 13

C.1.7 RPV Internals and Protection of Installed Plan Equipment during Construction ..........

Activities (IP 50053) .............................................................................................................. 14

C.1.8 Reactor Coolant System (RCS) Piping (IP 49053) .................................................. 14

C.1.9 Protection of Installed Plant Equipment During Construction Activities - Reactor .......

Coolant Pressure Boundary Piping (IP 49053) ...................................................................... 16

C.1.10. URI 78-05-02, Reactor Vessel - Nozzle Weld Surface Cracking ............................. 18

C.1.11 Inservice Inspection - Review of Program (IP 73051) ............................................. 19

C.1.12 Inservice Inspection - Review of Procedures (IP 73052) ........................................ 20

C.1.13 Preservice Inspection - Observation of Work and Work Activities (IP 73053) ......... 20

C.1.14 Preservice Inspection - Data Review and Evaluation (IP 73055) ............................. 21

C.1.15 Nuclear Welding General Inspection Procedure (IP 55050) .................................... 23

C.1.16 Structural Welding General Inspection Procedure (IP 55100) ................................. 26

C.1.17 Visual Examination of Safety Related Welds (IP 57050) ......................................... 29

C.1.18 Liquid Penetrant Examination of Safety Related Welds (IP 57060) ......................... 30

C.1.19 Magnetic Particle Examination of Safety Related Welds (IP57070) ......................... 31

C.1.20 Ultrasonic Examination of Safety-Related Welds (IP 57080, 73053) ....................... 32

E.1 ENGINEERING ACTIVITIES ......................................................................................... 32

E.1.1 Procurement, Receiving, and Storage (IP35065) .................................................... 32

E.1.2 Engineering Design Activities and Design Control (IPs 35100 and 37055) .............. 35

T.1 TRAINING AND QUALIFICATION OF PLANT PERSONNEL ....................................... 37

T.1.1 Craft Training (IPs 51051 and 64051) ..................................................................... 37

T.1.2 Engineering Organization Training (IP 35960) ........................................................ 38

III. OPERATIONAL READINESS ACTIVITIES ........................................................................ 38

F.1 Fire Protection (IP 64051) ............................................................................................ 38

2

IV. OTHER ACTIVITIES ...................................................................................................... 39

OA.1.1(Discussed) QA Records Corrective Action Program (TI 2512/28, IPs 50075, 51065, ....

51055, 52055) ....................................................................................................................... 39

OA.1.2 Corrective Action Plans and Special Programs Reviews (TI 2512/017, 025) ...... 40

OA.1.3 (Closed) Electrical Issues CAP Sub-issue: Adhesive Backed Cable Support Mount .....

(ABCSM) (TI 2512/020, IP 51063) ........................................................................................ 41

OA.1.4 (Discussed) Cable Issues CAP Sub-Issue: Computerized Cable Routing System ........

(CCRS) Software and Database Verification and Validation (TI 2512/016) ........................... 41

OA.1.5 (Discussed) Station Blackout (SBO) Rule Procedures and Actions (TI 2515/120) ..... 42

OA.1.6 (Discussed) Non-cited Violation NCV-391/2008-010-01 corrective action for failure......

to document a cable raceway separation non-conforming condition...................................... 42

OA.1.7 (Closed) NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power ........

Cable Failures that Disable Accident Mitigation Systems or Cause Plant ..................................

Transients. ............................................................................................................................ 43

OA.1.8 (Discussed) Inspection of Watts Bar Nuclear Plant Master Fuse List Special ................

Program (TI 2512/037) .......................................................................................................... 43

OA.1.9 (Discussed) NRC Bulletins 74-15, Misapplication of Cutler-Hammer Three .................

Position Maintained Switch Model No. 10250T; 75-03, Incorrect Lower Disc ..........................

Spring and Clearance Dimension in Series 8300 and 8302 ASCO Solenoid .............................

Valves; and 75-06, Defective Westinghouse Type OT-2 Control Switches ........................ 45

OA.1.10 (Discussed) NRC Bulletin 76-02, Relay Coil Failures - General Electric Type HFA, ...

HGA, HKA, and HMA Relays ................................................................................................ 46

OA.1.11 (Discussed) Violation 391/86-02-01; Failure to Follow Procedures that Resulted in ....

Improperly Installed Solenoid Valves .................................................................................... 47

OA.1.12 (Discussed) Inspection of Watts Bar Nuclear Plant Radiation Monitoring System .......

Special Program (TI 2512/041) ............................................................................................. 47

OA.1.13 (Discussed) Applicant Actions on Three Mile Island (TMI) Action Items .................. 48

V. MANAGEMENT MEETINGS ............................................................................................. 51

X.1 EXIT MEETING SUMMARY .......................................................................................... 51

REPORT DETAILS

Summary of Plant Status

During the current inspection period, TVA performed pre-service inspection (PSI) activities and

construction completion activities on safety-related systems, and continued engineering design

activities.

I. Quality Assurance (QA) Program

Q.1 QA Oversight Activities

Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure (IP)

35007)

a. Inspection Scope

During this inspection period, the inspectors reviewed problem evaluation reports

(PERs) as part of TVAs corrective action program to verify that issues being identified

under the corrective action program were being properly identified, addressed, and

resolved by TVA. Additionally, the inspectors reviewed three recent Bechtel QA

surveillance reports regarding ongoing nondestructive examination work activities.

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

Generally, the PERs reviewed were properly identified, addressed, and resolved;

however, as noted in Section C.1.4, Structural Concrete, a violation of regulatory

requirements was identified for failure to promptly identify and correct a condition

adverse to quality.

Q.1.2 Safety Conscience Work Environment (IP 35007)

a. Inspection Scope

The inspectors continued routine meetings with the Unit 2 Employee Concerns Program

(ECP) representative to evaluate the effectiveness of the applicants program for

resolving employee concerns. The inspectors reviewed existing program requirements

and all recent safety-related concerns identified by the applicants and contractors ECP

programs. The inspectors also verified that significant problems were documented

under the corrective action program and were being properly identified, addressed, and

resolved by TVA. This included a review of anonymous PERs and trending for the

months of April and May.

b. Observations and Findings

No findings of significance were identified.

2

c. Conclusions

The inspectors did not identify any issues or concerns regarding the ability of the

applicant to provide a safety-conscience work environment.

Q.1.3 Procurement, Receiving, and Storage Inspection (IP 35060 and IP 35065)

a. Inspection Scope

The inspectors performed a procurement, receiving, and storage inspection in

accordance with IP 35065, Procurement, Receiving, and Storage, and Section 02.04 of

IP 35060, Applicant management of QA activities. In addition, IP 38703, Commercial

Grade Dedication, was used for guidance in reviewing commercial grade dedication

activities. The inspection covered all aspects of procurement and procurement

interfaces. This included a review of the design bases; material requests; procurement

data sheets; technical evaluations and commercial dedication plans; purchase orders;

10 CFR Part 21 provisions; receiving inspection records; storage; corrective action

program; interfaces between design, procurement engineering, procurement and QA;

personnel training and qualification; and internal and external oversight. The objectives

of the inspection were to verify that these activities were performed in accordance with

the applicable QA programs and NRC requirements.

Specifically, the inspectors:

1) Reviewed audit reports of procurement activities at the site.

2) Independently reviewed material requests, technical specifications in procurement

data sheets, and procurement documents to determine whether they invoked the

applicable Quality Assurance (QA) requirements and the applicable codes and

standards; and whether the specified design parameters were in accordance with

those listed in the design specifications. This included ASME Code Section III

requirements and environmental and seismic qualifications.

3) Reviewed purchasing documents for basic components to determine whether they

imposed the requirements of 10 CFR 21 and whether the suppliers were on the

approved suppliers list.

4) Reviewed two samples of commercial grade dedication, to determine the adequacy

of the dedication plan including the identification of critical characteristics, and to

ascertain that the completed dedication activities complied with the dedication plan.

5) Reviewed for adequacy, the requirements specified in the procurement documents

for documentation and acceptance of purchased items and sampled certificate of

conformances (COCs).

6) Reviewed procurement documents to determine whether source verification was

specified for complex engineered items when required and whether the appropriate

receiving inspection organization was aware of the source verification results.

7) Examined the CONEX trailer to determine the adequacy of implementation for the

protection, handling and control of purchasing documents.

8) Examined the system established for conducting receiving inspection including

facilities and records of acceptance such as COCs to determine whether receiving

inspection records were available and whether identified discrepancies were

reviewed by QA and/or engineering, as appropriate, to assure proper disposition.

9) Examined material receiving inspection records to determine compliance with

acceptance requirements and to ascertain whether receiving inspections were

based on acceptable documentation, direct examination, or record of source

verification.

3

10) Examined storage facilities for safety-related items to ensure adequate protection

and compliance with the applicable storage level. The inspectors checked for

proper segregation and identification of nonconforming items. The warehouses

examined included warehouse number 6 where the kick and count inspection takes

place, warehouse number 8 where Quality Control (QC) inspection takes place, and

warehouse number 7 where items are stored for issue to the field. Warehouse

number 7 also included storage of items originally intended for warehouses 6 and 8.

11) Reviewed purchaser notification points, hold points, and access rights when

required to be included in procurement documents.

b. Observations and Findings

The inspectors identified three violations of regulatory requirements as discussed below:

Violation 1:

Introduction: A Severity Level (SL) IV non-cited violation (NCV) of 10 CFR 50, Appendix

B, Criterion XV, Nonconforming Materials, Parts, or Components, was identified by the

inspectors for the failure to have procedures for identification, documentation and

segregation of materials identified as nonconforming to Purchase Order (PO)

requirements by the kick and count inspection. Specifically, effective measures did not

exist to segregate or properly identify hydraulic snubbers procured under PO 63534 as

nonconforming to the PO identification requirements.

Description: On June 8, 2010, the inspectors conducted a walk-down of warehouse

facilities at the WBN2 site. In warehouse number 7, the inspectors observed crates

containing hydraulic snubbers that had not been subjected to QC receipt inspection,

stored next to receipt inspected materials available for issue. Further review indicated

that some of these snubbers did not conform to the PO requirements in that they did not

have all the required identification. The finding was determined to be more than minor

because it represented an improper and uncontrolled work practice that can impact

quality or safety, involving nonconforming safety-related hydraulic snubbers, being

stored without proper identification in close proximity to other materials available for use.

This condition was documented in PER 234358. The cause of this finding was directly

related to the resources component of the Human Performance cross-cutting area, as

defined in IMC 0310, because TVA failed to provide a complete, accurate and up-to-date

procedure, 25402-000-GPP-0000-N6104, Material Receiving, Revision (Rev.) 4, to

address the handling of materials identified as nonconforming to PO requirements at the

kick and count stage of the receiving inspection (H.2(c)).

Enforcement: 10 CFR, Part 50, Appendix B, Criterion XV, Nonconforming Materials,

Parts, or Components, states in part that measures shall be established to control

materials, parts, or components which do not conform to requirements in order to

prevent their inadvertent use or installation. These measures shall include, as

appropriate, procedures for identification, documentation, segregation, disposition, and

notification to affected organizations.

Contrary to the above, on June 8, 2010, the inspectors observed crates containing

hydraulic snubbers being stored next to receipt inspected materials available for issue

even though some of the snubbers did not conform to the PO requirements, in that they

did not have all the required identification. In addition, the affected snubbers were not

properly identified as nonconforming. Although procedures SPP-4.3, Rev. 0006, section

3.5 and 25402-000-GPP-0000-N6104, Rev. 4, section 6.5.12, require the immediate

4

segregation or identification of nonconforming material, these requirements apply to the

QC portion of the receiving inspection and not the kick and count portion. This finding

was determined to be a SL IV violation using Supplement II of the Enforcement Policy.

Because this was a SL IV violation and because it was entered into the corrective action

program as PER 234358, it is being treated as a NCV consistent with Section VI.A of the

NRC Enforcement Policy: NCV 5000391/2010603-01, Marking and Segregation of

Nonconforming Materials from Accepted Materials Available for Use.

Violation 2:

Introduction: A SL IV NCV of 10 CFR 50, Appendix B, Criterion VI, Document Control,

was identified by the inspectors for the failure to establish adequate measures to control

the issuance of documents. Specifically, the applicant failed to establish proper storage

and control of documents stored in the CONEX storage area that were used during

performance of safety-related work activities.

Description: On June 8, 2010, the inspectors walked down the CONEX storage area

and interviewed warehouse personnel on its use. The storage area was environmentally

controlled, used fire rated cabinets, and was locked during off shift hours. Files in the

storage area were sometimes removed from storage or copied during performance of

safety-related work activities. A sign-out folder was to be used whenever a file was

removed from the area. The area included a refrigerator that was being used by

personnel to retrieve drinks and food. On June 9, 2010, the inspectors attempted to

retrieve a completed receiving package for PO 31774, I&C Instrument Isolation Valves

ASME Section III, Class 2, Safety-Related. The package had been removed from the

file cabinets without using a sign-out folder. The finding was determined to be more than

minor because it represented an improper and uncontrolled work practice that could

impact quality or safety, involving the use of improperly stored and uncontrolled

documents in safety-related activities. This condition was documented in PER 234281.

The cause of this finding was directly related to the resources component of the Human

Performance cross-cutting area, as defined in IMC 0310, because TVA failed to provide

a complete, accurate and up-to-date procedure, 25402-ADM-001, Document Control,

Rev. 9, that describes what to do with copies of documents once originals have been

transmitted to Document Control and how to control satellite document control facilities

(H.2(c)).

Enforcement: 10 CFR, Part 50, Appendix B, Criterion VI, Document Control, requires

that Measures shall be established to control the issuance of documents, such as

instructions, procedures, and drawings, including changes thereto, which prescribe all

activities affecting quality. These measures shall assure that documents, including

changes, are reviewed for adequacy and approved for release by authorized personnel

and are distributed to and used at the location where the prescribed activity is

performed.

Contrary to the above, some files in the CONEX trailer have been used or copied to

perform safety-related work activities effectively making it a satellite document control

station, and the files in this trailer were not properly protected nor controlled. The area

included a refrigerator containing food and drinks and the receiving records for PO

31774 were missing from the files in the CONEX trailer with no logout folder in place. In

addition, there were no signs in the trailer, on the filing cabinets or on the folders

themselves identifying these records as for information only (FIO). This finding was

determined to be a SL IV violation using Supplement II of the Enforcement Policy.

5

Because this was a SL IV violation and because it was entered into the corrective action

program as PER 234281, it is being treated as a NCV consistent with Section VI.A of the

NRC Enforcement Policy: NCV 5000391/2010603-02, Inadequate Storage and Improper

Control of Documents Used in Safety Related Activities.

Violation 3:

Introduction: A SL IV NCV of 10 CFR Part 21 was identified by the inspectors for the

failure to invoke the provisions of 10 CFR Part 21 on a supplier for services of safety-

related components. Specifically, lever arms for limit switches were purchased under

PO 87607. The lever arms were sent to TVA Central Laboratories to perform

commercial grade dedication activities without invoking the provisions of 10 CFR Part

21.

Description: The inspectors reviewed the completed package for PO 87607 and

concluded that it did not invoke the provisions of 10 CFR Part 21 on TVA Central

Laboratories. The inspectors also reviewed intergroup agreement (IGA) -11, Central

Laboratories, Rev. 001. This agreement, which is between TVA Nuclear Power Group

(NPG) and TVA Central Laboratories, establishes the responsibilities and requirements

in providing requested services. The inspectors noted that this agreement did not invoke

the provisions of 10 CFR Part 21. The finding was determined to be more than minor

because it represented an improper and uncontrolled work practice that can impact

quality or safety, involving the issuance of procurement documents that did not invoke

the provisions of 10 CFR Part 21. This condition was documented in PER 235485.

There was no cross-cutting aspect associated with this violation.

Enforcement: 10 CFR Part 21.31 states that each individual, corporation, partnership,

dedicating entity, or other entity subject to the regulations in this part shall ensure that

each procurement document for a facility, or a basic component issued by him, her or it

on or after January 6, 1978, specifies, when applicable, that the provisions of 10 CFR

Part 21 apply.

Contrary to the above, PO 87607 did not specify that the provisions of 10 CFR Part 21

applied to TVA Central Laboratories nor did IGA-11, between TVA (NPG) and TVA

Central Laboratories. This finding was determined to be a SL IV violation using

Supplement II of the Enforcement Policy. Because this was a SL IV violation and

because it was entered into the corrective action program as PER 235485, it is being

treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV

5000391/2010603-03, Failure to Invoke 10 CFR Part 21 in Safety Related Procurement

Documents.

In addition, the inspectors made the following observations as a result of their

inspections:

  • The dedication performed by TVA Central Laboratories for NAMCO limit switch

lever arms purchased under PO 87607 was accepted even though it did not fully

meet the dedication plan for verification of manufacturer and part number. This

condition was documented in PER 234290.

  • Level B Condition Examples on page 14 of CAP procedure 25402-MGT-0003,

Rev. 7 cover repetitive supplier nonconformances detected during receiving but

since trending only covers conditions documented in PERs, other

6

nonconformances detected during the kick and count portion of the receiving

inspection will not support this trending effort.

c. Conclusions

Problems were identified in the areas of equipment storage, document control and

invoking the provisions of 10 CFR Part 21 as documented above. Other inspected

procurement, receiving and storage activities were performed in accordance with the

applicable QA programs and NRC requirements.

II. Management Oversight and Controls

C.1 Construction Activities

C.1.1 Instrument Components and Systems - Work Observation (IP 52053)

a. Inspection Scope

The inspectors reviewed safety-related instrumentation components and systems by

direct observation of work performance and work in progress to verify related activities

were performed in accordance with NRC requirements and applicant procedures. Four

samples were inspected and selected from those associated with the reactor trip system

and the engineered safety features actuation system. Specifically, the inspectors

reviewed receiving documents, component identification, controls for potential

nonconforming components, storage conditions, qualifications of warehouse personnel,

and physical condition of the components. The inspectors interviewed responsible

personnel associated with receiving inspection and conducted walk-downs of

warehouses 7, 8, and the Spring City facility to observe the storage facilities for

purchased instrument components. The following items were inspected:

  • 2-FT-68-6A (Receipt and Storage)
  • 2-PT-68-340D (Receipt and Storage)
  • 2-FT-68-48A (Receipt and Storage)
  • Westinghouse Power Range Detector (Storage)

The following samples were inspected:

Additionally, the inspectors reviewed in-process work orders for containment sump level

transmitters. The inspectors verified the transmitters were bench calibrated with proper

control of measuring and test equipment.

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

Adequate receipt and storage controls were established for the inspected samples.

7

C.1.2 Instrumentation Installation Activities- Work Observation (IP 52053)

a. Inspection Scope

The inspectors interviewed responsible personnel, reviewed documentation, and

evaluated Unit 2 instrument installation activities.

The inspectors interviewed responsible construction oversight personnel to determine

the status of installation activities being performed at Unit 2. The inspectors reviewed

installation procedures MAI-4.4A, Instrument Line Installation and MAI-4.4B,

Instrument and Instrument Panel Installation to determine the verification, testing and

documentation requirements for instrument and instrument line installation. The

inspectors performed walk downs to evaluate the installation activities in the north and

south fan rooms to determine the progress and quality of installation activities.

The following items were inspected:

  • 2-RTV-003-0285A - Root Valve for 2-LT-3-42/174

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspection results are too limited to support a conclusion at this time.

