ML17069A133

NRC Problem Identification and Resolution Inspection (Part 2); and Safety Conscious Work Environment Issue of Concern Follow-up; NRC Inspection Report 05000390/2016013, 05000391/2016013

ML17069A133
Person / Time
Site:	Watts Bar
Issue date:	03/10/2017
From:	Joel Munday Division Reactor Projects II
To:	James Shea Tennessee Valley Authority
References
EA-17-022 IR 2016013
Download: ML17069A133 (33)

See also: IR 05000390/2016013

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

March 10, 2017

EA-17-022

Mr. Joseph W. Shea

Vice President, Nuclear Licensing

Tennessee Valley Authority

1101 Market Street, LP 3D-C

Chattanooga, TN 37402-2801

SUBJECT: WATTS BAR NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND

RESOLUTION INSPECTION (PART 2); AND SAFETY CONSCIOUS WORK

ENVIRONMENT ISSUE OF CONCERN FOLLOW-UP; NRC INSPECTION

REPORT 05000390/2016013, 05000391/2016013

Dear Mr. Shea:

On December 1, 2016, the U. S. Nuclear Regulatory Commission (NRC) completed Part 2 of a

Problem Identification and Resolution inspection at your Watts Bar Nuclear Plant Units 1 and 2.

On November 17, 2016, December 1, 2016, January 11, 2017, and February 21, 2017, the NRC

inspection team discussed the results of this inspection with Mr. Paul Simmons and other

members of your staff. The results of this inspection are documented in the enclosed report.

Additionally, security related activities are documented in inspection report 05000390 &

391/2016404 (ML17008A001). Results of the first part of the inspection are documented in

Inspection Report 05000390 & 391/2016007(ML16300A409).

The NRC inspection team reviewed the stations corrective action program and its

implementation to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting

problems, and to confirm that the station was complying with NRC regulations and licensee

standards for corrective action programs. The team identified weaknesses in the elements of

Problem Identification; and Problem Prioritizing and Evaluation. One finding was identified in

the area of Corrective Action Program Effectiveness.

Based on the results of this inspection, 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 Tennessee Valley

Authoritys (TVAs) failure to comply with a Confirmatory Order (CO) Modifying License, (EA-09-

009,203) (ML093510993) issued by the NRC on December 22, 2009. The CO required all TVA

nuclear plants to implement actions, including reviewing processes to determine whether

adverse employment actions comport with employee protection regulations, and to determine

whether the proposed adverse actions could negatively impact the Safety Conscious Work

Environment (SCWE). The NRCs recent Problem Identification and Resolution team

inspection, completed in December 2016, identified that TVAs Watts Bar Nuclear (WBN) facility

was not implementing certain review processes required in the CO in accordance with an

J. Shea 2

implementing procedure, from November 2014 to August 2016. The details of the AV are fully

described in the enclosed inspection report.

The team also evaluated the stations processes for use of industry and NRC operating

experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of

these areas adequately supported nuclear safety.

Finally the team reviewed the stations programs to establish and maintain a safety-conscious

work environment, and interviewed station personnel to evaluate the effectiveness of these

programs. In a letter dated March 23, 2016, the NRC issued a Chilling Effect Letter (CEL)

entitled, Chilled Work Environment for Raising and Addressing Safety Concerns at the Watts

Bar Nuclear Plant, (ML16083A479). The NRC determined there was sufficient evidence to

support the existence of an environment within the Operations department where your

employees did not feel free to raise safety concerns to management because they feared

retaliation and did not feel that their concerns were being addressed. As a follow-up to the

issuance of the CEL, this inspection continued the focused assessment of the SCWE

documented in part 1 of the inspection. The staff evaluated the attributes of a SCWE as

described in inspection procedure (IP) 93100, Safety Conscious Work Environment Issue of

Concern Follow-up. IP 93100 identifies a SCWE as an environment in which employees are

encouraged to raise safety concerns, are free to raise concerns both to their own management

and to the NRC without fear of retaliation, where concerns are promptly reviewed, given the

proper priority, appropriately resolved, and timely feedback is provided to those raising

concerns.

The inspection team conducted focus groups and interviews with members of the Watts Bar

staff and key management. A total of 28 employees participated in the focus groups and

interviews. The information from the focus groups, interviews, and document reviews were

organized into the themes that are discussed in the attached report. The team made the

following key observations associated with the current work environment, which are explained in

more detail in the report. All employees interviewed during Part 2 of the inspection indicated

that they were willing to raise nuclear safety concerns and felt free to raise concerns to their

direct supervisors without fear of retaliation. However, the insights provided by employees

confirmed that there were site-wide challenges to the SCWE at WBN, and some of the

conditions that prompted the issuance of the CEL extended beyond the Operations department.

