IR 05000390/2022002

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Integrated Inspection Report 05000390/2022002 and 05000391/2022002 and Exercise of Enforcement Discretion
ML22223A138
Person / Time
Site: Watts Bar  Tennessee Valley Authority icon.png
Issue date: 08/12/2022
From: Louis Mckown
NRC/RGN-II/DRP/RPB5
To: Jim Barstow
Tennessee Valley Authority
References
IR 2022002
Download: ML22223A138 (18)


Text

August 11, 2022

SUBJECT:

WATTS BAR NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000390/2022002 AND 05000391/2022002 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Barstow:

On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Watts Bar Nuclear Plant. On July 25, 2022, the NRC inspectors discussed the results of this inspection with Mr. Anthony Williams and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

The Regional Administrator has authorized staff to use IP 50001, Steam Generator Replacement Inspection, to inspect Watts Bar Unit 2 Steam Generator Replacement because the steam generator replacement inspection is an infrequent inspection and outside of the routine reactor oversight program (ROP) baseline inspections.

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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Louis J. McKown, 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:

05000390/2022002 and 05000391/2022002

Enterprise Identifier:

I-2022-002-0020

Licensee:

Tennessee Valley Authority

Facility:

Watts Bar Nuclear Plant

Location:

Spring City, TN 37381

Inspection Dates:

April 01, 2022 to June 30, 2022

Inspectors:

J. Bell, Resident Inspector

N. Childs, Senior Project Engineer

P. Cooper, Senior Reactor Inspector

W. Deschaine, Senior Resident Inspector

D. Lanyi, Senior Operations Engineer

A. Nielsen, Senior Health Physicist

N. Peterka, Senior Project Engineer

W. Pursley, Health Physicist

J. Rivera, Health Physicist

D. Simpkins, Sr. Tech Training Program Specialist

Approved By:

Louis J. McKown, Chief

Reactor Projects Branch5

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Watts Bar Nuclear Plant, 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

Type Issue Number Title Report Section Status EDG EA-22-034 Failure to Comply with 10 CFR 37 for the Protection of Category 2 Radioactive Material Contained in Contaminated Steam Generators Stored in a Concrete Mausoleum 71124.08 Closed LER 05000390/2020-001-00 LER 2020-001-00 for Watts Bar Nuclear Plant, Unit 1,

Manual Reactor Trip Due to Lowering Steam Generator Level Caused by a Hand Station Failure 71153 Closed LER 05000390,05000391/20 19-002-00 LER 2019-002-00 for Watts Bar Nuclear Plant, Units 1 &

2, Loss of Control Room Emergency Air Temperature Control System Due to Air Filter Failure.

71153 Closed

PLANT STATUS

Unit 1 operated at or near rated thermal power (RTP) for the entire inspection period.

Unit 2 began the inspection period shutdown for a refueling outage (U2R4) until it was restarted on June 30, 2022. Unit 2 remained in Mode 2 until the end of the inspection period.

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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Spent Fuel Pool Cooling System on April 19, 2022.
(2) Auxiliary Building Gas Treatment System (ABGTS) on April 21, 2022.
(3) Unit 1 Turbine Driven Axillary Feedwater System on June 15, 2022.

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of the Unit 1 Containment Spray system (CSS) (areas accessible outside containment) on May 27, 2022.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Cable Spreading Room (Control Building Elevation 729' and 741') on April 7, 2022.
(2) Intake Pumping Station (IPS) (Elevations 711', 722' and 741') on April 7, 2022.
(3) Unit 1 Control Rod Drive Equipment Room, Pressurizer Heater Transformer Room, and Miscellaneous Equipment Room (Auxiliary Building Elevations 782' and 786') on April 7, 2022.
(4) Mechanical Equipment and 480V Transformer Rooms (Auxiliary Building Elevation 772') on April 8, 2022.
(5) Auxiliary Building Corridor (Elevation 676') on April 8, 2022.

71111.07A - Heat Exchanger/Sink Performance

Annual Review (IP Section 03.01) (1 Sample)

The inspectors evaluated readiness and performance of:

(1) Component Cooling System (CCS) Heat Exchanger A & B on June 17, 2022.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during Unit 2 start-up activities on June 29-30, 2022.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated the following licensed operator requalification simulator scenarios: crew B and crew C on April 21, 2022. Both observations make up one sample.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:

(1) System 235-B - Vital Inverters (Condition Report (CR) 1685567)

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1) Risk assessment for (week of) May 16, 2022, with the Common Station Service Transformer C out of service for planned maintenance.
(2) Risk assessment for (week of) May 30, 2022, with the A train Main Control Room (MCR) chiller out of service for planned maintenance.

