IR 05000390/2023010
| ML23328A130 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 11/30/2023 |
| From: | Louis Mckown NRC/RGN-II/DRP/RPB5 |
| To: | Jim Barstow Tennessee Valley Authority |
| References | |
| EA-23-104 IR 2023010 | |
| Download: ML23328A130 (22) | |
Text
November 30, 2023
SUBJECT:
REISSUE WATTS BAR NUCLEAR PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000390/2023010 AND 05000391/2023010 AND APPARENT VIOLATION
Dear Jim Barstow:
The NRC identified that the inspection report sent to you dated October 24, 2023, contained several administrative errors: EA-23-104 was inadvertently left out from the report cover letter and the Agency was not ready to provide a preliminary significance at this time. Therefore, the report has been updated to reflect the pending significance determination. As a result, the NRC is reissuing the report in its entirety to correct these administrative errors. The content and context provided by these changes do 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 September 27, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Watts Bar Nuclear Plant and discussed the results of this inspection with Mr. Tony Williams and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
J. Barstow: 2 Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
Section 71152B of the enclosed report documents a finding with an associated apparent violation for which the NRC has not yet reached a preliminary significance determination.
This involved a licensee identified apparent violation (AV) of Unit 2 Technical Specification (TS) 5.7.1.1.a., Procedures, concerning the failure to implement procedure 2-TI-68.002, Containment Penetrations and Closure Control. Specifically, 2-TI-68.002 requirements for containment closure control were not implemented for containment penetration X-36 when the penetration was opened to support testing during U2R4.
The NRCs significance determination process (SDP) is designed to encourage an open dialogue between your staff and the NRC; however, neither the dialogue nor the written information you provide should affect the timeliness of our final determination. We ask that you promptly provide any relevant information that you would like us to consider in making our determination. We are currently evaluating the significance of this finding and will notify you in a separate correspondence once we have completed our preliminary significance review. You will be given an additional opportunity to provide additional information prior to our final significance determination unless our review concludes that the finding has very low safety significance (i.e., Green).
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the NCV or the significance or severity of the NCV 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.
J. Barstow: 3 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, Signed by McKown, Louis on 11/30/23 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: NPF-90 and NPF-96 Report Numbers: 05000390/2023010 and 05000391/2023010 Enterprise Identifier: I-2023-010-0028 Licensee: Tennessee Valley Authority Facility: Watts Bar Nuclear Plant Location: Spring City, TN 37381 Inspection Dates: August 07, 2023, to August 25, 2023 Inspectors: A. Alen, Senior Project Engineer D. Hardage, Senior Resident Inspector S. Ninh, Senior Project Engineer R. Wehrmann, Resident Inspector Approved By: Louis J. McKown, II, 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 biennial problem identification and resolution 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 Properly Adjust Containment Spray Pump Start Circuit Relay Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.11] - 71152B NCV 05000390/2023010-01 Challenge the Open/Closed Unknown A self-revealing Green Finding and associated non-cited violation (NCV) of Technical Specifications 5.7.1.1.a, Procedures, was identified for the licensees failure to implement instructions in maintenance procedure 0-MI-57.029, HFA Relay Maintenance, during contact wipe and gap adjustment of auxiliary relay 30RX associated with the unit 1 B train (1B)containment spray (CS) pump. As a result, the 1B CS spray pump was rendered inoperable.
Uncontrol opening of penetration X-36 results in Unrecognized Loss of Containment Closure Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Pending AV 05000391/2023010- [H.12] - Avoid 71152B 02 Complacency Open EA-23-104 A licensee identified finding with its safety significance as yet to be determined (TBD) and an associated apparent violation (AV) of Unit 2 Technical Specification (TS) 5.7.1.1.a.,
Procedures, was identified when the licensee failed to implement procedure 2-TI-68.002,
Containment Penetrations and Closure Control. Specifically, 2-TI-68.002 requirements for containment closure control were not implemented for containment penetration X-36 when the penetration was opened to support testing during U2R4.
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 - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the 125 volt vital DC system (batteries and DC boards) and emergency diesel generators. A sample of corrective actions for non-cited violations, licensee-identified violations, and findings issued since June 2021 were evaluated as part of the assessment.
- Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
- Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Assessment 1. Corrective Action Program Effectiveness Problem Identification: The team determined that the licensee was generally effective in identifying problems and entering them into the Corrective Action Program (CAP) at the appropriate threshold. This conclusion was based upon the inspectors' review of the requirements for initiating condition reports (CR) as prescribed by licensee procedure, NPG-SPP-22.300, "Corrective Action Program," and site management's expectation that employees are encouraged to initiate CRs. The inspection team observed licensee staff at the Plant Screening Committee (PSC) and Management Review Committee (MRC) meetings actively questioning and challenging CRs to ensure issues were adequately documented and entered into the CAP. Based on samples reviewed, the inspectors determined that licensee staff adequately trend equipment and programmatic issues at an appropriate level. The inspectors performed walkdowns, reviewed CRs, and system health and trend reports for the 125 volt vital DC system and the emergency diesel generators. Based upon these reviews and system walkdowns, the inspectors determined that deficiencies were being identified and entered into the CAP. Overall, the team determined that issues were being identified and documented at the appropriate threshold.
Problem Prioritization and Evaluation: Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were prioritized and evaluated in accordance with the CAP requirements prescribed in procedure NPG-SPP-22.300. Based on reviews and observations, the inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors reviewed causal analyses to ensure licensee staff appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. The inspectors determined that plant personnel had generally conducted cause evaluations in compliance with the CAP procedures and performed adequate levels of analysis based on the significance of the issue being evaluated. Overall, the licensee's process for evaluating and prioritizing issues supported nuclear safety.
Effectiveness of Corrective Actions: Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors determined that corrective actions generally were effective, timely, and commensurate with the safety significance of the issues. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed CRs and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition (CAPR) were sufficient to ensure corrective actions were properly implemented and were effective. The inspectors reviewed corrective action documents for NRC findings issued since the last problem, identification, and resolution (PI&R) biennial inspection. The team determined that corrective actions completed or planned, including expected completion dates, were adequate to address the NRC findings.
The inspectors did determine that the licensee had closed eleven CRs to toolpouch maintenance on the emergency diesel generators over the past two years. This practice is a minor violation of the licensee's Technical Specifications which require written instruction in order to perform maintenance on safety related systems.
2. Use of Operating Experience (OE)
Based on a review of selected documentation related to OE issues, the team determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of document. Relevant information was forwarded to the applicable department for further action or informational purposes. Operating experience issues requiring action were entered into the CAP for tracking and closure. The team determined that the licensee's use of industry and NRC OE was generally effective, and the program adequately supported nuclear safety.
3. Self-Assessments and Audits
The team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical. The team verified that CRs were created to document areas for improvement and findings resulting from self-assessments, and that actions had been completed consistent with the staff recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.
4. Safety Conscious Work Environments (SCWE)
The team interviewed approximately 30 individuals that had varying roles and levels of responsibility within the organization. These interviews included a conversation with the sites employee concerns program manager. The team focused their questions on individuals willingness and ability to identify issues, freedom from potential retaliation for raising safety concerns, and effectiveness of the CAP at resolving issues. The team did not identify any impediment to the establishment of a safety conscious work environment. Individuals felt free to raise safety concerns.
Failure to Properly Adjust Containment Spray Pump Start Circuit Relay Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.11] - 71152B NCV 05000390/2023010-01 Challenge the Open/Closed Unknown A self-revealing Green Finding and associated non-cited violation (NCV) of Technical Specifications 5.7.1.1.a, Procedures, was identified for the licensees failure to implement instructions in maintenance procedure 0-MI-57.029, HFA Relay Maintenance, during contact wipe and gap adjustment of auxiliary relay 30RX associated with the unit 1 B train (1B) containment spray (CS) pump. As a result, the 1B CS spray pump was rendered inoperable.
Description:
On August 10, 2021, the 1B CS pump was declared inoperable after the pump failed to start during a quarterly test per procedure 1-SI-72-901-B, Containment Spray Pump 1B-B Quarterly Performance Test. The licensee entered the associated TS Action Statement (TSAS 3.6.6.A) which has a 72-hour completion time for a required action to restore operability. Troubleshooting at the pumps breaker cubicle identified that the failure was due to inadequate contact wipe or make-up of the 9 and 10 contacts on the 30RX relay. The 9 and 10 contacts are normally open (NO) contacts in the start circuitry of pump. During a pump start the contacts close to arm the circuitry in order to close the pump breaker. The as-found measurement of the contacts wipe was out-of-spec (OOS) low and did not ensure good contact make-up. The 30RX relay was replaced and the pump was restored to operable status.
