IR 05000391/2016603
| ML16127A025 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 05/06/2016 |
| From: | James Baptist Division Reactor Projects II |
| To: | Skaggs M Tennessee Valley Authority |
| References | |
| IR 2016603 | |
| Download: ML16127A025 (35) | |
Text
May 6, 2016
SUBJECT:
WATTS BAR NUCLEAR PLANT UNIT 2 CONSTRUCTION - NRC INTEGRATED INSPECTION REPORT 05000391/2016603
Dear Mr. Skaggs:
On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of construction and testing activities at your Watts Bar Unit 2 reactor facility. The enclosed integrated inspection report documents the inspection results, which were discussed on April 14 2016, with Sean Connors and other members of your staff.
This inspection examined activities conducted under your Unit 2 operating license as they relate to safety and compliance with the Commissions rules and regulations, the conditions of your operating license, and fulfillment of Unit 2 regulatory framework commitments. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, the enclosed report documents one NRC-identified finding which was determined to involve violations of NRC requirements. However, because the finding was a Severity Level IV violation and was entered into your corrective action program, the NRC is treating the violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement Policy.
If you contest the non-cited violation in the enclosed report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTENTION: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Watts Bar Unit 2 Nuclear Plant. In addition, if you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II, and the NRC Resident Inspector at Watts Bar Unit 2 Nuclear Plant. In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have questions concerning this letter, please contact us.
Sincerely,
/RA/
James Baptist, Chief
Reactor Projects Branch 8
Division of Reactor Projects
Docket No. 50-391 License No. NPF-96
Enclosure:
Integrated IR 05000391/2016603 w/ Attachment
REGION II==
Docket No.:
50-391
License No.:
Report No.:
Licensee:
Tennessee Valley Authority (TVA)
Facility:
Watts Bar Nuclear Plant, Unit 2
Location:
Spring City, TN 37381
Dates:
March 1, 2016 - March 31, 2016
Inspectors:
E. Patterson, Senior Resident Inspector, Reactor Projects Branch (RPB) 8, Division of Reactor Projects (DRP), Region II (RII)
J. Eargle, Resident Inspector, RPB8, DRP, RII
R. Monk, Senior Project Inspector, RPB8, DRP, RII (Sections, P.1.3 and SU.1.6)
C. Even, Senior Construction Project Inspector, RPB8, DRP, RII (Section SU.1.5)
Approved by:
James Baptist, Chief
Reactor Projects Branch 8
Division of Reactor Projects
SUMMARY
Watts Bar Nuclear Plant, Unit 2
This integrated inspection included aspects of engineering and construction activities performed by Tennessee Valley Authority (TVA) associated with the Watts Bar Nuclear (WBN) Plant Unit 2 construction project. This report covered a one month period of inspections in the areas of quality assurance (QA), identification and resolution of construction problems, engineering and construction activities, preoperational and startup testing, and follow-up of other activities. The inspection program for Unit 2 construction activities is described in Nuclear Regulatory Commission (NRC) Inspection Manual Chapter (IMC) 2517, Watts Bar Unit 2 Construction Inspection Program. Information regarding the WBN Unit 2 Construction Project and NRC inspections can be found at http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html.
Inspection Results
- The NRC identified one example of a severity level (SL) IV non-cited violation (NCV) of 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, for failure to follow work order instructions associated with the sump inspection surveillance 2-SI-304-2. The surveillance instruction required the identification and documentation of foreign material inside of the safety-related containment sump. The licensee failed to identify the foreign material in the containment sump during the inspection. The inspectors determined this performance deficiency was more than minor in accordance with IMC-2517, Appendix C, because the failure to implement the work order instructions to clean the containment sump represented an improper work practice that could impact safety, involving safety-related structures, systems, or components. The finding was determined to be of very low safety significance in accordance with Section 6.5 of the NRC Enforcement Policy because it did not represent a breakdown in the QA process. This finding had a cross-cutting aspect in the Human Performance cross-cutting area, as defined in IMC 0310, regarding work management. The organization did not implement a process of planning, controlling, and execution of the work activities, such that nuclear safety was the overriding priority. The work process did not include the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities (H.5).
- Other areas inspected were adequate with no findings identified. These areas included QA; pre-operational testing activities; startup testing activities; and various NRC inspection procedures.
TABLE OF CONTENTS
I.
QUALITY ASSURANCE PROGRAM............................................................................... 5 Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure 35007)................................................................................................................... 5 II.
