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Category:Letter type:L
MONTHYEARL-20-006, Unit 2, Emergency Plan Implementing Procedure Revision2020-02-10010 February 2020 Unit 2, Emergency Plan Implementing Procedure Revision L-12-001, Revised Response to NRC Bulletin 2012-01, Design Vulnerability in Electrical Power System2019-12-26026 December 2019 Revised Response to NRC Bulletin 2012-01, Design Vulnerability in Electrical Power System L-19-061, Unit 2 - Emergency Plan Implementing Procedure Revision2019-12-16016 December 2019 Unit 2 - Emergency Plan Implementing Procedure Revision L-19-058, Statement of Payment of Civil Penalty2019-12-11011 December 2019 Statement of Payment of Civil Penalty L-19-054, Unit 2 - Emergency Plan Implementing Procedure Revision2019-12-0505 December 2019 Unit 2 - Emergency Plan Implementing Procedure Revision L-19-046, Notification of Readiness for NRC Independent Review to Confirm Chilling Effect Letter and Cross-Cutting Issue Closure Criteria Have Been Met2019-10-0303 October 2019 Notification of Readiness for NRC Independent Review to Confirm Chilling Effect Letter and Cross-Cutting Issue Closure Criteria Have Been Met L-19-052, Revision 47 to Emergency Plan Implementing Procedure EPIP 12, Emergency Equipment and Supplies2019-09-30030 September 2019 Revision 47 to Emergency Plan Implementing Procedure EPIP 12, Emergency Equipment and Supplies L-19-048, Response to Apparent Violation in NRC Inspection Report 05000390/2019013 and 05000391/2019013, EA-19-0422019-09-12012 September 2019 Response to Apparent Violation in NRC Inspection Report 05000390/2019013 and 05000391/2019013, EA-19-042 L-19-041, Cycle 2 Steam Generator Tube Inspection Report2019-08-27027 August 2019 Cycle 2 Steam Generator Tube Inspection Report L-19-045, American Society of Mechanical Engineers, Section XI, First 10-Year Inspection Interval, Inservice Inspection Owner'S Activity Report for Cycle 2 Operation2019-08-14014 August 2019 American Society of Mechanical Engineers, Section XI, First 10-Year Inspection Interval, Inservice Inspection Owner'S Activity Report for Cycle 2 Operation L-19-044, Unit 2 - Forward Emergency Plan Implementing Procedure Revisions2019-08-0808 August 2019 Unit 2 - Forward Emergency Plan Implementing Procedure Revisions L-19-036, Notification of Readiness for NRC Inspection Procedure 95001 Inspection2019-06-20020 June 2019 Notification of Readiness for NRC Inspection Procedure 95001 Inspection L-19-034, Wafts Bar Nuclear Plant, Unit 1 - Technical Specification (TS) 5.9.8 - Post Accident Monitoring System (Pams) Report2019-06-18018 June 2019 Wafts Bar Nuclear Plant, Unit 1 - Technical Specification (TS) 5.9.8 - Post Accident Monitoring System (Pams) Report L-19-031, Nuclear Regulatory Commission (NRC) Regulatory Issue Summary (RIS) 2019-02 - Preparation and Scheduling of Operator Licensing Examinations2019-05-15015 May 2019 Nuclear Regulatory Commission (NRC) Regulatory Issue Summary (RIS) 2019-02 - Preparation and Scheduling of Operator Licensing Examinations L-19-016, Annual Radiological Environmental Operating Report - 20182019-05-15015 May 2019 Annual Radiological Environmental Operating Report - 2018 L-19-029, Submittal of Revision 0 of Cycle 3 Core Operating Limits Report2019-04-24024 April 2019 Submittal of Revision 0 of Cycle 3 Core Operating Limits Report L-19-015, Annual Non-Radiological Environmental Operating Report - 20182019-04-11011 April 2019 Annual Non-Radiological Environmental Operating Report - 2018 L-19-026, Revised Pressure and Temperature Limits Report (PTLR)2019-04-0404 April 2019 Revised Pressure and Temperature Limits Report (PTLR) L-19-023, Periodic Submission for Changes Made to the WBN Technical Specification Bases and Technical Requirements Manual2019-03-19019 March 2019 Periodic Submission for Changes Made to the WBN Technical Specification Bases and Technical Requirements Manual L-19-024, Unit 2 - Emergency Plan Implementing Procedures Revision2019-03-0707 March 2019 Unit 2 - Emergency Plan Implementing Procedures Revision L-19-019, Transmittal of 10 CFR 50.46 - 30-Day and Annual Report for Watts Bar Nuclear Plant, Units 1 and 22019-03-0707 March 2019 Transmittal of 10 CFR 50.46 - 30-Day and Annual Report for Watts Bar Nuclear Plant, Units 1 and 2 L-19-011, Plant, Unit 1 - Revision 1 of the Cycle 16 Core Operating Limits Report (COLR)2019-01-29029 January 2019 Plant, Unit 1 - Revision 1 of the Cycle 16 Core Operating Limits Report (COLR) L-19-008, American Society of Mechanical Engineers, Section Xl, Third 10-Year Inspection Interval, Inservice Inspection Owner'S Activity Report for Cycle 15 Operation2019-01-24024 January 2019 American Society of Mechanical Engineers, Section Xl, Third 10-Year Inspection Interval, Inservice Inspection Owner'S Activity Report for Cycle 15 Operation L-18-001, Notification of Readiness for NRC Inspection Procedure 95001 Inspection2018-11-26026 November 2018 Notification of Readiness for NRC Inspection Procedure 95001 Inspection L-04-001, Completion of Action Required in Response to NRC Bulletin 2004-01: Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors2018-01-25025 January 2018 Completion of Action Required in Response to NRC Bulletin 