IR 05000390/2023002
| ML23227A031 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 08/16/2023 |
| From: | Louis Mckown Division Reactor Projects II |
| To: | Jim Barstow Tennessee Valley Authority |
| Shared Package | |
| ML23227A032 | List: |
| References | |
| IR 2023002 | |
| Download: ML23227A031 (1) | |
Text
SUBJECT:
REISSUE - WATTS BAR NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000390/2023002 AND 05000391/2023002
Dear James Barstow:
The NRC identified that the inspection report sent dated August 9, 2023, contained an error in section 71152A Assessment. As a result, the NRC is reissuing the report in its entirety to correct this error which could result in misinterpretation of the agencys assessment of licensee performance. The content and context provided by this change does not represent a change in the agencys assessment of licensee performance over the defined inspection period. The agencys assessment of the licensee remains the same as that previously discussed at exit.
On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Watts Bar Nuclear Plant. On August 3, 2023, the NRC inspectors discussed the results of this inspection with Mr. Anthony Williams, Site VP and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Watts Bar Nuclear Plant.
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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Watts Bar Nuclear Plant.
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.
August 16, 2023
Sincerely, Louis J. McKown, II, 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:
Report Numbers:
05000390/2023002 and 05000391/2023002
Enterprise Identifier:
I-2023-002-0023
Licensee:
Tennessee Valley Authority
Facility:
Watts Bar Nuclear Plant
Location:
Spring City, TN 37381
Inspection Dates:
April 1, 2023, to June 30, 2023
Inspectors:
J. Bell, Senior Health Physicist
W. Deschaine, Senior Resident Inspector
K. Henry, Resident Inspector
M. Keefe-Forsyth, Safety Culture Program Manager
M. Magyar, Reactor Inspector
A. Nielsen, Senior Health Physicist
J. Rivera, Health Physicist
D. Simpkins, Sr. Tech Training Program Specialist
J. Weaver, Allegations & Enforcement Specialist
R. Wehrmann, Resident Inspector
D. Willis, Team Leader
Approved By:
Louis J. McKown, II, Chief
Reactor Projects Branch #5
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
Failure to demonstrate effective control of performance of a maintenance rule (a)(2) system Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000390,05000391/2023002-01 Open/Closed
[H.3] - Change Management 71111.12 The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50.65(a)(2) for failure to demonstrate the effective control of performance of a maintenance rule scoped system through appropriate preventive maintenance. Specifically, the licensee failed to adequately monitor performance of the shutdown board room (SDBR) heating ventilation and air conditioning system (HVAC), a maintenance rule scoped system, in accordance with their preventive maintenance program and did not implement (a)(1) goals and corrective actions.
Failure to adequately implement ERCW Surveillance Test Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000390,05000391/2023002-02 Open/Closed
[H.14] -
Conservative Bias 71111.24 The inspectors identified a Green finding and associated NCV of Technical Specification (TS)5.7.1.1 a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2,
Appendix A, February 1978. Specifically, failure to implement Section 6.4 of 0-SI-67-917-A Revision 021, Essential Raw Cooling Water Pumps A-A and B-A Comprehensive Pump Test, and 0-SI-67-918-A, Revision 022, Essential Raw Cooling Water Pumps C-A and D-A Comprehensive Pump Test, and Appendix F of these procedures were not performed.
Specifically, failure to perform these sections did not ensure that the system was restored to its normal alignment.
Additional Tracking Items
None
PLANT STATUS
Unit 1 began the inspection period at rated thermal power (RTP). On April 14, 2023, the unit was shutdown for a planned refueling outage (U1R18). The unit was returned to 100 percent RTP on May 15, 2023. On May 16, 2023, the unit was down powered to 39% due to a Low-Pressure Feedwater Heater string isolation and dropped rod (M4). The unit was returned to 100 percent RTP on May 20, and remained there for the remainder of the inspection period.
Unit 2 operated at or near rated thermal power for the entire 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) Unit 1 Residual Heat Removal system (both trains) on April 20th, 2023.
- (2) Units 1 & 2 Spent Fuel Pool Cooling system on April 26th, 2023.
- (3) Unit 1 Auxiliary Feedwater System on June 28, 2023.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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) Intake Pumping Station (Elevations 711', 722' and 741') on May 24, 2023.
