CNL-15-217, Reply to Notice of Violation (EA-15-112)
| ML15289A384 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 10/16/2015 |
| From: | James Shea Tennessee Valley Authority |
| To: | Document Control Desk, NRC/RGN-II |
| References | |
| CNL-15-217, EA-15-112 | |
| Download: ML15289A384 (5) | |
Text
Tennessee Valley Authority, 11 01 Market Street. Chattanooga, Tennessee 37402 CNL-15-217 October 16, 2015 10 CFR 2.201 U.S. Nuclear Regu latory Commission ATTN : Document Control Desk Washington , D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 Construction Perm it No. CPPR-2 NRC Docket No. 50-391
SUBJECT:
WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 - REPLY TO NOTICE OF VIOLATION (EA-15-112)
Reference:
NRC letter dated September 29, 2015, "Watts Bar Nuclear Plant Unit 2 Construction - NRC Integrated Inspection Report 05000391 /2015607 and Notice of Violation" Pursuant to Title 10, Code of Federal Regulations (10 CFR) 2.201 , Tennessee Valley Authority's (TVA) response to Notice of Violation EA-15-112 is enclosed.
TVA accepts the violation and has developed and implemented corrective actions to ensure the identified discrepancies have been corrected and will not recur.
The enclosure provides TVA's reply to the violation, including a detailed description of the corrective steps taken and the results achieved. TVA achieved full compliance in December 2011 when specific corrective actions were completed.
There are no new regulatory comm itments made in this letter. Should you have questions regarding this response , please contact Gordon Arent at (423) 365-2004.
ice President, Nuclear Licensing Enclosure cc: See Page 2
U.S. Nuclear Regulatory Commission CNL-15-217 Page 2 October 16, 2015
Enclosure:
Reply to Notice of Violation cc (Enclosure):
NRC Regional Administrator - Region II NRC Director, Office of Enforcement NRC Senior Resident Inspector - Watts Bar Nuclear Plant, Unit 2 NRC Project Manager - Watts Bar Nuclear Plant, Unit 2
ENCLOSURE WATTS BAR NUCLEAR PLANT, UNIT 2 REPLY TO NOTICE OF VIOLATION Description of the Violation:
Title 10 of the Code of Federal Regulations (10 CFR), section 50.9(a), Completeness and accuracy of information states, "Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects."
The Watts Bar Nuclear [Plant] final safety analysis report (FSAR), Revision 113, Table 3.2-3, classifies the reactor coolant drain tank pumps as Seismic Category l(L) components.
TVA's Nuclear Quality Assurance Plan, Revision 31, Appendix C, section 4.0, paragraph B, states, in part, that those components or systems designated as Seismic Category l(L) in nuclear plant FSARs shall be classified as quality-related. Section 6.3.2.A requires that, "Sufficient records and documentation shall be prepared and maintained to provide evidence of the quality of items affecting quality. QA records shall be legible, complete, and identifiable to the item involved."
Contrary to the above, on or about August 30, 2011, the licensee failed to maintain complete and accurate quality-related work order documents covered by the TVA and Bechtel QA programs in all material respects. Specifically, a contract employee deliberately removed a quality control (QC) data sheet, which contained a valid QC rejection for a damaged anchor bolt, from work order (WO) 10-951093-000, which provided steps for grouting of the reactor coolant drain tank (RCDT) pump WBN-2-PMP-077-0006 base plate, essential for the seismic qualification of the RCDT pump. A new, blank QC data sheet was substituted for the data sheet that contained the QC rejection to allow grouting work to be completed without site engineering approval of the damaged anchor bolt. This caused the quality related WO documentation to be incomplete and inaccurate in that the actual physical condition and properties of the anchor bolt, which is required information for Seismic Category l(L) calculations, were no longer represented in the WO. This documentation is material to the NRC in that it provides the basis for compliance with seismic and construction-related QA procedures and regulatory requirements.
This is a Severity Level IV violation (Enforcement Policy Sections 6.5 and 6.9).
TVA Response:
TVA does not dispute the facts as described by the Nuclear Regulatory Commission (NRC) and accepts the violation. The missing data sheet was identified when the WO was reviewed by Bechtel Construction. The base plate supporting the Reactor Coolant Drain Tank pump was evaluated and determined to be acceptable as is.