C.1.3 Pipe Support and Restraint Systems (IP 50090, 46071, and TI 2512/023)

a. Inspection Scope

The inspectors reviewed procedures and instructions pertaining to pipe support and

restraint systems to determine if they had been evaluated and approved by appropriate

applicant personnel. The inspectors also conducted interviews with personnel engaged

in pipe support installation and performed work observations to confirm adequate

performance of pre-installation checks, field adjustments, equipment control, and

calibrations. The inspectors assessed whether that personnel had received the

appropriate training, had the latest revisions of applicable drawings, and significant

modifications to supports had been approved by appropriate personnel.

The inspectors conducted walk-downs of the following installed safety-related pipe

supports to verify their compliance with NRC requirements and applicant commitments:

  • H-406-14-23-72 (Chemical and Volume Control System (CVCS))
  • H-406-14-23-71 (CVCS)
  • 2-47A462-11-172 (Ice Condenser System)
  • 2-47A462-11-173 (Ice Condenser System)
  • 2-47A462-11-174 (Ice Condenser System)
  • 2-47A450-26-304 (Essential Raw Cooling Water (ERCW) System)

Specifically, the inspectors performed a visual inspection to verify the absence of

deformation and corrosion. Independent measurements were also performed to

determine whether the installed configuration of pipe supports was consistent with final

as-built drawings.

8

The inspectors also observed applicable controls of specific processes and activities

including torquing of bolts, minimum spacing between bolts, slippage of nut during

installation, and number of washers used on bolts for the following supports:

SUPPORT ID # (2 bolts per support)

110714210-570

110714210-385

110714210-386

110714210-373

110714210-358

110714210-413

110714210-380

110714210-158

110714210-304

110714210-115

110714210-351

110714210-329

995417923-153

995417923-055

995417923-170

SUPPORT ID# (4 bolts per support)

110714194-084

110714194-126

110714194-128

110714194-129

The following samples were inspected:

  • IP 50090 Section 02.03.d.2 - six samples
  • IP 50090 Section 02.03.d.2 - six samples

b. Observations and Findings

The inspectors identified the following NCV:

Introduction: A SL IV NCV of 10 CFR 50, Appendix B, Criterion V, Instructions,

Procedures, and Drawings, was identified by the inspectors for failure to identify

improper weld size by the welder, field engineer, and quality control (QC) in accordance

with applicable instructions, procedures, and drawings.

Description: On February 25, 2010, the inspectors performed a walk-down of newly-

installed pipe supports to determine whether their as-installed configurations matched

those specified by the applicable drawing revision authorizations (DRAs). The

inspectors identified an example where the weld throat did not meet the minimum size

requirements, specified by DRA 52897-005, for a weld joining an embed plate to pipe

support 2-47A450-26-304 for the safety-related ERCW system.

9

Specifically, the inspectors identified that Weld #1 joining embed plate 48N913-8B to

pipe support 2-47A450-26-304 was (1) not welded in accordance with the drawings; (2)

was verified and signed off by the field engineer (FE) despite the incorrect weld size; and

(3) was accepted by QC despite the fact that the weld size did not meet the acceptance

criteria specified in DRA 52897-005.

On February 26, 2010 the applicant initiated PER 219205 to document the conditions

identified by the inspectors. The applicant concluded that although the weld had been

final accepted by QC, it did not meet the size requirements specified by DRA 52897-005,

and would have to be repaired or reworked. An initial extent of condition evaluation was

performed and included re-inspection of 67 safety-related welds, 18 of which were found

not to meet the acceptance criteria. The applicants review of this issue and follow-up

extent of condition review, which identified the additional 18 undersize weld, extended

into the inspection period covered by this report and is the reason this violation is

documented in this inspection report.

This finding was determined to be more than minor because it represented an

inadequate work activity and inadequate quality oversight function that, if left

uncorrected, could adversely affect the quality of the construction and records of a

safety-related system, the ERCW system. The cause of this finding was directly related

to the work practices component of the Human Performance cross-cutting area, as

defined in IMC 0310, because TVA failed to appropriately communicate human error

prevention techniques, such as self checking, and proper documentation of activities

(H.4 (a)).

Enforcement: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and

Drawings requires in part that activities affecting quality shall be accomplished in

accordance with instructions, procedures, or drawings.

Section 6.1.3 of Bechtel procedure 25402-000-GPP-0000-N3504, Pipe and Instrument

Tubing Supports requires that all materials, work, and services shall fully comply with

the design drawings, specifications, applicable codes and standards. Additionally,

Section 6.3.1 requires that the quality control engineer (QCE) inspect and verify all

inspection attributes for Safety-Related (SR) and Quality Related (QR) activities. These

inspection attributes include orientation, configuration, and dimensions as defined in

attachment B of the procedure. Finally, Section 6.3.7 requires that the FE verify that

hangers and supports are installed in accordance with design output documents,

including drawings.

Contrary to the above, activities affecting quality were not accomplished in accordance

with applicable instructions, procedures, and drawings. Specifically, Weld #1 joining

embed plate 48N913-8B to pipe support 2-47A450-26-304 was (1) not welded in

accordance with the drawings; (2) was verified and signed off by FE despite the incorrect

weld size; and (3) was accepted by QC despite the fact that the weld size did not meet

the acceptance criteria specified in DRA 52897-005.

This finding was determined to be a SL IV violation using Supplement II of the

Enforcement Policy. Because this was a SL IV violation and because it was entered into

the corrective action program as PER 219205, this violation is being treated as a NCV

consistent with Section VI.A of the NRC Enforcement Policy: NCV 5000391/2010603-04,

Undersized Pipe Support Welds.

10

c. Conclusions

The inspected activities associated with the installation of pipe supports for those

discussed above were not performed in accordance with applicant procedures and NRC

regulations; however, other activities observed were performed in accordance applicable

procedures.

C.1.4 Structural Concrete (IP 46053)

a. Inspection Scope

The inspectors observed concrete placement activities associated with work order (WO)

09-954333-011. The inspectors interviewed personnel involved with these activities and

assessed the following conditions prior to and during the placement process:

  • The pre-placement inspection performed by QC was completed before any

concrete was placed.

  • The placement area was cleaned and joint preparation was as specified in the

construction specification.

  • Records were produced, reviewed, and indicated mix, location, time placed,

water additions, and temperature of the concrete mix and ambient conditions.

  • Concrete temperature, slump, air content, and unit weight were determined at the

proper location and frequency.

  • Sampling and testing techniques conformed to the procedures specified in the

applicable American Society for Testing and Materials (ASTM) standards.

  • Test specimens, for concrete strength determination, were sampled at the

required location and frequency and were molded and cured in accordance with

specified requirements.

The following samples were inspected:

b. Observations and Findings

The inspectors identified the following NCV:

Introduction: A SL IV NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective

Action, was identified by the inspectors for inadequate measures to assure that

conditions adverse to quality, specifically non-conforming safety-related concrete,

were promptly identified and corrected.

Description: On May 17, 2010, the inspectors observed concrete placement activities

associated with work order (WO) 09-954333-011. On May 21, 2010, PER 230811,

Concrete Mixing and Placement Violations, was issued to document issues with

concrete mixing and placement discrepancies identified during the placement of

concrete into the floor for support No. 2-70-888 in accordance with WO 09-954333-

011. Prior to placement, QC rejected the safety-related concrete batch; however, the

concrete was placed with known concerns.

11

On June 30, 2010 the inspectors reviewed PER 230811 and discovered that the

PER and associated actions had been closed and archived. The action to address

the nonconforming condition did not fully address the discrepancies identified during

placement as stated in PER 230811. On July 1, 2010, the applicant initiated PER

237820 to document the inappropriate closure of PER 230811.

This finding was determined to be more than minor because it represented an

improper or uncontrolled work practice that can impact quality or safety, involving

safety-related SSCs, in that the failure to appropriately disposition the nonconforming

condition (concrete rejected by QC) led to the inadvertent use of concrete of

indeterminate quality in a safety-related application. The cause of this finding was

directly related to the work practices component of the Human Performance cross-

cutting area, as defined in IMC 0310, because the applicant failed to ensure

supervisory and management of oversight of work, including contractors, such that

nuclear safety is supported (H.4(c)).

Enforcement: 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires in

part that measures shall be established to assure that conditions adverse to quality,

such as deficiencies, deviations, defective materials, and nonconformances are

promptly identified and corrected.

Contrary to the above, measures specified in the Corrective Action Program

procedure 25402-MGT-003 including oversight by responsible organizations, were

inadequate to assure that conditions adverse to quality, such as deficiencies,

deviations, defective materials, and nonconformances were corrected. Specifically,

PER 230811 was closed inappropriately without an adequate engineering disposition

for non-conforming (as rejected by QC) safety-related concrete and the responsible

organization did not verify completion of the PER corrective actions.

This finding was determined to be a SL IV violation using Supplement II of the

Enforcement Policy. Because this was a SL IV violation and because it was entered

into the corrective action program as PER 237820, this violation is being treated as a

non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement

Policy: NCV 5000391/2010603-05, Inadequate corrective actions for non-conforming

safety-related concrete.

c. Conclusions

The inspected activities associated with the disposition of non-conforming safety-related

concrete were not performed in accordance with applicant procedures and NRC

regulations as noted above.

C.1.5 Safety-Related and RCS Pressure Boundary Piping Records Review (IPs 49055

and 49065, TI 2512/024)

a. Inspection Scope

The inspectors reviewed the applicants actions related to the Heat Code Traceability

Corrective Action Program (CAP) implementation plan (plan) for Unit 2 following the

guidance in Temporary Instruction (TI) 2512/024. This CAP was designed to resolve

issues related to traceability problems identified in the mid-1980s with pressure retaining

loose piping, fittings, and flange bolting (materials) used in American Society of

Mechanical Engineers (ASME) applications. The overall objective of the CAP was to

12

provide a re-verification of ASME Section III Code compliance of the installed hardware.

The plan for the CAP was designed to address the following identified issues and to

provide for recurrence control:

  • ASME systems containing lower class ASME or ASTM material; and
  • ASTM plate material attached to ASME pressure boundaries.

The inspectors compared the Unit 2 plan to the Unit 1 plan to evaluate the similarity of

approach for both units and to determine whether any differences were appropriate.

Overall, the inspectors reviewed records related to ASME Section III, Class 1, 2, and 3

pressure retaining materials to determine if the applicant was effectively implementing

the Unit 2 plan. The inspectors reviewed applicant efforts to resolve unverified non-

destructive evaluation (NDE) for Class 1, 2, and 3 pressure retaining materials as well as

recurrence control efforts. More specifically, the inspectors:

  • Reviewed records to determine if the required performance tests, nondestructive

tests, and other specification requirements were met and if the required

inspections were performed. The inspectors reviewed the applicants efforts to

ensure adequate traceability and Code compliance of Class 1, 2, and 3 pressure

retaining materials to determine if those efforts were being performed in

accordance with the plan;

  • Reviewed the applicant/contractor system for reporting and dispositioning

nonconforming materials associated with the reactor coolant pressure boundary

piping and other safety-related piping and two nonconforming reports to

determine:

  • whether the records adequately documented the status of the

nonconformances;

  • whether the sample of records was legible and complete; and,
  • whether the records were being properly identified and stored.
  • Performed field walk-downs on nine Class 1 welds, four Class 2 welds, one

Class 3 weld, and one Class 2 valve to evaluate the base metal traceability to the

material certifications and the adequacy of the material certifications compared to

the relevant Code requirements. This review included 27 loose material pieces

consisting of 17 separate heat numbers installed in four systems. The nine

reactor coolant pressure boundary welds reviewed included five 3/4 diameter,

two 2 diameter, and two 3 diameter parts. These reactor coolant pressure

boundary parts were located in the reactor coolant, chemical and volume control,

and safety injection systems. The specific list of welds that were inspected is

included in the Attachment to this report;

  • Performed field walk-downs of welds 2-068A-T035-27 and 2-068A-T015-27,

which were annotated in the N-5 database as being removed, to evaluate the

accuracy of the database; and,

  • Reviewed Bechtel and TVA procurement and material control procedures to

determine if the procedures contained appropriate recurrence control elements;

The inspectors interviewed ASME N-5 personnel about TVAs implementation of the

plan. The inspectors also reviewed Boundary Information Transmittals (BIT),

engineering evaluations, work orders, material certification packages (weld map,

13

certified mill test reports, certificates of compliance, weld fit-up data sheets, and

examination record data sheets), historical condition reports, and the Unit 1 plan to

evaluate the applicants plan for Unit 2. Other documents reviewed are also included in

the attachment.

These inspection activities reviewed a portion of the applicants plan. Therefore, this

CAP remains open.

b. Observations and Findings

No findings of significance were identified.

During implementation of the Unit 2 plan, the applicant identified numerous traceability

concerns with installed materials and addressed each issue by writing a BIT. The

inspectors reviewed two BITs and determined the BITs appropriately characterized the

nonconformance and the BITs were in conformance with all applicable procedures.

Additionally, the inspectors reviewed all deviations between the plans for both units and

determined that they were acceptable because the scope of the Unit 2 plan exceeded

the scope of the Unit 1 plan. For example, the plan for Unit 1 consisted of a statistical

sampling of all Class 2 & 3 materials to obtain a 95% confidence level that all materials

complied with the Code; however, the applicant reviewed all Class 2 & 3 materials for

Unit 2 and did not rely on a statistical sampling technique to ensure Code compliance.

c. Conclusions

The applicants closure plan for the Heat Code Traceability CAP was similar to the plan

used to close the Unit 1 CAP with no unacceptable deviations identified. The applicant

was effectively implementing the Unit 2 plan for those activities reviewed during this

inspection.

C.1.6 Cable Signal Tracing - Work Observation (TI 2512/016, IP 52053)

a. Inspection Scope

The inspectors reviewed calculation EDQ00299920090014, Engineering Document

Construction Release (EDCR) 54264, and WO 111010149 associated with the signal

tracing of B-train, safety-related cable 2V1916B. Additionally, the inspectors interviewed

responsible engineering staff and observed field cable signal tracing activities.

b. Observations and Findings

No findings of significance were identified. The inspectors determined that the pre-job

briefings were adequate, covering staff qualifications, equipment calibration and

operating conditions, other staff assistance requirements for providing ladders and

access to spaces inside the Auxiliary Building, operations coordination, and appropriate

tools. The inspectors verified that the staff performing the tracing were following proper

peer-to-peer verification procedures. The inspectors observed the signal tracing;

however, the applicant noted the results did not appear reasonable to accurately identify

routing. It was identified that the routing picked up by the tracing was different from the

routing shown on the drawings and Integrated Cable and Raceway Design System

(ICRDS) data sheets. At the end of the inspection period, the applicant was still

investigating the tracing anomaly.

14

c. Conclusions

Further inspection is needed to verify ICRDS is updated with the results from the signal

tracing.

C.1.7 RPV Internals and Protection of Installed Plan Equipment during Construction

Activities (IP 50053)

a. Inspection Scope

During the inspection period, the inspectors conducted observations of the reactor

pressure vessel (RPV) condition assessment activities. The assessment activities

included walk-downs and non-destructive examinations (NDEs). This inspection was to

determine whether requirements, work procedures, and inspection (quality control)

procedures were being met. The inspectors also observed ongoing visual examination

activities performed by PCI Energy Services (PCI) inside the RPV. Housekeeping and

protection controls of the RPV were observed to determine whether procedural

requirements were being met. These activities are controlled by procedure 25402-000-

GPP-0000-N2102, Housekeeping. Specific documents reviewed are listed in the

attachment.

The following samples were inspected:

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

Adequate controls were in place to protect the RPV during the inspection period.

C.1.8 Reactor Coolant System (RCS) Piping (IP 49053)

a. Inspection Scope

The inspectors observed work activities associated with the reactor coolant system

including loops 1 through 4 hot legs and cold legs. The inspectors entered and visually

examined the piping to verify the material condition. The inspectors also verified the

following:

  • Inspection (QC) and/or work performance verification, including specified

frequency of inspections

  • Utilization of qualified inspection personnel
  • Control of nonconforming items

15

The following samples were inspected:

b. Observations and Findings

The inspectors identified the following unresolved item:

Introduction: The inspectors identified an unresolved item (URI) related to the material

condition inside of the loop-3 RCS crossover piping.

Description: On June 30, 2010, the inspectors reviewed PER 224434 associated with

the material condition of the loop-3 RCS crossover piping. The inspectors had

previously entered the loop-3 crossover piping on March 20 and 21 to inspect the

material condition of the interior of the piping as documented in inspection report

05000391/2010602. During that time and after work had been completed and signed off

by QC. The inspectors noted that some potential areas of pitting had not been

documented by the applicant as specified in WO 110739214. Specifically, Step 5.5.3.C

of WO 110739214, stated the following:

After cleaning, the surface of the RCS piping and welds shall be visually

examined to determine if surface pitting has occurred. The pipe interior shall be

inspected for any area showing a reduction in wall thickness as PER NDRF

211911. Any suspect areas shall be forwarded to engineering for inspection and

further evaluation.

In addition, Appendix B of the Corrective Action Program procedure 25402-MGT-003

requires that nonconforming items be dispositioned by engineering and a technical

justification be included for Accept-As-Is or Repair.

As result of the NRCs questions, on April 7, 2010 the applicant initiated PER 224434 to

address the issues identified by the NRC related to the material condition of the

crossover piping and document the location of these potential areas of concern;

however, on June 30 after further review of the PER, the inspectors noted that corrective

action 224434-002 included an engineering disposition unrelated to the issue and

instead addressed a 3 drain line.

The inspectors concluded that in order to properly evaluate the applicants disposition of

this issue, additional inspection would be required to determine (1) whether areas of

concern (potential pitting) were properly identified and documented at the time by QC

and FE in accordance with applicable instructions and procedures; and (2) whether the

engineering disposition appropriately addressed the area of concern. This issue was

identified as URI 05000391/2010603-06, Material Condition Inside Loop-3 RCS

Crossover Piping.

c. Conclusions

The inspectors concluded that additional inspection would be required to resolve

questions associated with material condition of RCS piping.

16

C.1.9 Protection of Installed Plant Equipment During Construction Activities - Reactor

Coolant Pressure Boundary Piping (IP 49053)

a. Inspection Scope

The inspectors performed a walk-down of a sample of installed safety-related welds,

piping, and components to determine whether the applicant and their contractors had

established adequate controls for the storage and preservation of safety-related, ASME

materials and equipment. Specifically, the inspectors performed walk-downs of portions

of the following systems:

relief and safety valve lines)

  • Safety injection system

The inspectors observed housekeeping activities to determine whether quality

assurance program requirements were adequately implemented by the applicant and

their contractors. The inspectors compared observations made to the following quality

assurance program requirements:

  • Appendix B, Criterion XIII, Handling, Storage, and Shipping, of 10 CFR Part 50
  • The TVA quality assurance program, TVA-NQA-PLN89-A, Nuclear Quality

Assurance Program (NQAP), Rev. 23

  • Watts Bar Unit 2 Construction Completion Project, Bechtel Project Nuclear Quality

Assurance Manual (PNQAM), Rev. 6

  • American National Standards Institute (ANSI) N45.2.3-1973, Housekeeping during

the Construction Phase of Nuclear Plants, (referenced in both NQAP and PNQAM)

Items for Nuclear Plants. (Referenced in both NQAP and PNQAM)

Installation, Inspection, and Testing of Mechanical Equipment and Systems for the

Construction of Nuclear Power Plants.

b. Observations and Findings

The inspectors identified the following NCV:

Introduction: The inspectors identified a SL IV, NCV of 10 CFR 50, Appendix B,

Criterion XIII, Handling, Storage, and Shipping, in that, the applicant failed to control

the storage and preservation of safety-related material (welds, piping, and components)

to prevent damage from nearby construction activities. Specifically, the inspectors

identified multiple locations of weld and paint spatter, arc strikes, and mechanical

damage on safety-related welds, piping, and components.