The licensee conducted a causal evaluation of the failed relay (CR 1713247), which included a failure analysis by the relay vendor. On October 7, 2021, the licensee received the failure analysis. The vendor findings were consistent with an improperly set relay. Specifically, the vendor confirmed the contact wipe was OOS low, consistent with the licensees troubleshooting assessment. The contact wipe was measured at 0.018-inches where the acceptable range is 0.046 - 0.093-inches, and the relays armature stop-screw locknut was loose. These conditions would cause unreliable operation of the relay. The licensee replaced the 30RX relay on March 29, 2021, approximately four and half months before the pump failure. A review of the relay replacement work order (WO) WO119409898 and maintenance procedure 0-MI-57.029 identified that technicians
- (1) adjusted the contacts wipe by contact forming/bending (step 6.6.3), and
- (2) adjusted the NO contact gap, by adjustment of the stop-screw (step 6.6.7), during relay bench testing and prior to installation in the breaker cubicle.
With respect to configuration control of the stop-screw, it was noted that tightening of the stop-screw locknut, following adjustment, was not explicitly covered by a procedure step and likely contributed to the as-found condition. Considering the maintenance activities conducted during the March 2023 relay replacement, the stop-screw configuration control shortfall, and the as-found condition/setup of the relay it was determined that the relay was not properly set during execution of WO119409898.
The inspectors reviewed the bench test and post-maintenance test (PMT) results following replacement of the relay. Despite satisfactory operation of the relay during these tests, the deficiency introduced by the maintenance would not have resulted in a guaranteed failure of the relay, but rather unreliable operation, and therefore, the condition may or may not have been revealed during the PMT.
Corrective Actions: The licensee replaced the failed 30RX relay on August 10, 2021, per WO 122325520, and restored operability of the pump. Additionally, revised maintenance procedure 0-MI-57.029 to minimize relay adjustments, when not needed; and included instructions to secure the stop-screw locknut following adjustment.
Corrective Action References: CRs 1713247 and 1873548; WO 122325520
Performance Assessment:
Performance Deficiency: The failure to properly implement instructions in maintenance procedure 0-MI-57.029, HFA Relay Maintenance, during contact wipe and gap adjustment of auxiliary relay 30RX associated with the unit 1B CS pump was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the improperly set relay affected the operability of the 1B CS pump.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix H, Containment Integrity SDP. The finding screened out as Green using the guidance in IMC 0609 Appendix H because, per Table 4.1, containment sprays do not impact the large early release frequency (LERF) for pressurized water reactors.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. The contact wipe and gap of new relays, for which contact configuration is not modified by the user (such as the subject relay), should not need contact wipe and gap adjustment because these specs are checked and verified by the relay supplier during the commercial grade dedication process. Watts Bar personnel did not stop when identifying that the contact wipe and gap were OOS, during WO119409898, to evaluate both the
- (1) adequacy of contact wipe and gap check maintenance practices or
- (2) the performance of the new relay before proceeding with making potentially unwarranted adjustments.
Enforcement:
Violation: Unit 1 Technical Specifications 5.7.1.1 a., requires, in part, that written procedures shall be implemented for the applicable procedures recommended in Regulatory Guide (RG)1.33 Revision 2, Appendix A February 1978. Section 9.a of Appendix A of RG 1.33 required in part, that maintenance which can affect the performance of safety-related equipment should be performed in accordance with written procedures. Procedure 0-MI-57.029 HFA Relay Maintenance, revision 2, is a maintenance procedure which can affect the performance the multi-contact auxiliary relays used for safety-related equipment. Procedure steps 6.6.3 and 6.6.7 required verification and as-needed adjustment of the normally open relay contacts.
Contrary to the above, on March 29, 2021, the licensee failed to properly implement relay maintenance procedure 0-MI-57.029 steps 6.6.3 and 6.6.7, which affected the reliability and operability of the 1B CS pump until August 10, 2021. Specifically, the licensee failed to set and verify NO contacts wipe and secure the armature stop-screw locknut following gap adjustment of NO contacts during relay bench testing prior to installation on the pump breaker control circuit.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Uncontrol opening of penetration X-36 results in Unrecognized Loss of Containment Closure Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Pending AV 05000391/2023010- [H.12] - Avoid 71152B Complacency Open EA-23-104 A licensee identified finding with its safety significance as yet to be determined (TBD) and an associated apparent violation (AV) of Unit 2 Technical Specification (TS) 5.7.1.1.a.,
Procedures, was identified when the licensee failed to implement procedure 2-TI-68.002, Containment Penetrations and Closure Control. Specifically, 2-TI-68.002 requirements for containment closure control were not implemented for containment penetration X-36 when the penetration was opened to support testing during U2R4.