The team identified weaknesses in the documentation and tracking of corrective actions to

improve the SCWE in departments outside of Operations. There were also weaknesses in the

criteria used to evaluate nuclear safety culture standards, which likely contributed to the missed

opportunities to identify and address safety culture concerns prior to the development of the

chilled work environment.

Before the NRC makes its enforcement decision, we are providing you an opportunity to (1)

respond 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, it will be open for public observation and

the NRC will issue a press release to announce the time and date of the conference. If you

decide to participate in a PEC or pursue ADR, please contact Alan Blamey at 404-997-4415

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.

J. Shea 3

If you choose to provide a written response, it should be clearly marked as a Response to An

Apparent Violation in NRC Inspection Report (05000390/2016013 & 05000391/2016013); EA-

17-022, 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.

Additionally, your response should be sent to the NRCs Document Control Center, with a copy

mailed to Joel T. Munday, Director, Division of Reactor Projects, Region II, 245 Peachtree

Center Avenue, NE, Suite 1200, Atlanta, GA 30303-1257, within 30 days of the date of this

letter. 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 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

described in the enclosed 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.

NRC inspectors also documented one NRC-identified finding of very low safety significance

(Green or SL-IV) that did not involve a violation of NRC requirements. Additionally, NRC

inspectors documented one Severity Level IV violation with no associated finding. Further,

inspectors documented one licensee-identified violation which was determined to be of very low

safety significance in this report. The NRC is treating these violations as non-cited violations

(NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

J. Shea 4

If you contest the violations or significance of these NCVs, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the

NRC resident inspector at the Watts Bar Plant.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a

regulatory requirement in this report, you should provide a response within 30 days of the date

of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC, 20555-0001; with copies to the

Regional Administrator, Region II; and the NRC resident inspector at the Watts Bar Plant.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of the NRCs document

system (ADAMS). Adams is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Joel T. Munday, Director

Division of Reactor Projects

Docket Nos. 50-390, 50-391

License Nos. NPF-90, NPF-96

Enclosure:

IR 05000390/2016013 and

05000391/2016013 w/Attachment:

Supplemental Information

J. Shea 5

SUBJECT: WATTS BAR NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND

RESOLUTION INSPECTION (PART 2); AND SAFETY CONSCIOUS WORK

ENVIRONMENT ISSUE OF CONCERN FOLLOW-UP; NRC INSPECTION

REPORT 05000390/2016013, 05000391/2016013 March 10, 2017

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ADAMS Accession Number: ML17069A133

OFFICE RII:DRP RII:DRP RII:DCP RII:DRS RII:DRP HQ:OE HQ:RES

NAME RTaylor JHamman CEven JWallo TStephen DWillis SMorrow

DATE: 2/27/2017 2/27/2017 2/22/2017 2/27/2017 2/21/2017 2/27/2017 2/21/2017

OFFICE RII:DRP RII:EICS RII:DRP RII:DRP

NAME CKontz SSparks ABlamey JMunday

DATE: 2/27/2017 3/10/2017 3/9/2017 3/10/2017

OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No.: 50-390, 50-391

License No.: NPF-90, NPF-96

Report No.: 05000390/2016013, 05000391/2016013

Licensee: Tennessee Valley Authority (TVA)

Facility: Watts Bar, Units 1 and 2

Location: Spring City, TN 37381

Dates: October 31 - December 1, 2016

Inspectors: C. Kontz, Senior Project Engineer (Team Lead)

S. Morrow, Human Factors Engineer (Lead Safety Culture

Assessor)

D. Willis, Allegations Team Leader

J. Wallo, Senior Security Inspector

C. Even, Senior Construction Inspector

R. Taylor, Senior Project Inspector

J. Hamman, Resident Inspector Watts Bar

T. Stephen, Resident Inspector Browns Ferry

Approved by: Alan Blamey, Chief

Reactor Projects Branch 6

Division of Reactor Project

Enclosure

SUMMARY

IR 05000390/2016013 and 05000391/2016013; October 31 - December 1, 2016; Watts Bar,

Units 1 and 2; (Problem Identification and Resolution).

This inspection constituted the conclusion of the biennial inspection of the Problem Identification

and Resolution Program and was conducted by a senior project engineer, two resident

inspectors, human factors engineer, an allegations team leader, senior allegations coordinator,

and a senior construction inspector. One Apparent Violation (AV), one Severity Level IV (SLIV)

violation, and one Green Finding were identified. The significance of inspection findings is

indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP) dated April 29, 2015. Cross-cutting aspects

are determined using IMC 0310, Components Within the Cross Cutting Areas dated December

4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs

Enforcement Policy dated August 1, 2016. The NRCs program for overseeing the safe

operation of commercial nuclear power reactors is described in NUREG-1649, Reactor

Oversight Process, Revision 6.