Description: On June 23, 2010, while performing a walk-down of the pressurizer safe-

end to elbow weld (RCF-D144-11), the inspectors identified multiple examples of weld

and paint spatter, arc strikes, and mechanical damage (e.g., dents, dings, gouges, etc.)

on adjacent ASME Class 1, safety-related welds, piping, and components. On June 24,

2010, the inspectors performed another walk-down of piping systems in the reactor

building and identified additional examples of weld and paint spatter, arc strikes, and

mechanical damage on ASME Class 1, safety-related welds, piping, and components.

17

The inspectors identified approximately 70 locations of damage associated with welds,

piping, and components within the following systems: (1) reactor coolant system, (2)

safety injection system, and (3) residual heat removal system. The specific issues

identified by the inspectors were documented by the applicant in PER 236720.

The inspectors noted that affected welds, piping, and components were fabricated from

stainless steel alloys, and were all ASME Class 1, pressure boundary items. The

inspectors determined that these issues were reasonably within the applicants ability to

foresee and correct, and should have been prevented.

TVAs Nuclear Quality Assurance Program and the Bechtel PNQAM both require the

implementation of ANSI N45.2.8-1975, "Supplementary Quality Assurance

Requirements for the Installation, Inspection, and Testing of Mechanical Equipment and

Systems for the Construction of Nuclear Power Plants. Section 4.6, Care of Items, of

ANSI N45.2.8-1975, states in part:

Items on which inspection and testing activities are being performed shall be

protected from personnel traffic, weather, and adjacent construction activities

such as sandblasting, acid cleaning, welding, jack hammering, chipping,

burning and stress relieving that would adversely affect the quality of the item

or test results. Such protection shall be provided through good cleanliness

and housekeeping practices, temporary packaging, erection of barriers,

protective covers, and walkways as required in accordance with Subsection

2.6.

ANSI N45.2.8-1975, Section 2.6 references ANSI N45.2.3-1973, Housekeeping during

the Construction Phase of Nuclear Plants, which both TVA and Bechtel commit to in

their quality assurance programs. This ANSI standard specifically addresses the

protection of materials and equipment from physical damage during the construction

phase. Bechtel implements the requirements of ANSI N45.2.3-1973 through adherence

to Procedure 5402-000-GPP-0000-N2102, Housekeeping. Section 6.11,

Housekeeping During Construction Activities, of this procedure, states in part:

Barriers, screens, shields, restricted access, or other protection shall be

provided as necessary for isolation of areas where dust, inclement weather,

or other conditions exist that may affect the quality of work being performed.

This protection should be maintained throughout the work cycle.

Based on the applicants preliminary evaluation of the conditions identified, the

inspectors determined that the applicant failed to provide adequate protection of safety-

related welds, piping, and components from adjacent construction activities in

accordance with work and inspection instructions.

The inspectors determined that this finding was more than minor because it represented

an inadequate quality oversight function that, if left uncorrected, could adversely affect

the quality of the construction of safety-related, pressure boundary welds, piping, and

components. Specifically, these conditions could render the quality of the installed items

unacceptable or indeterminate. Additionally, the repairs or rework required to correct the

identified conditions may require additional examinations to verify conformance with the

construction code of record. Furthermore, the applicant had previously completed pre-

service inspections on some of the affected welds, and depending on the repair required

to correct the condition, the pre-service examination results may be invalidated.

18

This issue was entered into the corrective action program as PER 236720. This PER

stated that some of these issues were likely the result of recent construction activities

and others were likely historical issues, in that they were caused by construction and/or

installation activities that occurred prior to 2008. There was no cross-cutting aspect

associated with this violation.

Enforcement: 10 CFR 50 Appendix B, Criterion XIII, Handling, Storage, and Shipping,

requires, in part, that, measures shall be established to control the handling, storage,

shipping, cleaning and preservation of material and equipment in accordance with work

and inspection instructions to prevent damage or deterioration.

TVAs Nuclear Quality Assurance Program and the Bechtel PNQAM both require the

implementation of ANSI N45.2.8-1975 and ANSI N45.2.3-1973. Section 4.6, Care of

Items, of ANSI N45.2.8, states in part that, Items on which inspection and testing

activities are being performed shall be protected from adjacent construction

activitiesthat would adversely affect the quality of the item or test results.

Section 6.11, Housekeeping During Construction Activities, of Procedure 5402-000-

GPP-0000-N2102, Housekeeping, Rev. 8, states in part: Barriers, screens, shields,

restricted access, or other protection shall be provided as necessary for isolation of

areas where dust, inclement weather, or other conditions exist that may affect the quality

of work being performed.

Contrary to the above, prior to June 24, 2010, the applicant failed to control the storage

and preservation of material and equipment in accordance with work and inspection

instructions to prevent damage from adjacent construction activities as evidenced by

multiple locations of weld and paint spatter, arc strikes, and mechanical damage on

safety-related welds, piping, and components.

This finding was determined to be a SL IV violation using Supplement II of the

Enforcement Policy. Because this was a SL IV violation and because it was entered into

the corrective action program as PER 236720, it is being treated as a NCV consistent

with Section VI.A of the NRC Enforcement Policy: NCV 5000391/2010603-07, Failure to

Protect Safety-Related Welds, Piping, and Components During Construction Activities.

c. Conclusions

The inspectors identified a violation for the applicants failure to control the storage and

preservation of material and equipment in accordance with work and inspection

instructions to prevent damage from nearby construction activities.

C.1.10. Unresolved Item 78-05-02, Reactor Vessel - Nozzle Weld Surface Cracking

a. Inspection Scope

The inspectors conducted interviews and reviewed documentation related to URI 78-05-

02, Reactor Vessel - Nozzle Weld Surface Cracking, to determine whether the cracking

had been adequately repaired. The inspectors reviewed welding records and NDE

reports related to repairs completed to loop four, reactor vessel cold leg nozzle weld 2-

068C-W004-01, to evaluate compliance with the requirements of ASME Section III,

1971 edition through the summer 1973 addenda. Following all repairs, the final

radiographic exam (RT) was performed on May 9, 1978, and was accepted by both the

19

Level II reviewer and Authorized Nuclear Inspector (ANI). However, a subsequent May

19, 1988, review rejected the May 9, 1978, RT due to excessive geometric unsharpness

and use of the wrong penetrameter. This issue was generic in nature, in that, during an

NRC conducted review of RT film for both Unit 1 and Unit 2, 683 Class 1 and Class 2

welds were identified with geometrical unsharpness issues. See NRC inspection report

50-390, 391/91-23 for additional information on the RT review. A subsequent

evaluation, and development of a special procedure per the 1971 edition of the ASME

Section III, Appendix IX, paragraph IX-3110, was performed by the applicant to resolve

the geometrical unsharpness issue for Watts Bar Unit 1. See NRC inspection report 50-

390, 391/91-32 for additional details and disposition.

As these issues relate to Watts Bar Unit 2, the applicant intends to submit a special

procedure to the NRC as a proposed alternative per the requirements of 10 CFR

50.55a, Codes and Standards, and to the ANI for review and acceptance. Further

inspection of URI 78-05-02 will continue, once those reviews or acceptable alternatives,

have been completed.

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspectors determined that URI 78-05-02, Reactor Vessel - Nozzle Weld Surface

Cracking will remain open.

C.1.11 Inservice Inspection - Review of Program (IP 73051)

a. Inspection Scope

The inspectors reviewed a sample of NDE coverage calculations to determine whether

the applicant adequately calculated the percentage of code-required examination

volume coverage obtained. The inspectors also performed a walk-down of the following

welds in order to evaluate the validity of relief requests intended to be submitted for less

than 90% NDE coverage within the preservice inspection (PSI) program. The inspectors

also reviewed the following NDE report coverage diagrams:

The following samples were inspected:

b. Observations and Findings

No findings of significance were identified.

20

c. Conclusions

The inspectors determined that the observed NDE activities met the requirements

established by the applicants PSI program and the ASME Code.

C.1.12 Inservice Inspection - Review of Procedures (IP 73052)

a. Inspection Scope

The inspectors reviewed N-UT-78, PDI Generic Procedure for the Manual Ultrasonic

Examination of Reactor Pressure Vessel Welds PDI-UT-6, Rev. 0005 to determine the

adequacy of both the scope and technical content in meeting the requirements of the 10

CFR 50.55a Codes and Standards, and Section XI of the ASME Boiler and Pressure

Vessel Code, 2001 edition through 2003 addenda. The inspectors also observed the

procedure in use during the examination of W09-10, reactor pressure vessel head

circumferential weld.

The following samples were inspected:

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspectors determined that the ultrasonic examination procedure reviewed met

applicable ASME code and 10 CFR 50.55a requirements.

C.1.13 Preservice Inspection - Observation of Work and Work Activities (IP 73053)

a. Inspection Scope

The inspectors observed a selected sample of PSI related activities to determine

whether the onsite preservice inspection of ASME Class 1, 2 and 3 pressure retaining

components was performed in accordance with the applicants PSI program, Preservice

Inspection Program Plan, Watts Bar Nuclear Plant Unit 2, Rev 3. Specifically, the

inspectors observed the ultrasonic (UT) PSI examination of reactor pressure vessel

head Circumferential Weld W09-10.

The inspectors observed portions of the examination and reviewed associated NDE

reports to determine whether the examinations were performed in accordance with

approved procedures and consistent with the ASME Code of Record for the PSI

program (ASME, Boiler and Pressure Vessel Code, 2001 edition including 2003

addenda,Section XI, Division 1, Inservice Inspection of Nuclear Power Plant

Components). Examination records were reviewed to determine whether they were

prepared, evaluated, and maintained in accordance with the applicants QA program

requirements (TVA-NQA-PLN89-A, Rev. 23) and the requirements specified in ASME

Section XI.

21

Qualification and certification records for examiners, inspection equipment, and

consumables along with the applicable NDE procedures for the pre-service examination

activities were reviewed to determine whether they met the requirements established by

the applicants PSI program and the ASME Code.

The following samples were inspected:

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspectors determined that the observed NDE activities and qualification records for

examination personnel met the requirements established by the applicants PSI program

and the ASME Code.

C.1.14 Preservice Inspection - Data Review and Evaluation (IP 73055)

a. Inspection Scope

The inspectors reviewed a sample of recently completed PSI examination records (NDE

records) for safety-related systems. The inspectors reviewed these records to determine

whether they met the requirements the ASME Code, the associated NDE procedure,

and the applicants quality assurance program. Specifically, the inspectors reviewed the

records to determine whether they contained or referenced the following information:

  • Examination results and data sheets
  • Examination equipment data
  • Calibration data sheets (as applicable)
  • Extent of examination
  • Records on disposition of findings (if applicable)
  • Identification of NDE material such as penetrant, penetrant cleaner, couplant,

films, tapes, etc.

The inspectors also reviewed these records to determine whether:

  • Collected examination data and any recordable indications were properly

recorded to permit accurate evaluation and documentation.

  • Evaluation of examination data was performed by a Level II or Level III

examiner.

  • Evaluation of examination data was consistent with the procedure.
  • Evaluation of indications (if applicable) complied with the criteria of the NDE

procedure and ASME Section XI.

  • Incomplete examinations and results were repeated to permit full evaluation (if

applicable).

22

The inspectors reviewed the following PSI examinations:

Report # NDE Weld # / System Description ASME

Method Component Class

R-P0240 Liquid RCF-D144-11 Reactor Safe End to 1

Penetrant Coolant Elbow Weld

R-P0970 Liquid SIS-163 Safety Elbow to Pipe 2

Penetrant Injection Weld

R-P0972 Liquid SIF-D123-07 Safety Valve to 2

Penetrant Injection Reducer

Weld

R-P0992 Visual RCP3FLG Reactor Flange 1

Coolant

R-P0993 Magnetic FWF-D002-03 Feed Water Valve to Pipe 2

Particle Weld

R-P0994 Magnetic FWS-015 Feed Water Pipe to 2

Particle Reducer

Weld

R-P0996 Magnetic MSS-052 Main Steam Cap to Pipe 2

Particle Weld

For PSI examinations that identified unsatisfactory examination results, the inspectors

reviewed the applicants actions to determine whether indications were dispositioned in

accordance with approved procedures, and the ASME Code. Specifically, for PSI report

R-P0240 (weld number RCF-D144-11), the inspectors reviewed the associated

corrective action documents (PER 166624) that the applicant used to correct an

unsatisfactory linear indication. The inspectors reviewed WO 10-951028-000 and

supplemental examination reports (PT-019 and UT-019) to determine whether the

indication was adequately corrected. The inspectors also performed an independent

visual inspection of the repair area to determine whether the weld conformed to contour

and surface finish requirements. For the other PSI reports that documented

unacceptable indications, the inspectors were unable to review the corrective actions

because the conditions had not been corrected at the time of the inspection. The

inspectors reviewed the PERs that were generated for the unacceptable indications.

The inspectors reviewed records related to the PSI ultrasonic examination of the reactor

pressure vessel head circumferential weld, W09-10, to determine whether the

examination was performed in accordance with N-UT-78, Rev. 5. The inspectors also

reviewed these records to determine whether the records provided documentary

evidence that the examination met the prescribed acceptance criteria and other technical

and quality requirements. Specifically, the inspectors reviewed records to determine

whether:

  • The method, extent and technique complied with the requirements of the PSI

program and ASME Section XI.

criteria.

  • Recording, evaluation and disposition of findings were in compliance with Section

XI and the NDE procedure.

  • The method used was sufficient to determine the full extent of an indication or its

acceptance.

23

The inspectors performed the following samples:

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspectors determined that the PSI data reviewed met applicable ASME Code

Sections, the applicant quality assurance program, and PSI Program requirements. The

inspectors also determined that the PSI data was complete and was either within the

prescribed acceptance criteria or documented in a corrective action document to restore

compliance with acceptance criteria.

C.1.15 Nuclear Welding General Inspection Procedure (IP 55050)

a. Inspection Scope

The inspectors performed an inspection of applicant activities associated with the

fabrication and repair of safety-related piping welds at Watts Bar Unit 2. The inspectors

reviewed the contractors welding program controls for welding fabrication and weld

repair of safety-related piping welds.

The inspectors compared safety-related welding activities and records reviewed to the

following technical and quality requirements:

  • Bechtel Quality Assurance Manual, Rev. 3 (Section 9, Control of Special

Processes)

  • The applicants quality assurance manual TVA-NQA-PLN89-A, Rev. 23 (Section

9.3, Control of Special Processes)

  • Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B,

Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing

Plants

  • The Watts Bar Unit 2 piping code of record (American Society of Mechanical

Engineers [ASME] Boiler and Pressure Vessel Code, 1971 Edition with addenda

through summer 1973,Section III, Division 1, Rules for Construction of Nuclear

Facility Components).

The inspectors reviewed portions of the contractors Special Processes Manual (SPM),

Rev. 1, to determine whether the contractor had established an adequate program to

implement the above quality and technical requirements. The SPM included program

documents such as: welding procedure specifications (WPSs) with supporting

procedure qualification records (PQRs); welding filler metal control procedures; welder

performance qualification procedures; general welding standards; general purging

specification; various NDE procedures; postweld heat treatment (PWHT) procedures;

and weld documentation procedures.

24

Base Material and Weld Filler Material Compatibility for Welding

The inspectors reviewed WFMC-1, Bechtel Welding Specification - Welding Filler

Material Control, Rev. 1, to verify that the contractor had established procedures and

instructions for the purchasing, receiving, storing, identifying, disbursing, and handling of

welding filler metals. The inspectors reviewed the contractors procedures to determine

whether they had established procedural controls for the following: (1) environmental

(moisture) control; (2) holding and baking temperatures and out-of-oven exposure times

for covered electrodes; (3) filler metal identification and control; and (4) filler metal

disbursement. The inspectors compared WFMC-1 to the applicable quality requirements

of 10 CFR Part 50, Appendix B; and technical requirements of the ASME Section III

piping code of record.

The inspectors reviewed a sample of welding material purchasing and receiving records

to verify conformance with the applicable quality and technical requirements. The

inspectors reviewed the certified material test reports (CMTRs) for 17 heat/lot numbers

of welding filler metals to determine whether they met the requirements of the ASME

code (ASME Section II - Part C) and the applicable technical requirements prescribed by

the contractors specifications. The inspectors also reviewed these records to determine

whether the traceability of heat/lot numbers for weld filler metals and base materials

were properly recorded on production weld records.

The inspectors observed the issuance of weld filler material from the weld rod issue

room and observed the identification, storage, and handling of welding filler materials.

The inspectors observed these activities to determine whether they were performed in

accordance with WFMC-1.

Welding Procedures

The inspectors reviewed the contractors welding program to determine whether they

had established adequate procedures for the preparation, qualification, distribution, and

revision of WPSs. Specifically, the inspectors reviewed the contractors general welding

requirements for pressure retaining components GWS-1, Bechtel General Welding

Standard, Rev. 2, along with the following four welding procedures:

  • P1-AT-Lh (CVN+10)
  • P1-AT-Lh
  • P8-AT-Ag
  • P8, P1-AT-Ag

The inspectors reviewed the above welding procedures to determine whether they met

the requirements of ASME Section IX, Welding and Brazing Qualification. The

inspectors reviewed these procedures to determine whether they adequately defined the

essential, supplementary essential (for impact toughness), and nonessential variables

for each welding process, as prescribed by ASME Section IX.

For the above welding procedures, the inspectors also reviewed the supporting PQRs

for conformance to ASME Section IX requirements to verify that the procedures were

properly qualified. The inspectors verified that the PQRs were certified by the contractor

and properly listed the essential variables. For each PQR, the inspectors: (1) verified

that the ranges of the essential variables were consistent with those permitted by the

WPS and were within the limits of ASME Section IX; and (2) reviewed the mechanical

25

testing results to verify that they were completed and properly documented in the PQR,

and that the test results met or exceeded the minimum technical requirements.

During the review of the above WPSs, the inspectors verified that any changes or

revisions to the essential or nonessential variables were properly identified, documented,

and supported by requalification (if necessary).

Welder Performance Qualifications

The inspectors reviewed the contractors welding program to determine whether: (1) the

contractor had established adequate procedures for the qualification of welders and

welding operators; and (2) the contractor had established an adequate system to control

the qualification status of welding personnel. Specifically, the inspectors reviewed the

contractors procedure, WQ-1, Welding Performance Qualification Specification [ASME

Section IX], Rev. 2, for conformance to welder qualification requirements prescribed by

ASME Section III and Section IX. The inspectors reviewed six welder performance

qualification records, and compared these records to procedure WQ-1 and ASME

Section IX.

Production Welding

The inspectors reviewed three work packages containing completed weld records for

compliance with the contractors welding program requirements, the applicants ASME

Section III code of record, and 10 CFR Part 50, Appendix B. Specifically, the inspectors

reviewed Field Weld Checklists (WR-5) and associated fabrication and installation

drawings, material traceability documents, ASME code data reports, and NDE reports on

the following welds:

The inspectors reviewed the weld records for the above welds to determine whether: (1)

the welding activity was properly documented on the weld traveler; (2) the weld traveler

appropriately referenced the correct welding procedure; (3) the welding technique and

sequence requirements were specified; (4) the weld traveler established quality control

and authorized nuclear inspector hold points; and (5) the base materials and welding

filler materials were properly identified and traceable to the required test reports and

certifications.