2004-01: Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors L-11-001, Submittal of 30-Day Response to NRC Bulletin 2011-01, Mitigating Strategies.2015-09-24024 September 2015 Submittal of 30-Day Response to NRC Bulletin 2011-01, Mitigating Strategies. L-11-011, Transmittal of Response to NRC Bulletin 2011-01, Mitigating Strategies.2015-06-29029 June 2015 Transmittal of Response to NRC Bulletin 2011-01, Mitigating Strategies. L-88-017, Response Clarification to Generic Letter 88-0172013-08-13013 August 2013 Response Clarification to Generic Letter 88-017 L-03-004, Tennessee Valley Authority Response to Nuclear Regulatory Commission Bulletin 2003-04, Rebaselining of Data in the Nuclear Materials Management and Safeguards System, Dated October 8, 20032003-12-18018 December 2003 Tennessee Valley Authority Response to Nuclear Regulatory Commission Bulletin 2003-04, Rebaselining of Data in the Nuclear Materials Management and Safeguards System, Dated October 8, 2003 2020-02-10
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARML21027A3942020-12-0707 December 2020 TVA Response to Notice of Violations (EA-19-092) ML20198M4202020-07-0808 July 2020 William Bill Sprinkle, Response to Apparent Violation, IA-20-018 L-19-048, Response to Apparent Violation in NRC Inspection Report 05000390/2019013 and 05000391/2019013, EA-19-0422019-09-12012 September 2019 Response to Apparent Violation in NRC Inspection Report 05000390/2019013 and 05000391/2019013, EA-19-042 ML16344A0482016-12-0909 December 2016 Reply to Notice of Violation (EA-16-117) CNL-15-217, Reply to Notice of Violation (EA-15-112)2015-10-16016 October 2015 Reply to Notice of Violation (EA-15-112) CNL-15-152, Reply to Notice of Violation (EA-15-075)2015-07-24024 July 2015 Reply to Notice of Violation (EA-15-075) CNL-15-079, Reply to Notice of Violation (EA-14-179)2015-05-0101 May 2015 Reply to Notice of Violation (EA-14-179) ML13204A3832013-07-18018 July 2013 Reply to Notice of Violation (EA-13-019) 391/2013611-01, -02, and -03 Related to Tva'S Commercial Grade Dedication Program ML13192A0332013-07-0303 July 2013 Reply to a Notice of Violation; EA-13-018 IR 05000391/20106032012-07-17017 July 2012 Units 1 & 2 - Reply to Notice of Violation 05000391/2010603-08 - Failure to Adequately Evaluate and Qualify Molded Case Circuit Breakers - Revised Response ML12202A0102012-07-17017 July 2012 Units 1 & 2 - Reply to Notice of Violation 05000391/2010603-08 - Failure to Adequately Evaluate and Qualify Molded Case Circuit Breakers - Revised Response ML12172A4122012-06-18018 June 2012 Tennessee Valley Authority - Reply to Notice of Violation 05000391-10-603-08 - Failure to Adequately Evaluate and Qualify Molded Case Circuit Breakers - Revised Response ML12160A3522012-06-0707 June 2012 Reply to Notice of Violation 391/2012612-01 - Failure to Correct a Condition Adverse to Quality Associated with Containment Spray Pump Layup and Preventive Maintenance ML11164A1412011-06-0909 June 2011 Reply to Notice of Violation 05000391/2010603-08 - Failure to Adequately Evaluate and Qualify Molded Case Circuit Breakers - Revised Response ML11105A1502011-04-11011 April 2011 Request for Extension for Time to Respond to Severity Level IV, Non-Cited Violation 05000390-11-008-01 ML1109605912011-03-31031 March 2011 Response to Non-Cited Violations 05000390-10-005-03, Failure to Use Worst Case 6900 Vac Bus Voltage in Design Calculations ML1033002172010-11-24024 November 2010 Reply to Notice of Violation 05000391/2010603-08 - Failure to Adequately Evaluate and Qualify Molded Case Circuit Breakers ML1028804932010-10-15015 October 2010 Denial of Notice of Violation (NOV) 05000391-2010603-08, Failure to Adequately Evaluate and Qualify Molded Case Circuit Breakers - Additional Information ML1025204352010-09-0707 September 2010 Denial of Notice of Violation, 05000391/2010603-08, Failure to Adequately Evaluate and Qualify Molded Case Circuit Breakers ML0908306622009-03-23023 March 2009 Denial of Non-Cited Violation 05000390-08-05-04, Carbon Dioxide System in Fire Area 48 Failed to Meet Design Criterion ML0416002752004-06-0303 June 2004 & Watts Bar Nuclear Plant - Interim Safeguards and Security Compensatory Measures Reports & Notices of Violation - Reply to Notices of Violation ML0322000402003-07-25025 July 2003 National Pollutant Discharge Elimination System Permit No.TN0020158 - Response to Notice of Violation ML0316701792003-06-0404 June 2003 National Pollutant Discharge Elimination System (NPDES) Permit No. TN0020168 - Response to Notice of Violation 2020-07-08
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Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381 WBL-19-048 September 12, 2019 10 CFR 50.9(a)
U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391
Subject:
Response to Apparent Violation in NRC Inspection Report 05000390/2019013 and 05000391 /2019013, EA-19-042 On August 19, 2019, the Nuclear Regulatory Commission (NRC) issued Inspection Report 05000390/2019013 and 05000391/2019013 (ML19231A179), detailing an apparent violation (AV) of NRC requirements for Tennessee Valley Authority's (TVA) failure to provide complete and accurate information in all material respects, as required by 10 Code of Federal Regulations (CFR) 50.9(a).