Identification and Resolution of Problems

The inspectors identified several examples that demonstrated weaknesses in the licensees

ability to identify problems and enter them into the CAP for resolution, as evidenced by the

number of deficiencies identified by external organizations (including the NRC) that had not

been previously identified by the licensee and placed into the CAP, during the review period.

The prioritization of issues was effective; however, a weakness was noted in the root cause

evaluations for significant problems. Corrective actions developed and implemented for issues

were generally effective and implemented in a timely manner. The inspectors determined that

overall, audits and self-assessments were adequate in identifying deficiencies and areas for

improvement in the CAP, and appropriate corrective actions were developed to address the

issues identified. Operating experience usage was found to be generally acceptable and

integrated into the licensees processes for performing and managing work, and plant

operations.

A. NRC-Identified Findings and Self-Revealed Findings

Cornerstone: Other

• Green. The NRC identified a Finding for the licensees failure to consistently implement

the program requirements of the CAP. Specifically, the licensee failed to implement

NPG-SPP-22.301, section 3.2.2 which required the licensees staff to initiate a Condition

Report (CR) to enter various items into their CAP. The licensee placed this issue into

their corrective action program.

The performance deficiency was more than minor because, if left uncorrected, issues

would remain unanalyzed that could represent a more significant safety concern. The

performance deficiency was screened using IMC 0609, Appendix A, Exhibit 2 Mitigating

Systems Cornerstone dated June 19, 2012. The finding screened to Green because

none of the examples were related to any structure, system, component, (SSC)

3

exceeding its technical specification allowed outage time. A cross cutting aspect of

Identification was assigned because the licensees threshold for identifying and entering

issues into their CAP was not low enough as defined by their procedures. (P.1) (Section

4OA2)

• SL-IV. The NRC identified a Non-cited Violation (NCV) of 10 CFR 50.9, Completeness

and Accuracy of Information for the licensees failure to provide accurate information in

all material respects to the Commission. The team determined on April 22, 2016, the

licensee provided inaccurate information in a letter to the NRC titled, RESPONSE TO

NRC LETTER CONCERNING A CHILLED WORK ENVIRONMENT FOR RAISING AND

ADDRESSING SAFETY CONCERNS AT THE WATTS BAR NUCLEAR PLANT

(ML16113A228). This information was material because the NRC relied on this

information to conclude that TVA was in compliance with CO-EA-09-009/203

requirements. The licensee placed this issue into their corrective action program.

The NRC determined this violation constituted a more than minor traditional enforcement

violation associated with failure to provide accurate information. The ROPs significance

determination process does not specifically consider the regulatory process impact in its

assessment of licensee performance. Therefore, it is necessary to address violations

which impede the NRCs ability to regulate using traditional enforcement. The inspector

determined that the licensees failure to provide accurate information was a violation of

10CFR50.9 which had the potential to impede or impact the regulatory process, and

therefore subject to traditional enforcement as described in the NRC Enforcement

Policy, dated November 1, 2016. This violation is characterized as a Severity Level IV

violation because it was similar to Example Section 6.9.d.1 of the NRC Enforcement

Policy. (Section 4OA5.1.b)

• TBD. The NRC identified an Apparent Violation of Confirmatory Order Modifying

License, (EA-09-009,203) Dated December 22, 2009 (ML093510993) for the licensees

failure to; (1) implement a process to review proposed licensee adverse employment

actions at Watts Bar Nuclear plant before actions were taken to determine whether the

proposed action comports with employee protection regulations, and whether the

proposed actions could negatively impact the SCWE; and (2) implement a process to

review proposed significant adverse employment actions by contractors performing

services at TVAs nuclear plant sites before the actions were taken to determine whether

the proposed action comports with employee protection regulations, and whether the

proposed action could negatively impact the SCWE.

The NRC determined this violation constituted a more than minor traditional enforcement

violation associated with failure to implement actions required by Confirmatory Order

Modifying License, (EA-09-009,203). The ROPs significance determination process

does not specifically consider the regulatory process impact in its assessment of

licensee performance. Therefore, it is necessary to address violations which impede the

NRCs ability to regulate using traditional enforcement. The inspector determined that

the licensees failure to implement the requirements of the Confirmatory Order had the

potential to impede or impact the regulatory process, and therefore subject to traditional

enforcement as described in the NRC Enforcement Policy, dated November 1, 2016.

The NRC has not made an enforcement decision on this matter. (Section 4OA5.2.b)

4

B. Licensee-Identified Violations

Violations of very low safety or security significance or Severity Level IV that were

identified by the licensee have been reviewed by the NRC. Corrective actions taken or

planned by the licensee have been entered into the licensees corrective action program.

These violations and corrective action tracking numbers are listed in Section 4OA7 of

this report.