Reason for the Violation:
A Watts Bar Nuclear Plant (WBN) Unit 2 contract employee knowingly removed QC documentation from WO 10-951093-000 in violation of TVA's Nuclear Quality Assurance (QA) Plan, Section 6.3.2.A. TVA's extent of condition review determined that the inappropriate work was isolated to work activities associated with WO 10-951093-000.
CNL-15-217 E-1
Corrective Steps That Have Been Taken And The Results Achieved:
When Bechtel Construction identified the missing documentation in the WO, Condition Reports (CR) 428905 and 432288 were generated to enter the concern into the Corrective Action Program. The name of the involved individual was turned over to the TVA Office of Inspector General (OIG) for their investigation and determination of any legal recourse. Bechtel Employee Concerns, Internal Audits, and Legal Counsel also initiated an investigation.
The following corrective actions have been completed:
Data Sheet MAI-5.4-01 for WO 10-951093-000 was amended to add reference to the missing data sheet and CRs 428905 and 432288.
An extent of condition review confirmed that the inappropriate work was isolated to work activities associated with WO 10-951093-000.
An Engineering evaluation confirmed that the base plate (anchor bolt configuration) supporting Reactor Coolant Drain Tank pump, WBN-2-PMP-077-0006, was adequately supported.
Disciplinary action was taken against the responsible individual.
TVA Site Vice President and Bechtel Project Director issued a site communication highlighting Integrity, which addressed intentionally destroying records, trustworthiness, and personal consequences.
WBN Unit 2 held a stand down (town hall meetings) for Unit 2 employees and contractors. The Unit 2 TVA Vice President provided guidance on the following issues:
Authentication of records and what a person's signature represents How Quality Records are to be treated (i.e., once initiated you may not destroy it)
Records Corrections Role of QA/QC processes/function(s) in overall project delivery/completion efforts QC and/or QA Holds and their functions Public trust in the nuclear power industry Related Corrective Actions:
In response to a previous TVA violation (EA-12-021) and Confirmatory Order, TVA has already taken a significant number of actions addressing expectations for assuring work activities are performed and documented in a complete and accurate manner. Specifically, the following actions were taken:
The Chief Nuclear Officer and the Senior Vice President of Nuclear Construction issued a joint communication to Nuclear Power Group and Nuclear Construction employees regarding expectations for assuring work activities are performed and documented in a complete and accurate manner.
CNL-15-217 E-2
The executive management expectations (above) were reinforced through the use of fleet wide posters and communications. These communications specifically discussed 10 CFR 50.9, Completeness and Accuracy of Information, willful violations, and the consequences of non-compliance.
TVA revised the existing Nuclear Power Group (NPG) procedure, NPG-SPP-01.2, "Administration of Site Technical Procedures," to reinforce the requirements of 10 CFR 50.9 and the need to ensure complete and accurate documentation of work completion steps.
TVA provided initial 10 CFR 50.9 training in 2012 (manager, supervisor and craft-level) to employees at all Nuclear Construction sites.
TVA provided refresher 10 CFR 50.9 training in 2014 (manager, supervisor and craft-level) to WBN Unit 2 employees, which will continue every two years through 2016, or until construction is complete.
TVA enhanced existing 10 CFR 50.9 related general employee training (GET) for new employees joining Nuclear Power Group and Nuclear Construction, and updated the associated annual requalification training.
Within six months of issuance of the Confirmatory Order and prior to July 1, 2013, TVA surveyed WBN Unit 2 construction contractors and subcontractors via the Employee Concerns Program (ECP), to identify scheduling pressure issues. Surveys were also taken in December 2012 and May 2013. Issues identified were and continue to be addressed commensurate with safety and in accordance with TVA's Corrective Action Program.
In 2013, TVA performed effectiveness reviews of actions taken, including those taken in response to the ECP surveys described above. Based on the results of the effectiveness reviews, TVA implemented appropriate corrective actions.
Corrective Steps That Will Be Taken:
TVA will continue to provide refresher 10 CFR 50.9 training (manager, supervisor and craft-level) to WBN Unit 2 employees every two years through 2016, or until construction is complete.