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (2 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1) CR 1772929 - Essential Raw Cooling Water (ERCW) pump B-A oil level high.
(2) CR 1772709 - Emergency Diesel Generator (EDG) 2A1 lube oil circulating pump running hot and a lot of dust/oil buildup on the motor suction.

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

The inspectors evaluated the following temporary or permanent modifications:

(1) Temporary modification WBN-2-2022-067-001, Isolation of Unit 2 Containment Penetrations for 2A and 2D Upper Compartment Coolers (UCCs) on June 30, 2022.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (2 Samples)

The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:

(1) Maintenance Instruction 0-MI-235.002, 120 VAC Vital Inverter Automatic Transfer Test, following replacement of failed diodes and transformers for the Vital Inverter 1-II on May 17, 2022 (Work Order (WO) 122838226).
(2) Technical Instruction 2-TI-88.01, Primary Containment Vessel Post-Modification Pressure/New Weld Leakage Inspection Test, following reinstallation of the Unit 2 Steel Containment Vessel (SCV) on June 24, 2022 (WO 122343467).

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated refueling outage Unit 2 R4 activities from April 1, 2022, to June 30, 2022. The inspectors completed inspection procedure Sections 03.01.C, D, and E (This completes one sample)

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:

Surveillance Tests (other) (IP Section 03.01) (2 Samples)

(1) Surveillance Instruction 0-SI-82-19-A, 184 Day Fast Start and Load Test DG 2A-A, on April 20, 2022 (WO 122403523).
(2) Surveillance Instruction 0-SI-82-6, Loss of Offsite Power with Safety Injection - DG 2B-B, on June 30, 2022 (WO 121876540).

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Surveillance Instruction 1-SI-74-901-A, Residual Heat Removal Pump 1A-A Quarterly Performance Test, on April 22, 2022 (WO 122403484).

Ice Condenser Testing (IP Section 03.01) (1 Sample)

(1) Surveillance Instruction 2-SI-61-5, 18-month Ice Condenser Lower Inlet Doors Inspection, on June 27, 2022 (WO 121876704).

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) The inspectors observed the sites response to an emergency preparedness drill on June 22, 2022. This drill involved a tornado hitting the site and a loss of offsite power, followed by both emergency diesel generators failing which left the site with no AC power leading to a general emergency declaration.

RADIATION SAFETY

71124.01 - Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated how the licensee identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards. This included the licensee's assessment of radiological hazards specific to steam generator replacement activities.

Instructions to Workers (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards. This included observation of pre-job briefings for steam generator replacement activities.

Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)

The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:

(1) Observed workers exiting the radiologically controlled area (RCA) exit.
(2) Free release of Unit 2 shield building concrete cutout blast plates.
(3) Effluent monitoring plans for control of materials released through U2 containment openings due to steam generator replacement activities.

Radiological Hazards Control and Work Coverage (IP Section 03.04) (4 Samples)

The inspectors evaluated the licensee's As Low As Reasonably Achievable (ALARA)planning, dose tracking, use of temporary shielding, and control of radiological hazards for steam generator replacement activities and general U2R4 job tasks.

(1) U2 pressurizer spray line valve actuator work.
(2) U2 steam generator no. 4 pipe end buffing activities.
(3) ALARA Plan for Radiation Work Permit (RWP) 2022-276, Steam Generator Replacement Structural Interferences, Pipe Supports, and Replace Steam Generators.
(4) Temporary Shielding Request 2022-022, Containment Access Facility Shield Wall.

High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (3 Samples)

The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:

(1) Spent Resin Tank Valve Gallery Room Locked High Radiation Area (LHRA).
(2) Tritiated Drain Collector Tank Room LHRA.
(3) Unit 2 Chemical and Volume Control System (CVCS) Seal Water Return Filter Room LHRA.