REPORT DETAILS

4OA2 Problem Identification and Resolution

1. Corrective Action Program Effectiveness

a. Inspection Scope

The team reviewed the licensees CAP procedures, which described the administrative

process for initiating and resolving problems primarily through the use of condition

reports (CRs). To verify that problems were being properly identified, appropriately

characterized, and entered into the CAP, the inspectors reviewed CRs that had been

issued between November 2014 and October 2016. Where possible, the team

independently verified that the corrective actions were implemented as intended.

The team also reviewed selected common causes and generic concerns associated with

root cause analyses (RCA) to determine if they had been appropriately addressed. To

help ensure that samples were reviewed across all cornerstones of safety identified in

the Reactor Oversight Process (ROP), the team selected a representative number of

CRs that were identified and assigned to the major plant departments, including quality

assurance, operations, health physics, chemistry, emergency preparedness and

security. These CRs were reviewed to assess each departments threshold for

identifying and documenting plant problems, thoroughness of evaluations, and adequacy

of corrective actions. The team reviewed selected CRs, verified corrective actions were

implemented, and attended meetings where CRs were evaluated for significance to

determine whether the licensee was identifying, accurately characterizing, and entering

problems into the CAP at an appropriate threshold.

The inspectors reviewed CRs, maintenance history, corrective actions (CAs), completed

work orders (WOs) for selected systems, and reviewed associated system health

reports. These reviews were performed to verify that problems were being properly

identified, appropriately characterized, and entered into the CAP. Items reviewed

generally covered a two-year period of time; however, in accordance with the inspection

procedure, a five-year review was performed for selected systems for age-related

issues.

The main control room deficiency list was assessed to ascertain if deficiencies were

entered into the CAP and tracked to resolution. Operator workarounds and operator

burden screenings were reviewed, and the inspectors verified appropriate compensatory

measures were being implemented in the field for the deficient equipment. The

inspectors also reviewed Shift Orders, Standing Orders, and Operational Decision

making instructions.

The inspectors conducted a detailed review of selected CRs to assess the adequacy of

the root cause and apparent cause evaluations of the problems identified. The

inspectors reviewed these evaluations against the descriptions of the problem described

in the CRs and the guidance in licensee procedure NPG-SPP-22.306, Level 1

Evaluation and NPG-SPP-22.305, Level 2 Evaluation. The inspectors assessed if the

licensee had adequately determined the cause(s) of identified problems, and had

adequately addressed operability, reportability, common cause, generic concerns,

6

extent-of-condition, and extent-of-cause. The review also assessed if the licensee had

appropriately identified and prioritized corrective actions to prevent recurrence.

The inspectors reviewed selected industry operating experience (OE) items, including

NRC generic communications, to verify that they had been appropriately evaluated for

applicability and that issues identified through these reviews had been entered into the

CAP.

The inspectors reviewed site trend reports, to determine if the licensee effectively

trended identified issues and initiated appropriate corrective actions when adverse

trends were identified.

The inspectors reviewed licensee audits and self-assessments, including those which

focused on problem identification and resolution programs and processes, to verify that

findings were entered into the CAP and to verify that these audits and assessments

were consistent with the NRCs assessment of the licensees CAP. The inspectors

attended various plant meetings to observe management oversight functions of the

corrective action process. These included the Plant Screening Committee (PSC) and

Management Review Committee meetings.

Documents reviewed are listed in the Attachment.

b. Assessment

Problem Identification

The inspectors identified a weakness in the licensees ability to identify problems and

enter them into the CAP. This conclusion was based on a review of the requirements for

initiating CRs as described in licensee procedure NPG-SPP-22.300, Corrective Action

Program, and managements expectation that employees were encouraged to initiate

CRs for any reason. Additionally, the inspectors identified significant challenges to the

sites environment for raising concerns as discussed in a later section of this report.

Trending was generally effective in monitoring equipment performance. Site

management was actively involved in the CAP and focused appropriate attention on

significant plant issues. Based on reviews and walkdowns of accessible portions of the

selected systems, the inspectors determined that system deficiencies were being

identified and placed in the CAP.

The inspectors identified multiple issues surrounding the licensees review of the events

that led to the Unit 1, November 11, 2015, use of the Residual Heat Removal (RHR)

system to arrest an uncontrolled rise in Pressurizer Level as documented in CR

1199024. The licensee failed to document these events in their control room logs, they

failed to follow their procedures for placing RHR into service, and they failed to follow

their operability procedures (these issues were dispositioned in Watts Bar Inspection

Report 2016-001)(ML 16098A323). Additionally, the licensee exceeded their self-

imposed time limit for initiation of a condition report and commencement of a causal

analysis for these issues. The licensee took 55 days to generate a condition report to

begin their required causal analysis of this issue, which was in excess of the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

time limit and thus the condition report was not able to be screened promptly.