MANAGEMENT OVERSIGHT AND CONTROLS............................................................ 5 C.1 Construction Activities.................................................................................................... 5 C.1.1 Unit 1 and Unit 2 Construction and Testing Activity Interface Controls................. 5 P.1 Preoperational Activities................................................................................................. 5 P.1.1 Preoperational Test Program Implementation Verification (Inspection Procedure 71302)................................................................................................................... 5 P.1.2 Preoperational Test Witnessing (Inspection Procedures 70312 and 70317)........ 7 P.1.3 Preoperational Test Results Evaluation (Inspection Procedure 70400)................ 8 SU.1 STARTUP TESTING ACTIVITIES........................................................................ 9 SU.1.1 Startup Test Procedure Review (Inspection Procedure 72300)............................ 9 SU 1.2 Startup Test Procedure Review (Inspection Procedure 72300).......................... 10 SU 1.3 Startup Test Procedure Review (Inspection Procedure 72300).......................... 11 SU1.4 Startup Test Results Evaluation (Inspection Procedure 72301).......................... 12 SU1.5 Startup Test Results Evaluation (Inspection Procedure 72301).......................... 13 SU.1.6 System Operational Readiness Assessment Inspection (Inspection Procedure 93806)................................................................................................................. 14 III.
OTHER ACTIVITIES....................................................................................................... 16 OA.1.1 (Discussed) Generic Letter 2004-02 - Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors and Pressurized Water Reactor Containment Sump Blockage (Temporary Instruction 2515/166)....................................................................... 16 IV.
MANAGEMENT MEETINGS.......................................................................................... 19 X1 Exit Meeting Summary................................................................................................... 19
REPORT DETAILS
Summary of Plant Status
During the inspection period covered by this report, Tennessee Valley Authority (TVA)performed construction completion as well as preoperational and startup testing activities on safety-related systems and continued engineering design activities of the Watts Bar Nuclear (WBN) Plant, Unit 2.
I.
QUALITY ASSURANCE PROGRAM
Q.1.1 Identification and Resolution of Construction Problems (Inspection Procedure 35007)
a. Inspection Scope
The inspectors continued to review condition reports (CRs), as part of the licensees corrective action program, to verify that issues being identified under the corrective action program were being properly identified, addressed, and resolved by the licensee.
The inspectors reviewed corrective actions for CR 1140303, and 1142428, for the 2B component cooling system (CCS) pump seal leak. During the performance of the CCS two pump test a significant seal leak on the pump inboard seal developed. The inspectors reviewed Work Order (WO) 117605569, the vendor failure analysis, and reviewed the corrective actions, to verify that the licensee replaced the mechanical seal, the corrective actions were adequate, and the seal failure did not invalidate the licensees ability to meet the safety function of the CCS system to support dual unit operations.
The inspectors also reviewed and followed up on the corrective actions of several CRs discussed throughout various sections of this report.
b. Observations and Findings
No findings were identified.
c. Conclusions
The issues identified in the CRs reviewed were adequately identified, addressed, and resolved.
II.
MANAGEMENT OVERSIGHT AND CONTROLS
C.1 Construction Activities
C.1.1 Unit 1 and Unit 2 Construction and Testing Activity Interface Controls
a. Inspection Scope
The inspectors independently assessed licensee controls, associated with Unit 2 testing activities, to prevent adverse impact on Unit 1 operational safety. The inspectors attended routine Unit 1/Unit 2 interface meetings to assess the exchange and sharing of information between the two site organizations. Periodic planning meetings were observed, at least once per week, to assess the adequacy of the licensees efforts to identify those testing activities that could potentially impact the operating unit. This included the review of select testing activities, which the licensee had screened as not affecting Unit 1, to verify the adequacy of that screening effort. Additionally, the inspectors independently assessed select testing activities to verify that potential impacts on the operating unit had been identified and adequately characterized with appropriate management strategies planned for implementation. Furthermore, the inspectors performed independent walkdowns of select testing work locations to verify that controls to protect the operating unit provided an adequate level of protection and had been properly implemented.
Specific work activity observed included work associated with:
- WO 117641714, PMT leak test for ERCW check valve 0-CKV-067-0503G-B Specific work activities that the licensee had screened out as not affecting Unit 1 included, but were not limited to, work activities as noted in this inspection report.
b. Observations and Findings
No findings were identified.
c. Conclusions
Overall, management oversight and controls were in place for the observed preoperational tests and survelliance activities that could potentially impact the operating unit.
P.1 Preoperational Activities
P.1.1 Preoperational Test Program Implementation Verification (Inspection Procedure 71302)
a. Inspection Scope
02.01 (Weekly Inspection Activities): The inspectors verified that the licensees management control system was effectively discharging its responsibilities over the preoperational testing program by facility record review, direct observation of activities, tours of the facility, interviews, and discussions with licensee personnel. Preoperational testing activities during the inspection period included the following systems or portions thereof:
- System 99 - Reactor Protection System (RPS)
- 0 - As systems became available for preoperational testing, inspectors observed the accessible areas of the facility to make an independent assessment of equipment conditions, plant conditions, security, and adherence to regulatory requirements. The inspectors also reviewed the following, as available and on a sampling basis, during the inspections:
- general plant/equipment conditions
- plant areas for fire hazards - examined fire alarms, extinguishing equipment, actuating controls, firefighting equipment, and emergency equipment for operability and also verified that ignition sources and flammable material were being controlled in accordance with the licensee's procedures
- activities in progress (e.g., maintenance, preoperational testing, etc.) were being conducted in accordance with the licensees procedures
- watched for abuse of installed instrumentation such as stepping or climbing on the instrumentation that could affect the calibration or ability to function
- listened for the public address system announcements to determine that blind spots do not exist; (i.e., cannot be heard clearly enough to be understood)
- construction work force was authorized to perform activities on systems or equipment
- looked for uncontrolled openings in previously cleaned or flushed systems or components
02.02 (Monthly Inspection Activities): During this inspection period, the inspectors reviewed the turnover package for the Unit 2 portion of the essential raw cooling water system (ERCW), emergency gas treatment system, auxiliary feedwater system, and safety injection systems as part of procedure PP-37, System Turnover to Operations, Revision (Rev.) 6, to verify jurisdiction controls were appropriate and licensee procedures were followed.