Preheat and Postweld Heat Treatment

The inspectors reviewed the contractors welding program to determine whether the

contractor had established adequate procedures for weld joint preheating and PWHT.

Specifically, the inspectors reviewed the contractors procedure; PHT-1, Bechtel

General Welding Standard, Rev. 2; for the process of localized PWHT. The inspectors

verified that PHT-1 contained requirements for the monitoring and recording of the time

and temperature of the weld joint. The inspectors reviewed this procedure to determine

whether it implemented the applicable ASME Section III requirements for PWHT.

26

The inspectors performed the following samples:

  • IP 55050 Section 02.01 - seventeen heat/lot numbers for welding filler metals
  • IP 55050 Section 02.02 - four welding procedures, with supporting PQRs
  • IP 55050 Section 02.03 - six welder performance qualification records
  • IP 55050 Section 02.04 - three field welding document packages

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The welding program documents reviewed met the requirements of 10 CFR Part 50,

Appendix B; the contractors quality assurance manual; the applicants quality assurance

manual; and the applicants ASME Section III code of record.

C.1.16 Structural Welding General Inspection Procedure (IP 55100)

a. Inspection Scope

The inspectors performed an inspection of applicant activities associated with the

fabrication and repair of safety-related structural steel welds at Watts Bar Unit 2. The

inspectors reviewed the contractors welding program controls for welding fabrication

and weld repair of safety-related structural steel.

The inspectors observed in-process welding, inspected completed structural steel welds,

and reviewed completed weld records. The inspectors compared safety-related welding

activities and records reviewed to the following technical and quality requirements:

  • Bechtel Quality Assurance Manual, Rev. 3 (Section 9, Control of Special

Processes)

  • The applicants quality assurance manual, TVA-NQA-PLN89-A, Rev. 23 (Section

9.3, Control of Special Processes)

Plants and Fuel Reprocessing Plants

  • Watts Bar Unit 2 structural steel welding code of record (American Welding

Society [AWS] D1.1, Structural Welding Code, 1972 edition with Rev. 1-73 and 1-

73.)

Base Material and Filler Material Compatibility for Welding

The inspectors reviewed WFMC-1, Bechtel Welding Specification - Welding Filler

Material Control, Rev. 1, to verify that the contractor had established procedures and

instructions for the purchasing, receiving, storing, identifying, disbursing, and handling of

welding filler metals. The inspectors reviewed the contractors procedures to determine

whether the contractor had established procedural controls for the following: (1)

environmental (moisture) control; (2) holding and baking temperatures and out-of-oven

exposure times for covered electrodes; (3) filler metal identification and control; and (4)

filler metal disbursement. The inspectors compared WFMC-1 to the applicable quality

27

requirements of 10 CFR Part 50, Appendix B; and technical requirements of the AWS

D1.1.

The inspectors reviewed a sample of welding material purchasing and receiving records

to verify conformance with the applicable quality and technical requirements. The

inspectors reviewed the CMTRs for two heat/lot numbers of welding filler metals to

determine whether they met applicable quality and technical requirements. The

inspectors also reviewed these records to determine whether the traceability of heat/lot

numbers for weld filler metals and base materials were properly recorded on production

weld records.

The inspectors observed the issuance of weld filler material from the weld rod issue

room and observed the identification, storage, and handling of welding filler materials.

The inspectors observed these activities to determine whether they were performed in

accordance with WFMC-1. The inspectors also observed the control and handling of

welding material during the welding of safety-related conduit supports to determine

whether they met the requirements of procedure WFMC-1.

Welding Procedures

The inspectors reviewed the contractors welding program to determine whether the

contractor had established adequate procedures for the preparation, qualification,

distribution, and revision of WPSs. The inspectors reviewed the contractors general

welding standard, GWS-Structural, Rev. 1, and a prequalified structural steel welding

procedure for conformance with the AWS D1.1 code of record. Specifically, the

inspectors reviewed the prequalified welding procedure P1-A-Lh (Structural) for

conformance with AWS D1.1.

Welder Performance Qualification

The inspectors reviewed the contractors welding program to determine whether: (1) the

contractor had established adequate procedures for the qualification of welders and

welding operators; and (2) the contractor had established an adequate system to control

the qualification status of welding personnel.

The inspectors reviewed the contractors procedure WQ-2, Bechtel Welding

Performance Qualification Specification [D1.1], Rev. 0, for the qualification of welders,

and compared the procedure to the Watts Bar Unit 2 AWS D1.1 code of record. The

inspectors reviewed three welder performance qualification records to determine

whether welding personnel were qualified in accordance with procedure WQ-2, ASME

Section IX, and AWS D1.1.

Production Welding

The inspectors observed a sample of in-process welding activities associated with

safety-related conduit supports to determine whether: (1) welding procedures, detailed

drawings and instructions, and weld data sheets were readily available to the welder; (2)

the WPS used was appropriate for the weld joint; (3) the welding technique and

sequence requirements were specified; (4) base materials and welding filler materials

were properly inspected, tested, and identified, and were traceable to test reports and

certifications; (5) weld joint geometry was specified and the weld joint surfaces were

properly prepared, cleaned, and inspected; (6) weld fit-up was as specified on the design

28

drawing; (7) welding was performed in accordance with approved welding procedures;

and (8) welders were properly qualified.

The inspectors also reviewed portions of WO 09-954179-023, Fabricate Typical

Supports in the Fabrication Shop to be Installed in WOs under EDCR 54633. During

the review of this WO, the inspectors reviewed a sample of completed weld records to

determine whether the welds met applicable quality and technical requirements.

The inspectors reviewed weld records for the following safety-related conduit support

welds:

  • 995417923-001
  • 995417923-002
  • 995417923-003
  • 995417923-031
  • 995417923-036
  • 995417923-040
  • 995417923-066
  • 995417923-155 FW-2
  • 995417923-156 FW-3
  • 995417923-157 FW-4
  • 995417923-160 FW 7
  • Four support welds (WO 09-954333-01)

The inspectors reviewed the weld records for the above welds to determine whether: (1)

the welding activity was properly documented on the weld traveler; (2) the weld traveler

appropriately referenced the correct welding procedure; (3) the welding technique and

sequence requirements were specified; (4) the weld traveler established quality control

hold points; and (5) the base materials and welding filler materials were properly

identified and traceable to the required test reports and certifications.

Examination and Inspection of Welds

The inspectors independently inspected a sample of safety-related conduit support

welds fabricated on-site by the contractor to determine whether these welds met the

acceptance criteria specified in the AWS-D1.1 code of record. During the inspection of a

sample of fillet welds, the inspectors also compared the following attributes to the AWS

D1.1 code or record: weld surface finish; shape and size of fillet welds; and the absence

of surface defects including cracks, lack of fusion, porosity, and slag.

Specifically, the inspectors observed the following safety-related conduit support welds:

  • 995417923-124
  • 995417923-125
  • 995417923-126
  • 995417923-155
  • 995417923-157
  • 995417923-160
  • 995417923-163
  • 995417923-164
  • 995417923-165

29

  • 995417923-166
  • 995417923-167

The inspectors performed the following samples:

  • IP 55100 Section 02.01 - two samples of lot numbers for welding filler metals
  • IP 55100 Section 02.02 - one sample for a prequalified welding procedure
  • IP 55100 Section 02.03 - three samples of welder performance qualification

records

  • IP 55100 Section 02.04 - seventeen samples (2 in-process welds, 15 completed

weld records)

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The welding program documents reviewed met the requirements of 10 CFR Part 50,

Appendix B; the contractors quality assurance manual; the applicants quality assurance

manual; and the applicants AWS D1.1 code of record. Welding activities observed were

performed in accordance with approved welding procedures. With the exception of

undersized welds identified in Section C.1.3, the completed welds observed by the

inspectors met the acceptance criteria of the contractors inspection procedures and the

AWS D1.1 code of record.

C.1.17 Visual Examination of Safety Related Welds (IP 57050)

a. Inspection Scope

The inspectors reviewed the contractors NDE procedure; VT-ASME III Piping, Bechtel

Nondestructive Examination Standard, Visual Examination, Rev. 1. The inspectors

compared this procedure to the ASME Section III code of record and ASME Section V,

Nondestructive Examination, 1971 edition with addenda through summer 1973.

The inspectors also reviewed the contractors visual examination procedure for safety-

related structural steel VT-AWS D1.1, Bechtel Nondestructive Examination Standard,

Visual Examination, Rev. 1. The inspectors compared this procedure to the AWS code

of record.

The inspectors also reviewed the above procedures to determine whether they were

issued and qualified in accordance with the contractors quality assurance program, and

were reviewed and approved by the authorized nuclear inspector (if required).

The inspectors reviewed the contractors written practice NEPQ, Bechtel Construction

Operations Inc. Nondestructive Examination Standard, NDE Personnel Qualification and

Certification, Rev. 1. The inspectors compared the written practice to the NDE

personnel qualification requirements specified in the ASME Section III code of record.

The inspectors also reviewed the personnel qualification records (visual examination) for

one Level III inspector, for conformance with the requirements of the contractors written

practice.

30

The inspectors performed the following samples:

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The visual examination procedures and NDE personnel qualification records reviewed

by the inspectors met the requirements of 10 CFR Part 50, Appendix B, and the

applicants ASME Section III and AWS codes of record.

C.1.18 Liquid Penetrant Examination of Safety Related Welds (IP 57060)

a. Inspection Scope

The inspectors reviewed the contractors NDE procedure PT (SR)-ASME III Piping,

Bechtel Nondestructive Examination Standard, Liquid Penetrant Examination, Rev. 5.

The inspectors compared this procedure to the ASME Section III code of record and

ASME Section V, Nondestructive Examination, 1971 edition with addenda through

summer 1973.

The inspectors also reviewed the above procedure to determine whether it was issued

and qualified in accordance with the contractors quality assurance program and

approved by the authorized nuclear inspector.

The inspectors also reviewed the personnel qualification records (liquid penetrant

examination) of one Level III inspector for conformance with the requirements of the

contractors written practice.

The inspectors reviewed the following liquid penetrant examination reports to determine

whether they met the requirements of the applicants procedure PT (SR)-ASME III

Piping: PT-022, ASME Section III Class 1, pressurizer spray line, pipe to fitting.

The inspectors performed the following samples:

  • IP 57060 Section 02.03 - two samples (one personnel and one examination

record)

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The liquid penetrant examination procedure and NDE personnel qualification records

reviewed by the inspectors met the requirements of 10 CFR Part 50, Appendix B, and

the applicants ASME Section III code of record.

31

C.1.19 Magnetic Particle Examination of Safety Related Welds (IP57070)

a. Inspection Scope

The inspectors reviewed the contractors NDE procedure MT-ASME, Bechtel

Nondestructive Examination Standard, Magnetic Particle Examination, Rev. 5. The

inspectors compared this procedure to the ASME Section III code of record and ASME

Section V, Nondestructive Examination, 1971 edition with addenda through summer

1973.

The inspectors reviewed the above procedure to determine whether it was issued and

qualified in accordance with the contractors quality assurance program and was

approved by the authorized nuclear inspector.

The inspectors also reviewed the personnel qualification records (magnetic particle

examination) of one Level III inspector for conformance with the requirements of the

contractors written practice.

The inspectors reviewed the following magnetic particle examination reports to

determine whether they met the requirements of the applicants procedure MT-ASME:

In addition to the document review, the inspectors observed magnetic particle (MT)

examination for the completed pipe welds listed below, including review of the

qualification records of examination personnel and review of the applicable measuring

and test equipment calibration records. These welds were on safety-related piping and

part of the ongoing ice condenser drain piping modification activities performed under

WOs 08-956218-025 and 08-956218-038. These welds were ASME Section III Class III

piping welds associated with EDCR 52813, Redesign and Reinstall Ice Condenser Drain

Piping. MT examinations were observed to determine whether they were performed in

accordance with the applicable ASME Boiler and Pressure Vessel Code,Section III.

Specific MT examinations observed included the following:

Weld ID Component

2-061B-T018-09 12-inch diameter pipe weld

2-061B-T028-04 12-inch diameter pipe weld

The inspectors performed the following samples:

  • IP 57070 Section 02.03 - three samples (one personnel and two examination

records)

b. Observations and Findings

No findings of significance were identified.

32

c. Conclusions

The magnetic particle examination procedure and NDE personnel qualification records

reviewed by the inspectors and the magnetic particle examinations observed by the

inspectors met the requirements of 10 CFR Part 50, Appendix B, and the applicants

ASME Section III code of record.

C.1.20 Ultrasonic Examination (UT) of Safety-Related Welds (IP 57080, 73053)

a. Inspection Scope

The inspectors observed phased array UT examination for completed dissimilar metal

welds on nine safety-related control rod drive mechanism (CRDM). A circumferential

and axial scan was performed with both the shear and refracted longitudinal waves. UT

examinations were observed to determine whether they were performed in accordance

with ASME Boiler and Pressure Vessel Code,Section III, 1971 Edition with Addenda

through summer 1973 to verify compliance.

The inspectors reviewed applicant NDE procedure N-UT-87, Generic Procedure for the

Phased Array Ultrasonic Examination of Dissimilar Metal Welds, Rev. 0. For the

examination, the inspectors reviewed the completed NDE reports, the qualification

records of the examination personnel, and observed calibration checks of the UT

equipment. The observed examinations and completed examination reports were

compared with the contractors procedures for UT examination of ASME Code welds.

Specific UT examination was observed for dissimilar metal welds on CRDMs 54, 60, 64,

65, 66, 67, 71, 72, and 73.

Additionally, the inspectors reviewed records of completed observation reports for QA

oversight activities of contractor NDE activities. A list of QA observation reports is

included in the attachment.

The following samples were inspected:

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspectors determined that the observed/reviewed UT examinations met applicable

Code requirements and other regulatory requirements.

E.1 Engineering Activities

E.1.1 Procurement, Receiving, and Storage (IP35065)

a. Inspection Scope

The inspectors reviewed the applicants actions to resolve Bulletin 88-10 for non-

conforming molded case circuit breakers (breakers). The inspectors reviewed the

33

applicants program for commercial grade molded case breakers dedicated under the

QA plan. The inspectors compared observations to references in the Final Safety

Analysis Report, Chapter 3.10 Seismic Design of Category I Instrumentation and

Electrical Equipment, paragraph 3.10.1 Seismic Qualification Criteria based on IEEE

344-1971 or IEEE 344-1975 and IEEE 323-1974 requiring the capability of Class 1E

power equipment to withstand seismic disturbances to be established by seismic

analysis and/or testing of each system component.

b. Observations and Findings

The inspectors identified the following VIO:

Introduction: On April 30, 2010, the inspectors identified a violation with two examples of

10 CFR 50, Appendix B, Criterion III, Design Control, for failure to implement design

control measures that provided for design reviews, calculational methods, and

qualification testing of a prototype unit under the most adverse design conditions and to

review for suitability of application of materials, parts, and equipment.

Description: The applicant installed breakers into the 4 divisions of 120VAC Vital

Instrument Power Boards. The electrical loads in the power boards are safety related

and necessary to shut down and maintain the plant in a safe condition. The following

describes the violation with two examples resulting from the inspectors observations

and review of the records and time line involved in the installation of the breakers.

Example 1: The inspectors found that significant differences existed between the

original qualification mounting and the actual mounting method of the breakers in the

power boards. During the 1992 qualifications testing, (report S522-RP-02) the breakers

were individually mounted to a plate with screws and no front cover. The actual

breakers are mounted in the power boards by clamping 12 breakers with a 36 front

cover against two horizontal angle iron supports in the rear and without additional

screws. The actual mounting method used introduces different shock and random

frequency impacts during a postulated seismic event to the breakers that were not

simulated nor analyzed in the tested mounting method. Additionally, the actual mounting

method exposes the bus bar to additional seismic loading not simulated in the

qualification testing. The front cover plate is held in place with one screw in each corner

and introduces an uncertain clamping pressure across the 12 breakers. The inspectors

determined that the tested breaker mounting did not envelope the mounted condition of

the breakers in the power boards.

Example 2: The inspectors reviewed WO 08-816370-000 used to replace old and add

new breakers into the WBN-2-BD-235-0003 120VAC vital instrument power board. The

inspectors determined the applicant received breakers in which two attributes had been

changed. The depth (Z dimension), a critical characteristic, was reduced and the

auxiliary contact was moved from the outside to the inside of the breakers. The 1992

qualification report indicated a Z dimension of 3.75 and the manufacturers catalog now

indicates 2.609 for the critical characteristic. The applicant recognized that the breaker

with the smaller Z dimension would not mount into the power board. The inspectors

determined that the applicant modified the breaker by attaching a Micarta plate to the

rear of the breaker using 4 nuts and bolts to fit them in the power boards as described in

example 1 without updating the qualification package. The inspectors determined the

applicant did not analyze if any detrimental effects may have been introduced by the

modification, demonstrate an adequate review for suitability of application, or the impact

on other components.

34

The inspectors reviewed calculation WCG-ACQ-1004, Rev. 1, used by the applicant to

demonstrate qualification by analysis. The inspectors verified the calculations purpose

was to qualify the breakers and the calculation concluded the breakers were qualified.

The calculation only determined the power board weight change and the shift in natural

frequency of the power board and its effect on the power board floor anchor bolts.

However, the calculation did not address the breaker performance during a seismic

event. The inspectors determined that the conclusion that the breakers were qualified

was not validated by the calculation.

The inspectors reviewed problem evaluation report (PER) 227786 dated May 10, 2010

for the qualification findings identified by the inspectors. The inspectors determined that

the PER was inadequate. The PER characterized the seismic evaluation calculation

WCG-ACQ-1004, Rev. 1 as having evaluated and addressed the seismic qualification of

the breakers. The inspectors determined the calculation did not address the qualification

of the breakers but rather the qualification of the floor anchor bolts of the power boards.

The PER further stated that the breaker installation was in compliance with the 1992

qualification report S522-RP-02. The inspectors determined that the 1992 seismic

qualification of the breakers did not envelope the breaker mounting method used for the

breakers in the power boards. The 1992 seismic qualification report did not envelope

the breaker mounting method used either before or after the attribute changes imposed

by the manufacturer occurred. The PER stated that the breakers are acceptable and the

integrity of the breakers in the power boards is maintained. No further action was

required by the applicant in the corrective actions of the PER. The inspectors

determined the PER did not address the effects that changes in attributes may impose

on safety, verify the conclusions made in the above calculation, address the qualification

of the breakers, or the different mounting method in the 1992 qualification report. The

inspectors determined the PER failed to adequately address the findings identified and

would not ensure that compliance was restored in a reasonable timeframe or prevent

recurrence in accordance with the enforcement policy. Therefore, the criterion for a non-

cited violation was not met and a Notice of Violation is warranted, requiring a formal

response from the applicant.

Example 1 is more than minor because the finding represents a deviation that, if left

uncorrected, could adversely affect the environmental or seismic qualification of a

component. Example 2 is more than minor because the violation represents an

inadequate process, procedure, or quality oversight function that, if left uncorrected,

could adversely affect the quality of the fabrication, construction, testing, analysis, or

records of a safety-related component. The cause of this finding was directly related to

the decision-making component of the Human Performance cross-cutting area because

the applicant failed to appropriately review safety significant decisions to verify the

validity of the underlying assumptions and identify possible unintended consequences.