7

The inspectors identified weaknesses in the licensees ability to identify problems as

evidenced by multiple examples associated with not appropriately entering issues into

the CAP. The inspectors determined that issues identified through external reviews

were not consistently being input into the CAP but rather addressed by actions outside

of the CAP. The majority of the issues identified in the reviews met NPG-SPP-22.301

criteria for CR initiation. Additionally, the resident inspectors identified multiple examples

of issues that would not have been entered into the licensees CAP without their

involvement.

The inspectors found that the licensee had an adequate process for identifying Operator

Burdens, Workarounds, and Control Room Deficiency issues, entering them into the

corrective action program, screening them to the appropriate level per site procedures,

and generating an up to date control room deficiency list each day. The control room

deficiency list comported with the inspectors walk-down of the main control board.

Additionally, the inspectors reviewed the transition process from CR to work order for

operator burdens, workarounds, or control room deficiencies.

The inspectors noted that the CR software (MAXIMO) does not have a function to allow

a CR initiator to code an issue as either an operator burden, workaround, or control

room deficiency. The initiator must identify that the condition reported is one of these

types of issues by entering descriptive text into the CR detail or summary field. The

licensees Quality Assurance (QA) department identified four condition reports where the

condition represented a control room deficiency; however, that terminology was not used

in the detail or summary field, and the CRs were not properly screened as C Level CRs

as required by NPG-SPP-22.302 by the PSC. Instead, the CRs were screened as work

order only. The licensee entered this QA finding into their corrective action program as

CR 1152376. Once the CRs are transferred to a work order, focus codes are added and

the main control room deficiency list is then generated off the focus codes, and provided

to the control room staff each morning.

The inspectors also reviewed a failure of the Unit 1 1B-B Centrifugal Charging Pump

(CCP) room cooler on December 4, 2015. The analysis that was completed on May 13,

2016, did not identify the true cause of the failure. Following the second failure on

August 3, 2016, the licensee was able to identify the cause and appropriate corrective

actions.

Problem Prioritization and Evaluation

Based on the review of CRs sampled by the inspection team during the onsite period,

the inspectors concluded that problems were generally prioritized and evaluated in

accordance with the licensees CAP procedures as described in NPG-SPP-22.302,

Corrective Action Program Screening. One notable exception the inspectors identified

was the weakness identified in the performance of formal root cause analysis.

Inspectors concluded CRs were assigned a priority level at the CR screening meeting,

and adequate consideration was given to system or component operability and

associated plant risk.

8

The inspectors identified weaknesses in the performance of formal root cause

evaluations for significant problems. The inspectors determined that station personnel

had conducted root cause and apparent cause analyses mostly in compliance with the

licensees CAP procedures and assigned cause determinations were appropriate,

considering the significance of the issues being evaluated. A variety of formal causal-

analysis techniques were used depending on the type and complexity of the issue

consistent with licensee procedures NPG-SPP-22.300, Corrective Action Program,

NPG-SPP-22.306, Level 1 Evaluation, and NPG-SPP-22.305, Level 2 Evaluation.

There were several examples of root cause evaluations that did not meet the licensees

procedural requirement for independence. This constitutes roughly half of all the

licensees root cause evaluations performed since the last PI&R inspection. The

licensees procedures required the Responsible Manager who approved the root cause

evaluations to be independent from the organization involved in the event. The

licensees procedures also required that the members of the root cause evaluation team

not include personnel who were directly involved or immediately responsible for the

problem. Independence for personnel approving or conducting a root cause evaluation

is not a NRC requirement.

1) Chilled Work Environment Root Cause (Revision 0 and 1) (CR 1155393) was

approved by a different Watts Bar senior manager for each revision despite the fact

that Watts Bar senior management was involved in the chilling effect.

2) Scope Growth on a Safety Related Component (Revision 0 and 1) (CR 1199024)

had a member of the root cause team that was in the Outage Control Center leading

up to the event that required a causal evaluation.

3) Unit 1 Ice Bed Temperature Increasing root cause evaluation (Revision 1) (CR

974404) was approved by a manager who was responsible for the organization that

was determined to be the direct cause of the event.

4) Unit 1 Manual Reactor Trip root cause evaluation (Revision 0) (CR 991403) was

approved by a manager who was responsible for the work group that was the root

cause for the event.

5) Inoperable Source Range Detectors during Reactor Startup (Revision 1) (CR

1096405) was approved by a manager who was responsible for the work group that

was a contributing cause for the event.

6) Seal Plug Found Loose on Control Rod Drive Mechanism (Revision 0) (CR 1102231)

had a member of the root cause team that was responsible for one of the programs

that was determined to be a contributing cause for the event.

The inspector identified the licensee did not adhere to their standards for performing a

root cause analysis in completing the initial revision of the Chilled Work Environment

Root Cause (CR 1155393). The licensee received some support from an external

contractor to review the root cause and incorporated some changes into revision 1 of the

RCA. Not all recommendations or conclusions presented were accepted by the licensee.

