IR 05000391/2014616
| ML15012A409 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 01/12/2015 |
| From: | William Jones NRC/RGN-II/DCP |
| To: | Skaggs M Tennessee Valley Authority |
| Michelle Adams | |
| References | |
| 2-2013-011, EA-14-179 IR 2014616 | |
| Download: ML15012A409 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ary 12, 2015
SUBJECT:
WATTS BAR NUCLEAR PLANT - INSPECTION REPORT 05000391/2014616; INVESTIGATION REPORT NO. 2-2013-011; AND APPARENT VIOLATION
Dear Mr. Skaggs:
This refers to an investigation completed on October 30, 2014, by the U.S. Nuclear Regulatory Commissions (NRC) Office of Investigations (OI) at Tennessee Valley Authoritys (TVA) Watts Bar Nuclear Plant (Watts Bar), Unit 2. The purpose of the investigation was to determine whether contract employees working at Watts Bar Unit 2 deliberately violated a TVA procedure during anchor bolt installation for overhead base plates on Unit 2 hangers 86-1541 and 86-1545 in December 2011. A Factual Summary, included as an enclosure, provides details of the OI investigation.
Based on the results of the investigation, one apparent violation (AV) was identified and is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy.
The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.
The apparent violation involves 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, which requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances, and be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
In this case, contract employees were using TVA Procedure MAI-5.1B, Wedge Bolt (WB)
Anchor Installation, Revision 21, for anchor bolt installation for overhead base plates on Unit 2 hangers 86-1541 and 86-1545. Section 6.2.6 of that procedure states that wedge bolt anchors shall be installed to within 5 degrees of perpendicular. Newly installed wedge bolt anchors exceeding this requirement are removed and replaced per Section 6.4 or approval of the deviation obtained from Site Engineering. Contrary to the requirements of this procedure, on approximately December 19, 2011, a contract foreman assigned to install anchor bolts for overhead base plates on hangers 86-1541 and 86-1545 willfuly failed to remove and replace or obtain site engineering approval for newly installed wedge bolt anchors exceeding the 5 degrees of perpendicular as required by MAI-5.1B. The contract foreman requested one of the contract employees to fabricate a non-approved modified tool. At the direction of the contract foreman, the tool was then used to straighten the wedge bolt anchors to within 5 degrees of perpendicular. The contract foreman was also observed by others to use the modified tool to straighten the wedge bolt anchors. All four overhead base plates of hangers 86-1541 and 86-1545 had at least one bent bolt.
Since you identified the apparent violation, and based on our understanding of your corrective actions, a civil penalty may not be warranted in accordance with Section 2.3.4 of the Enforcement Policy. The final decision will be based on you confirming on the docket that the corrective actions have been or are being taken.
Before the NRC makes its enforcement decision, we are providing you an opportunity to (1)
respond in writing to the apparent violation addressed in this inspection report within 30 days of the date of this letter, (2) request a Pre-decisional Enforcement Conference (PEC), or (3)
request Alternative Dispute Resolution (ADR). If a PEC is held, the NRC will issue a press release to announce the time and date of the conference; however the PEC will be closed to public observation since information related to an Office of Investigations report will be discussed and the report has not been made public. If you decide to participate in a PEC or pursue ADR, please contact Robert Haag at 404-997-4446 within 10 days of the date of this letter. A PEC should be held within 30 days and an ADR session within 45 days of the date of this letter.
If you choose to provide a written response, it should be clearly marked as a Response to Apparent Violations in NRC Inspection Report 05000391/2014616 and Investigation Report No.
2-2013-011; EA-14-179 and should include for the apparent violation: (1) the reason for the apparent violation or, if contested, the basis for disputing the apparent violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response. If an adequate response is not received within the time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a PEC.
If you choose to request a PEC, the conference will afford you the opportunity to provide your perspective on these matters and any other information that you believe the NRC should take into consideration before making an enforcement decision. The decision to hold a predecisional enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference would be conducted to obtain information to assist the NRC in making an enforcement decision. The topics discussed during the conference may include information to determine whether a violation occurred, information to determine the significance of a violation, information related to the identification of a violation, and information related to any corrective actions taken or planned.
In lieu of a PEC, you may also request Alternative Dispute Resolution (ADR) with the NRC in an attempt to resolve this issue. ADR is a general term encompassing various techniques for resolving conflicts using a third party neutral. The technique that the NRC has decided to employ is mediation. Mediation is a voluntary, informal process in which a trained neutral (the mediator) works with parties to help them reach resolution. If the parties agree to use ADR, they select a mutually agreeable neutral mediator who has no stake in the outcome and no power to make decisions. Mediation gives parties an opportunity to discuss issues, clear up misunderstandings, be creative, find areas of agreement, and reach a final resolution of the issues. Additional information concerning the NRC's program can be obtained at http://www.nrc.gov/about-nrc/regulatory/enforcement/adr.html. The Institute on Conflict Resolution (ICR) at Cornell University has agreed to facilitate the NRC's program as a neutral third party. Please contact ICR at 877-733-9415 within 10 days of the date of this letter if you are interested in pursuing resolution of this issue through ADR.
In addition, please be advised that the number and characterization of the apparent violation(s)
described in this inspection report may change as a result of further NRC review. You will be advised by separate correspondence of the results of our deliberations on this matter.
