IR 05000390/2019501

Preliminary White Finding and Apparent Violation (NRC Inspection Report No. 05000390/2019501 and 05000391/2019501)

ML19053A547
Person / Time
Site:	Watts Bar
Issue date:	02/21/2019
From:	Gody A Division of Reactor Safety II
To:	James Shea Tennessee Valley Authority
References
EA-18-182 IR 2019501
Download: ML19053A547 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ary 21, 2019

SUBJECT:

WATTS BAR NUCLEAR PLANT - PRELIMINARY WHITE FINDING AND APPARENT VIOLATION (NRC INSPECTION REPORT NOS. 05000390/2019-501 AND 05000391/2019-501)

Dear Mr. Shea:

This letter and its enclosure documents a finding that the NRC has preliminarily determined to be of low-to-moderate safety significance (White), which may require additional NRC inspection.

As described in this letter, and initially in Watts Bar Inspection Report 2018-004, an apparent violation (AV) was identified of Title 10 Code of Federal Regulations (CFR) Part 50.54(q)(2),

regarding Tennessee Valley Authoritys (TVA) failure to maintain the effectiveness of an emergency plan that meets the requirements in Appendix E and the planning standards of § 50.47(b). Title 10 CFR Part 50.47(b)(4), (b)(9), and Part 50 Appendix E,Section IV.B.,

Assessment Actions, require licensees to have a standardized Emergency Action Level (EAL)

scheme and adequate methods, systems, and equipment in use based on facility system and effluent parameters for assessing and monitoring actual or potential offsite consequences of a radiological emergency. Specifically, EAL threshold values for certain radiation monitors were found to be significantly non-conservative and therefore, would cause an Unusual Event, Alert, Site Area, and General Emergency to be declared in an untimely manner. The finding was assessed based on the best available information, using the Significance Determination Process (SDP). The final resolution of this finding will be conveyed in separate correspondence.

The finding was assessed for significance in accordance with NRC Inspection Manual Chapter (IMC) 0609, Appendix B, Emergency Preparedness Significance Determination Process. The inspectors determined that the situation constituted a degraded risk-significant planning standard. Additionally, incorrect effluent radiation monitor conversion factors were found in use in the licensees dose assessment software that could affect the licensees ability to perform dose assessment in some cases. Also, in accordance with IMC 0609, dose projections incapable of providing technically accurate estimates of radioactive material releases or projected offsite dose in some cases, is preliminarily assigned a White safety significance.

Because these two findings resulted from the same performance deficiency, one finding with a preliminary significance of White is identified.

The issue was entered into the sites corrective action program on September 11, 2018. Other actions taken by the licensee were to perform an extent of condition review and correct the errors in the associated procedures and calculations. In addition, a Root Cause Analysis was completed on December 27, 2018. The finding is an apparent violation of NRC requirements and is being considered for escalated enforcement action in accordance with the Enforcement Policy, which can be found on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html In accordance with NRC Inspection Manual Chapter (IMC) 0609, we intend to complete our evaluation using the best available information and issue our final determination of safety significance within 90 days of the date of this letter. The SDP encourages an open dialogue between the NRC staff and the licensee; however, the dialogue should not impact the timeliness of the staffs final determination.

Before we make a final decision on this matter, we are providing you with an opportunity to (1)

attend a Regulatory Conference where you can present to the NRC your perspective on the facts and assumptions the NRC used to arrive at the finding and assess its significance, or (2)

submit your position on the finding to the NRC in writing. If you request a Regulatory Conference, it should be held within 40 days of the receipt of this letter and we encourage you to submit supporting documentation at least one week prior to the conference in an effort to make the conference more efficient and effective. The focus of the Regulatory Conference is to discuss the significance of the finding and not necessarily the root cause(s) or corrective action(s) associated with the finding. If a Regulatory Conference is held, it will be open for public observation. If you decide to submit only a written response, such submittal should be sent to the NRC within 40 days of your receipt of this letter. If you decline to request a Regulatory Conference or to submit a written response, you relinquish your right to appeal the final SDP determination, in that by not doing either, you fail to meet the appeal requirements stated in the Prerequisite and Limitation sections of Attachment 2 of NRC IMC 0609.

Please contact Eugene Guthrie at (404) 997-4662 or in writing using the address above, within 10 days from the issue date of this letter to notify us of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination. The final resolution of this finding will be conveyed in separate correspondence.

Because the NRC has not made a final determination in this matter, no Notice of Violation is being issued for this inspection finding at this time. In addition, please be advised that the number and characterization of the Apparent Violation described in this letter and the enclosure may change as a result of further NRC review. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room and in the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

Sincerely,

/RA: Mark S. Miller for/

Anthony T. Gody, Director Division of Reactor Safety Docket Nos.: 50-390 and 50-391 License Nos.: NPF-90 and NPF-96 Enclosure:

Apparent Violation cc: Distribution via Listserv