H.1 (b) An unresolved item, URI-05000390/2009002-03, was identified on Unit 1 related

to the adequacy of the same seismic qualification report for breakers associated with

station 120VAC Vital Instrumentation Boards.

Enforcement: 10 CFR 50, Appendix B, Criterion III, Design Control, states that

measures shall be established for the review for suitability of application of materials,

parts, and equipment that are essential to the safety-related functions of the structures,

systems, and components (SSCs). The design control measures shall provide for

verifying or checking the adequacy of design, such as by the performance of design

reviews, by the use of alternate or simplified calculational methods, or by the

performance of a suitable testing program. Where a test program is used to verify the

35

adequacy of a specific design feature in lieu of other verifying or checking processes, it

shall include suitable qualifications testing of a prototype unit under the most adverse

design conditions.

Contrary to the above, measures used to review for the suitability of application of

materials, parts, and equipment essential to the safety related functions of molded case

circuit breakers and measures to provide for the verification of checking the adequacy of

design, such as, calculational methods, performing a suitable test program, including

qualifications testing of a prototype unit under the most adverse conditions were not

adequate in that:

1. On October 5, 2009, the applicant installed molded case breakers into the 120VAC

vital instrument power boards, however, the test program used to qualify a prototype

breaker failed to use a suitable mounting method that reflected the most adverse

mounting condition.

2. On September 3, 2009, the applicant failed to perform an adequate review for

suitability of application parts and material used to modify dimensional critical

characteristic in molded case breakers, and further, the applicant failed to verify the

adequacy of design for the modification and the effects on essential safety related

functions of the breakers.

This is identified as violation (VIO) 005000391/2010603-08, Failure to Adequately

Evaluate and Qualify Molded Case Circuit Breakers.

c. Conclusions

The applicant failed to verify the validity of the underlying assumptions and identify

possible unintended consequences resulting from inadequate qualification testing and a

modification to a critical characteristic of the molded case circuit breakers used for safety

related 120VAC power applications.

E.1.2 Engineering Design Activities and Design Control (IPs 35100 and 37055)

a. Inspection Scope

The inspectors reviewed the implementation of design controls and the content of

drawings, specifications, and instructions that had been verified, approved, and issued

for construction. The reviews consisted of document reviews and interviews with

responsible engineering personnel.

The inspectors reviews were conducted to verify the design documents were correctly

incorporated into applicable design inputs, including a site-specific commitment to

maintain fidelity to the associated Unit 1 designs. Inspectors evaluated whether designs

were technically adequate, and that they had been reviewed, verified, approved, and

controlled in accordance with NRC requirements and applicants procedures.

b. Observations and Findings

The inspectors identified the following NCV associated with EDCR 52424, Rev. B,

Replace Level Transmitters for the Safety Injection System Cold Leg Accumulators:

Introduction: A SL IV NCV of 10 CFR 50 Appendix B, Criterion III, Design Control, was

identified by the inspectors for a failure to correctly translate the design basis, as

36

described in a System Description Document, into affected drawings and specifications.

Specifically, a design basis requirement to provide diverse level measurement systems

for the Safety Injection System Accumulators was not correctly translated into affected

specifications and drawings issued for construction.

Description: The inspectors identified that Section 3.3.1 of System Description

Document WBN2-63-4001, Rev.1, Safety Injection System, stated Each CLA [i.e. Cold

Leg Accumulator] is provided with two diverse level measurement systems. Both

systems are used to determine the operational readiness of the accumulators during

steady state operations.

TVA Nuclear Standard Department procedure NEDP-1, Rev. 5, Design Basis and

Design Input Control, Appendix D, identified System Description Documents as a

primary source for defining design inputs.

The drawings and specifications released for construction under EDCR 52424 did not

provide diverse level measurement systems for the Cold Leg Accumulators. Instead, the

design documents provided duplicate level measurement systems. This configuration

also differed from the Unit 1 design which contained diverse level measurement

systems. The inspectors identified that the level measurement systems were required to

implement Technical Specification Surveillance 3.5.1.2, and were classified as Quality-

Related and non-Safety Related.

EDCR 52424 identified that differences existed between Unit 1 and Unit 2 on Attachment

E, EDCR Unit Difference Form. Specifically, the EDCR stated that each accumulator on

Unit 1 was provided a Rosemount Model 1152 DP level transmitter and an FCI Thermal

Dispersion level element; whereas each accumulator on Unit 2 was provided two

Rosemount Model 1153 DD3RB transmitters. Although the EDCR documentation

provided a justification for using a different model Rosemount transmitter on Unit 2 than

installed on Unit 1, it did not provide a basis for specifying a different form and function

of level sensor in comparison to the thermal dispersion devices provided for Unit 1. The

inspectors noted this omission did not comply with a requirement in procedure 25402-

3DPG04G-00081, Engineering Document Construction Release, Section 7.2.4, which

states that every unit difference must contain an evaluation which addresses differences

in form, fit, or function.

The inspectors also noted the EDCR contained a draft Revision to WBN-63-4001,

System Description for Safety Injection System; however, neither the description of the

revision contained in the document nor the marked changes in Section 3.3.1 identified

any intent to change the requirement for diverse level measurement systems.

The violation was determined to be more than minor because the failure to correctly

translate the design requirement from the System Description Document and the failure

to properly evaluate the difference created with the Unit 1 design represented an

improper work practice which could impact the proper functioning of the Safety Injection

System Accumulator level measurement system.

A cross-cutting aspect was identified for this violation which was related to Human

Performance - Work Practices (H.4 (b)). This aspect is applicable in that the applicant

did not effectively communicate expectations regarding procedural compliance and

personnel following procedures.

The applicant issued PER 226246 to address this condition and other concerns with

discrepancies in EDCR Technical Evaluations.

Enforcement: 10 CFR 50 Appendix B, Criterion III, Design Control, requires, in part, that

measures are to be established to correctly translate the design basis into affected

37

drawings and specifications. TVA Nuclear Standard Department procedure NEDP-1,

Design Basis and Design Input Control, identifies System Description Documents as a

primary source for defining design inputs.

Contrary to the above, on May 21, 2010, the inspectors identified that the applicant failed

to correctly translate a requirement for a diverse level measurement system into design

drawings and specifications issued for construction under EDCR 52424, as specified in

System Description Document WBN2-63-4001, Safety Injection System.

This finding was determined to be a SL IV violation using Supplement II of the

Enforcement Policy. Because this was a SL IV violation, and because it was entered

into the corrective action program under PER 226246, this violation is being treated as a

NCV consistent with Section VI.A of the NRC Enforcement Policy: NCV

5000391/2010603-09, Failure to Correctly Translate the Design Basis into Affected

Specifications and Drawings Issued for Construction.

c. Conclusions

The inspectors determined that, in most cases, design drawings, specifications, and

instructions were developed in accordance with NRC and applicant requirements.

Design documents were provided specific approvals for differences that were created

between the Unit 2 design and the Unit 1 design. However, one violation was identified

where a requirement to provide diverse level measurement systems for Safety Injection

System Cold Leg Accumulators was not correctly translated into design documents.

T.1 Training and Qualification of Plant Personnel

T.1.1 Craft Training (IPs 51051 and 64051)

a. Inspection Scope

The inspectors observed a classroom training session for electrical craft personnel.

Specifically, the inspectors observed containment CONEX penetration and Kapton

insulated conductor familiarization in accordance with vendor technical document

WBN-VTD-C515-0060, Installation Manual for CONEX Electrical Conductor Seal

Assemblies. The training session included discussions on installation and repair of

Kapton insulated conductors.

The inspectors also observed classroom fire watch training. The inspectors reviewed

the associated procedures and lesson plans, and held discussions with the instructors.

The training highlighted selected portions of TVA procedure SPP-10.11, Control of

Ignition Sources (Hot Work).

Samples inspected are as follows:

b. Observations and Findings

No findings of significance were identified.

38

c. Conclusions

TVAs program for training of newly hired personnel relating to repair or installation of

CONEX Penetration Seals and Kapton Insulated Conductors and training for hot work

fire watches was adequate for the current level of construction activities being

performed.

T.1.2 Engineering Organization Training (IP 35960)

a. Inspection Scope

The inspectors observed a classroom training session for engineering personnel.

Specifically, the inspectors observed Introduction to ASME Code for Design Engineers.

The training session was intended to be an introduction on use of the ASME Class III

Code by engineering design personnel. Additional future training on ASME Code

requirements would be required.

Samples inspected are as follows:

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

The inspection results are too limited to support a conclusion at this time.

III. Operational Readiness Activities

F.1 Fire Protection (IP 64051)

a. Inspection Scope

The inspectors conducted a walk-down of TVAs established fire protection/prevention

controls for Unit 2 and inspected hot work activities inside the Unit 2 reactor building.

Inspectors observed fire watches and verified that fire suppression devices were

available at or near the location of the hot work activities. The inspectors interviewed fire

watch personnel to verify knowledge of responsibilities as fire watches. The inspectors

also verified that hot work permits were posted at the location of any hot work and that

appropriate signoffs had been completed in the associated work control documents.

The inspectors also verified that the assigned fire watches had current training and

appropriate qualifications. The inspectors observed fire prevention aspects associated

with welding activities. Specific documents reviewed are listed in the attachment.

The following samples were inspected:

39

b. Observations and Findings

No findings of significance were identified.

c. Conclusions

TVA implemented adequate fire protection measures and controls to support Unit 2

construction activities and minimize impact on Unit 1 operation activities.

IV. Other Activities

OA.1.1 (Discussed) Quality Assurance Corrective Action Program (TI 2512/28, IPs 50075,

51065, 51055, 52055)

a. Inspection Scope

Background: The QA Records Corrective Action Program (CAP) was developed in the

mid-1980s after TVA determined that required QA records were:

  • Not retrievable in a timely manner or were missing
  • Not maintained in proper storage
  • Incomplete, technically, or administratively deficient

The applicant has taken various actions to correct previously identified records

deficiencies. These actions included:

  • Ensuring adequate storage and retrievability
  • Resolving quality and technical problems
  • Ensuring programs were established to prevent recurrence of previous record

problems

TVA selected a sample size of 124 records for each of the ANSI/ASME N45.2.9, 1974,

Appendix record types for Unit 2 and utilized an accepted statistical sampling

methodology (95/95). NRC Safety Evaluation Reports (SERs) dated June 9, 1992, and

September 8, 2009, approved the sampling methodology used by the applicant.

The inspectors reviewed the applicants implementation of the QA Records CAP.

Specifically, the inspectors reviewed the results of sample assessments performed by

the applicant in several areas to verify resolution of previously identified problems with

retrievability, storage, and completeness and to resolve quality and technical problems.

Additionally, the inspectors performed an independent sample selection of 47 records

which were shown on the applicants Engineering Construction Monitoring and

Documentation (ECM&D) database as active records for the following QA record types:

Mechanical Records (23 records)

  • Valves (7 records)
  • Mechanical Equipment (5 records)
  • Piping (5 records)
  • Ductwork (6 records)

40

Electrical/Instrument Records (24 records)

  • Cables (6 records)
  • Electrical Equipment (8 records)
  • Instrument Subassemblies (4 records)
  • Electrical Instruments (6 records)

Specific QA records and applicant sample assessment reports reviewed are listed in the

attachment.

The following samples were inspected:

b. Observations and Findings

No findings of significance were identified. The applicant was able to produce each of

the above requested QA records from the Unit 2 records vault. The inspectors reviewed

the original records and determined that the records were legible and complete.

The inspectors verified that TVA had adequately reviewed an appropriate size sample of

each record type for mechanical and electrical/instrument records. Record-related

discrepancies were properly identified and entered into the Corrective Action Program as

appropriate. The applicant had not yet completed all planned QA record sample

assessments at the end of the inspection period. Future QA record sample

assessments are planned for various civil, welding and system cleanliness record types.

c. Conclusions

The actions performed to resolve the issues associated with the QA Records CAP for

Unit 2 mechanical and electrical/instrument records were found to be adequately

planned and implemented. Additional NRC review of future applicant QA record

assessments will be needed prior to closure of this CAP.

OA.1.2 Corrective Action Plans and Special Programs Reviews (TI 2512/017, 025)

The inspectors held discussions with both TVA and Bechtel engineering and licensing

personnel regarding the actions planned to resolve the issues associated with the Cable

Tray and Cable Tray Supports CAP, TI 2512/017, and HVAC Duct and Supports, CAP TI

2512/025. The initial meeting associated with these CAPs was held during previous

inspection periods; however, the inspectors reviewed applicable documentation to plan

future inspections in these areas.

41

The actions discussed covered the following areas as applicable:

  • Walk-downs
  • Engineering
  • Construction
  • Testing

The purpose of these discussions was for the inspectors to gain an understanding of the

actions required to close the subject CAPs, in order to help them develop inspection

plans and preliminary inspection schedules. Actual inspection activities associated with

CAPs and SPs performed during this reporting period are discussed elsewhere in this

report and contain the appropriate observations and findings.

OA.1.3 (Closed) Electrical Issues CAP Sub-issue: Adhesive Backed Cable Support Mount

(TI 2512/020, IP 51063)

a. Inspection Scope

The inspectors reviewed the applicants actions to resolve the Electrical CAP Sub-Issue,

Adhesive Backed Cable Support Mount, to confirm that the applicants program complies

with all commitments and NRC requirements. The inspectors reviewed calculations,

specification (G-38), EDCR, drawings, documentation of walk downs, and inspected a

number of control panels in the Unit 2 Control Room.

b. Observations and Findings

No findings of significance were identified. The inspectors determined that all adhesive

backed cable support mounts have been removed and replaced with cable ties and Ty-

rap clamps to maintain separation inside panels and control cabinets to provide the

physical restraint required by the specifications. The inspectors verified that redundant

divisional train safety-related cables inside selected Main Control Room cabinets were

placed in braided sleeves as called out in the specifications.

c. Conclusions

This inspection concluded that concerns pertaining to the electrical CAP sub-issue, on

adhesive backed cable mount supports, have been appropriately addressed for Watts

Bar Unit 2.

OA.1.4 (Discussed) Cable Issues CAP Sub-Issue: Computerized Cable Routing System

Software and Database Verification and Validation (TI 2512/016)

a. Inspection Scope

The inspectors reviewed the applicants actions to resolve the Cable CAP Sub-Issue,

Computerized Cable Routing System (CCRS) software and database verification and

validation and to evaluate related activities to confirm that the applicants program

complies with all commitments and NRC requirements. The inspectors reviewed

documentation and scheduling to inspect signal tracing field activities associated with

this sub-issue. The inspectors interviewed responsible design personnel and reviewed

the Environmental Qualification Cable Walkthroughs that establishes the schedule for

signal tracing field activities. Anomaly tables and action listings were reviewed to

establish reasonable assurance that data transfer from CCRS to ICRDS has been

verified.

42

b. Observations and Findings

No findings of significance were identified. The applicant replaced CCRS with ICRDS

and transferred the data, which included Unit 1 and 2 cables, to the new system. The

inspectors determined that the applicant verified and validated the transfer of data into

ICRDS in accordance with TVA QA procedures. Part of the Unit 2 verification

methodology will be to signal trace all Environmental Qualification (EQ) and Appendix R

cables that are shown as installed in ICRDS, but do not have pull cards available

(missing QA records). The purpose of the signal trace is to verify the routing and lengths

of cables for comparison with information in ICRDS. Observations of signal tracing

activities are discussed in Section C.1.6.

Conclusions

The inspectors determined that further inspection will be required to verify acceptable

completion of the CAP Sub-Issue, ICRDS software and database verification and

validation.

OA.1.5 (Discussed) Station Blackout (SBO) Rule Procedures and Actions (TI 2515/120)

a. Inspection Scope

The inspectors reviewed design activities associated with implementation of the SBO

requirements for Unit 2. The inspectors examined planned and in-process actions to

confirm Unit 2 actions paralleled the actions implemented on Unit 1 and to determine

whether the Unit 2 actions were technically valid, and were implemented in accordance

with NRC and applicant requirements.

The inspectors interviewed the responsible engineering representatives to determine the

applicants status toward completion of the SBO rule requirements. The inspectors

reviewed design calculations EPMMA041592 Rev. 10, SBO Coping Evaluation, to

determine the applicants required SBO time period and actions necessary to cope with

an the event. Additionally, the inspectors reviewed EDQ00023620070003 Rev. 5, 125V

DC Vital Battery System Analysis, to determine the adequacy of the applicants 125V

DC batteries and chargers.

b. Observations and Findings

No findings of significance were identified. The inspectors interviews and reviews of

design calculations determined that the applicant has not completed the as-built design

calculations, procedures, and action requirements. The applicants intent is to parallel

Unit 1 SBO requirements.

c. Conclusions

The inspectors determined that further inspection will be required to verify acceptable

completion of SBO procedures and processes.

OA.1.6 (Discussed) Non-cited Violation NCV-391/2008-010-01 Corrective Action for

Failure to Document a Cable Raceway Separation Non-conforming Condition.

a. Inspection Scope

The inspectors reviewed documentation, performed an independent walk down, and

interviewed responsible personnel related to the Unit 2 corrective action plan associated

with NCV-391/2008-010-01 for failure to document non-conforming cable raceways.

The inspectors reviewed PER 158979 to determine the corrective action plan taken by

the applicant. The inspectors reviewed walk down procedure WDP-GEN-1 package

43

number LSWDP-430 to determine the extent of condition found by the applicant. The

inspectors performed an independent walk down of a portion of the facility to verify the

adequacy of the applicant findings. The inspectors interviewed engineering personnel

responsible for implementing the extent of condition walk down to determine the

synthesis of the corrective action plan and extent of condition.

b. Observations and Findings

No findings of significance were identified.

The inspectors independent walk down and interviews with applicant personnel

determined that corrective actions were adequate with the exception of non safety

raceways associated with safety race ways and conduits and their traceability between

divisions, which could not be verified.

c. Conclusions

The inspectors determined that further inspection will be required to verify acceptable

closure of the NCV. The inspection of the associated raceways could not be completed

during this inspection.

OA.1.7 (Closed) NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power

Cable Failures that Disable Accident Mitigation Systems or Cause Plant

Transients.

a. Inspection Scope

The inspectors reviewed the TVAs actions in response to GL 07-01 including Response

Letter dated September 7, 2007 - Attachment 22 identifying the extent of the scope

covering 24 pump feeder cables. The inspectors reviewed ICRDS cable reports on

safety-related control cables running underground to address similar concerns of

disabling accident mitigating systems. The inspectors reviewed wiring diagram drawings

and conduit & grounding detail drawings associated with the underground control cables.

b. Observations and Findings

This generic issue identified that cables, qualified for 40 years through the equipment

qualification program, were failing at several nuclear stations prior to the end of their

qualified life. In an effort to address this issue, the NRC published Generic Letter 2007-

01. At Watts Bar Nuclear Plant, twenty of the 24 feeders that fall under this category are

either Unit 1 or are common to both units and are already in service. The remaining four

feeders are the Unit 2 Condenser Circulation Water (CCW) pump non safety-related

cables that the applicant has scheduled for testing prior to fuel load. Based on the

results of this inspection, this GL is closed for Unit 2.

c. Conclusions

Based on the results of this inspection, Generic Letter 2007-01 is closed for Unit 2. The

only four remaining feeder cables left as part of the response to the generic letter are the

Unit 2 CCW pump feeders, which are non safety-related and are scheduled to be tested.

