IR 05000390/2019012

Follow Up for NRC Confirmatory Order Ea-17-022 and Chilled Work Environment Letter EA-16-061; NRC Inspection Report 05000390/2019012 and 05000391/2019012

ML19357A240
Person / Time
Site:	Watts Bar
Issue date:	12/23/2019
From:	Omar Lopez-Santiago NRC/RGN-II/DRP/RPB5
To:	Jim Barstow Tennessee Valley Authority
References
EA-16-061, EA-17-022 IR 2019012
Download: ML19357A240 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 23, 2019

SUBJECT:

WATTS BAR NUCLEAR PLANT - FOLLOW UP FOR NRC CONFIRMATORY ORDER EA-17-022 AND CHILLED WORK ENVIRONMENT LETTER EA-16-061; NRC INSPECTION REPORT 05000390/2019012 AND 05000391/2019012

Dear Mr. Barstow:

On October 24, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed a follow-up inspection of NRC Confirmatory Order (CO) EA-17-022 (Agency-wide Documents Access and Management System (ADAMS) Accession Number ML17208A647) and Chilling Effect Letter (CEL) EA-16-061 (ADAMS Accession No. ML16083A479) at Watts Bar Nuclear Plant Units 1 and 2. On October 24, 2019, the NRC inspectors discussed the results of this inspection with Mr. Thomas Marshall, Plant Manager and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

The NRC inspection team determined that Watts Bar continued to make progress with improving their safety conscious work environment. The results from this inspection will be an input into decision-making regarding closure of the Watts Bar CCI and CEL. The NRC will continue to monitor your activities to maintain a safety conscious work environment at Watts Bar through the Reactor Oversight Process.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Omar R. López-Santiago, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos. 05000390 and 05000391 License Nos. NPF-90 and NPF-96

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000390 and 05000391 License Numbers: NPF-90 and NPF-96 Report Numbers: 05000390/2019012 and 05000391/2019012 Enterprise Identifier: I-2019-012-0038 Licensee: Tennessee Valley Authority Facility: Watts Bar Location: Spring City, TN Inspection Dates: October 21, 2019 to October 24, 2019 Inspectors: D. Edwards, Fuel Facilities Inspector S. Mendez-Gonzalez, Allegations Coordinator S. Morrow Human Factors Engineer R. Taylor, Senior Project Engineer Approved By: Omar R. López-Santiago, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a confirmatory order and safety conscious work environment follow up inspection at Watts Bar in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

92702 CONF - Enforcement Related Order Follow-Up-Only Enforcement Related Order Follow-Up-Only

(1) The inspectors reviewed commitments associated with two items from Confirmatory Order EA-17-022, issued to TVA on July 27, 2017.

(1) Commitment V.1.d.1: This commitment required an independent third-party to perform quarterly audits for the first year after the date of issuance of the CO, and semi-annually for the next two years, of the adverse employment action process. The inspectors reviewed the Sixth Independent Auditors Report of the TVA Adverse Employment Action Process for Quarter Ending 6/30/2019, dated 6/27/2019. The inspectors verified that the audits included a review of all adverse employment actions, periodic attendance at Executive Review Boards and a review of chilling effect mitigation plans (inclusive of recommendations as appropriate).

(2) Commitment V.1.e.1: This commitment required TVA to conduct an independent nuclear safety culture assessment at Watts Bar in 2019, evaluate the results and develop, implement, and track to completion corrective actions to address weaknesses identified through the assessment. The inspectors reviewed corrective actions and enhancements associated with the 2019 nuclear safety culture assessment at Watts Bar to verify that corrective actions were developed and appropriate to address the weaknesses identified through the assessment.

93100 - Safety-Conscious Work Environment Issue of Concern Followup Safety-Conscious Work Environment Issue of Concern Followup

(1) Qualified safety culture assessors performed a limited assessment of the safety conscious work environment (SCWE) at Watts Bar in accordance with IP 93100, Safety Conscious Work Environment Issue of Concern Follow-up, and other IPs as referenced by IP 93100. The objectives of the assessment were to:

(1) determine whether actions taken by TVA have improved the work environment in the Radiation Protection and Operations departments;

(2) determine if employees are currently reluctant to raise safety or regulatory issues; and

(3) determine if employees are currently being discouraged from raising safety or regulatory issues.

The assessors conducted semi-structured focus groups and interviews with 66 Watts Bar employees, contractors, and management. Individuals were randomly selected for the focus groups and interviews by the assessors. The following departments were sampled: Radiation Protection (RP), Chemistry, Operations, and Maintenance. Inspectors also sampled contractors from the Day and Zimmerman organization.