The inspectors reviewed maintenance activities on safety-related equipment WO 117641714, PMT leak test for ERCW check valve 0-CKV-067-0503G-B, to verify that the activities were scheduled in accordance with developed procedures and that these procedures were adequate for the maintenance being performed.
02.03 (Quarterly Inspection Activities): The inspectors reviewed jurisdictional controls to verify that maintenance activities were performed by the proper group and sampled preventative maintenance activities to ensure satisfactory completion. The inspectors also witnessed testing of 2-PTI-99-01 and 2-PTI-99-06 and interviewed personnel to verify that the method for testing was current, that methods existed to assure personnel involved were knowledgeable of the test, that approved change methodologies were followed, that criteria for test interruptions were discussed, and that test deficiencies were properly documented.
b. Observations and Findings
No findings were identified.
c.
Conclusion
The licensees implementation of the preoperational test program was in accordance with procedures for those activities observed during the inspection period.
P.1.2 Preoperational Test Witnessing (Inspection Procedures 70312 and 70317)
a. Inspection Scope
Background: The purpose of preoperational test inspection is to verify through direct observation, personnel interviews, and review of facility records that:
- systems and components important to the safety of the plant are fully tested to demonstrate that they satisfy their design requirements; and
- management controls and procedures, including QA programs, necessary for operation of the facility have been documented and implemented.
Inspection Manual Chapter (IMC) 2513 requires the preoperational test witnessing of the mandatory tests defined in IMC 2513 and five of the primal tests defined in IMC 2513.
The following inspection was performed in relation to satisfying the required preoperational test witnessing.
Inspection Activities: The inspectors witnessed activities associated with the performance of preoperational test procedure 2-PTI-099-01, RPS & ESFAS Response Times, Rev. 0, and 2-PTI-099-06, Reactor Protection Setpoint Verification, Rev. 0, to verify that the testing was conducted in accordance with approved procedures and to verify the adequacy of test program records and preliminary evaluation of test results.
The following surveillance instructions were selected for inspection of this item:
- 2-SI-99-207, WO 117060130, Response Time Test - Input Relays Cycle B, Rev.
- 2-SI-99-208, WO 117060133, Response Time Test - Input Relays Cycle C, Rev.
- 2-SI-3-26, WO 115872482, 18 Month Channel Calibration, Response Time Test AFW Initiation from Main Feedpump Turbine 2B trip, Rev. 1
- 2-SI-3-201-A, WO 115872210, Response Time Test, AFW Pump 2A-A Suction Header Transfer-Train A, Rev. 4
The inspectors assessed the following attributes associated with this test observation:
- all test personnel were on station and had the latest revision of the procedure;
- test prerequisites were performed;
- plant systems were in service to support the test;
- minimum crew requirements were met;
- testing was performed in accordance with the approved procedure;
- test interruptions and continuations were handled in accordance with approved procedures and documented in the chronological test log;
- testing events and discrepancies were properly evaluated and documented in the test deficiency log;
- testing was executed and coordinated properly;
- data was properly collected;
- temporary equipment was installed and tracked appropriately;
- administrative test controls were properly followed; and
- test personnel were using approved drawings and vendor manuals.
The inspectors observed the tests to verify that the overall test acceptance criteria were met. The inspectors conducted a review with the responsible test engineer to assure that the preliminary test evaluations were consistent with the inspectors observations.
During the tests, the inspectors observed important data gathering activities to ensure the data was properly gathered and recorded. A post-test cursory review of the test data was performed to verify legibility, traceability, and permanence of the data sheet entries.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the licensees test procedure was performed in a manner consistent with the guidance of procedure SMP-9, Watts Bar Nuclear Plant Unit 2, Conduct of Test, Rev. 9. The preoperational test witnessing of the RPS and engineered safeguards features actuation system (ESFAS) components are still in progress.
P.1.3 Preoperational Test Results Evaluation (Inspection Procedure 70400)
a. Inspection Scope
Background: IMC 2513, Light Water Reactor Inspection Program - Preoperational Testing and Operational Preparedness Phase, issue date January 1, 1984, purpose is to verify through direct observation, personnel interviews, and review of facility records that:
- systems and components important to the safety of the plant are fully tested to demonstrate that they satisfy their design requirements; and
- management controls and procedures, including QA programs, necessary for operation of the facility have been documented and implemented.