- (2) Cable Spreading Room (Control Building Elevation 729' and 741') on June 5, 2023.
- (3) Unit 1 Control Rod Drive Equipment Room, Pressurizer Heater Transformer Room, and Miscellaneous Equipment Room (Auxiliary Building Elevations 782' and 786') on June 26, 2023.
- (4) Auxiliary Building Corridor (Elevation 676') on June 27, 2023.
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an announced fire drill on May 31, 2023.
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the Unit 1 and 2 turbine driven auxiliary feedwater pump rooms on June 29, 2023.
===71111.08P - Inservice Inspection Activities (PWR) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from April 24, 2023, to April 27, 2023:
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding Activities (IP Section 03.01)===
The inspectors verified that the following nondestructive examination and welding activities were performed appropriately:
- (1) Ultrasonic Examination (UT)
MRP-146-CL-1, Pipe to Nozzle, Augmented (reviewed)
MRP-146-CL-2, Pipe to Nozzle, Augmented (reviewed)
Visual Examination (VT)
Bare metal visual of the Reactor Vessel Closure Head, N-729-6 (reviewed)
PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection
Activities (IP Section 03.02) (1 Sample)
The inspectors verified that the license conducted the following vessel upper head penetration inspections and addressed any identified defects appropriately:
- (1) Bare metal visual of the Reactor Vessel Closure Head, N-729-6 (reviewed)
PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities (IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program through a review of the following evaluations:
- (1) Boric Acid Walkdown - April 17, 2023
CR 1739795
CR 1850475 CR 1850485
CR 1850488
CR 1850494
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (2 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the control room for the following activities:
Unit 1 Startup on May 11, 2023
Dropped Rod recovery on May 18, 2023
- (2) The inspectors observed and evaluated licensed operator performance in the control room during the following activities:
Unit 1 shutdown activities on April 14, 2023
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated the following licensed operator requalification (LOR) simulator scenarios (LOR training cycle 2302), which included a reactor coolant system (RCS) loop 2 T cold failing high, a small break loss-of coolant accident (LOCA), and a large break LOCA.
Crew 5A on June 1, 2023
Crew 5B on June 1, 2023
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 31 - Shutdown Board Room HVAC and timeliness of placing the system in (a)1 status, CR 1848149 documented this condition on April 4, 2023, and inspectors reviewed the CR and Maintenance Rule (a)1 evaluation during May 2023.
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Electrical cable termination on safety related cables in the RCS on April 25, 2023.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 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) Unit 1 shutdown activities for refueling outage April 14 - 15, 2023.
- (2) Unit 1 Blackout testing & Mode 5 & 6 activities during the week of April 16, 2023.
- (3) Risk assessment for (week of) April 23, 2023, with testing on the A train shutdown board and the Unit 1 core having been off-loaded.
- (4) RWST level switch troubleshooting and repair on May 17, 2023, under WO 123741821 and CR 1856924.
- (5) Dropped rod troubleshooting and recovery under CR 1856992 and WO 123741325 on May 17, 2023.
- (6) Unit 1 elevated risk due to A train essential raw cooling water (ERCW) pump troubleshooting and comprehensive testing on May 23, 2023, under WO 123109038.
- (7) Unit 1 elevated risk due to Delta T/TAVG channel tuning being extended to a second workday under WO 122773491 on May 24, 2023, and May 25, 2023.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Operability evaluation of A train ERCW pumps documented in CR 1858712 and Immediate Determination of Operability documented in EWR 123753097 on May 25, 2023.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) WBN-2021-031-002, Temporary chiller to support replacement of B train shutdown board room chiller on June 30, 2023.
- (2) WO TM - 122006136, Installation of an electrical jumper (which supports auto-start logic for SDBR A chiller package) while the SDBR B chiller package is out-of-service for maintenance on June 30, 2023.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage 1R18 activities from April 14, 2023, to May 12, 2023.
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)
- (1) Surveillance Instruction 1-SI-32-901-A, Valve Full Stroke Exercising during Cold Shutdown Control Air (Train A), following maintenance of 1-FCV-32-80 and 1-FCV-32-110, on April 27, 2023 (WO 122771552).