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)

(1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &

Transportation

Radioactive Material Storage (IP Section 03.01)

The inspectors evaluated the licensees performance in controlling, labeling and securing the following radioactive materials:

(1) Radioactive Material Storage Area (RMSA) where the steam generators removed from Unit 2 are stored.
(2) Two temporary satellite RMSAs inside the protected area that were established for the unit 2 steam generator replacement outage.
(3) RMSA in warehouse number two outside the protected area.

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

The inspectors walked down the following accessible portions of the solid and liquid radioactive waste systems and evaluated system configuration and functionality:

(1) Spent resin storage tank and associated piping to railroad bay.
(2) Reverse osmosis units in use at Watts Bar waste packaging area.

Waste Characterization and Classification (IP Section 03.03) (3 Samples)

The inspectors evaluated the following characterization and classification of radioactive waste:

(1)2019 and 2021 Dry Active Waste (DAW) 10CFR61 waste stream.

(2)2019 Radwaste Resin 10CFR61 Analysis October 9, 2019

(3) CVCS Waste Stream Generation (February 2022 CVCS Resin L95207) March 3, 2022

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed the preparation of radioactive shipment # WBN-22-111, Low Specific Activity

Shipping Records (IP Section 03.05) (3 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1) WBN-22-02, UN2916, Type B package, CVCS Resin
(2) WBN-21-01, UN2916, Type B package, CVCS Resin
(3) WBN-20-01, UN2916, Type B package, CVCS Resin

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15)===

(1) November 20th, 2021, to April 4th, 2022.

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) November 20th, 2021, to March 12, 2022

71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Freeze Protection deficiencies identified by the NRC during inspections: CRs

===1743977, 1745311, and 1772585. A minor violation was documented in the section of inspection results.

71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)===

(1) The inspectors reviewed the licensees corrective action program for potential adverse trends in third party identified issues in the Corrective Action Program (CAP)that might be indicative of a more significant safety issue. An observation was documented in the section of inspection results.

71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)

The inspectors evaluated the following licensee event reports (LERs):

(1) LER 2021-001-00 for Watts Bar Nuclear Plant, Unit 2, Automatic Reactor Trip on Main Turbine Trip caused by Main Feed Pump Trip due to Low Condenser Vacuum (ADAMS Accession No. ML21130A027): The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.
(2) LER 2019-002-00 for Watts Bar Nuclear Plant, Units 1 & 2, Loss of Control Room Emergency Air Temperature Control System Due to Air Filter Failure (ADAMS Accession No. ML19219A219): The inspectors determined that it was not reasonable to foresee or correct the cause discussed in the LER therefore no performance deficiency was identified. The inspectors did not identify a violation of NRC requirements.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 50001 - Steam Generator Replacement Inspection During the Watts Bar Unit 2 Spring 2022 refueling outage, all four of the Westinghouse model D3 (Alloy 600) original steam generators (OSGs) were replaced with Westinghouse Model 68AXP (Alloy 690) replacement steam generators (RSGs). This inspection report documents inspection activities completed during the second quarter of 2022, as required by IP 50001, Steam Generator Replacement Inspection.

Steam Generator Replacement Inspection (4 Samples 5 Partials)

(1)

(Partial)

Design Changes and Modifications to Systems, Structures, and Components - 10 CFR 50.59 Review (Sections 02.02.a.1 and 02.02.a.2)

The inspectors reviewed the following engineering design change packages for key design aspects and modifications associated with the SG replacement and verified that changes to the facility as described in the updated final safety analysis report (UFSAR) were reviewed and documented in accordance with 10 CFR 50.59. The inspectors used IPs 71111.17T and 71111.18 as guidance to complete the reviews.

31814-EP-C-001, Temporary Structure and Commodities for Reactor Building Modifications

31814-EP-C-002, Temporary Structures and Commodities for Removal and Restoration of the Shield Building Dome and Steel Containment Vessel

DCA 66308-0707, -0708, -0709, and -0715, Modifications to Shield Building Concrete Dome

(2) Review Radiation Protection Program Controls, Planning, and Preparations (Section 02.02.c)The inspectors reviewed radiation protection program controls, planning, and preparation in the following areas utilizing applicable portions of baseline inspection procedures IP 71124.01, 71124.03, 71124.04, 71124.06, and 71124.08 as guidance:

As Low As Reasonably Achievable (ALARA) planning

Dose estimates and dose tracking

Exposure controls including temporary shielding

Contamination controls

Radioactive material management

Radiological work plans and controls

Airborne radioactivity effluent controls

Radioactive waste and material handling, storage, and transportation These areas are documented in Sections 71124.01 and 71124.08 of this report.

