L-19-021, Response to Preliminary White and Apparent Violation: Difference between revisions

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{{Adams
#REDIRECT [[L-19-021, Holtec Decommissioning International (Hdi) Response to Confirmatory Order EA-17-132/EA-17-153]]
| number = ML19080A178
| issue date = 03/21/2019
| title = Response to Preliminary White and Apparent Violation
| author name = Williams A
| author affiliation = Tennessee Valley Authority
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000390, 05000391
| license number = NPF-090, NPF-096
| contact person =
| case reference number = WBL-19-021
| document type = Letter type:L, Licensee Response to Notice of Violation
| page count = 3
}}
 
=Text=
{{#Wiki_filter:Tennessee Valley Authority, Post Office Box 2000 Spring City, Tennessee 37381 wBL-19-021 March 21 ,2019 10 cFR 50.4 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Watts Bar Nuclear Plant, Units 1 and2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391
 
==Subject:==
Response to Watts Bar Nuclear Plant, Units 1 and 2 - Preliminary White and Apparent Violation (NRC lnspection Report Nos.
0500039012019-501 and 05000391/2019-501 )
References        1. Letter from A. Masters (NRC) to J. W. Shea (TVA), "Watts Bar Nuclear Plant - Nuclear Regulatory Commission lntegrated lnspection Report 05000390/201 8004 and 05000391/201 8004,' dated February 5, 2019 (M1190364682)
: 2. Letter from A. T. Gody (NRC) to J. W. Shea (TVA), "Watts Bar Nuclear Plant - Preliminary \ffhite Finding and Apparent Violation (NRC lnspection Report Nos. 05000390/2019-501 and 05000391/201 9-501)," dated February 21, 2019 (M119053A547)
On February 5, 2019, the NRC issued lnspection Report 05000390/2018004 and 05000391/2018004 (Reference 1) detailing an apparent violation of NRC requirements for Tennessee Valley Authority's (TVA) failure to maintain the effectiveness of the emergency plan and a standard emergency classification scheme which included facility effluent parameters at its Watts Bar Nuclear Plant WBN). On February 21,2019,the NRC issued a letter (Reference 2) documenting that the apparent violation (AV) was preliminarily determined to be of low-to-moderate safety significance (VVhate).
On February 28,2019, TVA informed the NRC that it would submit a written response to the apparent violation by March 22,2019.
 
U.S. Nuclear Regulatory Commission wBL-19-021 Page 2 March 21 ,2019 TVA hereby submits its response to the finding preliminarily determined to be of low-to-moderate safety significance (White). This finding was a failure to maintain the effectiveness of an emergency plan to meet the requirements of 10 CFR Part 50.47(b)(4), (bxg), and Part 50 Appendix E, when calculation preparers and checkers failed to recognize the technical risk associated with calculations supporting emergency preparedness (EP). TVA does not dispute that the violation occurred or the preliminary significance determination as a White finding with a cross-cutting aspect of H.3.
The errors were corrected on September 17, 2018, thereby restoring compliance. TVA completed a Root Cause Analysis (RCA) in December 2018, and determined the root cause of the calculation errors to be that preparers and checkers failed to recognize the technical risk associated with calculations supporting emergency preparedness. EP technical products are inherently higher risk due to the fact that conservativism cannot be used in the same manner as in other technica! products. As stated in RG 1.219, Revision 1, an overly conseruative decision during an emergency response could trigger actions that could place the public at unnecessary risk, thus resulting in a non-conservative situation. However, these calculation errors did not have any actual safety consequences as they impacted Emergency Action Level (EAL) threshold values and dose assessment capabilities which are only utilized once an accident has occurred.
Additionally, as part of the RCA an interim action was taken to ensure that EP personnel were aware of the risks and focus areas needed when performing impact reviews.
Corrective actions that have been taken thus far are listed below:
: 1. Revised the procedure related to risk management of Technical Products to include a consideration of the adverse impact to the Radiological Emergency Plan (REP) or Equipment lmportant to Emergency Response (EITER), and unintended consequences or challenges to event free performance of all individual products
: 2. Revised the Design Calculation Process Control procedure to provide guidance on keyrvords associated with calculations.
: 3. Revised calculations that impact emergency preparedness to clearly identiff them as such.
: 4. ldentified Engineering calculations that get Offsite Dose Calculation Manual (ODCM) input, fleet wide, to more easily identify when Engineering affected organization review is required when revising the ODCM. These calculations were linked as child documents to the respective site's ODCM.
 
U.S. Nuclear Regulatory Commission wBL-19-021 Page 3 March 21 , 2019
: 5. ldentified two other special programs (other than fire protection) to evaluate for extent of cause. lt was concluded that the selected programs do not have any programmatic failures.
There are no new regulatory commitments contained in this letter. Please direct any questions concerning this matter to Kim Hulvey, WBN Licensing Manager, at (423) 365-7720.
espectfully, Anthony L. Williams lV Site Vice President Watts Bar Nuclear Plant cc:
NRC Regional Administrator - Region ll NRC Resident lnspector - WBN NRC Project Manager - WBN}}

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