- (2) Surveillance Instruction 1-SI-74-905-A, Residual Heat Removal Pump 1A-A Comprehensive Test during refueling outages, following pump rebuild, on April 28, 2023 (WO 122772523).
- (3) Surveillance Instruction 1-SI-72-906-A, Containment Spray Valve Position Indication Verification / Full Stroke Exercising (Train A), following maintenance of 1-FCV-72-2, on April 30, 2023 (WO 122772211).
- (4) Surveillance Instruction 1-SI-72-908-A, Containment Spray Pump 1A-A Comprehensive Pump Test, following a motor replacement, on April 30, 2023 (WO
===123456131).
- (5) Surveillance Instruction 1-SI-3-920, Valve Position Indication Verification AFW System Turbine Driven AFW Train, following Level Control Valve maintenance on the Unit 1 TDAFW, on May 3, 2023 (WO 122772376).
- (6) Surveillance Instruction 1-SI-3-901-A, Motor Driven Auxiliary Feedwater Pump 1A-A Quarterly Performance Test, following maintenance of 1-CKV-3-815, on May 3, 2023 (WO 123590770).
Surveillance Testing (IP Section 03.01)===
- (1) Surveillance Instruction 0-SI-82-3, Loss of Offsite Power with Safety Injection - DG 1A-A, on April 16-17, 2023 (WO 122771788).
- (2) Surveillance Instruction 0-SI-82-19-A, 184 Day Fast Start and Load Test DG 2A-A, on May 16, 2023 (WO 123108830).
- (3) Surveillance Instructions 0-SI-67-917-A and 0-SI-67-918-A, A train Essential Raw Cooling Water (ERCW) Comprehensive Tests, on May 30, 2023, (WOs 123765351 and 123765355).
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) Surveillance Instruction 1-SI-63-907, Residual Heat Removal Hot Leg and Cold Leg Injection Check Valve Testing During Refueling Outages, on April 18, 2023 (WO
===122771649).
Containment Isolation Valve (CIV) Testing (IP Section 03.01)===
- (1) Surveillance Instruction 1-SI-43-701-A, Containment Isolation Valve Local Leak Rate Test Post Accident Sampling (X-86A), on April 24, 2023 (WO 122772805).
Ice Condenser Testing (IP Section 03.01) (1 Sample)
- (1) Surveillance Instruction 1-SI-61-2, Unit 1 Ice Weighing, from April 30, 2023, to May 7, 2023, (WO 122771773).
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 April 5, 2023. This drill involved a reactor coolant system leak that started small and progressed into a larger break. As the refueling water storage tank drained due to injection into the core, a transfer to cold leg recirculation was required but both containment sump recirculation valves failed to open so the emergency core cooling system pumps and containment spray pumps had to be turned off which led to inadequate core cooling and 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.
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.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
- (1) Material stored in spent fuel pool
- (2) Licensee surveys of potentially contaminated material leaving the Radiologically Controlled Area.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) Unit 1 reactor vessel head lift
- (2) Refuel floor activities
- (3) Unit 1 reactor vessel defueling High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
- (1) Unit 1 entry to under-vessel area
- (2) Tritiated drain collector tank
- (3) Waste packaging area
- (4) Unit 2 pipe chase
- (5) Unit 1 regenerative heat exchanger 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.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Main Control Room Emergency Ventilation System
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) High Efficiency Particulate Air unit in use for Unit 1 seal table work
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the following internal dose assessments:
- (1) Reviewed three positive whole body count records from 06/01/2021 to 05/17/2023
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Reviewed three declared pregnant worker records from 06/01/2021 to 05/17/2023
- (2) Reviewed three multi-badging records from 06/01/2021 to 05/17/2023
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (10 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) Area Radiation Monitors (ARMs) in the auxiliary building
- (2) ARMs in the turbine building
- (3) ARMs on the refueling floor
- (5) Portal Monitors (PMs) at the exit to the RCA
- (7) Portable ion chamber survey meter ready for use in the instrumentation lab
- (8) Telepole radiation survey meter ready for use in the instrumentation lab
- (9) REM Ball neutron survey meter ready for use in the instrumentation lab
- (10) AMP-100 GM ratemeter ready for use in the instrumentation lab
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection instruments:
- (1) Waste Packaging Area Radiation Monitor, 0-RE-90-3