Description:
On March 1, 2022, Unit 2 shutdown for refueling outage U2R4. The scope of this outage included the replacement of steam generators. To support differential pressure testing on ECCS motor operated valves, work order (WO) 122641445, Breach and Seal Penetrations in Support of Differential Pressure Test, was planned to breach Unit 2 containment penetration X-36, a 24-inch penetration that is normally sealed with a blind flange, and penetration 0-SLV-304-R2S051 which is a one-inch penetration from the auxiliary building to the annulus.
Breaching containment penetration X-36 is not a standard outage activity, and planning, engineering, and operations personnel responsible for planning WO 122641445 did not identify the requirement that X-36 needed to be controlled in accordance with 2-TI-68.002 to establish emergency containment closure controls.
During Modes 5 and 6, the licensee maintains control of the containment vessel in accordance with 2-TI-68.002, Containment Penetrations and Closure Control. Per 2-TI-68.002 Sec.1.2.C. the scope of this procedure is to control the breaching, tracking and closure of Any penetration providing direct access from the containment atmosphere to the outside atmosphere. Additionally, 2-TI-68.002 states under Sec. 2.3 (Commitments) Any work that involves an open penetration will have a predetermined action plan for re-establishing containment closure. The action plan for re-establishing containment closure ensures that in the event of a loss of cooling to the reactor, primary containment can be established prior to the core boiling and the potential release of radioactive material. Thus, for each open penetration, a responsible on-shift individual is designated to maintain communication with the Operations on-shift crew and to have personnel and material available to, if directed, seal the penetration within the prescribed time.
On March 4, 2022, at 2000 with Unit 2 in mode 5, containment penetration X-36 was logged opened by licensee maintenance personnel on TI-65 breech permit number 7242, but containment closure requirements were not established in accordance with 2-TI-68.002. The requirement to ensure X-36 was controlled by 2-TI-68.002 was not in WO 122641445 and was not recognized by Operations on shift personnel who authorized the work or by the maintenance personnel who performed the work.
At the time containment penetration X-36 was opened, the unit was in Mode 5. The plant entered mode 6 on March 5, 2022, at 1013 and was defueled March 9, 2022, at 1013.
Corrective Actions: The licensee initially identified this issue during a post steam generator replacement containment return to service (ILRT) pretest walkdown on June 20, 2022 and closed the penetration to reestablish containment closure control.
Corrective Action References: CR 1784613, WO 122641445
Performance Assessment:
Performance Deficiency: The licensees failure to evaluate and maintain containment closure control of Penetration X-36 in accordance with 2-TI-68.002, Containment Penetrations and Closure Control, 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 Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, on March 4, 2022, Penetration X-36 was breeched but not evaluated or tracked for containment closure.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix G, Shutdown Safety SDP. Using Attachment 1 "Phase 1 Initial Screening and Characterization of Findings," Exhibit 4 "Barrier Integrity Screening Questions" the inspectors were directed to IMC 0609 Appendix H "Containment Integrity Significance Determination Process, because the finding degraded the physical integrity of reactor containment (valves, penetrations, containment isolation components). Using IMC 0609 Appendix H, since the finding only affects LERF, and not CDF, it is considered a Type B shutdown finding and is evaluated per Section 07.02, Approach for Assessing Type B Findings at Shutdown. Per Step 2.1, the finding occurred within eight days of the outage in POS 2, so the inspectors continued to Step 2.2. Containment status was determined to be intact, based on Note 1 of Table 7.3, Phase 1 Screening-Type B Findings at Shutdown. (An intact containment is one in which, the licensee intends to:
- (1) close all containment penetrations with a single barrier or can be closed in time to control the release of radioactive material, and
- (2) maintain the containment differential pressure capability necessary to stay intact following a severe accident at shutdown. A Type B performance deficiency results when a licensee intends to have an intact containment but cannot maintain that capability due to a performance deficiency). Step 2.2.A directs the inspectors to use Table 7.3. Table 7.3 directs a phase II evaluation to be performed.
Because the issue did not screen to green in phase II, a phase III detailed risk assessment using plant specific values, actual exposure times for this case, potential release paths from this penetration, and shutdown risk models is required. At the time of the report a shutdown risk model was being developed independently by the NRC and licensee to accurately assess shutdown risk posed by this performance deficiency.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools.
Enforcement:
Violation: Violation: Unit 2 TS 5.7.1.1 a., requires, in part, that written procedures shall be implemented for the applicable procedures recommended in Regulatory Guide (RG) 1.33 Revision 2, Appendix A February 1978. Section 3.f of Appendix A of RG 1.33 required in part, procedures for maintaining containment integrity. Procedure 2-TI-68.002, Containment Closure Control implements penetration closure requirements to establish containment integrity. 2-TI-68.002, requires in part that when breaching the containment during modes 5 and 6, the breach is evaluated to ensure the breach can be closed within an allowed closure time and an owner is assigned to close the breach if containment closure is required.
