ML16344A048

Reply to Notice of Violation (EA-16-117)

ML16344A048
Person / Time
Site:	Watts Bar
Issue date:	12/09/2016
From:	Simmons P Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-16-117
Download: ML16344A048 (5)

Text

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381 December 9, 2016 10 cFR 2.201 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391

SUBJECT:

Watts Bar Nuclear Plant Units 1 and 2 - Reply to Notice of Violation (EA-l6-117)

Reference:

NRC letter dated November 10,2016, "Watts Bar Nuclear Plant- NRC I ntegrated I nspection Report 05000390/2016, 05000391 /201 6003 and Notice of Violation and Ol Report Number 0l-2-2015-039' Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 2.201, Tennessee Valley Authority's (TVA) response to Notice of Violation EA-16-1 17 is enclosed.

The enclosure provides TVA's reply to the violation (Reference), including a detailed description of the corrective steps taken and the results achieved. TVA achieved full compliance for this issue on August 27,2015.

There are no new regulatory commitments made in this letter. Should you have questions regarding this response, please contact Gordon Arent at (423) 365-2004.

Respectfully, /

Paul Simmons Site Vice President

Enclosure:

Reply to Notice of Violation cc: see Pag e 2

U.S. Nuclear Regulatory Commission Page 2 December 9, 2016 cc (Enclosure):

U.S. Nuclear Regulatory Commission Region ll Marquis One Tower 245 Peachtree CenterAve., NE Suite 1200 Atlanta, Georgia 30303 -1257 NRC Resident lnspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 Fred Brown, Deputy Regional Administrator for Construction U.S. Nuclear Regulatory Commission Region ll Marquis One Tower 245 Peachtree Center Ave., NE Suite 120A Atlanta, Georgia 30303 -1257 Director, Office of Enforcement U.S. Nuclear Regulatory Commission 4p.1 5A One White Flint North 1 1555 Rockville Pike Rockville, Maryland 2A852-2738

WATTS BAR NUCLEAR PLANT, UNITS 1 and 2 ENCLOSURE REPLY TO NOTICE OF VIOLATION EA.l6-117 Description of the Wolation 10 CFR 50.9(a) sfafes, in paft, that information required by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respecfs.

Watts Bar Nuclear Plant Units 1 and 2 Technical Specification 5.7.1.1.d requires, in part, that written procedures be esfab/rshed, implemented, and maintained coveing the activities involved with Fire Protection Program implementation.

The Watts Bar Fire Protection Report lists compensatory actions that must be implemented when there are impaired fire protection sysfems, including, under some circumstances, a continuous fire watch.

TVA Corporate Procedure NPG-SPP-18.4.6, Control of Fire Protection lmpairmenfs, Rev.

0006, is the implementing/controlling process for all Fire Protection impairments, and esfab/tshes the process for implementing compensatory actions for fire impairments as directed by the Fire Protection Report.

NPG-SPP-18.4.6, Section 3.2.6.A, sfafes that "Fire watches are utilized forthe surueillance of areas where fire protection sysfems are impaired. The compensatory fire watch process r.s descnbed in Attachment 7" of NPG-SPP-I8.4.6.

NPG-SPP-18.4.6, Aftachment 7, Section 3.1, specifie,s compensatory fire watch responsibilities, and requires that compensatory fire watches .log on Form NPG-SPP-18.4.6-3, Continuous Compensatory Fire Watch Tumover Fom, each time coverage is assumed or tran sfe rred.'

NPG-SPP- 1 8. 4. 6, Secfrbn 4.2. C, requires th at Fonn NPG-SPP- 1 8. 4. G3 be retained for g0 days.

Fire Protection lmpairment Permit C10-0639, dated August 6, 2010, established a continuous fire watch for multiple areas on the 713' elevation of the auxiliary building as a compensatory measure for fire protection equipment disabled to support Unit 2 construction activities.

Contrary to the above, on April 28, 2015, the licensee failed to maintain continuous compensatory fire watch information that was complete and accurate in all mateial respecfs. Specifically, a Continuous Compensatory Fire Watch Tumover Form, NPG-SPP-18.4.6-3, stated that continuous fire watch patrols for Fire Protection lmpairment Permit C10-0639 were completed, when in fact such fire watches had not been pertonned. The continuous fire watch patrol data is material to the NRC in that it provides evidence of compliance with regulatory requirements. I/,,s,s a Severity Level lV violation (Enforcement Policy Secfion 2.2. 1.d).