- (2) Unit 2 Upper Containment High Range Radiation Monitor, 2-RE-90-271
- (3) Unit 2 Lower Containment High Range Radiation Monitor, 2-RE-90-273
- (4) SAM-12s, TVA no. 848507
- (7) Ludlum 9-3 ion chamber survey meter, TVA no. 952051
- (8) Telepole II survey meter, TVA no. 952194
- (9) RadEye-G survey meter, TVA no. 951239
- (11) AMS-4 continuous air monitor, TVA no. 860405
- (12) Steadfast II whole body counter
- (13) Ludlum Model-177 benchtop counter, TVA no. 07212
- (14) DMC 3000 self-reading dosimeter, serial no. A1DCE9 Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) Unit 2 Shield Building Vent Radiation Monitor, 2-RE-90-400
- (2) Waste Disposal System Liquid Effluent Monitor, 0-RE-90-122
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) April 4, 2022, through May 17, 2023
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) Qualified Safety Culture Assessors performed a follow-up corrective action inspection the week of May 1, 2023. The scope of this inspection included review of corrective actions taken following identification of safety conscious work environment (SCWE)concerns in the Watts Bar Chemistry Department as observed in NRC Inspection Report 05000390, 391/2022003 and ML23128A275. The May 2023, team conducted interviews and focus groups of impacted licensee staff and leadership.
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 the area of procedure use and adherence in the operations department that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion Personnel Performance (IP section 03.03)
- (1) The inspectors evaluated the B train low pressure feedwater heater isolation and subsequent dropped control bank rod and licensees performance on May 16, 2023.
- (2) The inspectors evaluated operator performance during an unanticipated Unit 2 trip from an intermittent failure of the Current Transformer (CT) 252 on June 29, 2023.
Reporting (IP section 03.05) (1 Sample)
- (1) Inspectors evaluated the licensee submittal of Event Notification 55441 eight-hour notification under 10 CFR 50.72(b)(3)(ii)(B) for unanalyzed condition of 2A EDG.
INSPECTION RESULTS
Failure to demonstrate effective control of performance of a maintenance rule (a)(2) system Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000390,05000391/2023002-01 Open/Closed
[H.3] - Change Management 71111.12 The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR 50.65(a)(2) for failure to demonstrate the effective control of performance of a maintenance rule scoped system through appropriate preventive maintenance. Specifically, the licensee failed to adequately monitor performance of the shutdown board room (SDBR) heating ventilation and air conditioning system (HVAC), a maintenance rule scoped system, in accordance with their preventive maintenance program and did not implement (a)(1) goals and corrective actions.
Description:
While reviewing reliability and availability data for the SDBR HVAC system (system 031, function 030-K) from December 1, 2020, to, January 30, 2023, the inspectors identified that the licensee had changed the plant configuration of the system from the described configuration in the UFSAR.
UFSAR section 9.4.3.2.4 Shutdown Board Room Air-Conditioning System states in part that The electrical boards for either unit can provide the service necessary for the safe shutdown of both plant units following an accident in either unit. Environmental control (for the shutdown boards) is provided by four fan-coil air-handling units supplied with chilled water from two 100% redundant water chillers. One of the two redundant chillers is normally operating, and the other is in standby.
As of February 10, 2022, the licensee modified the plant configuration under TMOD WBN-0-2021-031-002, to install a temporary non-safety related chiller for the B train SDBR chiller.
This non-safety related chiller has been in service providing environmental control for the SDBRs since this date and the A train SDBR room chiller was placed in standby and has not been started or run since. Without performance data required to support (a)(2) status start or run demands the reliability of the A train of SDBR could not be assessed.
The licensees procedure NPG-SPP-03.4, Maintenance Rule, Performance Indicator Monitoring, Trending and Reporting - 10CFR50.65, Section 3.2.6 A. directs licensee staff to change monitoring status from (a)(2) to (a)(1) when performance data required to support (a)(2) status is no longer collected or available.
Hence, NPG-SPP-03.4 required the licensee to change the status of this system from (a)(2)to (a)(1) which they failed to do until the NRC brought this to the sites attention on January 30, 2023.