OA.1.8 (Discussed) Inspection of Watts Bar Nuclear Plant Master Fuse List Special

Program (TI 2512/037)

a. Inspection Scope

The inspectors reviewed design activities associated with implementation of the Master

Fuse List (MFL) Special Program for Unit 2. The inspectors evaluated planned and in-

process activities to confirm Unit 2 actions paralleled the actions implemented on Unit 1;

44

and to determine whether the Unit 2 actions were technically valid and were

implemented in accordance with NRC and applicant requirements. The inspectors

interviewed responsible design personnel and reviewed documents related to the Unit 2

implementation plan. The information was compared to actions taken on Unit 1 as

described in the Watts Bar SER (NUREG 0847), the Watts Bar Nuclear Performance

Plan, and the Watts Bar Unit 1 CAPs/SPs Closure Book.

b. Observations and Findings

The Unit 2 implementation plans were found to be generally consistent with the scope of

the Unit 1 MFL Special Program.

The inspectors made the following observations about the key elements of the Unit 2

Special Program:

1) Establishment and maintenance of a field-verified Master Fuse List

Consistent with the Unit 1 Special Program, the inspectors found that

requirements for Unit 2 fuses were formally defined in Design Criteria WB-DC-30-

05, WB-DC-30-27, and WB-DC-30-28. The design criteria were applicable to

both units and were controlled according to TVA Nuclear procedure NEDP-1,

Design Basis and Design Input Control.

A review of EDCRs 52324, 54796, and 54798 determined that design

engineering had developed coordinated fuse applications and had specified fuse

types, fuse sizes, and fuse ratings. The requirements were formally input into a

master list of fuses (i.e. Fuse Tabulations) in the Master Equipment List (MEL).

The inspectors review of EDCR 52324 verified that, consistent with Unit 1,

vendor-supplied fuses were controlled in the MEL for those instances where the

fuses were credited for protection of safety-related items. A review of TVA

procedure SPP-9.6, Master Equipment List, verified the control of the MEL

information system was guided by a written procedure, and was applicable to

both Unit 1 and Unit 2.

A review of TVA Operations procedure OPDP-7, Fuse Control, verified that

controls had been established to maintain correct fuse configurations after

equipment turnover from construction. The controls were applicable to both Unit

1 and Unit 2.

The inspectors noted that the Unit 1 program called for field walk-downs by the

applicant to verify correct installations of Special Program fuses; however,

interviews with responsible applicant personnel indicated that the construction

project had not yet progressed to the point where the fuses have been installed.

Thus, the applicant had not yet implemented plans to field-verify the correct

installation of fuses on Unit 2. Further, interviews with responsible applicant

personnel indicated the fuse tabulations in the MEL will not be appended to the

permanent equipment information system (MAXIMO) until after the as-installed

fuse configurations are verified.

2) Correction of deficiencies with misapplication of Bussmann KAZ actuators

The inspectors review of electrical calculations WBNEEBEDQ00299920080019

and WBNEEBMSTI0070005 verified that the applicant has identified applications

using KAZ actuators and, consistent with Unit 1, has specified replacement fuses

that were electrically coordinated with the associated distribution systems.

Requirements for the replacement fuses were formally input to the Fuse

Tabulations of the MEL as documented in EDCR 54798.

45

The inspectors interviews with responsible applicant personnel indicated that the

construction project had not progressed to the point where replacement fuses for

KAZ actuators could be physically installed on Unit 2. Accordingly, the applicant

was not ready to field-verify the correct installations of replacement fuses as

done under the Unit 1 Special Program.

3) Correction of deficiencies with redundant protection for electrical penetration

assemblies.

The inspectors review of calculation WBNEEBEDQ00299920080019 verified the

calculation specified redundant protection for electrical penetration assemblies to

prevent damage from fault currents or overload conditions. The calculation

documented that the analyzed configurations were based upon reviews of as-

designed drawings and ultimately were to be compared to as-constructed or

configuration controlled drawings. The inspectors determined that the analyzed

capabilities of the penetration assemblies were documented and demonstrated to

be able to withstand the analyzed fault currents. Also, the calculation

demonstrated the coordination of electrical protection devices associated with the

penetration assemblies. The inspectors determined that the requirements for the

electrical penetration assembly fuses were formally input to the Fuse Tabulations

of the MEL as documented in EDCR 54798.

Because the construction project had not progressed to the point where the new

fuse configurations have been installed, inspectors did not perform a verification

of correct installation.

c. Conclusions

The inspectors determined that the activities committed for the MFL Special Program are

still in process and will require further inspection to verify acceptable completion. In this

inspection, the inspectors obtained sufficient samples to verify that a master list of fuses

was being configured in the MEL; however, the permanent fuse list had not been

updated. Inspectors verified that provisions have been made to replace KAZ actuators,

and that design requirements have been developed to provide redundant protection of

electrical penetration assemblies. However, the applicant had not yet installed the

Special Program fuses on Unit 2, and had not conducted field verifications of the as-

installed configurations. Further inspection will be required to verify effective

implementation and completion of the Special Program.

OA.1.9 (Discussed) NRC Bulletins 74-15, Misapplication of Cutler-Hammer Three

Position Maintained Switch Model No. 10250T; 75-03, Incorrect Lower Disc

Spring and Clearance Dimension in Series 8300 and 8302 ASCO Solenoid

Valves; and 75-06, Defective Westinghouse Type OT-2 Control Switches

a. Inspection Scope

The inspectors reviewed the responses from the applicant regarding all three NRC

Bulletins. The inspectors reviewed historical NRC inspection reports, response letters,

and tracking records. The inspectors interviewed TVA engineers responsible for

compliance with the individual bulletins to understand what activities had been

performed. The documents reviewed in response to each of the NRC Bulletins were:

1)Bulletin 74-15; the inspectors reviewed NRC inspection reports 50-390/75-5 and 50-

391/75-5, response letter T90 080128 001, and tracking record NCO080008070.

2)Bulletin 75-03; the inspectors reviewed NRC inspection reports 50-390/75-6 and 50-

391/75-6, response letter T90 080128 001, and tracking record NCO080008030.

46

3)Bulletin 75-06; the inspectors reviewed NRC inspection reports 50-390/85-25 and

50-391/85-20, response letter T02 080320 001, and tracking record 10187136.

b. Observations and Findings

No findings of significance were identified.

The inspectors made the following observations about each electrical component and

system:

1) Interviews conducted by the inspectors with TVA and Bechtel engineers, responsible

for compliance with this bulletin, revealed that TVA plans to replace existing Cutler-

Hammer model 10250T switch with the new Eaton 10250T switch and to

environmentally qualify existing Eaton 10250T switches.

2) Discussions with licensing and engineering personnel overseeing compliance to

Bulletin 75-03 revealed that the intent was to replace all associated valves instead of

modification.

3) The original applicant response letter for Bulletin 75-06 stated that the only action

would be to inspect these switches. Licensing and engineering personnel indicated

that the applicant will be refurbishing functional control switches and replacing

inadequate control switches.

In all three cases the applicant has not yet prepared design modification packages for

this work.

c. Conclusions

The inspectors determined that the activities committed to correct the misapplication of

the Cutler-Hammer three position switches, incorrect lower disc spring and clearance

dimension in Series 8300 and 8302 ASCO solenoid valves, and defective Westinghouse

Type OT-2 control switches are still in process and will require further inspection to verify

acceptable completion.

OA.1.10 (Discussed) NRC Bulletin 76-02, Relay Coil Failures - General Electric Type HFA,

HGA, HKA, and HMA Relays

a. Inspection Scope

The inspectors reviewed the response from the applicant regarding NRC Bulletin 76-02,

Relay Coil Failures - GE Type HFA, HGA, HKA, and HMA Relays. The inspectors

reviewed the applicants response letter T02 080320 001 and tracking record 10187197.

The inspectors interviewed the TVA and Bechtel engineers responsible for compliance

with this bulletin to understand what activities had been achieved.

b. Observations and Findings

No findings of significance were identified. The responsible engineer for this effort

informed the inspectors that 14 of these relays were safety-related and that the entire

population would be replaced with the current version of the same relay.

c. Conclusions

The inspectors determined that the activities committed to correct relay coil failures for

GE type HFA, HGA, HKA, HMA relays are still in process and will require further

inspection to verify acceptable completion.

47

OA.1.11 (Discussed) Violation 391/86-02-01; Failure to Follow Procedures that Resulted in

Improperly Installed Solenoid Valves

a. Inspection Scope

The inspectors reviewed the response from the applicant regarding NRC Violation 86-

02-01, 10 CFR 50, Appendix B, Criterion V, Failure to Follow Procedures. The

inspectors reviewed the historical NRC reports 50-390/86-02 and 50-391/86-02, as well

as the applicants response letter to Violation 86-02-01, tracking record NCO860152003,

and PER 143711. The inspectors interviewed the TVA and Bechtel engineers

responsible for resolution of this violation to understand what activities had been

achieved.

b. Observations and Findings

No findings of significance were identified.

Actions required to resolve this violation for Unit 2 have not been completed. An

updated response to the violation dated June 12, 1995 sent to the NRC (Applicant

tracking number T04950612145 - WATTS BAR NUCLEAR PLANT (WBN) - REVISED

RESPONSE TO VIOLATION 50-390, 391/86-02-01, FAILURE TO FOLLOW

PROCEDURE AND REVISED FINAL REPORT FOR CDRs 50-390/85-52 AND 50-

391/86-14) outlined the proposed solution to modify the solenoid valve mounts to

become compliant through vendor-approved instructions or justification to use as-is.

c. Conclusions

The inspectors determined that the activities committed to correct this violation have not

been performed and will require further inspection to verify acceptable completion.

OA.1.12 (Discussed) Inspection of Watts Bar Nuclear Plant Radiation Monitoring System

Special Program (TI 2512/041)

a. Inspection Scope

The inspectors reviewed design activities associated with implementation of the

Radiation Monitoring System (RMS) Special Program for Unit 2. The inspectors

examined planned and in-process actions to confirm Unit 2 actions paralleled the actions

implemented on Unit 1; and to determine whether the Unit 2 actions results were

technically valid, and were implemented in accordance with NRC and applicant

requirements. The inspectors interviewed responsible design personnel and reviewed

program documentation related to the Unit 2 implementation plan. The information was

compared to actions taken on Unit 1 as described in the Watts Bar SER (NUREG 0847),

the Watts Bar Nuclear Performance Plan, and the Watts Bar Unit 1 CAPs/SPs Closure

Book.

b. Observations and Findings

The Unit 2 activities were found to be generally consistent with the scope of the Unit 1

RMS Special Program.

The inspectors made the following determinations about the key elements of the Unit 2

Special Program:

1) Establishment and maintenance of formally defined design criteria

The inspectors review of RMS Design Criteria, WB-DC-40-24, determined the

document implemented the Special Program commitment to formally define RMS

design requirements and to incorporate the requirements of NRC Regulatory

Guide 1.97. The design criteria were applicable to both units. In addition,

48

inspectors found that design criteria documents were controlled according to TVA

Nuclear procedure NEDP-1, Design Basis and Design Input Control.

2) Correction of deficiencies with RMS sample lines

Design actions to correct deficiencies with radiation monitoring system sampling

lines were still in process. No samples were yet available for NRC inspection.

3) Correction of deficiencies with RMS hardware

The inspectors evaluated design measures for the Main Steam Line Radiation

Monitors as defined in EDCR 2-52342. Consistent with the Special Program

actions implemented for Unit 1, the Unit 2 EDCR and its supporting calculations

were found to define range and accuracy requirements in accordance with the

specifications for Type E variables contained in NRC Regulatory Guide 1.97.

The EDCR documented that the Unit 2 design had no equipment differences or

operating differences with Unit 1. Inspectors noted a companion design change,

Design Change Notice (DCN) 51154, was incorporated into the EDCR that

changed the radiation monitors reset logic following loss of power to the

monitors. The design change was appropriately justified, was reviewed and

approved by designated authority, and was applied to both units.

Interviews with responsible management indicated the procurement of the Main

Steam Line Radiation Monitors was still in process, and the monitors have not yet

been received or installed.

No other designs for Special Program radiation monitors were issued at the time

of this inspection.

4) Correction of omissions in documenting calibrations of RMS devices

Actions to correct deficiencies with documenting primary calibrations of radiation

monitor were still in process. No samples were available for NRC inspection.

c. Conclusions

The inspectors determined that the activities committed for the RMS Special Program

were still in process and will require further inspection to verify acceptable completion.

The inspectors verified that formal design criteria had been established for the Unit 2

radiation monitoring system. The inspectors reviewed one of the Special Program

measures to correct hardware deficiencies. No significant issues were identified;

however, further inspection will be required to evaluate correct installation of design

features. Also, additional reviews of hardware designs will be required to determine

acceptable implementation of this element of the RMS Special Program. The Special

Program elements associated with deficient sample lines and primary calibrations were

still in process and not available for inspection. Further inspection will be required to

verify effective implementation of the Special Program.

OA.1.13 (Discussed) Applicant Actions on Three Mile Island (TMI) Action Items

a. Inspection Scope

The inspectors reviewed Unit 2 design activities associated with TMI Action Items and

for the following electrical components and systems: 1) Acoustic Monitoring Valve

position indication, 2) emergency power for pressurizer heaters, 3) power supplies for

pressurizer relief valves, block valves, level indicators, and 4) emergency power

associated with coolant pump seals. Unit 2 design activities associated with hydrogen

igniter backup power were also reviewed for consistency with Generic Safety Issue-189

49

(GI-189) requirements. The inspectors assessed whether TMI or GI-189 actions

including NRC requirements and SAR commitments were properly translated into

drawings, design change packages, procedures, and other electrical component design

documentation and whether the design was adequately controlled.

The inspectors observed and evaluated storage activities and conditions for electrical

components to determine whether components were stored in the proper storage level

designation, properly identified, and that storage environmental conditions and

requirements were controlled and monitored as specified by the applicable manufacturer

specification. The inspectors reviewed applicant and contractor monitoring activities to

determine if they were being performed in accordance with procedural requirements.

The inspectors reviewed documentation received with components relative to quality

requirements to assure manufacturer requirements were met.

The inspectors reviewed storage procedure, Bechtel Field Material Storage Control No.

25402-PRO-0007, to determine if it provided a means to assure that proper storage

environments were established for various types of electrical components and met

applicable storage classification levels regardless of location of stored component.

The inspectors reviewed design drawings and documents and interviewed responsible

design personnel related to this inspection scope. The design information was reviewed

for actions taken on Unit 2 required in NUREG 0737, Clarification of TMI Action Plan

Requirements. The Unit 2 planned or in-process activities were also compared to

actions taken on Unit 1 as a result of the TMI requirements to determine whether the

Unit 2 actions were technically valid and were implemented in accordance with NRC and

applicant requirements.

Additionally, the inspectors evaluated actions planned or in-process for the following TMI

Action Items: Noble Gas Monitors (TMI II.F.1.2.A), Iodine Particulate Sampling (TMI

II.F.1.2.A), Containment High Range Monitoring (TMI II.F.1.2.C), and In-Plant Radiation

Monitoring (TMI III.D.3.3).

b. Observations and Findings

No findings of significance were identified.

The inspectors made the following observations about each electrical component and

system:

1) Valve Position Indication of Acoustic Monitoring on PORVs (TMI Action Item

II.D.3)

The inspectors reviewed EDCR 52409, Replacement of Equipment required for

Unit 2 Acoustic Monitoring system. Since Unit 1 has already completed the

required TMI Actions, the Unit 2 design parallels Unit 1. Types of new

components that were installed in Unit 1 are planned to be installed in Unit 2 per

EDCR 52409. The inspectors determined that the design change package was in

accordance with Procedure SPP-9.3, Plant Modification & Engineering Change

Control, and design changes were technically valid.

The design had not progressed to the point of installation of the Acoustic

Monitors on Unit 2. Therefore, the inspectors were unable to verify the correct

installation of Acoustic Monitor level indication components on Unit 2.

Procurement documentation for Acoustic Monitors and electrical components

(PO#: 00049277) was reviewed for adherence to manufacturers storage

specifications and applicant requirements. Five samples of electrical

components were inspected for proper storage in the warehouse. The electrical

components were stored in the proper storage level designation and were

50

properly identified by the correct labels, part numbers, and serial numbers on the

receipt inspection label. Storage conditions and requirements were controlled

and monitored as specified by the applicable specification and manufacturer, and

in-place storage requirements were satisfied.

2) Emergency Power for Pressurizer (PZR) Heaters (TMI Action Item: II.E.3.1) /

Power Supplies for PZR Relief Valves, Block Valves, & Level Indicators (TMI

Action Item: II.G.1) / Power from Emergency Diesel Generator on Reactor

Coolant Pump seals (TMI Action Item: II.K.3.25)

According to the drawings, the design for Unit 2 PZR heater emergency power,

power supplies for PZR relief and block valves, level indicators, and power from

emergency diesel generator for reactor coolant pump seals is identical to the Unit

1 design. TMI actions, NRC requirements and SAR commitments were properly

translated into design drawings for adequate control and installation of electrical

components. Through interviews with responsible applicant personnel, the

inspectors determined that there was no other design documentation to review

because there were no planned design change activities taking place on the Unit

2, and the design had not progressed to the point of installation on Unit 2.

Therefore, the inspectors were unable to verify the correct installation of the PZR

heater components on Unit 2.

3) Back-up Power for Hydrogen Igniters (GI-189 and TI 2515/174)

The inspectors reviewed EDCR 52348, complete installation/refurbish of

Hydrogen Mitigation System in Unit 2. The inspectors determined that the design

change package was in accordance with Procedure SPP-9.3, design changes

were technically valid, and the Unit 2 design of hydrogen igniters parallels Unit 1.

New hydrogen igniters will be installed on Unit 2 per EDCR 52348.

Procurement documentation for Hydrogen Igniters and electrical components

(PO#: 00070570) was reviewed for adherence to manufacturers storage

specifications and applicant requirements. Two samples of electrical

components were inspected for proper storage in the warehouse. The electrical

components were stored in the proper storage level designation and were

properly identified by the correct labels, part numbers, and serial numbers on the

receipt inspection label. Storage conditions and requirements were controlled

and monitored as specified by the applicable specification and manufacturer, and

in-place storage requirements were satisfied.

The design of the backup power supply for hydrogen igniters per GI-189 and TI

2515/174 commitments could not be verified from design documentation

reviewed for Unit 2. The inspectors determined, from interviews with the

applicant, that Unit 1 has developed procedures to support the temporary

connection of a backup power supply to hydrogen igniters; however, the Unit 2

design activities have not progressed to incorporate any of the GI-189

requirements into the Unit 2 design, or to the point of installation of the hydrogen

igniters.

c. Conclusions

The inspectors determined that the activities committed to for the previously mentioned

TMI actions and GI-189 requirements are still in process or not available for review, and

will require further inspection to verify acceptable completion. Inspectors were able to

obtain sufficient samples of electrical components to verify that storage requirements

were met and manufacturer specifications were followed. Design packages and/or

51

drawings were also verified for adherence to SAR commitments and requirements. On

each system, the applicant had not yet installed the necessary components on Unit 2 in

accordance with TMI actions and GI-189, so further inspection will be required to verify

effective implementation and completion of the TMI Action Items and GI-189

commitments.

V. Management Meetings

X.1 Exit Meeting Summary

On July 13, 2010, the resident inspectors presented the inspection results to Mr. Masoud

Bajestani and other members of his staff. Although some proprietary information may

have been reviewed during the inspection, no proprietary information was included in

this inspection report..