On August 27, 2019, TVA informed the NRC that it would submit a written response to the AV by September 18, 2019.
TVA does not dispute that the violation occurred, and hereby submits its response to the subject AV. The AV was a failure to provide complete and accurate information in all material respects on multiple occasions as part of the Licensing of Watts Bar (WBN) Unit 2 from 2010 through 2013, and subsequently as part of a license amendment for WBN Unit 1 in 2015. TVA submitted inaccurate information that was material for an NRC licensing decision regarding the adequacy of the offsite electric power system.
Specifically, the analysis performed in the qualification of the Common Station System Transformer (CSST) A and Bas a Technical Specification (TS) offsite power source was incomplete because it did not consider the voltage transient that would occur as a result of the transfer from the Unit Station Service Transformer to either CSST A or B, contrary to General Design Criteria - 17 of 10 CFR 50, Appendix A.
TVA performed a Cause and Effect Analysis and determined the apparent cause for the incomplete analysis was a bad mental model created by an analysis performed at a sister plant and a corresponding misunderstanding of WBN alignments. The analysis performed was based upon previous calculations from a sister plant where no transfer was required.
U.S. Nuclear Regulatory Commission WBL-19-048 Page2 September 12, 2019 Unaware of WBN's difference with the sister plant, personnel performed similar analysis without fully understanding the difference in plant alignments.
Upon discovery, TVA took immediate action to restore compliance thrOUQh interim corrective actions to place caution cards on the 6.9 KV maintenance hand switchesj[AI] identifying to the operations staff that CSST A or B should not be aligned for this TS compliant configuration until further evaluation could be completed. The NRC was also informed of this condition and noncompliance in accordance with 10 CFR 50.9(b). There were no actual safety consequences of this unanalyzed condition, as the station had not been in the prohibited lineup.
In addition to placing caution cards, TVA completed the following actions:
- Operations procedures were updated to prevent crediting CSST A or B as offsite sources for TS compliance when the associated 6.9 kV unit board is originally powered from the USST.
- The TVA supplemental user guide for Electrical Transient and Analysis Program (ETAP) was updated to include guidance on voltage recovery analysis via motor starting analysis. Gap training was provided for TVA and non-TVA personnel on recognizing the limitations of the applicability of previous ETAP analysis.
- The relevant calculation was revised that performs the auxiliary power systems analysis to demonstrate that CSST A and/or B are able to supply power for both units only within specified limits as the GDC-17 compliant immediate offsite power source for either CSST C or D.
- The plant loading tables were updated and included in a memorandum submitted to Transmission Planning. The purpose of this memorandum is to provide the formal transmittal of updated Watts Bar Nuclear Plant loading, event scenarios, and acceptance criteria to use in determining the grid's ability to provide qualified offsite power to the Watts Bar Nuclear Generating Station.
As an aggregate response to this and unrelated submittal corrective actions, TVA's procedure for corresponding with the NRC was revised several times since the submittals resulting in the AV, including multiple changes to the validation process for NRC submittals.
The maturation of the validation process could prevent similar issues in the future.
Full compliance will be restored for this AV following NRC approval and station implementation of a license amendment, which corrects the previous inaccuracies introduced from 2010-2015. A pre-submittal meeting was held with the NRC on September 12, 2019, and the license amendment request is expected to be submitted by November 2019. The timeline to restore full compliance has no safety consequences, since the station maintained implementation of the above interim corrective actions restricting
U.S. Nuclear Regulatory Commission WBL-19-048 Page 3 September 12, 2019 entrance into the unanalyzed lineup.
This document contains no regulatory commitments.
Please direct any questions concerning this matter to Tony Brown, WBN Licensing Manager, at (423) 365-7720.
ony L. Williams, IV Site Vice President Watts Bar Nuclear Plant cc:
NRG Regional Administrator - Region II NRG Senior Resident Inspector - Watts Bar Nuclear Plant NRG Project Manager - Watts Bar Nuclear Plant