Corrective Actions: Following the meeting with the NRC on January 30, 2023, the site moved the SDBR HVAC system (system 031, function 030-K) from (a)(2) to (a)(1) and created an (a)(1) evaluation in accordance with their procedure NPG-SPP-03.4. The (a)(1) evaluation was presented to the maintenance rule expert panel on February 16, 2023, and the (a)(1)plan was approved by the maintenance rule expert panel on March 22, 2023. The site also entered this condition into their corrective action plan as CR 1848149.
Corrective Action References: CR 1848149
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to adequately implement the requirements of NPG-SPP-03.4, Maintenance Rule, Performance Indicator Monitoring, Trending and Reporting - 10CFR50.65, Revision 5 was a performance deficiency reasonably within the licensees ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, due to a lack of any performance or condition monitoring of the A Train of the SDBR HVAC system the licensee failed to demonstrate that the performance of the system is being effectively controlled through maintenance. This condition is similar to the Inspection Manual Chapter 0612 Appendix E more than minor Example 8.g.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, attachment 04, Initial Characterization of Findings, and determined that the finding was associated with the Mitigating Systems cornerstone. Using Inspection Manual Chapter 0609, appendix A, The Significance Determination Process For Findings At-Power, exhibit 2, Mitigating Systems Screening Questions, section A, the screening questions, were all answered a NO; therefore, the inspectors determined the finding was of very low safety significance (Green).
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
The inspectors determined that the finding has a cross-cutting aspect of Change Management - H.3 in the Human Performance area because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, when the plant was modified by TMOD WBN-0-2021-031-002 no maintenance rule evaluation was conducted the SDBR HVAC system.
Enforcement:
Violation: 10 CFR 50.65(a)(1), requires, in part, each holder of an operating license for a nuclear power plant under this part shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components, as defined by 10 CFR 50.65(b), are capable of fulfilling their intended functions.
10 CFR 50.65(a)(2), requires, in part, that monitoring as specified in 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function.
Contrary to the above, from January 15, 2022, until March 22, 2023, the licensee failed to demonstrate that the performance or condition of a structure, system, or component was being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remained capable of performing its intended function. Specifically, the licensee failed to demonstrate that the performance of the A SDBR HVAC system was being effectively controlled such that the system remained capable of performing its intended function.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to adequately implement ERCW Surveillance Test Procedure Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000390,05000391/2023002-02 Open/Closed
[H.14] -
Conservative Bias 71111.24 The inspectors identified a Green finding and associated NCV of Technical Specification (TS)5.7.1.1 a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, failure to implement Section 6.4 of 0-SI-67-917-A Revision 021, Essential Raw Cooling Water Pumps A-A and B-A Comprehensive Pump Test, and 0-SI-67-918-A, Revision 022, Essential Raw Cooling Water Pumps C-A and D-A Comprehensive Pump Test, and Appendix F of these procedures were not performed.
Specifically, failure to perform these sections did not ensure that the system was restored to its normal alignment.
Description:
On May 30, 2023, the NRC inspectors reviewed the completed surveillance tests packages of Essential Raw Cooling Water (ERCW) Train A Comprehensive Pump Testing Surveillances 0-SI-67-917-A Rev 021 (Essential Raw Cooling Water Pumps A-A and B-A Comprehensive Pump Test) and 0-SI-67-918-A Rev 022 (Essential Raw Cooling Water Pumps C-A and D-A Comprehensive Pump Test). ERCW Comprehensive Pump tests were performed on 30 May 2023.
During their review, the inspectors observed that the licensee had not performed Appendix F in either procedure. Appendix F in either procedure has a Note that states, in part, that the next steps ensure ERCW flow to the CS and SI Pump Room coolers. Specifically, from May 30, 2023, to June 1, 2023, the licensee failed to implement all portions of these Surveillance procedures. 0-SI-67-917/918-A, Section 6.4 Return to Normal Alignment, steps 12 and 9, respectively, state: Perform Appendix F to check ERCW flow to RHR Pump Room Cooler 1A-A. This step was marked NA due to the installed flow meter being out of service.