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Applicant personnel

C. Ankeny, Quality Assurance Manager, PCI Energy Services

G. Arent, Licensing Manager, Unit 2

M. Bajestani, Vice President, Unit 2

M. Bali, Electrical Design Manager, Bechtel

R. Baron, Nuclear Assurance Project Manager, TVA, Unit 2

D. Beckley, Electrical Design Manager, Bechtel

T. Moran, MELB and MIC Special Program Owner

B. Briody, Maintenance and Modifications Manager, TVA, Unit 2

B. Crouch, Lead Mechanical Engineer, TVA, Unit 2

M. Das, Principal Engineer, Bechtel

L. Davenport, Contracts/Procurement Manager, TVA, Unit 2

M. Easter, Westinghouse Joint Test Team Manager

R. Esnes, Engineering Manager, Washington Group, Inc

T. Franchuk, Quality Manager, Bechtel

E. Freeman, Engineering Manager, TVA, Unit 2

W. Goodman, Procurement Manager, Bechtel

J. Hannah, Corrective Action Coordinator, Bechtel

D. Helms, Lead Engineer CAPs & SPs, TVA, Unit 2

S. Hilmes, Lead Electrical Engineer, TVA, Unit 2

M. Lackey, ECP Rep, TVA, Unit 2

I. Khan, Electrical Engineer, Bechtel Design

R. Kuhn, Quality Assurance Manager, Bechtel

D. Malone, Quality Assurance, TVA, Unit 2

J. Mitchell, Field Procurement Manager, Bechtel

J. Moseley, Westinghouse Site Director

D. Myers, Quality Assurance Manager, TVA, Unit 2

B. Newton, General Manager- Welding Technology and Programs, PCI Energy Services

J. Robertson, Engineering Manager, Bechtel

S. Sawa, Training Manager, Bechtel

J. Schlessel, Construction Manager, TVA, Unit 2

P. Theobold, Radcon Supervisor, TVA, Unit 2

D. Tinley, Quality Assurance, TVA, Unit 2

R. White, Radiography Level III

Attachment

2

INSPECTION PROCEDURES USED

IP 35007 Quality Assurance Program Implementation During Construction

IP 35060 Licensee Management of QA Activities

IP 35065 Procurement, Receiving, and Storage

IP 35100 Review of QA Manual

IP 35960 QA Program Evaluation of Engineering Organization

IP 37002 Construction Refurbishment Process - Watts Bar Unit 2

IP 37055 Onsite Design Activities

IP 46053 Structural Concrete - Work Observation

IP 48053 Structural Steel and Supports Work Observation

IP 49053 Reactor Coolant Pressure Boundary Piping - Work Observation

IP 49055 Reactor Coolant Pressure Boundary Piping Record Review

IP 49061 Safety-Related Piping - QA Review

IP 49063 Safety-Related Piping - Work Observation

IP 50075 Safety-Related Components - Records Review

IP 50090 Pipe Support and Restrain Systems

IP 51051 Electrical Components and Systems - Procedure Review

IP 50053 Reactor Vessel and Internals Work Observation

IP 51055 Electrical Components and Systems - Record Review

IP 51061 Electrical Cable - Procedure Review

IP 51063 Electric Cable - Work Observation

IP 51065 Electric Cable - Record Review

IP 52051 Instrument Components and Systems - Procedure Review

IP 52053 Instrument Components and Systems - Work Observation

IP 52055 Instrument Components and Systems - Record Review

IP 51053 Electrical Components and Systems Work Observation

IP 55050 Nuclear Welding General Inspection Procedure

IP 55100 Structural Welding General Inspection Procedure

IP 57050 Visual Testing Examination

IP 57060 Liquid Penetrant Testing Examination

IP 57070 Nondestructive Examination Procedure Magnetic Particle Examination Procedure

Review/Work Observation/Record Review

IP 57080 Nondestructive Examination Procedure Ultrasonic Examination Procedure

Review/Work Observation/Record Review

IP 57090 Nondestructive Examination - RT

IP 64051 Procedures - Fire Prevention/Protection

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 73055 Preservice Inspection Data Review and Evaluation

IP 92701 Followup

TI 2512/015 Inspection of Watts Bar Nuclear Plant Employee Concerns Program

TI 2512/016 Plant Cable Issues Corrective Action Program

TI 2512/018 Inspection of Watts Bar Nuclear Plant Electrical Conduit and Supports Corrective

Action Program Plan

TI 2512/020 Plant Electrical Issues Corrective Action Program

TI 2512/024 Inspection of Watts Bar Nuclear Plant Heat Code Traceability Corrective Action

Program Plan

TI 2512/025 Inspection of Watts Bar Nuclear Plant HVAC Duct and Supports Corrective

Action Program Plan

3

TI 2512/028 QA Records Corrective Action Program

TI 2512/037 Inspection of Watts Bar Nuclear Plant Master Fuse List Special Program

TI 2512/041 Inspection of Watts Bar Nuclear Plant Radiation Monitoring System Special

Program

TI 2515/174 Hydrogen Igniter Backup Power Verification

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

2010603-01 NCV Marking and Segregation of nonconforming

materials from accepted materials available for use

(Section Q.1.3)

2010603-02 NCV Inadequate storage and improper control of

documents used in safety related activities (Section Q.1.3)

2010603-03 NCV Failure to invoke 10 CFR Part 21 in safety related

procurement documents (Section Q.1.3)

2010603-04 NCV Undersized pipe support welds (Section C.1.3)

2010603-05 NCV Inadequate corrective actions for non-conforming

safety-related concrete (Section C.1.4)

2010603-06 URI Material Condition inside loop-3 RCS crossover

piping (Section C.1.8)

2010603-07 NCV Failure to Protect Safety-Related Welds, Piping,

and Components During Construction Activities (Section

C.1.9)

2010603-08 VIO Failure to adequately evaluate and qualify molded

case circuit breakers (Section E.1.1)

2010603-09 NCV Failure to correctly translate the design basis into

affected specifications and drawings issued for

construction (Section E.1.2)

Discussed

2512/018 TI QA Records CAP (Section OA.1.1)

2512/016 TI Cable Issues CAP Sub-Issue: Computerized Cable

Routing System (CCRS) Software and Database

Verification and Validation (Section OA.1.4)

2515/120 TI Station Blackout (SBO) Rule Procedures and

Actions (Section OA.1.5)

4

2008-010-01 NCV Corrective action for failure to document a cable

raceway separation non-conforming condition (Section

OA.1.6)

2512/037 TI Inspection of Watts Bar Nuclear Plant Master Fuse

List Special Program (Section OA.1.8)

74-15 BL Misapplication of Cutler-Hammer Three Position

Maintained Switch Model No. 10250T (Section OA.1.9)

75-03 BL Incorrect Lower Disc Spring and Clearance

Dimension in Series 8300 and 8302 ASCO Solenoid

Valves (Section OA.1.9)

75-06 BL Defective Westinghouse Type OT-2 Control

Switches (Section OA.1.9)

76-02 BL Relay Coil Failures - General Electric Type HFA,

HGA, HKA, and HMA Relays (Section OA.1.10)

86-02-01 VIO Failure to Follow Procedures that Resulted in

Improperly Installed Solenoid Valves (Section OA.1.11)

2512/041 TI Inspection of Watts Bar Nuclear Plant Radiation

Monitoring System Special Program (Section OA.1.12)

Closed

2512/020 (Partial) TI Electrical Issues Corrective Action Program - Sub-

issue Adhesive Backed Cable Mount Supports CAP

Electrical Sub-issue (Section OA.1.3)

2007-01 GL Inaccessible or Underground Power Cable Failures

that Disable Accident Mitigation Systems or Cause Plant

Transients (Section OA.1.7)

5

LIST OF DOCUMENTS REVIEWED

I. Quality Assurance Program

Q.1.1 Identification and Resolution of Construction Problems

Procedures/Programs

25402-MGT-0003, Corrective Action Program, Rev. 5

Bechtel Oversight/Self-Assessment Documents

QA Surveillance Report 25402-WBN-SR-10-0932, NDE - Liquid Penetrant (PT) by Ivey Cooper

QA Surveillance Report 25402-WBN-SR-10-0958, NDE - Magnetic Particle (MT) by Ivey

Cooper

QA Surveillance Report 25402-WBN-SR-10-0960, Eye exam records of project QC personnel

Q.1.3 Procurement, Receiving, and Storage Inspection

Procedures/Programs

25402-000-GPP-0000-N6104, Materials Receiving, Rev. 4

25402-MGT-0003, Corrective Action Program, Rev. 7

CLS.QPP.03.001, TVA Central Laboratories Services, Corrective Action, Rev. 1

CLS.QPP.03.002, TVA Central Laboratories Services, 10 CFR Part 21 Reporting Requirements,

Rev. 1

IGA-2, Intergroup Agreement TVA Nuclear and Fossil Power Group, Rev. 4

IGA-11, Intergroup Agreement with Central Laboratories Services, Rev. 0001

SPP-4.3, Material Storage and Handling, Rev. 0006

Watts Bar Unit 2 Construction Completion Project, Project Nuclear Quality Assurance Manual,

Rev. 5

Audits

25402-WBN-AR-09-0004, Bechtels Internal Audit of Procurement, Supplier Quality, and

Subcontractors, Rev. 0

Procurement Documents

25402-000-FMR-JV01-00071, Field Material Requisition (FMR) for Diaphragm, Actuator, QA

1for Valve WBN-2-PCV-003-0183, Rev. 0

MEL Package No. 10EMC3072, Component Update Request for EDCR 53276, dated

04/06/2010

PEG PKG No. FMR-JV01-00011 M0, Technical Evaluation for Diaphragm, Aux Feedwater

Turbine Pressure Reducing Valve WBN-2-PCV-003-0183, Rev. 0

PEG PKG No. CPT802W, Procurement Data Sheet (PDS) for Diaphragm, Actuator, QA 1for

Valve WBN-2-PCV-003-0183, Rev. 0

PO 28498, Welding Consumables, Tape, Insulation, QA 2, Rev. 0

PO 22993-1, Pipe and Fittings, ASME III, for Auxiliary Feedwater System, Rev. 1

PO 32815 -1, Valve, Solenoid (Nuclear), Rev. 1

6

PO 33205, Breakdown Orifices for Aux Feedwater, Orifice Assembly, ASME Section III, Class 3,

QA 1, Rev. 0

PO 37189, Relay, QA 1, Order Date: 10/29/2010

PO 42199-2, Main Steam Safety Valves, Refurb., ASME Section III, Rev. 2

PO 54795, Fuses, Holder, QA 2, Order Date: 12/08/2009

PO 59120, Valves, Fittings, Bolt Studs, QA 2, Rev. 0

PO 63534, Snubber, Hydraulic, QA 1, for Steam Generators, Rev. 0

PO 80513, Diaphragm, QA 1, Order Date: 02/24/2010

PO 87607, Limit Switch, ARMS, for Actuator, QA 2, Rev. 0

PO 87844, Electrical, Push Buttons, Etc., QA 1, Rev. 0

PO 92806, Valve, Fittings, ASME, QA 1, Rev. 0

Problem Evaluation Reports

PER 224697, New MRs Generated for Issued EDCRs, Reported Date: 04/12/2010

PER 225712, Increased Activity in Project Trend Code M.1 - Procurement of Material, Reported

Date: 04/19/2010

II. Management Oversight and Controls

C.1.3 Pipe Support and Restraint Systems (IP 50090, 46071, and TI 2512/023 )

TVA Work Order 08-957282-001

Drawing Rev. Authorization 52897-005

C.1.4 Structural Concrete (IP 46053)

TVA Procedure MAI-5.10 Concrete Placement, Surface Preparation, Placing, Finishing, Curing,

and Testing, Rev. 5

TVA Procedure MAI-5.4 Concrete Removal, Repair, Grouting, and Dry Packing, Rev. 11

TVA Walk-down Procedure WDP-GEN-1 General Walk-down Requirements, Rev. 13

Service Request 180764, Concrete Mixing and Placement Violations

C.1.5 Safety-Related and RCS Pressure Boundary Piping Records Review (IPs 49055

and 49065, TI 2515/024)

Procedures/Programs

Bechtel Procedure 25402-3DP-G06G-00001, Material Requisitions, Rev. 6

Bechtel Procedure 25402-000-GPP-0000-N6204, Field Material Control and Traceability, Rev. 7

Bechtel Procedure 25402-3DP-G06G-00010, Specifying and Evaluating Supplier Quality

Management System or Quality Assurance Program Requirements, Rev. 2

Bechtel Procedure 25402-PRO-0002, Purchase Order Formation, Rev. 3

Bechtel Procedure 25402-3DP-G06G-00012, Supplier Deviation Disposition Requests, Rev. 3

Bechtel Procedure 25402-3DP-G04G-00082, Interface with the TVA Boundary Information

Transmittal Process, Rev. 3

TVA procedure SPP-4.1, Procurement of Material, Labor, and Services, Rev. 23

TVA Procedure NEDP-8, Technical Evaluation for Procurement of Materials and Services, Rev.

14

TVA Procedure NGDC-PP-6, Completion of TVA Partial ASME Section III N-5 Data Reports,

Rev. 5

7

Purchase Orders

Contract 74C38-83015, Principal Piping Systems, 11/19/1975

Corrective Action Documents

PER 228857, ASME Code Class Not Properly Recorded in WO 08-952876-000, 05/11/2010

PER 228824, Missing FME Cover, 05/11/2010

PER 228845, Procedure Enhancement Regarding Requirements for CMTRs, 05/11/2010

Miscellaneous

Watts Bar Unit 2 ASME N-5 Database

Watts Bar Unit 2 Heat Code Traceability Closure Implementation Plan

25402-011-YDA-PB02-00002-001, Evaluation of Flange Supplied to 1995 Code Edition,

08/05/2009

25402-011-YDA-JXF0-00002-001, Evaluation of Fittings Supplied to 1995 Code Edition,

08/13/2009

WO 08-952876-000, Remove Non-Code Pipe and Replace with Code Pipe, 01/07/2009

BIT 371 for TVA Partial N-5 No. TVA-2-62-1-P9, Rev. 2

BIT 841 for TVA Partial N-5 No. TVA-2-03-2-P6, Rev. 0

Weld No. 2-068A-T037-05 ASME Material Certification Package

Weld No. 2-068A-T037-06 ASME Material Certification Package

Weld No. 2-068A-T037-07 ASME Material Certification Package

Weld No. 2-068A-T037-08 ASME Material Certification Package

Weld No. 2-068A-T037-16 ASME Material Certification Package

Weld No. 2-062B-T342-10 ASME Material Certification Package

Weld No. 2-062B-D136-11 ASME Material Certification Package

Weld No. 2-062B-D136-11B ASME Material Certification Package

Weld No. 2-063A-T013-02 ASME Material Certification Package

Weld No. 2-063B-T082-06 ASME Material Certification Package

Weld No. 2-068G-T013-02 ASME Material Certification Package

Weld No. 2-062B-T328-01 ASME Material Certification Package

Weld No. 2-062A-T019-04A ASME Material Certification Package

Weld No. 2-062A-T036-03 ASME Material Certification Package

Valve 2-3-845 ASME Material Certification Package

C.1.7 RPV Internals and Protection of Installed Plant Equipment during Construction

Activities (IP 50053)

Service Request 180764, Concrete Mixing and Placement Violations

Service Request 182224, Liquid Penetrant Exam in Reactor Vessel

C.1.8, C.1.9, C.1.10, C.1.11, C.1.12, C.1.13, C.1.14, C.1.15, C.1.16, C.1.17, C.1.18, C.1.19,

C.1.20 Collective section documentation)

Procedures

TVA-NQA-PLN89-A, Tennessee Valley Authority Nuclear Quality Assurance Program, Rev. 23

25402-000-GPP-0000-N3701, Unit 2 Construction Completion Project Procedure (CCPP),

Welding Program, Rev. 3

25402-000-GPP-0000-N3705, Welding and NDE Documentation and Records Management,

Rev. 2

25402-000-GMX-GCE-00001, Watts Bar Unit 2 Construction Completion Project, Special

8

Processes Manual, Rev. 1

25402-000-4MP-T040-S0036, Bechtel Welding Standard, Documentation of Welds, WD-1, Rev.

6

25402-000-4MP-T040-S0012, Bechtel General Purging Standard, GPS-1, Rev. 1

25402-000-4MP-T040-S0013, Bechtel General Welding Standard, GWS-1, Rev. 2

25402-000-4MP-T040-S0021, Bechtel General Welding Standard, GWS-Structural, Rev. 1

25402-000-4MP-T040-S00038, WFMC-1, Bechtel Welding Specification - Welding Filler

Material Control, Rev. 1

25402-000-4MP-T040-S0078, WQ-1, Bechtel Welding Performance Qualification Specification

[ASME Section IX], Rev. 2

25402-000-4MP-T040-S0079, WQ-2, Bechtel Welding Performance Qualification Specification

[D1.1], Rev. 0

25402-000-4MP-T040-S0030, PHT-1, Bechtel General Welding Standard, Rev. 2

25402-000-4MP-T040-S0165, NEPQ, Bechtel Construction Operations Inc. Nondestructive

Examination Standard, NDE Personnel Qualification and Certification, Rev. 1

25402-000-4MP-T040-S0131, VT-ASME III Piping, Bechtel Nondestructive Examination

Standard, Visual Examination, Rev. 1

25402-000-4MP-T040-S0133, VT-AWS D1.1, Bechtel Nondestructive Examination Standard,

Visual Examination, Rev. 1

25402-000-4MP-T040-S0125, PT (SR)-ASME, Bechtel Nondestructive Examination Standard,

Liquid Penetrant Examination, Rev. 5

25402-000-4MP-T040-S0124, MT-ASME, Bechtel Nondestructive Examination Standard,

Magnetic Particle Examination, Rev. 5

25402-000-4MP-T040-S0049, Bechtel Technical Specification for Welding Filler Metal, WM-

E7018(CVN), Rev. 1

25402-000-4MP-T040-S0066, Bechtel Technical Specification for Welding Filler Metal, WM-

ER70S-2(CVN), Rev. 1

25402-000-4MP-T040-S0068, Bechtel Technical Specification for Welding Filler Metal, WM-

ER70S-6 (CVN), Rev. 1

TVA-NQA-PLN89-A, Tennessee Valley Authority Nuclear Quality Assurance Program, Rev. 23

25402-PRO-0007, Field Material Storage Control, Rev. 2

Bechtel Project Nuclear Quality Assurance Manual, Rev. 6

N-UT-78, PDI Generic Procedure for the Manual Ultrasonic Examination of Reactor Pressure

Vessel Welds PDI-UT-6, Rev 0005

N-PT-9, Liquid Penetrant Examination of ASME and ANSI Code Components and Welds, Rev

0033

EPRI-DMW-PA-1, Procedure for Manual Phased Array Ultrasonic Examination of Dissimilar

Metal Welds, Rev. 1

NPG Nondestructive Examination Procedure N-UT-87, Generic Procedure for the Phased Array

Ultrasonic Examination of Dissimilar Metal Welds, Rev. 0

Work Orders (WOs)

WO 10-951203-000, Cut-Out and Remake Weld 2-068A-D145-02 C0R0

WO 09-954333-001, Modification of Pipe Supports on the Component Cooling System in the

Reactor Building under EDCR 52526

WO 09-954179-023, Fabricate Typical Supports in the Fabrication Shop to be Installed in Work

Orders under EDCR 54633

WO 08-956218-021, Install New Drain Piping and Fittings for Lower Ice Condenser Bay #1 and

Reinstall Flapper Valve 2-CKV-61-913 System 061 under EDCR 52813

9

WO 10-951028-000, Rework weld by removing linear indication and have inspected and

accepted.