Date When Full Compliance Was Achieved:
TVA achieved full compliance in December 2011 when the base plate was evaluated and determined to be acceptable, and the corrective actions described on page E-2 were completed.
CNL-15-217 E-3
Tennessee Valley Authority, 11 01 Market Street. Chattanooga, Tennessee 37402 CNL-15-217 October 16, 2015 10 CFR 2.201 U.S. Nuclear Regu latory Commission ATTN : Document Control Desk Washington , D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 Construction Perm it No. CPPR-2 NRC Docket No. 50-391
SUBJECT:
WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 - REPLY TO NOTICE OF VIOLATION (EA-15-112)
Reference:
NRC letter dated September 29, 2015, "Watts Bar Nuclear Plant Unit 2 Construction - NRC Integrated Inspection Report 05000391 /2015607 and Notice of Violation" Pursuant to Title 10, Code of Federal Regulations (10 CFR) 2.201 , Tennessee Valley Authority's (TVA) response to Notice of Violation EA-15-112 is enclosed.
TVA accepts the violation and has developed and implemented corrective actions to ensure the identified discrepancies have been corrected and will not recur.
The enclosure provides TVA's reply to the violation, including a detailed description of the corrective steps taken and the results achieved. TVA achieved full compliance in December 2011 when specific corrective actions were completed.
There are no new regulatory comm itments made in this letter. Should you have questions regarding this response , please contact Gordon Arent at (423) 365-2004.
ice President, Nuclear Licensing Enclosure cc: See Page 2
U.S. Nuclear Regulatory Commission CNL-15-217 Page 2 October 16, 2015
Enclosure:
Reply to Notice of Violation cc (Enclosure):
NRC Regional Administrator - Region II NRC Director, Office of Enforcement NRC Senior Resident Inspector - Watts Bar Nuclear Plant, Unit 2 NRC Project Manager - Watts Bar Nuclear Plant, Unit 2
ENCLOSURE WATTS BAR NUCLEAR PLANT, UNIT 2 REPLY TO NOTICE OF VIOLATION Description of the Violation:
Title 10 of the Code of Federal Regulations (10 CFR), section 50.9(a), Completeness and accuracy of information states, "Information provided to the Commission by an applicant for a license or by a licensee or information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects."
The Watts Bar Nuclear [Plant] final safety analysis report (FSAR), Revision 113, Table 3.2-3, classifies the reactor coolant drain tank pumps as Seismic Category l(L) components.
TVA's Nuclear Quality Assurance Plan, Revision 31, Appendix C, section 4.0, paragraph B, states, in part, that those components or systems designated as Seismic Category l(L) in nuclear plant FSARs shall be classified as quality-related. Section 6.3.2.A requires that, "Sufficient records and documentation shall be prepared and maintained to provide evidence of the quality of items affecting quality. QA records shall be legible, complete, and identifiable to the item involved."
Contrary to the above, on or about August 30, 2011, the licensee failed to maintain complete and accurate quality-related work order documents covered by the TVA and Bechtel QA programs in all material respects. Specifically, a contract employee deliberately removed a quality control (QC) data sheet, which contained a valid QC rejection for a damaged anchor bolt, from work order (WO) 10-951093-000, which provided steps for grouting of the reactor coolant drain tank (RCDT) pump WBN-2-PMP-077-0006 base plate, essential for the seismic qualification of the RCDT pump. A new, blank QC data sheet was substituted for the data sheet that contained the QC rejection to allow grouting work to be completed without site engineering approval of the damaged anchor bolt. This caused the quality related WO documentation to be incomplete and inaccurate in that the actual physical condition and properties of the anchor bolt, which is required information for Seismic Category l(L) calculations, were no longer represented in the WO. This documentation is material to the NRC in that it provides the basis for compliance with seismic and construction-related QA procedures and regulatory requirements.
This is a Severity Level IV violation (Enforcement Policy Sections 6.5 and 6.9).
TVA Response:
TVA does not dispute the facts as described by the Nuclear Regulatory Commission (NRC) and accepts the violation. The missing data sheet was identified when the WO was reviewed by Bechtel Construction. The base plate supporting the Reactor Coolant Drain Tank pump was evaluated and determined to be acceptable as is.