The NRC inspectors brought the condition to the attention of the operations department leadership (CR 1859940). Comprehensive pump test alignment has the potential to cause shifts in debris due to opening the cross connection between A and B Trains of ERCW, which has resulted in blockage of some safety related coolers. Licensee staff performed WO 123771615 conditional performance of 1-TI-67.001 Rev 007 (Component Flow Blockage Testing Essential Raw Cooling Water (Train A)) Attachment 4 (Flow Blockage Testing - SI, CS, and RHR Pump Room Cooler 1A), which validated that there was adequate flow to the ECCS components. The test was completed satisfactory on June 01, 2023, at 03:54.
Corrective Actions: Condition was documented in a condition report, additional testing under WO 123771615 was performed to provide objective evidence that the A Train ERCW system was restored to proper alignment post ERCW pump testing.
Corrective Action References: CR 1859940
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to adequately implement Section 6.4 Step [12] of 0-SI-67-917-A Rev 021 and Section 6.4 Step [9] of 0-SI-67-918-A Rev 022 was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Configuration Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to implement procedure steps to ensure ERCW flow to safety related room coolers that are required to function after an accident to ensure continued operation of the supported pumps.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors performed a review of this finding using the guidance provided in IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, and determined this finding is of very low safety significance (Green)because the answer to all 6 questions was NO. For Question 6 if NO screen as Green.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. The inspectors determined that the finding has a cross-cutting aspect of H.14 - Conservative Bias because the licensee lacked the appropriate risk sensitivity to restoration of the ERCW system after performance of the comprehensive pump testing and failed to exercise procedure adherence during system restoration.
Enforcement:
Violation: Unit 1 and Unit 2 Technical Specifications 5.7.1.1 a., requires, in part, that written procedures shall be established, implemented and maintained for the applicable procedures recommended in Regulatory Guide 1.33 Revision 2, Appendix A February 1978. Regulatory Guide 1.33 Revision 2 Appendix A 8.b.(1)(f) requires, in part, that; specific procedures for surveillance tests are required for each surveillance test listed in technical specifications such as Service Water System Functional Tests.
0-SI-67-917-A Rev 021 (Essential Raw Cooling Water Pumps A-A and B-A Comprehensive Pump Test) and 0-SI-67-918-A Rev 022 (Essential Raw Cooling Water Pumps C-A and D-A Comprehensive Pump Test) are Surveillance procedures that perform Inservice Testing for the ERCW pumps. The licensee established 0-SI-67-917-A Rev 021 and 0-SI-67-918-A Rev 022 to verify the operational readiness of the ERCW pumps and provide for a partial determination that the Train A ERCW check valves stroke open or closed. Specifically, Section 6.4 Return to Normal Alignment Step [12] in 0-SI-67-917-A and Step [9] in 0-SI-918-A directed the licensee to PERFORM Appendix F to check ERCW Flow to RHR Pump Room Cooler 1A-A.
Contrary to the above, on May 30, 2023, the licensee failed to implement Section 6.4 Step
[12] of 0-SI-67-917-A and Section 6.4 Step [9] of 0-SI-67-918-A. Specifically, failure to perform Appendix F of 0-SI-67-917-A and 0-SI-67-918-A resulted in failure to ensure that adequate flow was established to the safety related coolers on the A Train ERCW.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Assessment 71152A Qualified Safety Culture Assessors performed a follow-up corrective action inspection the week of May 1, 2023. The scope of this inspection included review of corrective actions taken following identification of SCWE concerns in the Watts Bar Chemistry Department as observed in Reissue Watts Bar Nuclear Plant - Integrated Inspection Report 05000390/2022003 and 05000391/2022003 (ML23128A275). The May 2023 team conducted interviews and focus groups of impacted licensee staff and leadership.
The team found that the corrective actions put into place to correct previously identified work environment issues in this department appear to have been effective. TVA staff engaged by the inspection team reported willingness to raise safety concerns through multiple avenues without fear of retaliation including willingness to use employee concerns and corrective action programs. The agency will continue to monitor SCWE concerns at Watts Bar via the Resident Inspectors and baseline inspection under reactor oversight program.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On August 3, 2023, the inspectors presented the integrated inspection results to Mr.
Anthony Williams, Site VP, and other members of the licensee staff.
On April 27, 2023, the inspectors presented the ISI inspection results to Mr. Anthony Williams, Site VP, and other members of the licensee staff.