(3)

(Partial)

Welding and Non-Destructive Examination (NDE) Activities (Section 02.03.a)

The inspectors observed portions of the welding and nondestructive examination (NDE) activities associated with the steam generator (SG) replacement project.

These items and activities were inspected utilizing the guidance of IP 71111.08.

(4) Activities Associated with Lifting and Rigging (Section 02.03b)

The inspectors observed and reviewed activities associated with transportation of the SGs, both inside and outside of containment, including examination of the lifting equipment used to perform SG rigging and transport activities. The inspectors verified that these activities were bound by the analyses and evaluations as described in engineering packages 31814-EP-C-004, Rigging and Transport, and 31814-EP-C-006, Haul Route and RSG Offload.

(5)

(Partial)

Old and New SG Cutting, Movement, and Reconnection Inside and Outside Containment (Section 02.03.c)

The inspectors observed various portions of the process of removing the OSGs from their respective SG cubicles through the temporary penetrations in the steel containment vessel (SCV) and shield building to the hydraulic trailer transporter. The inspectors also observed various portions of the sequence of the RSGs being transferred from the hydraulic trailer transporter, upended, lifted, and positioned into their respective cubicles.

(6)

(Partial)

Major Structural Modifications to Facilitate SG Replacement (Section 02.03.d)

The inspectors observed several structural modification activities, including removal of sections of the dome of the shield building, removal of sections of the SCV, removal of the top of SG cubicles and their restoration, to verify that the work was done by approved procedures and complied with applicable codes and standards and industry practices.

(7)

(Partial)

Containment Access and Restoration of Temporary Containment Opening and Containment Leakage Testing (Section 02.03.e.)

The inspectors observed containment access and restoration activities associated with the two temporary construction openings in both the shield building dome and steel containment vessel, which were approximately 20 feet by 40 feet, for the Unit 2 SG replacement.

The inspectors reviewed drawings and procedures for the installation of concrete reinforcing steel and Bar-Lock splices and procedures for the control of concrete placement activities. The inspectors observed installation of concrete reinforcing steel and installation of Bar-Lock splices to determine if the work was completed in accordance with requirements shown on design drawings.

The inspectors also reviewed local leak rate test procedure 2-TI-88.01, Primary Containment Vessel Post-Modification Pressure/New Weld Leakage Inspection Test, and observed its implementation to assure ASME code compliance.

(8) Operating Conditions throughout the SGRP Process (Section 02.03.f)

The inspectors routinely inspected the following activities as they occurred throughout this inspection period:

implementation of radiation protection controls

implementation of controls for excluding foreign materials in the primary and secondary side of the SGs and in the related RCS openings

installation, use, and removal of temporary services directly related to steam generator replacement activities

(9) Radiological Safety Plans for Temporary Storage of Retired SGs and Components (Section 02.03.g)

The inspectors reviewed the licensees controls for storage and security of radioactive waste, including plans for the temporary storage of the retired SGs and their components. This area is documented in Section 71124.08 of this report.

INSPECTION RESULTS

Enforcement Discretion Enforcement Action EA-22-034: Failure to Comply with 10 CFR 37 for the Protection of Category 2 Radioactive Material Contained in Contaminated Steam Generators Stored in a Concrete Mausoleum 71124.08

Description:

On January 28, 2021, the NRC issued Inspection Report numbers 05000390/2020004 and 05000391/2020004, which documented a violation of 10 CFR Part 37.11 involving obsolete steam generators (Category 2 material, exempt waste) stored in large concrete storage modules. The violation met the criteria for Enforcement Discretion as described in Enforcement Guidance Memorandum (EGM) 14-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facilities Licensed Under 10 CFR Parts 50 and 52." The inspectors re-evaluated storage and security of the steam generators and determined that there have been no changes since the last inspection.

Corrective Actions: The licensee has documented the issue in their corrective action program. As specified in EGM 14-001, the application of discretion is authorized until the underlying technical issue is dispositioned through rulemaking or other regulatory action.

Corrective Action References: CR 1769321

Enforcement:

Violation: On January 28, 2021, a violation of 10 CFR Part 37.11 was documented in Inspection Report numbers 05000390/2020004 and 05000391/2020004. The inspectors determined that the previously identified violation remains.