Contrary to the above, from March 4, 2022, until June 20, 2022, 2-TI-68.002 was not implemented in that a breach of containment penetration X-36 existed and was not evaluated and no owner responsible to close the penetration was assigned.
Enforcement Action: This violation is being treated as an apparent violation for which the NRC has not yet reached a preliminary significance determination.
Minor Violation 71152B Maintenance on Safety Related Equipment performed without a procedure Minor Violation: 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. Section 9.a of Appendix A of RG 1.33 required in part, that maintenance which can affect the performance of safety-related equipment should be performed in accordance with written procedures. Contrary to this requirement, from May 2021 to August 2023, the licensee utilized toolpouch maintenance to perform maintenance on 11 safety-related components associated with the Emergency Diesel Generators without written instructions. This is documented in the following CRs: 1696966, 1696967, 1717823, 1720614, 1751484, 151487, 1788636, 1792337, 1805186, 1811355, and 1866458.
Screening: The inspectors determined the performance deficiency was minor. This performance deficiency is minor due to not adversely impacting a cornerstone objective. Specifically, the maintenance performed did not affect the Equipment Performance attribute of the Mitigating Systems cornerstone objective.
Enforcement:
This failure to comply with Technical Specification 5.7.1.1 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On August 24, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Tony Williams and other members of the licensee staff.
- On September 27, 2023, the inspectors presented the re-exit of the final inspection results inspection results to Mr. Tony Williams and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action Condition Reports 1713247, 1720521, 1723063, 1817755, 1849087, 1766257, Various
Documents 1701395, 1851822, 1793055, 1767760, 1817755, 1849087,
27818, 1720798, 1848129, 1837825, 1701395, 1828767,
1785142, 1790248, 1828755, 1730744, 1810067, 1716363,
24392, 1725092, 1725095, 1725098, 1725099, 1739851,
1693301, 1735476, 1726660, 1732325, 1735398, 1735476,
1805670, 1856992, 1864894, 1784613, 1738298, 1736528,
1736522, 1772573, 1776865, 1772580, 1832934, 1812859,
1812797, 1812353, 1812082, 1691949, 1733322, 1734382,
1735449, 1761784, 1851652, 1874817, 1731534, 1753834,
1770378, 1789760, 1806976, 1825295, 1861185, 1861244,
1702521, 1702823, 1701902, 1701567, 1769321, 1800709,
1692972, 1703452, 1712251, 1739331, 1741236, 1783684,
1784613, 1789589, 1789612, 1791856, 1803935, 1808489,
1819909, 1829930, 1831057, 1838903, 1853974, 1853985,
1856703, 1856708, 1856927, 1856930, 1856935, 1856945,
1857455, 1857459, 1858022, 1858759, 1858760, 1858921,
1860055, 1860056, 1867883,
1870480
71152B Corrective Action CR1431534 Organizational Effectiveness and Programmatic Checklist: 12/08/2021
Documents Elevated Sample Results in Well S and R
71152B Corrective Action CR1766257 Equipment Failure Investigation Checklist: Vital Inverter 01/11/2023
Documents Failure Resulting in the loss of 120VAC Vital Power Board
71152B Corrective Action CR1793055 Organizational Effectiveness and Programmatic and 09/15/2022
Documents Equipment Failure Investigation Checklists: Common
Station Service Transformer Tripped
71152B Corrective Action CR 1874651 2023 WBN PI&R Inspection - 125Vdc Safety-Related 08/15/2023
Documents Batteries Improper Power Cable Ties and Bend Radius
Resulting from
Inspection
71152B Corrective Action CR1873048 2023 NRC PI&R Inspection report - CR 1808489 contains 08/07/2023
Documents Proprietary information
Inspection Type Designation Description or Title Revision or
Procedure Date
Resulting from
Inspection
71152B Corrective Action CR1873437 2023 WBN PI&R Inspection - NPG-SPP-01.7.1 feedback 08/09/2023