On May 18, 2023, the inspectors presented the Radiation Protection inspection results to Mr. Anthony Williams, Site VP, and other members of the licensee staff.
On July 27, 2023, the inspectors presented the initial integrated inspection results to Mrs. Beth Jenkins, Watts Bar Plant Manager, and other members of the licensee staff.
THIRD PARTY REVIEWS Inspectors reviewed World Association of Nuclear Operators (WANO) report that was issued during October 2022. No safety significance issues were identified.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
0-47W855-1-ISI
Mechanical - Flow Diagram Fuel Pool Cooling And Cleaning
System
Revision 0
Drawings
1-47W810-1-ISI
Unit 1 Flow Diagram Residual Heat Removal System
Revision 0
Drawings
WBN-47W803-1
Flow Diagram Feedwater
Revision 39
Drawings
WBN-47W803-
101
Stress Analysis Problem Boundary Drawing Feedwater
Revision 2
Procedures
0-SOI-78.01
Spent Fuel Pool Cooling and Cleaning System
Revision
0042
Procedures
0-SOI-78.01 ATT
1V
Spent Fuel Pool Cooling and Cleaning System Valve
Checklist
Revision 10
Procedures
1-SOI-3.02
System Operating Instruction, Auxiliary Feedwater System
Revision 30
Procedures
1-SOI-74.01
Residual Heat Removal System
Revision
22
Calculations
EPMDOM-
2990
Combustible Loading Data
0148
Fire Plans
CON-0-729-01
Control Building Elevations 729 & 741
2
Fire Plans
CON-0-729-01
MAP
Control Building Elevations 729 & 741
003
Fire Plans
WBN-PFP-AUX-
0-676-01
Pre-Fire Plan for the Auxiliary Building Corridor Elevation 676
Revision 3
Fire Plans
WBN-PFP-AUX-
0-772-05, Rev. 5
Pre-Fire Plan for the Auxiliary Building Elevation 772
Revision 5
Fire Plans
WBN-PFP-AUX-
0-786-01
Pre-Fire Plan for the Auxiliary Building Elevation 786
Revision 2
Miscellaneous
TVA 41419
Fire Drill Evaluation Report
May 31,
23
Procedures
WBN-NPG-SPP-
18.4.7
Transient Combustibles
Revision 18
Procedures
MDN-000-999-
2008-0146
WBN Probabilistic Risk Assessment - Internal Flooding
Analysis Notebook
Revision 4
Procedures
WB-DC-40-31.51
Evaluating the Effects of Flooding due to Moderate Energy
Pipe Failures Inside and Outside Containment
Revision 5
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Inspection Report
Number: 868414
QC Inspection Report Number
4/25/2023
Miscellaneous
W47 230412 500
QC certifications for Darrick L. Handy
9/19/2022
Procedures
0-SOI-30.07
Shutdown Board Rooms HVAC EL 757 & 772
26
Procedures
0-TI-31.004
Installation and Operation of Temporary Chiller for B SDBR
Chiller
000
Procedures
NPG-SPP-09.4
CFR 50.59 Evaluations of Changes, Tests, and
Experiments
0018
Corrective Action
Documents
Resulting from
Inspection
CR 1855245
NRC Identified Containment Debris following Mode 4
containment closeout
05/9/2023
Corrective Action
Documents
Resulting from
Inspection
CR 1856847
(NRC Identified) Update DG test procedures to include
alternate method of cylinder measurement.