Basis for Discretion: This violation continues to meet the criteria for Enforcement Discretion as described in EGM 14-001.

Minor Violation 71152A Minor Violation: Watts Bar procedure 0-PI-OPS-1-FP, Freeze Protection, is a quality related procedure which ensures that freeze protection measures have been installed around the site prior to freezing temperatures occurring. The inspectors identified a performance deficiency and associated minor violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to ensure that activities affecting quality, such as freeze protection of safety related components, shall be prescribed by adequate procedures. Specifically, licensee procedure 0-PI-OPS-1-FP, Freeze Protection, lacks adequate guidance to install freeze protection measures around the Unit 1 and 2 Refueling Water Storage Tanks (RWST) and Main Feed Water (MFW) sensing lines.

Screening: The inspectors determined the performance deficiency was minor. While the 0-PI-OPS-1-FP lacks adequate guidance for installation of freeze protection measures at locations identified by the inspectors, the station does have heat trace over the safety related transmitters at these locations that ensures they would not freeze.

Enforcement:

TVA has established corrective actions to correct the conditions described prior to the onset of next winter. This failure to comply with 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation: Semi Annual Trend Observation 71152S The inspectors reviewed Watts Bar's corrective action program for trends that might be indicative of more significant safety issues. The inspectors reviewed condition reports, level one assessments, system health reports, and control room/panel deficiencies. In particular, the inspectors evaluated the condition reports generated during the first half of 2022 to identify any negative trends in equipment and procedure use and adherence, as well as problem identification and resolution. The inspectors determined that the issues were evaluated by licensee's staff for potential trends at a low threshold and resolved within the scope of the corrective action program. The inspectors did not identify any findings as a result of this inspection.

EXIT MEETINGS AND DEBRIEFS

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

On July 25, 2022, the inspectors presented the integrated inspection results to Mr.

Anthony Williams and other members of the licensee staff.

On April 15, 2022, the inspectors presented the Radiation protection inspection exit meeting inspection results to B. Jenkins and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

50001

Miscellaneous

U2R4 OSG Encapsulation, Rig-Out, and Transport

Communication Plan

Spring 2022

50001

Radiation Work

Permits (RWPs)

251002

U2R4 - SGR Specific Activities - HIGH RADIATION AREAS

- U2 Lower Containment

04/12/2022

71111.04

Corrective Action

Documents

Condition Report

1713247, 1779286

71111.04

Drawings

0-47W855-1-ISI

Mechanical Flow Diagram, Spent Fuel Pool Cooling and

Cleaning System

Revision 85

71111.04

Drawings

1-47W803-1,2

Flow Diagram Feedwater/Auxiliary Feedwater

Revision 1

71111.04

Miscellaneous

Containment Spray Heat Exchanger 1B-B Eddy Current

Examination Report

November

21

71111.04

Miscellaneous

Unit 1 Containment Spray Health Report Scorecard

04/1/2021

71111.04

Miscellaneous

Unit 1 Containment Spray Health Report Scorecard

4/13/2022

71111.04

Miscellaneous

Containment Spray Heat Exchanger 1A-A Eddy Current

Examination Report

September

2018

71111.04

Miscellaneous

47W611-72-1

Electric Logic Diagram

71111.04

Miscellaneous

Flow Diagram 1-

47W812-1

Containment Spray System

71111.04

Miscellaneous

WBN-SDD-N3-

3B-4002

System Description - Auxiliary Feedwater System

Revision 33

71111.04

Procedures

0-SI-30-7-A

Auxiliary Building Gas Treatment System Pressure Test

Train A

Revision 3

71111.04

Procedures

0-SOI-30.06

System Operating Instruction - Auxiliary Building Gas

Treatment System

Revision 6

71111.04

Procedures

0-SOI-78.01

System Operating Instruction - Spent Fuel Pool Cooling and

Cleaning System

Revision 37

71111.04

Procedures

1-SOI-3.02

System Operating Instruction - Auxiliary Feedwater System

Revision 28

71111.04

Procedures

1-SOI-72.01

System Operating Instruction - Containment Spray System

0004

71111.04

Work Orders

Work Orders

118684822, 118684824, 121967428, 122196583

71111.05

Fire Plans

WBN Prefire

Plans

AUX-0-676-01, Rev. 3; AUX-0-772-01, Rev. 1; AUX-0-772-

2, Rev. 5; AUX-0-772-03, Rev. 5; AUX-0-772-01, Rev. 1;