Documents
Resulting from
Inspection
71152B Corrective Action CR1873548 2023 WBN PI&R Inspection - Contact engineering prior to 08/09/2023
Documents performing wipe and gap in 0-MI-57.029
Resulting from
Inspection
71152B Corrective Action CR1873576 2023 WBN PI&R Inspection - Information Notice IN 21-03 08/09/2023
Documents
Resulting from
Inspection
71152B Corrective Action CR1873578 2023 WBN PI&R Inspection - Information Notice IN 22-01 08/09/2023
Documents
Resulting from
Inspection
71152B Corrective Action CR1874292 2023 WBN PI&R Inspection - Information Notice extent of 08/14/2023
Documents condition
Resulting from
Inspection
71152B Corrective Action CR1875277 2023 WBN PI&R Inspection - Gap between battery cell 1 08/17/2023
Documents and upper end stringer support larger than drawing
Resulting from (062823D) specification
Inspection
71152B Corrective Action CR1876034 2023 WBN PI&R Inspection - Vital batteries' power cables 08/22/2023
Documents unsupported per recommended length
Resulting from
Inspection
71152B Corrective Action CR1876051 2023 WBN PI&R Inspection - NRC identified POE required 08/22/2023
Documents for issue associated with CR 1713247
Resulting from
Inspection
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action CR1876404 2023 WBN PI&R Inspections - C-4 CR 1734382 closed to E 08/23/2023
Documents level CR
Resulting from
Inspection
71152B Corrective Action CR1876404 2023 WBN PI&R Inspections - C-4 CR 1734382 (U1 08/23/2023
Documents Reactor Cavity Leaking, assigned to RP) closed to E level
Resulting from CR
Inspection
71152B Drawings 0-45W700-1 Key Diagram - 120V AC &125V DC Vital Plant Control Rev. 0
Power Systems
71152B Drawings 0-45W700-2 Key Diagram - 250VDC, 120V Preferred, 48VDC & 120 Rev. 1
VAC Misc. Plant Power Systems
71152B Drawings 0-45W703-1 thru 4 Wiring Diagram - 125V Vital Battery Boards I, II, III, and IV - Rev. 0
Single Line
71152B Drawings 062823D Layout for 60 Cells NCX-2250 Battery on 2-S07-074526- Rev. 904
806 & 1-S07-074526-816 Two Step Racks; 13'-0" LG.
(Heavy Seismic Restraint)
71152B Drawings 1-45W760-72-1 Wiring Diagrams - Containment Spray System Schematic Rev. 19
Diagram
71152B Drawings 45N218 Electrical Equipment Battery & DC Equipment Rooms Rev. 12
Plans, Sections,& Details
71152B Drawings K-7569 C&D Outline LCUN-29, 33 (WBN Contract 95N7D-124639) Rev. 2
71152B Drawings M-11041 Battery Arrangement, 2 Step EP, (4) Sets of (60) LCUN-33 Rev. 0
Cells/125 Volt Battery Connection Diagram and Bill of
Material - (Sheets 1 & 2)
71152B Engineering EWR 122641447 Breech Evaluation of 0-SLV-304-R2S051 and 2-PENT-304- Revision 0
Evaluations 36
71152B Engineering MMTP-102 Erection of Scaffolds/Temporary Work Platforms and Rev. 23
Evaluations Ladders
71152B Engineering MMTP-102 Att. 6 WBN Site Engineering Scaffold Evaluation for Scaffold No. 02/07/2023
Evaluations 123455181 in Vital Battery Room V
71152B Engineering QR-59903-01 Environmental and Seismic Qualification Report of Type 01/13/1993
Evaluations LCUN-33 125-Volt DC Storage Battery
71152B Engineering Technibus Project TVA Watts Bar Bus Duct Failure Analysis (CR1793055)
Inspection Type Designation Description or Title Revision or
Procedure Date
Evaluations #6211
71152B Engineering TVA-FAR 2022-002 Ametek Failure Analysis Report for Inverter Transformer 11/30/2022
Evaluations Failure in March 2022 (CR1766257)
71152B Engineering WBPEVAR9006007 Determination of Remaining Life of Cable due to Lowered 06/12/1990
Evaluations Bend Radius Installations
71152B Engineering WCGACQ0543 Seismic Evaluation Report of 125 Volt Battery Rack, 02/13/1995
Evaluations Battery Board Rooms I, II, III and IV
71152B Miscellaneous Thermography Results for Units 1 and 2 Safety-Related 4/5/2023
Inverters T803 Transformers
71152B Miscellaneous 2022 Nuclear Safety Culture Assessment Survey 2022
Departments Statistics