IMC 2513 defines the minimum inspection program for a finding of readiness for license issuance (IP 94300, Status of Plant Readiness for an Operating Licensee). IMC 2513 requires the pre-operational test results review of the mandatory tests defined in IMC 2513 and five of the primal tests defined in IMC 2513. The following inspection was performed in relation to satisfying the required pre-operational test results review.
Inspection Activities: The inspectors performed a detailed review of the results for pre-operational test procedure 2-PTI-070-03, Component Cooling System (CCS) Dual Unit Shutdown Flow Test, Rev. 0, to verify that the licensees evaluation of the procedure performance and results was conducted in accordance with approved procedures. This review was performed to provide assurance that the test data was within the established acceptance criteria and the licensees methods for identifying and correcting deficiencies were adequate. The inspectors performed the following activities associated with this test results review:
- Reviewed all changes made to the test procedure to verify they were properly annotated, did not affect the objective of the test, and were performed in accordance with administrative procedures.
- Reviewed all documented test deficiencies to verify they had been properly resolved, reviewed, and accepted.
- Reviewed the test summary and evaluation to verify that the system was evaluated to meet design requirements and acceptance criteria.
- Reviewed the original as-run copy of the test to verify completion of data sheets, calculations and signatures/initials.
- The approval of the test results was reviewed for completeness with respect to the acceptance of the test results.
The inspectors reviewed the test results to verify that the overall test acceptance supported the ability of the component cooling system to meet all of the requirements of General Design Criteria V. The inspectors conducted a review with the responsible test engineer to assure that the test evaluation was performed in accordance with established procedures.
Documents reviewed are listed in the Attachment.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the licensees test procedure results were reviewed, evaluated, and accepted in a manner consistent with the guidance of procedure SMP-10.0, Watts Bar Nuclear Plant Unit 2 Packaging and Processing Test Results, Rev. 6.
This completes the test results evaluation of pre-operational test procedure 2-PTI-070-
03.
SU.1 STARTUP TESTING ACTIVITIES
SU.1.1 Startup Test Procedure Review (Inspection Procedure 72300)
a. Inspection Scope
Background: The purpose of IMC 2514, Light Water Reactor Inspection Program - Startup Testing Phase, issue date August 21, 1989, is to verify that the licensee is meeting the requirements and conditions of the facility license for precritical tests, initial fuel loading, initial criticality, low-power testing, and power ascension tests. This verification is to be achieved through reviewing procedures and records, direct observation, witnessing tests, reviewing test data, and evaluating test results.
Inspection Activities: The inspectors reviewed test procedure 2-PAT-1.4, Pipe Vibration Monitoring, Rev. 1, to verify that the test procedure adequately addressed NRC requirements and licensing commitments outlined in the final safety analysis report (FSAR), docketed correspondence, safety-evaluation report (SER), Technical Specifications (TS), and Regulatory Guide 1.68. Additionally, the inspectors reviewed power ascension test procedure 2-PAT-1.4 to verify that the procedure contained the following administrative good practice attributes:
- the title described the purpose of the procedure;
- the cover page had appropriate information and approval signatures;
- procedure format is consistent with Regulatory Guide 1.68, Appendix C;
- a clear statement of procedure purpose/objectives;
- planning information such as prerequisites, precautions, required tools, reference documents, and coordination requirements;
- acceptance criteria were clearly identified and evaluated against the source of the comparison of results with acceptance criteria;
- adequate initial test conditions were specified;
- the procedure included a section listing references to appropriate FSAR sections, TS, drawings, specification, codes, and other requirements;
- signoff requirements including concurrent and independent verification steps established where appropriate;
- actions to be taken within the steps were specifically identified;
- provisions were made for recording details of the conduct of the test, including observed deficiencies, their resolution, and retest;
- procedure provided for identification of personnel conducting the testing and evaluating the test data;
- the procedure as issued was consistent with the test description provided in the FSAR;
- special precautions for personnel and equipment safety were specified;
- detailed instructions specified testing over the full operating range and under the maximum anticipated load change of the system/component; and
- provisions were made for the data taker to indicate the acceptability of the data.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that 2-PAT-1.4, Pipe Vibration Monitoring, was written in a manner consistent with the guidance of procedure 2-TI-438, Watts Bar Nuclear Plant Unit 2 Power Ascension Test Program, Rev. 5. This completes the procedure review of power ascension test procedure 2-PAT-1.4, Rev. 1.
SU 1.2 Startup Test Procedure Review (Inspection Procedure 72300)
a. Inspection Scope
Background: The background for this startup test procedure review is the same as that in the background of Section SU.1.1 above.
Inspection Activities: The inspectors reviewed 2-PAT-5.3, Automatic Steam Generator Level Control Transients at Low Power, Rev. 1, to verify that the power ascension test procedure adequately addressed NRC requirements and licensing commitments outlined in the FSAR, docketed correspondence, SER, TS, and Regulatory Guide 1.68.