AUX-0-786-01, Rev. 2; CON-0-729-01, Rev. 2; IPS-0-711-

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

01, Rev. 2; IPS-0-728-01, Rev. 3

71111.05

Miscellaneous

WBN FHAR, Part 1 - Introduction, Table I-1 Summary

Compliance Fire Protection

Revision 59

71111.11Q

Miscellaneous

SEG 3-OT-SRT-

WOG3, Part A

WOG3 E-0, ES-1.1, ECA-0.0

Revision 0

71111.11Q

Procedures

2-GO-1

Unit Startup From Cold Shutdown To Hot Standby

Revision 34

71111.11Q

Procedures

2-GO-2

Reactor Startup

Revision 18

71111.11Q

Procedures

2-GO-3

Unit Startup From Less Than 4% Reactor Power to 30%

Reactor Power

Revision 14

71111.11Q

Procedures

2-PET-201

Initial Criticality and Low Power Physics Testing

Revision 6

71111.11Q

Procedures

OPDP-1

Conduct of Operations

Revision 54

71111.18

Engineering

Changes

WBN-2-2022-

067-001

Temporary modification - Isolation of Unit 2 Containment

Penetrations for 2A and 2D Upper Compartment Coolers

(UCCs)

Revision 2

71111.19

Corrective Action

Documents

Condition Report

1766257

71111.19

Procedures

0-MI-235.002

20 VAC Vital Inverter Automatic Transfer Test

0010

71111.19

Work Orders

2838226

71111.22

Corrective Action

Documents

1770894

2A Diesel Generator DG Jacket WTR Level/Pressure Lo

Alarm (Alarm window 213-C) locked in

71111.22

Procedures

0-SI-82-19-A

184-Day Fast Start and Load Test DG 2A-A

Revision 36

71111.22

Procedures

0-SOI-982.03

System Operating Instruction - Diesel Generator (DG) 2A-A

Revision 22

71111.22

Procedures

1-SI-74-901-A

Residual Heat Removal Pump 1A-A Quarterly Performance

Test

Revision 33

71111.22

Procedures

1-SOI-74.01

System Operating Instruction - Residual Heat Removal

System

Revision 20

71111.22

Work Orders

2403484;

2403523

71114.06

Miscellaneous

22 WBN June Quarterly Training Drill Package

6/22/2022

71124.01

Corrective Action

Documents

CR 1763178

04/08/2022

71124.01

Corrective Action

Documents

CR 1764551

71124.01

Corrective Action

CR 1769342

04/13/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

71124.01

Miscellaneous

U2R4 Outage Release Plans

Spring 2022

71124.01

Miscellaneous

U2R4 Radiation Protection Outage Plan

Spring 2022

71124.01

Procedures

NPG-SPP-05.1

Radiological Controls

Rev. 0015

71124.01

Procedures

NPG-SPP-05.18

Radiation Work Permits

Rev. 0009

71124.01

Procedures

RCI-100

Radiological Controls

Revision

0056

71124.01

Radiation Work

Permits (RWPs)

251002

U2R4 - SGR Specific Activities - HIGH RADIATION AREAS

- U2 Lower Containment

04/12/2022

71124.08

Corrective Action

Documents

Resulting from

Inspection

CR 1769069

04/12/2022

71124.08

Corrective Action

Documents

Resulting from

Inspection

CR 1769321

04/13/2022

71124.08

Miscellaneous

U2R4 OSG Encapsulation, Rig-Out, and Transport

Communication Plan

Spring 2022

71124.08

Procedures

RCDP-101

10-CFR-61 Waste Characterization

Revision

0000

71124.08

Radiation

Surveys

PO #34750303

Development of Waste Stream/Distribution for July 2019

DAW

06/27/2019

71124.08

Radiation

Surveys

PO #5871028

Development of Waste Stream/Distribution for DAW

Composite Smears 2021

05/24/2021

71124.08

Shipping Records

NRC Form 541

WBN-21-114

Uniform Low Level Radioactive Waste Manifest for Ice Melt

Shipment

11/30/2022

71124.08

Shipping Records

NRC Form 541

WBN-21-116

Uniform Low Level Radioactive Waste Manifest for Ice Melt

Shipment

11/30/2021