The assessors also reviewed case files and assessments of the Employee Concerns Program (ECP), minutes from the Nuclear Safety Culture Monitoring Panel and Site Leadership Team meetings, and condition reports and corrective actions associated with safety culture and SCWE.

INSPECTION RESULTS

Assessment 93100 The Watts Bar Nuclear Annual Assessment Follow Up Letter dated August 31, 2018 established the closure criteria for the Chilling Effect Letter (CEL) and SCWE Cross-Cutting Issue (CCI) as:

• Demonstration of improvement in SCWE, with particular emphasis on improvement in the Radiation Protection department and sustained improvement in the Operation department.

• Demonstration of identifying the causes of the weaknesses in the stations ability to 1) detect declining trends in safety culture and SCWE, particularly at the department level, and 2) take action to mitigate chilled work environments.

• Development of corrective actions to address identified weaknesses from item 2, documentation of progress in implementing actions, and demonstration of effectiveness of actions.

Based on the results of interviews, safety culture surveys, and assessments, the team determined that there is evidence of improvement in the safety conscious work environment in the RP department and sustained improvement in the Operations department. The team determined that Watts Bar has implemented a range of corrective actions to improve the sites ability to detect declining trends in safety culture and SCWE. For example, Watts Bar developed the Employee Issue Tracking Matrix to detect general work environment issues at a low threshold and implemented changes to the Nuclear Safety Culture Monitoring Panel process to improve tracking of safety culture and SCWE at the department level.

In addition, a review of recent allegations at Watts Bar did not identify any significant trend in allegations involving chilling effect and discrimination concerns.

Based on the teams interviews and focus groups, all individuals expressed that they are willing to raise nuclear safety concerns, but there was a small percentage of individuals who would feel hesitant to raise concerns due to fear of retaliation. The percentage of individuals was well under the threshold for a chilled work environment, and most individuals indicated that their hesitance was primarily based on past behaviors at the site during the time that the chilling effect letter was issued, not necessarily current behaviors. In particular, the team observed that that Operations department continued to experience challenges with trust in leadership, likely stemming from the events that led to the previous chilled work environment in 2015 and 2016. The ongoing work environment challenges in Operations had been identified by Watts Bar via their safety culture monitoring tools and was being tracked within the corrective action program (CR 1551550).

The inspection team determined that Watts Bar continued to make progress with improving their safety conscious work environment. The results from this inspection will be an input into decision-making regarding closure of the Watts Bar CCI and CEL.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On October 24, 2019, the inspectors presented the confirmatory order and safety conscious work environment follow up inspection results to Mr. Thomas Marshall, Plant Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2702 Miscellaneous September 2019, Watts Bar

CONF Nuclear Nuclear Safety Culture

Evaluation performed by Oak

Ridge

September 2017, Watts Bar

Nuclear Nuclear Safety Culture

Evaluation performed by Oak

Ridge

2702 Procedures NPG-SPP- Nuclear Safety Culture Rev. 5

CONF 01.7

2702 Procedures NPG-SPP- Nuclear Safety Oversight Rev. 14

CONF 03.2

93100 Corrective CR 1452420,

Action CR 1475636,

Documents CR 1534006,

CR 1534009,

CR 1544630,

CR 1551540,

CR 1551546,

CR 1551547,

CR 1551549,

CR 1551550,

CR 1552692,

CR 1550170,

93100 Miscellaneous Watts Bar Nuclear Safety

Culture Evaluation, September

2019

93100 Miscellaneous Conduct of Operations Rev. 7,

Employee Concerns 02/13/2019

93100 Miscellaneous Conduct of Operations Rev. 0,

Employee Concerns 07/12/2019

93100 Miscellaneous Watts Bar Nuclear Plant Chilled Rev. 2,

Work Environment in Radiation 04/24/2019

Protection, Level 1 Root Cause

Analysis Report

93100 Miscellaneous Nuclear Safety Culture 02/28/2019

Monitoring Panel Meeting to

Minutes 08/14/2019

93100 Miscellaneous Employee Issue Tracking 10/03/2019

Matrix Guideline

93100 Procedures NPG-SPP- Employee Concerns Program Rev. 3,

01.7.1 10/20/2017

93100 Procedures NPG-SPP- Nuclear Safety Culture Rev. 13,

01.7.2 Monitoring 04/24/2019

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