In accordance with 10 CFR 2.390 of the NRC's "Agency Rules of Practice and Procedure," after completion of enforcement activities, a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
For administrative purposes this letter is issued as Inspection Report 05000391/2014616 and the apparent violation is designated as AV 05000391/2014616-01, Failure to Follow Site Procedure for Installation of Anchor Bolts.
If you have any questions concerning this matter, please contact Robert Haag of my staff at 404-997-4446.
Sincerely,
/RA/
William B. Jones, Director Division of Construction Projects Docket No.: 50-391 Construction Permit No. CPPR-92 Enclosure: Factual Summary cc: See next page
__ML15012A409____________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DCP RII:EICS RII:ORA HQ:OGC RII: DCP SIGNATURE RCH DLG2 SAP1 KXH7 via e- WBJ mail NAME RHAAG DGAMBERONI SPRICE KHanely W. Jones DATE 12/18/2014 12/18/2014 12/18/2014 01/06/2015 01/12/2015 E-MAIL COPY? YES NO YES NO YES NO YES NO cc w/encl: Mr. R. R. Baron, Senior Manager Mr. Gordon P. Arent Nuclear Construction Quality Assurance Director, Licensing WBN Unit Two Watts Bar Nuclear Plant Watts Bar Nuclear Plant Tennessee Valley Authority Tennessee Valley Authority P.O. Box 2000 P.O. Box 2000 Spring City, Tennessee 37381 Spring City, Tennessee 37381 Mr. O. J. Zeringue, General Manager Mr. Joseph Shea, Vice President Engineering and Construction Nuclear Licensing WBN Unit Two Tennessee Valley Authority Watts Bar Nuclear Plant 1101 Market Street Tennessee Valley Authority 3R Lookout Place P.O. Box 2000 Chattanooga, TN 37402-2801 Spring City, Tennessee 37381 Mr. E. J. Vigluicci Paul Simmons, Vice President Assistant General Counsel WBN Unit Two Project Tennessee Valley Authority WBN Unit Two 400 West Summit Hill Drive Watts Bar Nuclear Plant 6A West Tower Tennessee Valley Authority Knoxville, Tennessee 37402 P.O. Box 2000 Spring City Tennessee 37381 Mr. Kevin Walsh Site Vice President Mr. James ODell, Manager Watts Bar Nuclear Plant Licensing and Industry Affairs Tennessee Valley Authority WBN Nuclear Plant P.O. Box 2000 Tennessee Valley Authority Spring City, Tennessee 37381 P.O. Box 2000 Spring City, Tennessee 37381 Mr. Joseph P. Grimes Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 1101 Market Place 3R Lookout Place Chattanooga, Tennessee 37402-2801 Mr. Sean Connors Plant Manager, WBN Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, Tennessee 37381 cc email distribution w/encl:
Michael Skaggs Tennessee Valley Authority Electronic Mail Distribution Joseph Shea Tennessee Valley Authority Electronic Mail Distribution
Letter to Michael from William B. Jones dated January 12, 2015.
SUBJECT: WATTS BAR NUCLEAR PLANT - INSPECTION REPORT 05000391/2014616; INVESTIGATION REPORT NO. 2-2013-011; AND APPARENT VIOLATION DISTRIBUTION:
L. Douglas, RII EICS R. Haag, DCP K. Hanley, OE L. Casey, NRR D. Cylkowski, OGC RIDSNRRDIRS PUBLIC (after completion of enforcement activities - see EICS)
FACTUAL SUMMARY Office of Investigations Report No. 2-2013-011 On October 30, 2014, the U.S. Nuclear Regulatory Commissions (NRC) Office of Investigations (OI), Region II, completed an investigation at the Tennessee Valley Authoritys (TVA) Watts Bar Nuclear Plant (Watts Bar), Unit 2. The purpose of the investigation was to determine whether contract employees working at Watts Bar Unit 2 deliberately violated a TVA procedure during installation of wedge bolt anchors for overhead base plates on Unit 2 hangers 86-1541 and 86-1545.
Based on the investigation, the pertinent facts are as follows:
On approximately December 19, 2011, a team of contract employees, led by a contract foreman, were assigned to install wedge bolt anchors in overhead base plates on Unit 2 hangers 86-1541 and 86-1545, using TVA Procedure MAI-5.1B, Wedge Bolt (WB) Anchor Installation, Revision 21. Section 6.2.6 of that procedure states that wedge bolt anchors shall be installed to within 5 degrees of perpendicular. Newly installed wedge bolt anchors exceeding this requirement are removed and replaced per Section 6.4 or approval of the deviation is obtained from Site Engineering.
After installation of the wedge bolt anchors, contract employees determined that the anchors had not been installed within 5 degrees of perpendicular. However, in lieu of removal and replacement, or obtaining approval of a deviation from Site Engineering, the contract foreman requested one of the contract employees to fabricate a modified tool. At the direction of the contract foreman, the tool was then used to straighten the wedge bolt anchors to within 5 degrees of perpendicular. The contract foreman was also observed by others to use the modified tool to straighten the wedge bolt anchors.
A preponderance of the evidence obtained demonstrates that the contract foreman understood the Watts Bar procedural requirements, as well as the importance of procedural adherence.
The evidence further demonstrates that the contract foreman deliberately used or caused others to use a modified tool to straighten wedge bolt anchors instead of removing the anchors per procedure (or obtaining Site Engineering approval), and that he was aware that his actions were in violation of procedural requirements.
Enclosure