Additionally, the inspectors reviewed 2-PAT-5.3 to verify that the procedure contained the following administrative good practice attributes:
- the title described the purpose of the procedure;
- the cover page had appropriate information and approval signatures;
- procedure format is consistent with Regulatory Guide 1.68, Appendix C;
- a clear statement of procedure purpose/objectives;
- planning information such as prerequisites, precautions, required tools, reference documents, and coordination requirements;
- acceptance criteria were clearly identified and evaluated against the source of the comparison of results with acceptance criteria;
- adequate initial test conditions were specified;
- the procedure included a section listing references to appropriate FSAR sections, TS, drawings, specification, codes, and other requirements;
- signoff requirements including concurrent and independent verification steps established where appropriate;
- actions to be taken within the steps were specifically identified;
- provisions were made for recording details of the conduct of the test, including observed deficiencies, their resolution, and retest;
- procedure provided for identification of personnel conducting the testing and evaluating the test data;
- the procedure as issued was consistent with the test description provided in the FSAR;
- special precautions for personnel and equipment safety were specified;
- detailed instructions specified testing over the full operating range and under the maximum anticipated load change of the system/component; and
- provisions were made for the data taker to indicate the acceptability of the data.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that 2-PAT-5.3, Automatic Steam Generator Level Control Transients at Low Power, Rev. 1, was written in a manner consistent with the guidance of procedure 2-TI-438, Watts Bar Nuclear Plant Unit 2 Power Ascension Test Program, Rev. 5. This completes the procedure review of 2-PAT-5.3, Automatic Steam Generator Level Control Transients at Low Power, Rev. 1.
SU 1.3 Startup Test Procedure Review (Inspection Procedure 72300)
a. Inspection Scope
Background: The background for this startup test procedure review is the same as that in the background of Section SU.1.1 above.
Inspection Activities: The inspectors reviewed 2-PAT-5.4, Calibration of Steam and Feedwater Flow Instruments at 30% Power, Rev. 1, to verify that the power ascension test procedure adequately addressed NRC requirements and licensing commitments outlined in the FSAR, docketed correspondence, SER, TS, and Regulatory Guide 1.68.
Additionally, the inspectors reviewed 2-PAT-5.4 to verify that the procedure contained the following administrative good practice attributes:
- the title described the purpose of the procedure;
- the cover page had appropriate information and approval signatures;
- procedure format is consistent with Regulatory Guide 1.68, Appendix C;
- a clear statement of procedure purpose/objectives;
- planning information such as prerequisites, precautions, required tools, reference documents, and coordination requirements;
- acceptance criteria were clearly identified and evaluated against the source of the comparison of results with acceptance criteria;
- adequate initial test conditions were specified;
- the procedure included a section listing references to appropriate FSAR sections, TS, drawings, specification, codes, and other requirements;
- signoff requirements including concurrent and independent verification steps established where appropriate;
- actions to be taken within the steps were specifically identified;
- provisions were made for recording details of the conduct of the test, including observed deficiencies, their resolution, and retest;
- procedure provided for identification of personnel conducting the testing and evaluating the test data;
- the procedure as issued was consistent with the test description provided in the FSAR;
- special precautions for personnel and equipment safety were specified;
- detailed instructions specified testing over the full operating range and under the maximum anticipated load change of the system/component; and
- provisions were made for the data taker to indicate the acceptability of the data.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that 2-PAT-5.4, Calibration of Steam and Feedwater Flow Instruments at 30% Power, Rev. 1, was written in a manner consistent with the guidance of procedure 2-TI-438, Watts Bar Nuclear Plant Unit 2 Power Ascension Test Program, Rev. 5. This completes the procedure review of 2-PAT-5.4, Calibration of Steam and Feedwater Flow Instruments at 30% Power, Rev.1.
SU1.4 Startup Test Results Evaluation (Inspection Procedure 72301)
a. Inspection Scope
Background: The background for this startup test procedure review is the same as that in the background of Section SU.1.1 above.
Inspection Activities: The inspectors performed a detailed review of the results for power ascension test procedure 2-PAT-3.10, Reactor Trip System, Rev. 3, to verify that the licensees evaluation of the procedure performance and results was conducted in accordance with approved procedures. This review was performed to provide assurance that the test data was within the established acceptance criteria and the licensees methods for identifying and correcting deficiencies were adequate. The inspectors performed the following activities associated with this test results review:
- Reviewed all changes made to the test procedure to verify they were properly annotated, did not affect the objective of the test, and were performed in accordance with administrative procedures.
- Reviewed all documented test deficiencies to verify they had been properly resolved, reviewed, and accepted.
- Reviewed the original as-run copy of the test procedure to verify that data sheets were completed and properly initialed and dated, data was recorded within acceptance tolerances, and test deficiencies that were identified were noted.
- Reviewed the test summary and evaluation to verify that the system was evaluated to meet design requirements and acceptance criteria.
- The approval of the test results was reviewed for completeness with respect to the acceptance of the test results.