71152B Miscellaneous 2021-07-01 NRC Part 21 Report: Notification of Potential Defect - 04/06/2021
10CFR Part 21 - Vishay/ International Rectifier Clamp,
Diodes 300V, 250A, forward and reverse
bias, Ametek part numbers 07-600250-00 and 07-600251-
(ADAMS Accession No. ML21096A114)
71152B Miscellaneous 2021-07-02 NRC Part 21 Report: Final Notification of Potential Defect, 02/11/2022
Vishay/ International Rectifier Clamp, Diodes 300V, 250A
(ADAMS Accession No. ML21092A129)
71152B Miscellaneous 2021-17-00 NRC Part 21 Report: Notification of Potential Defect - 10 09/09/2021
CFR Part 21 for Omron Timer Relay - Ametek Solidstate
Controls, Inc. (ADAMS Accession No. ML21260A007)
71152B Miscellaneous Audit Report Operations Watts Bar Nuclear Plant (WBN) April 15,
SSA2102 2021
71152B Miscellaneous Audit Report Chemistry and Environmental Monitoring Watts Bar June 24,
SSA2103 Nuclear Plant (WBN) 2021
71152B Miscellaneous Audit Report Radiation Protection And Radioactive Waste Watts Bar July 29,
SSA2104 Nuclear Plant (WBN) 2021
71152B Miscellaneous Audit Report Fire Protection Program Watts Bar Nuclear Plant August 22,
SSA2207 2022
71152B Miscellaneous Audit Report Emergency Preparedness Watts Bar Nuclear Plant (WBN) January 3,
SSA2301 2023
71152B Miscellaneous Audit Report Plant Operations Watts Bar Nuclear Plant (WBN), May 25,
SSA2302 2023
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Miscellaneous BMS Bridging or Mitigation Strategy (BMS): AMETEK Part 21: Rev. 1
Vital Battery Charger K306 Relay
71152B Miscellaneous CDE 1756 MRule Evaluation for 1B-B Containment Spray Pump 01/19/2023
Failure on 8/10/2021
71152B Miscellaneous Chemistry Results Units 1 & 2 Chemistry Results for Chloride and Fluoride 11/14/2022 -
2/12/2022
71152B Miscellaneous Chemistry Sample Chemistry Sample Results for Wells R and S (Date Range: 08/07/2023
Report March 2020 - April 2023)
71152B Miscellaneous EPRI TR102067 Maintenance and Application Guide for Control Relays and 12/1993
Timers
71152B Miscellaneous GE SIL 044S4R2 GE Service Information Letter (SIL) Supplement No. 4: Rev. 2
HFA Relay Magnetic Coil Assembly Replacement and
Relay Adjustments
71152B Miscellaneous IN 83-19 NRC Information Notice No. 83-19: General Electric Type 04/05/1983
HFA Relay Contact Gap and Wipe Setting Adjustments
71152B Miscellaneous IN 89-64 NRC Information Notice No. 89-64, Electrical Bus Bar 09/07/1989
Failures
71152B Miscellaneous Letter TVA Watts Bar Nuclear Plant. Letter from Donovan, David 10/07/2021
to TVA Watts Bar Nuclear Plan, 'WBN HFA Relay Failures'
71152B Miscellaneous Letter Chad
- W. Monroe. Letter from Drew Heimer, C&D 08/24/2023
Technologies, to Chad Monroe, Watts Bar Nuclear Plant,
'Justification for not Installing Top Tie Rod RE02350 Foam
Spacers'
71152B Miscellaneous Letter Watts Bar Nuclear Plant. Letter from Drew Heimer, C&D 09/25/2023
Technologies, to
- F. David Lively, Jr., Watts Bar Nuclear
Plant, 'Battery Cable Supports'
71152B Miscellaneous MRule a(1) Plan System 235-B 120 VAC Vital Instrument Power Rev. 1
Maintenance Rule (a)(1) Plan
71152B Miscellaneous MRule CDEs CDEs 1759, 1774, 1788, 1791 - Cause Determination Various
Evaluations (CDEs) for System 235-B -120 VAC Vital
Instrument Power
71152B Miscellaneous N/A Nuclear Safety Culture Site Leadership Team Meeting 03/23/2023
Minutes
71152B Miscellaneous N/A Nuclear Safety Culture Site Leadership Team Meeting 02/09/2023
Inspection Type Designation Description or Title Revision or
Procedure Date
Minutes
71152B Miscellaneous N/A Plant Health Committee Special Issues Team for
Monitoring Vital Inverter Transformer Operation
71152B Miscellaneous PMCR 1483704 Preventive Maintenance Change Request for Inspection of 09/01/2021
6.9KV CSS Bus D
71152B Miscellaneous TVA-NQA-PLN89-A Nuclear Quality Assurance Plan (NQAP) - Quality 11/01/2022
Assurance Program Description