These potential gaps were not entered into the CAP and addressed through the program

but rather addressed by revising the original RCA. Specifically, the following items were

most significant:

1) The root cause did not fully evaluate the ineffectiveness of the implementation of the

2009 NRC Confirmatory Order [EA-09-009, EA-09-203]. The root cause only

mentions this order in the timeline.

2) The root cause references the work done in a separate causal analysis for a loss of

confidence in the corrective action program (CR 1151960). However, neither

9

3) addresses the communication of why decisions were made to the disposition and

prioritization of corrective actions. This could have been a contributing cause to the

chilling effect.

4) The extent of condition of the chilling effect to other departments at Watts Bar was

dismissed without an adequate basis. The inspectors discovered substantial

weaknesses in various attributes of SCWE in other departments that were at risk of a

chilling effect.

The inspectors identified examples where CRs or actions were closed to separate CRs

causing challenges in implementing effective evaluation of issues. One example

included CR 1151962 which was initiated in response to an internal Special Review

Team report. The CR was specific and clearly worded that if the decision is made not to

perform causal evaluation, the disposition of this CR must be provided to the WBN Plant

Manager for his concurrence. CR 1151962 was approved for closure to RCA 1155393

by the Licensing Manager without the need for immediate and interim actions being

evaluated and documented in CR 1151962.

The issue was subsequently inadequately captured in CR 1155393 Root Cause

Investigation Charter as a weakness associated with implementation of the Adverse

Employment Action procedure (NPG-SPP-11.10). CR 1155393 Root Cause Analysis

did not address the knowledge weakness associated with the implementation of the

Adverse Employment Action procedure. A causal evaluation was not performed to

understand the organizational and programmatic factors that allowed this weakness to

manifest itself as required in the original CR and there was no indication that the

disposition of the original CR was provided to the WBN Plant Manager for his

concurrence.

Effectiveness of Corrective Actions

Based on a review of corrective action documents, interviews with licensee staff, and

verification of completed corrective actions, the inspectors determined that overall,

corrective actions were timely, commensurate with the safety significance of the issues,

and effective, in that conditions adverse to quality were corrected and non-recurring. For

Significant Conditions Adverse to Quality (SCAQ), the corrective actions directly

addressed the cause and effectively prevented recurrence in that a review of

performance indicators, CRs, and effectiveness reviews demonstrated that the

significant conditions adverse to quality had not recurred. Effectiveness reviews for

corrective actions to prevent recurrence (CAPRs) were generally sufficient to ensure

corrective actions were properly implemented and were effective.

The team reviewed green findings since the last PI&R along with CRs written to

document the findings. The inspectors found that the CRs had adequate corrective

actions in place, completed actions were appropriately closed, and open actions had

reasonable dates for completion. The inspectors reviewed the actions for the CRs and

noted that the majority of them were corrective actions not only for what happened, such

as the performance deficiency, but also included corrective actions for the reason why

the performance deficiency happened.

10

However, the inspectors identified several examples of corrective actions that were

inadequate, closed without an adequate basis, or CAPR actions that may not prevent

recurrence.

1. Corrective action number 6 from the licensees Security Loggable Event root cause

was ineffective in that it did not require the licensee to implement changes to the

Security Performance Improvement Plan. (CR 1228949)

2. Corrective action number 17 from the licensees CEL Response (CR 1162755) was

closed without an adequate basis. The inspectors determined that the action was

closed without providing objective evidence that an effectiveness review was

completed.

3. Corrective action number 18 from the licensees Chilled Work Environment Root

Cause Analysis (CR 1155393) was closed without an adequate basis. The

corrective action was to verify that the chilling effect in the operations department at

Watts Bar did not extend to other departments on site. The inspectors determined

that there was insufficient evidence at the time of closure to make this determination.

4. The root cause for the Unit 1 1B-B CCP room coolers failures (CR 1131520) was a

lack of procedural direction to ensure that CAPRs remain in effect to correct SCAQs.

5. The CAPR for the Scope Growth on a Safety Related Component root cause (CR

1199024) does not address the Outage Control Centers role in the event and most

likely will not preclude repetition.

These examples indicate that there are some challenges to the licensees ability to

sustain their corrective action program.

c. Findings

Introduction: The NRC identified a Green Finding for the licensees failure to consistently

implement the requirements of the CAP. Specifically, the licensee failed to implement

NPG-SPP-22.301, section 3.2.2 which required the licensees staff to initiate a CR to

enter various items into their CAP.