The inspectors reviewed the test results to verify that the overall test acceptance was met. The inspectors conducted a review with the responsible test engineer to assure that the test evaluation was performed in accordance with established procedures.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the licensees test procedure results were reviewed, evaluated, and accepted in a manner consistent with the guidance of procedure 2-TI-438, Watts Bar Nuclear Plant Unit 2 Power Ascension Test Program, Rev. 5. This completes the test results evaluation of pre-operational test procedure 2-PAT-3.10.
SU1.5 Startup Test Results Evaluation (Inspection Procedure 72301)
a. Inspection Scope
Background: The background for this startup test procedure review is the same as that in the background of Section SU.1.1 above.
Inspection Activities: The inspectors performed a detailed review of the results for power ascension test procedure 2-PAT-3.1, Control Rod Drive Mechanism Timing and CERPI Initial Calibration, Rev. 2, to verify that the licensees evaluation of the procedure performance and results was conducted in accordance with approved procedures. This review was performed to provide assurance that the test data was within the established acceptance criteria and the licensees methods for identifying and correcting deficiencies were adequate. The inspectors performed the following activities associated with this test results review:
- Reviewed all changes made to the test procedure to verify they were properly annotated, did not affect the objective of the test, and were performed in accordance with administrative procedures.
- Reviewed all documented test deficiencies to verify they had been properly resolved, reviewed, and accepted.
- Reviewed the original as-run copy of the test procedure to verify that data sheets were completed and properly initialed and dated, data was recorded within acceptance tolerances, and test deficiencies that were identified were noted.
- Reviewed the test summary and evaluation to verify that the system was evaluated to meet design requirements and acceptance criteria.
- The approval of the test results was reviewed for completeness with respect to the acceptance of the test results.
The inspectors reviewed the test results to verify that the overall test acceptance was met. The inspectors conducted a review with the responsible test engineer to assure that the test evaluation was performed in accordance with established procedures.
b. Observations and Findings
No findings were identified.
c. Conclusions
The inspectors determined that the licensees test procedure results were reviewed, evaluated, and accepted in a manner consistent with the guidance of procedure 2-TI-438, Watts Bar Nuclear plant Unit 2 Power Ascension Test Program, Rev. 5. This completes the test results evaluation of pre-operational test procedure 2-PAT-3.1.
SU.1.6 System Operational Readiness Assessment Inspection (Inspection Procedure 93806)
a. Inspection Scope
Inspection Activities: The inspectors reviewed the system turnover processes associated with the completion of construction activities and turnover of Unit 2 systems, listed below, to operations to ensure the licensee was following the requirements of procedures 0-TI-37, Systems Turnover to Operations, Rev. 0; 0-TI-435, Engineering Programs and Components Turnover, Rev. 3; and 0-TI-441, Operational Readiness Process for Unit 2 Systems, Rev. 6. As part of the review, the inspectors verified that equipment turnover deferral items were adequately justified and equipment punch-list items were appropriately dispositioned. The inspectors reviewed selected WOs, design changes, program and component evaluation reports to verify that overall system condition and capability supported system turnover. The inspectors interviewed selected control room operators and work management control operators to ensure they were knowledgeable of the procedures governing the system turnover process and changes in plant status configuration controls. The inspectors reviewed a sample of outstanding WOs for each system to verify that there were no significant open WOs that could impact the current mode of operation. The inspectors verified a sample of design changes had been translated to system operating procedures. Additionally, the inspectors performed partial system walkdowns of each system in accordance with IP 71111.04, Equipment Alignment.
The inspectors performed an independent review of completed 0-TI-37 and 0-TI-441 packages to determine whether the activities were accomplished in accordance with NRC requirements and licensee procedures. The inspectors reviewed system 63, safety injection; system 65, emergency gas treatment system; system 67, essential raw cooling water system; and system 3B, auxiliary feedwater.
During the review of the 0-TI-37 packages the inspectors performed the following:
- The inspectors reviewed Attachment 2, Functional Support Requirements Completion Checklist and Required Drawings, to verify that controlled critical drawings were transferred to the main control room and the online Business Support Library (BSL). The inspectors verified two master equipment list (MEL)items switched to operating control.
- The inspectors reviewed Attachment 3, Startup Testing Complete Form, to verify that deferrals were assessed for impact on operability and qualification.
- The inspectors reviewed Attachment 4, Turnover Boundary Walkdown Form, to verify that any incomplete deficiencies were assessed for impact on operability or qualification.
- The inspectors reviewed Attachment 5, Design Engineering Complete Form, and sampled two design documents to verify they were completed.
- The inspectors reviewed Attachment 6, Functional System Turnover Agreement Form.
- The inspectors reviewed Attachment 7, Supporting Documentation, to verify that a list of deferrals or special operating conditions, if any, had been assessed for impact on operability or qualification.
- The inspectors reviewed Attachment 11, Turnover Open Issue Summary Form, to verify all issues identified on the preceding attachments were captured on this summary form.