Reason for the Violation:
A Watts Bar Nuclear Plant (WBN) Unit 2 contract employee knowingly removed QC documentation from WO 10-951093-000 in violation of TVA's Nuclear Quality Assurance (QA) Plan, Section 6.3.2.A. TVA's extent of condition review determined that the inappropriate work was isolated to work activities associated with WO 10-951093-000.
CNL-15-217 E-1
Corrective Steps That Have Been Taken And The Results Achieved:
When Bechtel Construction identified the missing documentation in the WO, Condition Reports (CR) 428905 and 432288 were generated to enter the concern into the Corrective Action Program. The name of the involved individual was turned over to the TVA Office of Inspector General (OIG) for their investigation and determination of any legal recourse. Bechtel Employee Concerns, Internal Audits, and Legal Counsel also initiated an investigation.
The following corrective actions have been completed:
Data Sheet MAI-5.4-01 for WO 10-951093-000 was amended to add reference to the missing data sheet and CRs 428905 and 432288.
An extent of condition review confirmed that the inappropriate work was isolated to work activities associated with WO 10-951093-000.
An Engineering evaluation confirmed that the base plate (anchor bolt configuration) supporting Reactor Coolant Drain Tank pump, WBN-2-PMP-077-0006, was adequately supported.
Disciplinary action was taken against the responsible individual.
TVA Site Vice President and Bechtel Project Director issued a site communication highlighting Integrity, which addressed intentionally destroying records, trustworthiness, and personal consequences.
WBN Unit 2 held a stand down (town hall meetings) for Unit 2 employees and contractors. The Unit 2 TVA Vice President provided guidance on the following issues:
Authentication of records and what a person's signature represents How Quality Records are to be treated (i.e., once initiated you may not destroy it)
Records Corrections Role of QA/QC processes/function(s) in overall project delivery/completion efforts QC and/or QA Holds and their functions Public trust in the nuclear power industry Related Corrective Actions:
In response to a previous TVA violation (EA-12-021) and Confirmatory Order, TVA has already taken a significant number of actions addressing expectations for assuring work activities are performed and documented in a complete and accurate manner. Specifically, the following actions were taken:
The Chief Nuclear Officer and the Senior Vice President of Nuclear Construction issued a joint communication to Nuclear Power Group and Nuclear Construction employees regarding expectations for assuring work activities are performed and documented in a complete and accurate manner.
CNL-15-217 E-2
The executive management expectations (above) were reinforced through the use of fleet wide posters and communications. These communications specifically discussed 10 CFR 50.9, Completeness and Accuracy of Information, willful violations, and the consequences of non-compliance.
TVA revised the existing Nuclear Power Group (NPG) procedure, NPG-SPP-01.2, "Administration of Site Technical Procedures," to reinforce the requirements of 10 CFR 50.9 and the need to ensure complete and accurate documentation of work completion steps.
TVA provided initial 10 CFR 50.9 training in 2012 (manager, supervisor and craft-level) to employees at all Nuclear Construction sites.
TVA provided refresher 10 CFR 50.9 training in 2014 (manager, supervisor and craft-level) to WBN Unit 2 employees, which will continue every two years through 2016, or until construction is complete.
TVA enhanced existing 10 CFR 50.9 related general employee training (GET) for new employees joining Nuclear Power Group and Nuclear Construction, and updated the associated annual requalification training.
Within six months of issuance of the Confirmatory Order and prior to July 1, 2013, TVA surveyed WBN Unit 2 construction contractors and subcontractors via the Employee Concerns Program (ECP), to identify scheduling pressure issues. Surveys were also taken in December 2012 and May 2013. Issues identified were and continue to be addressed commensurate with safety and in accordance with TVA's Corrective Action Program.
In 2013, TVA performed effectiveness reviews of actions taken, including those taken in response to the ECP surveys described above. Based on the results of the effectiveness reviews, TVA implemented appropriate corrective actions.
Corrective Steps That Will Be Taken:
TVA will continue to provide refresher 10 CFR 50.9 training (manager, supervisor and craft-level) to WBN Unit 2 employees every two years through 2016, or until construction is complete.
Date When Full Compliance Was Achieved:
TVA achieved full compliance in December 2011 when the base plate was evaluated and determined to be acceptable, and the corrective actions described on page E-2 were completed.
CNL-15-217 E-3