Description: During the preparation for the 2016 Problem Identification and Resolution

inspection the licensee contracted an outside organization to review several of their

causal analyses and CEL responses. The outside organization identified multiple

examples of issues that were not subsequently entered into the licensees corrective

action program. These issues met the CR initiation requirements of NPG-SPP-22.301,

Condition Report Initiation, section 3.2.2, When to Initiate a Condition Report, which

requires in part, any condition adverse to quality (CAQ), equipment issue, performance

concern, issue not meeting written management expectations, and identified gaps to

standards be documented in a Condition Report.

Some of these examples of the outside organizations issues are listed below:

1) The independence of the people assigned to perform the Chilled Work

Environment root cause and the Special Review Team was in question. These

teams consisted primarily of TVA managers.

2) The closure documentation for some corrective actions in the Chilled Work

Environment root cause did not include the critical thinking for closure or

decisions made regarding long term practices.

11

3) The CEL response and the Chilled Work Environment Root Cause Analysis

(RCA) (CR 1155393) did not address the evaluation of the implementation of

Confirmatory Order (EA-09-009, EA-09-203) in a substantial manner. This was

required by the NRC CEL to WBN. Specifically, only 4 of the 10 required actions

had a documented review. Additionally, 2 of the 10 that were reviewed were

considered ineffective.

4) The CR 1162755 causal analysis did not address why 20% of CAP items

converted to work orders were subsequently closed with no work occurring.

5) The effectiveness of the adverse employment action procedure was not

evaluated in the CR 1155393 RCA for two events whose subsequent

management actions should have been considered adverse which were not

entered into the adverse employment action procedure. The events were the

Unit Supervisor that was pulled off shift and the training instructor who was

reassigned from the Outage Control Center back to the training center.

6) Four actions to change procedures in CR 1127691 (actions 006/009/010/016)

were incorrectly coded as enhancements vice corrective actions and were

subsequently not approved to be performed. Since these procedure changes

were enhancements, they only needed peer review and the peer disapproved the

changes.

7) CR 1102231 and the causal analysis never evaluated whether a 10 CFR 21

evaluation was done for reportability. The RCA concluded that a possible cause

for the decreased in vent plug torque was a latent design flaw. Latent design

flaws are required to be evaluated under 10 CFR 21.

Analysis: The licensees failure to implement the requirements of their CAP as required

by NPG-SPP 22.301 was a performance deficiency. Specifically, on at least seven

occasions, the licensee failed to enter issues into their CAP that would have required

corrective actions. The performance deficiency was more than minor because, if left

uncorrected, issues would remain unanalyzed that could represent a more significant

safety concern. The performance deficiency was screened using IMC 0609, Appendix A,

Exhibit 2 Mitigating Systems Cornerstone dated June 19, 2012. The finding screened to

Green because none of the examples were related to any SSC exceeding its technical

specification allowed outage time. A cross cutting aspect of Identification was assigned

because the licensees threshold for identifying and entering CAQ into their CAP was not

low enough as defined by their procedures. (P.1)

Enforcement: Inspectors did not identify a violation of regulatory requirements

associated with this finding. FIN 050000390, 391/2016013-01, Failure to Implement the

Program Requirement to Enter Issues into the CAP.

2. Use of Operating Experience (OE)

a. Inspection Scope

The team examined the licensees use of industry OE to assess the effectiveness of how

external and internal operating experience information was used to prevent similar or

recurring problems at the plant. In addition, the team selected operating experience

documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event

reports, vendor notifications, and plant internal operating experience items, etc.), which

had been issued since November 2014, to verify the licensee had appropriately

12

evaluated each notification for applicability to the Sequoyah Nuclear Plant, and if issues

identified through these reviews were entered into the CAP.

b. Assessment

Based on a review of selected documentation related to operating experience issues,

the inspectors determined that the licensee was generally effective in screening

operating experience for applicability to the plant. Industry OE was evaluated at either

the corporate or plant level depending on the source and type of the document. Relevant

information was then forwarded to the applicable department for further action or

informational purposes. OE issues requiring action were entered into the CAP for

tracking and closure. In addition, operating experience was included in all apparent

cause and root cause evaluations in accordance with licensee procedure NPG-SPP-

22.500, Operating Experience Program.

The team noted that the site is working on making their OE program more robust as they

self-identified some screening weaknesses prior to our inspection.

Documents reviewed are listed in the Attachment.

c. Findings

No finding were identified.

3. Self-Assessments and Audits

a. Inspection Scope

The team reviewed audit reports and self-assessment reports, including those which

focused on problem identification and resolution, to assess the thoroughness and self-

criticism of the licensee's audits and self-assessments. The team reviewed

implementation and audits of the Quality Assurance program against Nuclear Quality

Assurance Plan (NQAP) (TVA-NQA-PLN89-A Rev. 0032) and ANSI/ANS-3.2-2012:

Managerial, Administrative, and Quality Assurance Controls for the Operational Phase of

Nuclear Power Plants. Additionally, the team verified that problems identified through

those activities were appropriately prioritized and entered into the CAP for resolution in

accordance with licensee procedure NPG-SPP-22.102, NPG Self-Assessment and

Benchmarking Program.