- The inspectors reviewed Appendix A, Turnover Action Deferral Form, to verify that a list of deferrals or special operating conditions, if any, had been assessed for impact on operability or qualification. The inspectors verified that any deferrals were dispositioned appropriately in the associated 0-TI-441 review for the system.
- The inspectors reviewed Appendix B, Special Operating Conditions Form, to verify that the licensee had listed and assessed special operating conditions that could impact operability or qualification and that they are resolved in the associated 0-TI-441 package.
During the review of the 0-TI-441 packages the inspectors performed the following:
- The inspectors reviewed Appendix A, Boundary Health Indicator Worksheet, to verify all attributes that were outside of acceptance criteria do not adversely impact operability requirements for the system.
- The inspectors reviewed Appendix C, Rescission Process Form, to note any system or components returned by Operations to Nuclear Construction and verify that deficiencies were resolved and the system or component was returned to Operations.
- The inspectors reviewed Attachment 1, Functional Support Requirements, and sampled to verify that system operating instructions and annunciator response instructions were complete, assistant unit operator rounds reflected ownership of the system, and any outstanding clearances did not affect operability of the system.
- The inspectors reviewed Attachment 2, Operational Alignment Form, to verify that all applicable attributes of the system (Appendix R, IST, etc.) in 0-TI-435, Engineering Programs and Components Turnover, support system operability.
The inspectors reviewed all open design changes to verify that they were complete or had been evaluated not to adversely impact system operability. The inspectors verified by sample that surveillance, maintenance, chemistry, radiological, and engineering procedures for the system were available in document control (BSL). The inspectors verified that outstanding items potentially affecting operability from the 0-TI-37 process were reflected in the limiting condition for operation (LCO) tracking system.
- The inspectors reviewed Attachment 3, Licensing Actions Complete, to verify that no outstanding licensing actions remained for the system.
- The inspectors verified that Attachment 4, Declaration of System Boundary Ready to Operate, was complete.
The inspectors evaluated the licensee corrective actions on problems identified and entered into the CAP. The inspectors reviewed CRs to verify that system construction/testing discrepancies had been appropriately characterized and corrected:
- System 63-CR 1091982
- System 63-CR 1097502
- System 3B-CR 1039165
- System 3B-CR 1072954
- System 3B-CR 1039165
- System 3B-CR 1038287
- System 3B-CR 1037971
- System 65-CR 1093577
- System 65-CR 1147403
- System 67-CR 1024651
b. Observations and Findings
No findings were identified. The inspectors review of all outstanding WOs and Modifications indicated that there were no safety significant issues related to their functionality for Mode 4 operation.
c. Conclusions
The licensee met the procedural requirements of 0-TI-37, 0-TI-435, and 0-TI-441 for the safety injection, emergency gas treatment, essential raw cooling water, and the auxiliary feedwater systems.
III.
OTHER ACTIVITIES
OA.1.1 (Discussed) Generic Letter 2004-02 - Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors and Pressurized Water Reactor Containment Sump Blockage (Temporary Instruction 2515/166)
a. Inspection Scope
Background: Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, requested licensees to evaluate the emergency core cooling system (ECCS)and containment spray systems (CSS) recirculation functions and take actions, if appropriate. Pressurized water reactor recirculation sump screens had been identified to be potentially susceptible to debris blockage during design basis accidents requiring recirculation operation of ECCS or CSS and on the potential for additional adverse effects due to debris blockage of flow paths necessary for ECCS and CSS recirculation and containment drainage.
In response to the generic letter mentioned above, WBN determined that they would remove the outer trash racks provided on each side of the sump and install a new strainer. The new strainer has an available flow area of 4600 ft² compared to the original screen area of approximately 200 ft². The new strainer openings are 0.085 inches in diameter compared to the 0.25 inch mesh that cover the outer trash racks. The strainer has an advanced configuration intended to be much more resistant to potential sump blockage.
Unit 2 containment is a mirror image to Unit 1 containment. Therefore, the results of debris generation, transport analyses, and downstream effects will be the same for Unit 2 as for Unit 1. The WBN Unit 2 letter to the NRC dated March, 4, 2011 (Agencywide Documents Access and Management System [ADAMS] Accession Number [No.]
ML110680248) stated that Unit 2 actions are to replace containment sump intake screens with an advanced design containment sump strainer arrangement under Engineering Document Construction Release (EDCR) 53580. The design is the same as that used for Unit 1 except that the strainer stack to plenum opening was increased in size. This change reduces the strainer pressure drop, thus increasing the margin to plugging the strainer when compared to Unit 1.
As stated in the NRC closeout letter dated September 18, 2014 (ADAMS Accession No.
ML14163A658), it was identified that three actions needed to be accomplished prior to closeout for the GL 2004-02:
- (1) install sump modifications per the requirements of GL 2004-02 prior to Unit 2 fuel load;
- (2) complete a confirmatory walkdown for loose debris after containment work is complete, prior to start-up, to ensure that potential quantities of post-accident debris are maintained within the bounds of the analyses and design bases that support ECCS and CSS recirculation functions; and
- (3) install new throttle valves in the chemical volume control system and safety injection system lines to the reactor coolant system, opened sufficiently to preclude downstream blockage.