71152B Miscellaneous WBL-21-051 30-Day Voluntary Report in Accordance with Industry 11/18/2021
Groundwater Protection Initiative (EN 55550)
71152B Miscellaneous WBN-VTD-C173- Vendor Technical Manual: C&D Technologies, Inc. Standby Revs. 2, 3,
0070 Battery Vented Cell Installation and Operating Instructions 4, 6, 8
RS-1476 Section 12-800
71152B Miscellaneous WBN-VTD-C173- Vendor Technical Manual: C&D Technologies Field Service Rev. 0
0170 Procedure FSP-0157-B - Repair For Minor Cover Cracks in
Nuclear Safety-Related (1E) Batteries
71152B Miscellaneous WBN-VTD-G080- Vendor Technical Manual: Instructions for General Electric Rev. 1
1800 Multi-Contact Auxiliary Relays Type HFA154 (Pub. # GEK-
4586A)
71152B Procedures 0-MI-57.113 Cable Bend Radius Rev. 1
71152B Procedures 0-TI-449 Watts Bar Tritium Management Strategic Plan Rev. 0
71152B Procedures 1-PI-OPS-ANN Annunciator Verification Revision 13
71152B Procedures 1-TRI-68-3 RCS Chloride, Fluoride, and Dissolved Oxygen Rev. 13
Determination
71152B Procedures 2-PI-OPS-ANN Annunciator Verification Revision 7
71152B Procedures CM 12.75 Calibration of Portable Orbisphere Analyzers Rev. 18
71152B Procedures CM 7.10 Degassing Operations Rev. 11
71152B Procedures ECP-1 Conduct of ECP - Desktop Guide Rev.0005
71152B Procedures NEDP-27 Past Operability Evaluations Revs. 6 & 7
71152B Procedures NPG-SPP-01.16 Condition Report Initiation Rev. 0006
71152B Procedures NPG-SPP-01.7.1 Employee Concerns Program Rev. 0007
71152B Procedures NPG-SPP-03.19, Conduct of Quality Assurance Internal Audits Rev. 0017
Conduct of Quality
Assurance Internal
Audits
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Procedures NPG-SPP-06.1 Work Order Process Rev.0012
71152B Procedures NPG-SPP-06.2 Preventive Maintenance Rev. 17
71152B Procedures NPG-SPP-07.3 Work Activity Risk Management Process Rev. 0037
71152B Procedures NPG-SPP-07.3 Work Activity Risk Management Process Rev.0036
71152B Procedures NPG-SPP-09.20 Vendor Manual Control Rev. 4
71152B Procedures NPG-SPP-22.102 Self-Assessment and Benchmarking Programs Rev. 0013
71152B Procedures NPG-SPP-22.102 NPG Self-Assessment and Benchmarking Programs Rev. 0011
71152B Procedures NPG-SPP-22.300 Corrective Action Program Rev.0023
71152B Procedures NPG-SPP-22.500 Operating Experience Program Rev.0017
71152B Procedures NPG-SPP-22.600 Issue Resolution Rev.0012
71152B Self-Assessments CR1763729 WBN Operations Self- Assessment: Following 3/20/2022
implementation of corrective/improvement actions for
Functional Area Gap related to the identification/ resolution
of low-level clearance events, perform an analysis of level 4
clearance learnings
71152B Self-Assessments CR1787814 2023 NRC Baseline Emergency Preparedness Exercise 03/28/2023
Inspection
71152B Self-Assessments CR1819727 Problem Identification and Resolution 04/04/2023,
71152B Self-Assessments CR1826809 Watts Bar Units 1 and 2 Steam Generator Program 6/15/2023
Implementation
71152B Self-Assessments CR1834136 Observations by a cross functional team to observe WBN 3/1/2023
maintenance behaviors
71152B Self-Assessments SSA2103 Audit Report - Chemistry and Environmental Monitoring, 06/14 -
Watts Bar Nuclear Plant (WBN) 24/2021
June 14, 2021 - June 24, 2021
71152B Work Orders 122595239 MIG Install and Remove Transducer for DP Testing 06/13/2022
71152B Work Orders 122641445 Breach and Seal Penetrations in Support of Differential 06/21/2022
Pressure Test
71152B Work Orders 122641635 Install Transducer Cable in Support of DP Testing 03/09/2022
71152B Work Orders Work Orders (WO) 123596573, 122702938, 123310867, 122838226,
2118912, 122453450, 123622082 , 123640513,
2009541, 116078170, 114559304, 123596573,
2188181, 122485433, 123248003, 122702958,
2118912, 122118913, 122453450, 122528980,
Inspection Type Designation Description or Title Revision or
Procedure Date
119409898, 2008-817128-000, 2008-819658-000
18