05/16/2023
Procedures
0-MI-61.06
Servicing Ice Condenser
Revision 13
Procedures
0-SI-67-917-A
Essential Raw Cooling Water (ERCW) Pump A-A and Pump
B-A Comprehensive Tests
Revision 21
Procedures
0-SI-67-918-A
Essential Raw Cooling Water (ERCW) Pump C-A and Pump
D-A Comprehensive Tests
Revision 22
Procedures
0-SI-82-19-A
184 Day Fast Start and Load Test DG 2A-A
Revision 37
Procedures
0-SI-82-3
Loss of Offsite Power With Safety Injection - DG 1A-A
Revision 80
Procedures
1-SI-3-901-A
Motor Driven Auxiliary Feedwater Pump 1A-A Quarterly
Performance Test
Revision 40
Procedures
1-SI-32-901-A
Valve Full Stroke Exercising during Cold Shutdown Control
Air (Train A)
Revision 22
Procedures
1-SI-43-701-A
Containment Isolation Valve Local Leak Rate Test Post
Accident Sampling
Revision 13
Procedures
1-SI-61-2
Unit 1 Ice Weighing
Revision 25
Procedures
1-SI-63-907
Residual Heat Removal Hot Leg and Cold Leg Injection
Check Valve Testing During Refueling Outages
Revision 36
Procedures
1-SI-72-906-A
Containment Spray Valve Position Indication Verification /
Full Stroke Exercising (Train A)
Revision 18
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
1-SI-72-908-A
Containment Spray Pump 1A-A Comprehensive Pump Test
Revision 6
Procedures
1-SI-74-905-A
Residual Heat Removal Pump 1A-A Comprehensive Test
during refueling outages
Revision 8
Procedures
1-TI-61.003
Containment Debris Log
Revision 2
Procedures
1-TI-61.005
Manipulation and Use of ICEMAN Data
Revision 0
Procedures
TI-100.001
Inservice Testing of Pumps
Revision 19
Procedures
TI-100.002
Inservice Testing of Valves
Revision 17
Miscellaneous
23 WBN April Training Drill (Team B) Package
4/5/2023
Corrective Action
Documents
Resulting from
Inspection
CR 1850900
Corrective Action
Documents
Resulting from
Inspection
CR 1857250
Corrective Action
Documents
Resulting from
Inspection
CR 1857499
Corrective Action
Documents
Resulting from
Inspection
CR 1857503
Miscellaneous
NuclearIQ Database, tritium concentrations in the spent fuel
pool
03/18/23 -
04/19/23
Procedures
NISP-RP-002
Radiation and Contamination Surveys
Rev. 1
Procedures
NISP-RP-004
Radiological Posting and Labeling
Rev 1
Procedures
NISP-RP-007
Control of Radioactive Material
Rev 1
Procedures
RCI-137
Radiation Protection Tritium Control Program
Rev 9
Radiation
Surveys
140423105
1R18 Upper Containment Upper Containment Air Sample
04/14/2023
Radiation
Surveys
WBN-M-
230415-1
U1 A CCP Room
04/15/23
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation
Surveys
WBN-M-
230516-7
2' Plenum Room Posting Update
05/16/23
Radiation Work
Permits (RWPs)
23160012
U1R18 Outage - Upper Containment High Radiation Area
Rev 0
Procedures
RCI-107
Respiratory Protection Equipment Inspection, Maintenance,
Issuance and Accountability
Rev 33
Corrective Action
Documents
Resulting from
Inspection
CR 1851507
Miscellaneous
TVA RP Prospective Determination for Occupational
Exposure (2011-2018)
Rev. 2
Miscellaneous
SSD-0-LPR-90-3
Scaling and Setpoint Document for Waste Package Area
Monitor
Rev. 11
Miscellaneous
SSD-2-LPR-90-
400
Scaling and Setpoint Document for Unit 2 Shield Building
Radiation Monitor
Rev. 22
Procedures
2-SI-90-1
Month Channel Calibration Containment Upper
Compartment High Range Post Accident Area Radiation
Monitor Loop 2-LPR-90-271-A
Rev. 0005
Procedures
2-SI-90-3
Month Channel Calibration Containment Lower
Compartment High Range Post Accident Area Radiation
Monitor Loop 2-LPR-90-273-A
Rev. 0005
Corrective Action
Documents
CR 1805670
Corrective Action
Documents
CR 1805670
Corrective Action
Documents
1856930
Several Operations SIs do not have the correct Start and
Stop times in Maximo
Corrective Action
Documents
1856935
The surveillance task sheets (STS) for 13 vaulted
surveillances were not fully completed
Corrective Action
Documents
1856945
Incomplete QA records in ECM
Corrective Action
Documents
1858681
QA identified a deficiency associated with T-Mods not being
correctly closed
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
WBN-2-GO-5
Unit Shutdown From 30% Reactor Power to Hot Standby
Revision 9
Procedures
WBN-ES-0.1
Reactor Trip Response
Revision 26