As documented in integrated inspection report (IIR) 05000391/2016609 (ADAMS Accession No. ML15287A199), the NRC has completed inspection activities related to installation of the sump screen modifications, installation of throttle valves in the chemical volume and control system, and installation of throttle valves in the safety injection system lines. Remaining items for inspection, as documented in IIR 05000391/2016609, include a review of the TVA confirmatory walkdown for loose debris, review of additional coatings related information, and a final walkdown of the sump once work is complete, prior to start-up.
Inspection Activities: The inspectors performed an inspection of the containment sump to ensure that no loose items or debris were found. As part of the sump inspection close-out, the inspectors reviewed WOs 115886614 and 117656364 and observed the performance of the licensee surveillance 2-SI-304-2, 18 Month ECCS Containment Sump Inspection, Rev. 0. In addition, the inspectors conducted containment closure activities, including a detailed containment walkdown prior to initial criticality, to verify no evidence of leakage and that debris had not been left which could affect the performance of the containment sump or ice condenser.
b. Observations and Findings
Introduction:
The inspectors identified an example of a Severity Level (SL) IV non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for failure to follow work order instructions associated with the sump inspection surveillance 2-SI-304-2, which required the identification and documentation of foreign material inside of the safety-related containment sump.
Description:
The inspectors conducted a walkdown of the completed safety-related containment sump inspection performed under WO 115886614. The inspectors observed that the completed sump inspection failed to identify and document foreign material, found by the inspector inside the sump. The work instructions to inspect the sump surfaces for foreign material were signed for as complete on March 3, 2016, and indicated that there was no foreign material or discrepancies found during the licencees inspection.
The inspectors determined that the failure to perform work instructions to identify, document, and evaluate the foreign material found during the safety-related containment sump inspection was a performance deficiency. This performance deficiency was determined to be more than minor in accordance with IMC-2517, Appendix C, because the failure to implement the work order instructions to clean the containment sump represented an improper work practice that could impact safety, involving safety-related SSCs. Specifically, the inadequate removal of foreign material from the containment sump could transport the material throughout the emergency core cooling system during a design basis accident that could challenge the ability of the ECCS to accomplish its design functions. The inspectors determined this finding to be of very low safety significance,( i.e., SL-IV), in accordance with Section 6.5 of the Enforcement Policy because it did not represent a breakdown of the licensees QA program.
This finding has a cross-cutting aspect in the Human Performance cross-cutting area, as defined in IMC 0310, regarding work management. The organization did not implement a process of planning, controlling, and execution of the work activities, such that nuclear safety was the overriding priority. The work process did not include the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities (H.5).
Enforcement:
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, and procedures, and shall be accomplished in accordance with these instructions, and procedures. WO 115886614 implements 2-SI-304-2, the ECCS containment sump inspection, which documents the performance of the inspection of the containment internal surfaces. The approved instructions required the containment sump to be inspected and document any foreign material found during the inspection.
Contrary to the above, on March 3, 2016, the WO instructions were implemented without identifying and documenting the foreign material identified in the containment sump during the inspection.
The SL IV violation was entered into the licensees corrective action program as CR 1148722, 1145455 and 1148640 to address this finding. This violation is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy. This NCV is identified as05000391/2016603-01, Failure to Accomplish the Containment Sump Inspection in Accordance with the Approved Procedures.
c.
Conclusion
The inspectors identified an NCV associated with the inspection of the safety-related containment sump. The licensee generated CR 1148722, 1145455 and 1148640 to address the finding and remove the foreign material prior to entry into Mode 4. Based on inspection activities, the inspectors concluded that Generic Letter 2004-02 and Temporary Instruction 2515/166 will remain open. The remaining items, TVAs completed containment debris and coatings calculations, will be inspected.
IV.
MANAGEMENT MEETINGS
X1
Exit Meeting Summary
An exit meeting was conducted on April 14, 2016, to present inspection results to Sean Connors. The inspectors identified that no proprietary information had been received during the inspection and none would be used in the inspection report. The licensee acknowledged the observations and provided no dissenting comments.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- P. Simmons, TVA - Site Vice President
- R. Proffitt, TVA - Licensing
INSPECTION PROCEDURES USED
Quality Assurance Program Implementation During Construction and
Pre-Construction Activities
Preoperational Test Witness
Reactor Protection System Test
Preoperational Test Results Evaluation
Preoperational Test Program Implementation Verification
Startup Test Procedure Review
Startup Test Results Evaluation
IP 93806 Operational Readiness Assessment
Pressurized Water Reactor Containment Sump Blockage (NRC Generic Letter 2004-02)
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Discussed
2004-02
2515/166
GL
TI
Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors (Section OA.1.1)
Pressurized Water Reactor Containment Sump Blockage (Section OA.1.1)