Bechtel Welding Procedure Specification

P1-AT-Lh (CVN+10)

P1-AT-Lh

P8-AT-Ag

P8-P1-AT-Ag

P1-A-Lh (Structural)

NDE Reports

MT-058, ASME Class III

MT-064, ASME Class III

PT-022, ASME Class 1

R-P0240, Penetrant - ASME Class 1

R-P0970, Penetrant - ASME Class 2

R-P0992, Visual - ASME Class 1

R-P0993, Magnetic Particle - ASME Class 2

R-P0994, Magnetic Particle - ASME Class 2

R-P0996, Magnetic Particle - ASME Class 2

TVA Radiographic Examination Report for acceptance of weld 2-068C-W004-01, 10/28/08

TVA-WPNP NDE Evaluation Data Sheet Radiographic No. 2-1228, 5/19/88

PERs and Service Requests

PER 212696

PER 219039

PER 222093

PER 222236

PER 214589

PER 166624

PER 236720

PER 236733

Service Request 166386

Service Request 167044

Other

NRC Inspection Report 50-390/91-32

NRC Inspection Report 50-390, 391/91-23

NRC Inspection Report 50-390/78-05 and 50-391/78-04

Preservice Inspection Program Plan Watts Bar Nuclear Plan Unit 2, WBN-2 PSI Rev. 3

NGDC PP-15, Watts Bar Unit 2 ASME Section XI, Rev 0

Watts Bar Unit 2 Red Lined FSAR Sections 5.2.8, 5.4.4.4, and 6.6

PDI RPV Manual Detection PDI-UT-06 Table 1 and Table 2, Rev 15

Performance Demonstration Qualification Summary No. 621, PDI-UT-06, Rev G, Addenda 0

NDE UT Examination Report R-P1028, Welds CRDW-60, CRDW-64, CRDW-65, CRDW-72,

CRDW-73

10

NDE UT Examination Report R-P1029, Welds CRDW-54, CRDW-60, CRDW-62, CRDW-64,

CRDW-65, CRDW-66, CRDW-67, CRDW-72, CRDW-73

III. Operational Readiness Activities

F.1 Fire Protection

Procedures and Standards

SPP-10.9, Control of Fire Protection Impairments, Rev. 3

SPP-10.11, Control of Ignition Sources (Hot Work), Rev. 3

IV. Other Activities

OA.1.1 QA Records CAP

Procedures

TVA Construction Engineering Procedure CEP-1.40-3, Universal System Program, Rev. 2

TVA QA Record Sample Assessment Reports

Records Assessment, Mechanical Valves, April 2010

Records Assessment, Mechanical Equipment, April 2010

Records Assessment, Mechanical Ductwork, April 2010

Records Assessment, Mechanical Piping, April 2010

Records Assessment, Electrical Cables, April 2010

Records Assessment, Electrical Equipment, April 2010

Records Assessment, Electrical Instrument Subassemblies, April 2010

Records Assessment, Electrical Instruments, April 2010

Corrective Action Documents

PER 233454, ASME/Hanger inspection records cannot be retrieved in timely manner

Other

Engineering Construction Monitoring and Documentation (ECM&D) database

Mechanical Records

Valve, 0-067-DA-V-RTV-825B, Test 70A

Valve, 2-001-NV-V-RTV-290A, Test 70A

Valve, 2-030-RB-V-TV-555, Test 70A

Valve, 2-062-AB-V-FCV-128, Test 73B

Valve, 2-062-AB-V-ISV-537, Test 70A

Valve, 2-063-AB-V-FCV-175, Test 70A

Valve, 2-067-AB-V-TCV-132, Test 70A

Mechanical Equipment, 0-03B-AB-SL-0786A, Test 35A

Mechanical Equipment, 0-041-AB-SL-2014A, Test 01A

11

Mechanical Equipment, 0-082-DIEG-0C1, Test 34A

Mechanical Equipment, 2-I&C-RB-SL-0005, Test 01A

Mechanical Equipment, 2-081-PMP-81-7, Test 33A

Duct, 0-030-DA-D-029, Test 12A

Duct, 2-030-AB-D-141C, Test 11A

Duct, 2-030-RB-BKD-572, Test 13A

Duct, 2-030-RB-BT-TVA4, Test 91A

Duct, 2-030-RB-CT-005, Test 15A

Pipe Segment, 0-018-DA-L-840-2-018, Test 23A

Pipe Segment, 0-067-FB-F-0041, Test 02A

Pipe Segment, 0-067-YD-P-845-5-12, Test 79A

Pipe Segment, 0-067-47W845-5-6-18, Test 50A

Pipe Segment, 2-003-NV-P-803-1-14, Test 23A

Pipe Segment, 2-003-PT-F-0009, Test 28A

Pipe Segment, 2-03B-AB-P-803-3-50, Test 18A

Electrical Records

Cable, 2-2A-62-3624, Test 77A

Cable, 2-2NM-92-100-D, Test 55A

Cable, 2-2NM-92-243-E, Test 77A

Cable, 2-2NM-92-416-F, Test 64A

Cable, 2-3V-1-7611-A,Test 77A

Cable, 2-3V-74-1938-A,Test 77B

Electrical Component, 2-BKR-212-B2/3B-B, Test 67A

Electrical Component, 2-JB-290-2875-D, Test 25B

Electrical Component, 2-JB-293-692-A, Test 61A

Electrical Component, 2-MCCC-213-A1/17E-A, Test 70A

Electrical Component, 2-MTR-61-AHU/07, Test 25A

Electrical Component, 2-PENT-293-14-A, Tests 04A and 64A

Electrical Component, 2-PENT-293-31-G, Test 25A

Instrument Subassembly, 0032JN-042, Test 59A

Instrument Subassembly, 0032LA-A, Test 52A

Instrument Subassembly, 2001AO-001, Test 04A

Instrument Subassembly, 2032BC-042, Test 41A

Electrical Instrument, 2-FCV-62-90-A, Test 47A

Electrical Instrument, 2-FCV-63-118-A, Test 75A

Electrical Instrument, 2-FCV-67-146-A, Test 61A

Electrical Instrument, 2-HS-1-18A-B, Test 61D

Electrical Instrument, 2-HS-3-164A-A, Test 61B

Electrical Instrument, 2-TM-68-65B-E, Test 25A

12

OA.1.6 Non-cited Violation NCV-391/2008-010-01 corrective action for failure to

document a cable raceway separation non-conforming condition.

Walk Down Package

LSWDP-430 Cable Trays for Electrical External Separation Baseline Calculation Program:

Corrective Action for PER 158979

Others

ICRDS QA Report, Cable ID 2PM3870D, 2PM3877E, 2PM3882F, and 2PM3887G; Conduits

2PLC29D, 2PLC62E, 2PLC31E, 2-2PLC-299-23F, and 2-2PLC-299-39G.

OA.1.7 NRC Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable

Failures that Disable Accident Mitigation Systems or Cause Plant Transients.

Others

T90 070911 002, TVA - Watts Bar Nuclear Plant Unit 2 Initial Responses to Bulletins and

Generic Letters dated September 7, 2007.

OA.1.8 Inspection of Watts Bar Nuclear Plant Master Fuse List Special Program

(TI 2512/037)

Design Change Documents

EDCR 52324, Rev. A, Refurbish Solid State Rod Control System Cabinets

EDCR 54796, Rev. A, Install Fuses for Radiation Monitoring System, etc.

EDCR 54798, Rev. A, Install Fuses for 120 VAC Vital AC, etc.

Procedures

SPP 4.1 - Rev. 21

NEDP-1, Rev. 5, (TVA Procedure) Design Basis and Design Input Control

OPDP-7, Rev. 3, (TVA Procedure) Fuse Control

SPP-9.3, Rev. 22, (TVA Procedure) Plant Modifications and Engineering Change Control

SPP-9.6, Rev. 9, (TVA Procedure) Master Equipment List (MEL)

25402-3DP-G04G-0081, Rev. 007, (Bechtel Procedure) Engineering Document Construction

Release

WB-DC-30-5, Rev. 022, (Design Criteria) Power, Control, and Signal Cables For Use in

Category I Structures -- (Unit 1 / Unit 2)

WB-DC-30-27, Rev. 030, (Design Criteria) AC and DC Control Power Systems - (Unit 1 / Unit 2)

WB-DC-30-28, Rev. 20, (Design Criteria) Low and Medium Voltage Power Systems

Others

WBNEEBMSTI070005, Rev. 53, (Calculation) 125V DC Protection and Coordination Calculation

EDQ00299920080019, Rev. 001, (Calculation) Electrical Penetration Protection Study Voltage

Level V3 - Unit 2

CATD 20103-WBN-02, (Concern) Discrepancies Have Been Identified for Electrical Design

Criteria

CATD 23702-WBN-04, (Concern) No Calculations could be found to demonstrate that fuses

provided adequate full range short circuit protection

CATD 23702-WBN-05, (Concern) Circuit breakers with trip settings higher than permitted by

criteria

NCO850160001, (Commitment) Provide redundant tripping devices to protect containment

penetrations

13

OA.1.9 NRC Bulletins 74-15, Misapplication of Cutler-Hammer Three Position

Maintained Switch Model No. 10250T; 75-03, Incorrect Lower Disc Spring and

Clearance Dimension in Series 8300 and 8302 ASCO Solenoid Valves; and 75-06,

Defective Westinghouse Type OT-2 Control Switches

Others

10187136, B 1975-06, Defective Westinghouse Type OT-2 Control Switches Inspect

Westinghouse Type OT-2 control switches, 6 October 2009

T02 080320 001, Dated 20 March 2008

T90 080128 001, Dated 29 January 2008

NCO080008030 (Commitment), B 75-03, Incorrect Lower Disc Spring and Clearance

Dimension in Series 8300 8302 ASCO Solenoid Valves-Modify Valves Not Modified At

Factory, initiated 27 March 2008

NCO080008070 (Commitment), Misapplication of Cutler-Hammer Three Position Maintained

Switch Model No. 10250T, initiated 31 March 2008

OA.1.10 NRC Bulletin 76-02, Relay Coil Failures - General Electric Type HFA, HGA, HKA,

and HMA Relays

Others

T02 080320 001, Dated 20 March 2008

10187197, B 1976-02, Relay Coil Failures - GE Type HFA, HGA, HKA, HMA Relays; Repair

or replace relays before preoperational tests., 6 October 2009

OA.1.11 Violation 391/86-02-01, Failure to Follow Procedures that Resulted in Improperly

Installed Solenoid Valves

Others

NCO860152003 (Commitment), Modify Existing ASCO 8315 Series Valves or Ensure

Justification for Use As-Is is provided

OA.1.12 Inspection of Watts Bar Nuclear Plant Radiation Monitoring System Special

Program (TI 2512/041)

Design Change Documents

EDCR 2-52342, Rev. A, Install Radiation Monitoring Loops in the Unit 2 Auxiliary Building

Procurement Documents

25402-011-MRA-HARA-00001, Rev. 4, (Purchase Requisition) Radiation Monitoring System

(System 90)

Procedures

WB-DC-40-24, Rev. 021, (Design Criteria) Radiation Monitoring (Unit 1/ Unit 2)

Others

WBNAPS3047, Rev. 4, (Calculation) Calibration Factors for the Main Steam Line Radiation

Monitors

WO 08-813772-000 - Field Change

WBNAPS3048, Rev. 19, (Calculation) Instrument Range and Accuracy for Measurement of

Regulatory Guide 1.97 Type E Variables

14

OA.1.13 Applicant Actions on Three Mile Island (TMI) Action Items

Design Change Documents

EDCR 52409, Rev. A, Replacement of Equipment required for Unit 2 Acoustic Monitoring

system

EDCR 52348, Rev. A, Complete installation/refurbish of Hydrogen Mitigation System in Unit 2

EDCR-2 # 55127, Rev. A, - Resolves physical internal cable separation and electrical isolation

breakages identified by Calc EDQ0029992009002 Rev. 0. - dated: 4/20/10

Drawings

2-45W724-3 Rev. 0, Unit 2 6900 Shutdown Board 2A-A Single Line, 12/15/08

2-45W724-4 Rev. 0, Unit 2 6900 Shutdown Board 2B-B Single Line, 12/15/08

2-45W760-68-3 Rev. 1, Unit 2 Reactor Coolant System Schematic Diagrams, 12/15/08

2-45W760-68-4 Rev. 1, Unit 2 Reactor Coolant System Schematic Diagrams, 12/15/08

1-45W724-3 Rev. 23, Units 1& 2 6900 Shutdown Board 2A-A Single Line, 9/22/90

1-45W724-4 Rev. 20, Units 1& 2 6900 Shutdown Board 2B-B Single Line, 9/22/90

1-45W760-68-3 Rev. 12, Unit 1 Reactor Coolant System Schematic Diagrams, 9/22/90

1-45W760-68-4 Rev. 8, Unit 1 Reactor Coolant System Schematic Diagrams, 9/17/90

2-45W751-8 Rev. 1, Unit 2 480V Reactor MOV Bds 2B1-B Single Line SH-2, 12/15/08

2-45W751-3 Rev. 1, Unit 2 480V Reactor MOVE Bds 2A1-A Single Line SH-3, 12/15/08

2-45W760-68-5 Rev. 0, Unit 2 Reactor Coolant System Schematic Diagrams, 12/15/08

2-45W600-68-1 Rev. 1, Unit 2 Reactor Coolant System Schematic Diagrams, 12/11/08

1-45W600-68-1 Rev. 12, Unit 1 Reactor Coolant System Schematic Diagrams, 9/22/90

1-45W760-68-5 Rev. 18, Unit 2 Reactor Coolant System Schematic Diagrams, 9/21/90

1-45W751-3 Rev. 42, Units 1& 2 480V Reactor MOVE Bds 1A1-A & 2A1-A Single Line SH-3,

9/22/90

1-45W751-8 Rev. 26, Units 1& 2 480V Reactor MOV Bds 1B1-B & 2B1-B Single Line SH-2,

9/22/90

1-45W703-1 Rev. 47, Units 1&2 125V Vital Battery Board I Single Line Sh-1, 9/22/90

1-45W703-2 Rev. 36, Units 1&2 125V Vital Battery Board II Single Line Sh-2, 9/22/90

1-45W703-3 Rev. 40, Units 1&2 125V Vital Battery Board III Single Line Sh-3, 9/22/90

1-45W703-4 Rev. 32, Units 1&2 125V Vital Battery Board IV Single Line Sh-4, 9/22/90

2-45W760-68-4 Rev.1, Unit 2 RCS Schematic Diagram, 12/15/08

2-45W760-68-3 Rev.1, Unit 2 RCS Schematic Diagram, 12/15/08

1-45N709-4 Rev.2, Units 1&2 Chargers Inverters and Misc Equip Connections Diagram, SH-4,

6/14/76

1-45W756-2 Rev.69, Units 1&2 480V Cont and Aux Bldg VT BD 1A1-A & 2A1-A Single Line,

SH-2, 9/22/90

1-45W756-6 Rev.74, Units 1&2 480V Cont and Aux Bldg VT BD 1B1-B & 2B1-B Single Line,

SH-2, 9/22/90

2-45W756-2 Rev.0, Unit 2 480V Cont and Aux Bldg VT BD 2A1-A & 2B1-B Single Line, SH-2,

12/15/08

1-45W749-4A Rev.40, Units 2 480V 2B2-B Single Line, 1/29/93

1-45W749-1A, Rev.37, Units 2 480V 2A1-A Single Line, 2/1/93

1-45W749-3A, Rev.38, Units 2 480V 2B1-B Single Line, 1/29/93

2-45W749-4, Rev.2, Units 2 480V 2B2-B Single Line, 12/15/08

2-45W749-1, Rev.1, Units 2 480V 2A1-A Single Line, 12/15/08

2-45W749-3, Rev.1, Units 2 480V 2B1-B Single Line, 12/15/08

2-45W2640, Rev. 1, Unit 2 Wiring Diagram Control Boards Critical Wiring Braid Installation,

08/14/09

15

2-45W2640-1, Rev. 0, Unit 2 Wiring Diagram Control Boards Critical Wiring Braid Installation,

07/14/09

Procurement Documents

25402-011-MRA-HAYS-00001, Acoustic Monitoring Material Requisition

PO# 00070570, Hydrogen Igniter Purchase Order

PO# 00049277, Acoustic Monitoring Purchase Order

25402-011-MRA-EWE2-00012, Hydrogen Igniters Material Requisition

QAR-2375, Qualification Summary Report, Tayco Engineering Inc, Hydrogen Igniter Assembly

Procedures

25402-PRO-0007 Rev.1, Bechtel Field Material Storage Control, 10/9/08

MAI-4.4B Instrument and Instrument panel Installation

Walk Down Package

LSWDP-404 Rev. 0, 2-PNL-99-L116 Internal Separation Walk-down

LSWDP-409 Rev. 0, 0-PNL-278-M26 Internal Separation Walk-down

LSWDP-422 Rev. 0, 2-PNL-278-M9 Internal Separation Walk-down

Others

N3-68-4001, Rev. 0028, TVA, Reactor Coolant System, 8/27/09

WBN2-68-4001, Rev. 0000, TVA, Reactor Coolant System, 7/23/08

PER Service Request # 170923, Drawing Deviation, NRC Identified 1-45W760-68-5, 2-

45W760-68-5, 4/29/10

Problem Evaluation Report (PER) 158979, Cable separation issues not identified during walk

down.

WO 08-951069-001 - CRDR EDCR2 52366 (U1RG Approved) PHASE III, PANEL 2-M-9, WILL

PROCURE, MOUNT, & WIRE ONLY T, June 15, 2010.

16

LIST OF ACRONYMS

10 CFR Title 10 of the Code of Federal Regulations

ANSI American National Standards Institute

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

AWS American Welding Society

BIT Boundary Information Transmittals

CAP Corrective Action Program

CAQ condition adverse to quality

CCRS Computerized Cable Routing System

CET core exit thermocouple

CFR Code of Federal Regulations

CMTR certified material test report

CRDM control rod drive mechanism

DCN design change notice

ECM&D Engineering construction monitoring & documentation

ECP Employee Concerns Program

EDCR engineering document construction release

FE Field Engineer

FPIP fire protection impairment permit

HDR Historical Document Review

IMC Inspection Manual Chapter (NRC)

ICRDS Integrated Cables Raceway Design System

IP Inspection Procedure (NRC)

IR inspection report

MT magnetic particle

NA Nuclear Assurance

NCV non-cited violation

NDE non-destructive examination

NRC Nuclear Regulatory Commission

NRR Nuclear Reactor Regulation (NRC)

NUREG (NRC) technical report designation

PCI PCI Energy Services

PER Problem Evaluation Report

PO purchase order

PSI Pre-Service Inspection

PT Liquid Penetrant Testing (examination)

QA quality assurance

QC quality control

RCP reactor coolant pump

RCS reactor coolant system

RHR residual heat removal

RMS radiation monitoring system

RPV reactor pressure vessel

RT radiograph test (examination)

SCWE safety conscience work environment

SL Severity Level

SP Special Program

SSC structures, systems, and components

SWBP sidewall bearing pressure

17

TI Temporary Instruction (NRC)

TVA Tennessee Valley Authority

UHI upper head injection

URI unresolved item

UT Ultrasonic test

VIO Violation

WBN WBN Nuclear Plant

WBNPP Watts Bar Nuclear Performance Plan

WO work order

Retrieved from "https://kanterella.com/w/index.php?title=ML102170465&oldid=2129575"