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TVA Response TVA does not dispute the facts as described by the Nuclear Regulatory Commission (NRC) and accepts the violation. As noted in the Notice of Violation, the violation was of low safety significance and was self-identified.

Reason for the Violation The willful falsification of Fire Watch (FW) records and coercion by FW foreman to solicit individuals to falsify records was identified a result of a referral from TVA Employee Concerns to TVA's Office of the lnspector General (OlG). This document falsification was performed in an effort to hide an inadequately performed fire watch.

On April 27 , 2015 trom 0747 to 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, a continuous fire watch was not properly performed for multiple areas of the Watts Bar Nuclear Plant WBN) Auxiliary Building 713' elevation. Specifically, a continuous fire watch for Fire Protection lmpairment Permit C10-0639 was not briefed as being within the scope of fire watch duties for the fire watch standers involved with this event. When fire watch foremen recognized a discrepancy in the fire watch documentation on April 28, 2015, the fire watch foremen prepared, and convinced several craft individuals to sign, false fire watch turnover paperwork. When not all individuals involved would sign the falsified documents, the documents were destroyed.

Condition Report (CR) 1019953 was subsequently generated on April 29, 2015 by an operations senior reactor operator and addressed the missing fire watch records.

On May 1,2015, a concerned individual contacted the Senior Vice President (SVP) at Watts Bar and informed him of this document falsification event. The WBN SVP informed the VP Watts Bar Unit 2 Project who informed the Employee Concerns Program (ECP). ECP personnel then made contact with the concerned individual on May 4,2015. Because the issue involved document falsification, the ECP investigator requested that OIG investigate the document falsification concern. After the ECP investigator met with a Special Agent of the OlG, OIG accepted the case on May 5, 2015.

Corrective Steps That Have Been Taken And The Results Achieved Upon learning that records may have been falsified on May 1 ,2015, the VP Watts Bar Unit 2 Project contacted TVA's Employee Concerns Program (ECP) on behalf of the WBN Senior Vice President. Because the issue involved potentialwillful misconduct, ECP site personnel requested an investigation to be performed by the Office of the lnspector General (OlG).

This investigation, completed on August 27,2015, concluded that a number of individuals had attempted to falsify fire watch records.

One of the foreman involved in this event was a WA employee. Upon determining his involvement with this event, the individual was suspended on June 3,2015 in accordance with TVA disciplinary procedures. The contract foreman and laborers were removed from fire watch duties in May 2015 when their employer became aware they were involved in an on-going investigation. Upon completion of the investigation by OlG, TVA denied site access to the individuals involved with this incident on August 27,2015.

TVA considers this violation to be an isolated action of employees , and the violation was not caused by lack of management oversight. lt is likely that prior 10 CFR 50.9 training provided to site personnel led an individual to identify this issue to TVA management and to the NRC.

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As part of a previous confirmatory order, TVA had taken actions to stress the importance of complete and accurate reporting in accordance with 10 CFR 50.9. This included the following corrective actions:

The Chief Nuclear Officer and the Senior Vice President of Nuclear Construction issued a joint communication to all Nuclear Power Group and Nuclear Construction employees regarding expectations for assuring work activities are performed and documented in a complete and accurate manner.

The executive management expectations (above) were reinforced through the use of fleet wide posters and communications. These communications specifically discussed 10 CFR 50.9, Completeness and Accuracy of !nformation, willful violations, and the consequences of non-compliance.

TVA provided initial 10 CFR 50.9 training in 2012 (manager, supervisor and craft level) to employees at all Nuclear Construction sites and refresher training in 2014.

TVA enhanced existing 10 CFR 50.9 related general employee training (GET) for new employees joining Nuclear Power Group and Nuclear Construction, and updated the associated annual requalification training.

Priorto issuance of the NRC Notice of Violation on November 10, 2016, WBN took action to investigate this issue and implemented personnel actions for those involved.

Corrective Steos That Will Be Taken No additional corrective actions are required.

Date When Full Compliance Was Achieved TVA achieved full compliance on August 27,2015.

Additional Actions TVA will communicate this event by December 31, 2016 to Wafts Bar personnel, stressing the importance of accuracy of records and the need to maintain personal integrity when signing record documents.

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