Documents reviewed are listed in the Attachment.

b. Assessment

The team determined that the scopes of assessments and audits were adequate. Self-

assessments were generally detailed and critical. The team verified that CRs were

created to document areas for improvement and findings resulting from the self-

assessments, and verified that actions had been completed consistent with those

recommendations. Audits of the quality assurance program appropriately assessed

performance and identified areas for improvement. Generally, the licensee performed

evaluations that were technically accurate.

13

c. Findings

No finding were identified.

4. Safety-Conscious Work Environment

a. Inspection Scope

The team conducted interviews and focus groups with 28 staff, primarily at the first line

supervisor level or above to provide insights regarding the licensees safety conscious

work environment (SCWE). These interviews and focus groups were used to

supplement the information gathered during Part 1 of the PI&R inspection (IR 05000390/2016007; ML16300A409). The team also reviewed the licensees programs

and processes for assessment and monitoring of nuclear safety culture, and the

licensees Employee Concerns Program (ECP) to verify they were effective at supporting

the SCWE.

b. Assessment

Safety Conscious Work Environment

During Part 1 of the PI&R inspection, many of the non-supervisory employees

interviewed felt that their supervisors were most at risk for being retaliated against for

raising concerns. However, all supervisory staff interviewed during Part 2 of the

inspection indicated that they were willing to raise nuclear safety concerns and felt free

to raise concerns to their direct supervisors without fear of retaliation. Many supervisory

staff acknowledged that there had been challenges to the SCWE in their departments in

the past year, but that actions taken following the CEL have resulted in improvements.

However, similar to non-supervisory staff, most supervisory staff also expressed a wait

and see attitude with regard to the sustainability of positive changes. Although there

continued to be department-specific challenges to the work environment, the team

observed that senior management was aware of the challenges and taking actions to

address those challenges. However, with the exception of the Operations department,

many of the other department-specific actions taken or planned to improve the safety

culture and SCWE were not being documented and tracked within the scope of WBNs

chilled work environment improvement plan.

In addition to the feedback provided by non-supervisory staff during Part 1 of the PI&R

inspection, the insights provided by the supervisory staff confirmed that there were site-

wide challenges to the SCWE at WBN. However, managements actions to address the

chilled work environment had improved some of the most significant issues identified by

non-supervisory employees (e.g., management behaviors that discouraged the free flow

of information), and additional actions were planned to address more long-standing

concerns, such as perceptions regarding the lack of adequate resolution to problems

identified via the corrective action program. Notwithstanding these improvements, the

conditions that prompted the issuance of the CEL were confirmed to extend beyond the

Operations department, and the corrective actions to address the CEL should

appropriately be extended site-wide. However, as noted previously, the lack of

documentation and tracking of department-specific actions outside of the Operations

department may impede the sites ability to thoroughly evaluate the effectiveness of

actions to address department-specific SCWE challenges.

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Nuclear Safety Culture Assessment and Monitoring

The team identified weaknesses in the assessment and monitoring of safety culture. In

particular, the team noted a lack of clear, objective or independent criteria for evaluating

when nuclear safety culture standards were met. This was evidenced in how the site

interpreted responses from safety culture surveys and interviews, and how the Nuclear

Safety Culture Monitoring Panel (NSCMP) and Site Leadership Team (SLT) rated

nuclear safety culture traits as part of their continuous monitoring process. The lack of

clear criteria for evaluating nuclear safety culture standards likely contributed to the

missed opportunities to identify and address safety culture weaknesses prior to the

development of the chilled work environment.

• The Extent of Condition review in the Chilled Work Environment Root Cause

(RCA CR 1155393, Attachment E) noted that site-wide pulsing surveys at WBN

had a declining trend from 2015 to March of 2016. In particular, the percentage of

employees who responded favorably to the question, my work environment

encourages the voluntary expression of concerns and differing views about

nuclear safety or quality, dropped from 89% in 2015 to 69% in March of 2016.

However, the extent of condition review concluded that, there was no evidence

of a chilled work environment in any of the WBN departments outside of

Operations. Although the extent of condition was ultimately extended to the

entire site, the statement that there was no evidence of a chilled work

environment in other departments was not consistent with the data presented.

• The Extent of Condition review in RCA CR 1155393 also noted that pulsing

surveys improved for the Operations department from February 2016 to March

2016. However, an in-depth review of the ECP pulsing data and interviews with

the ECP manager revealed that the pulsing surveys in Operations were being

conducted on a shift-by-shift basis. As a result, differences in the monthly pulsing

survey results for Operations may not have indicated actual improvements or

declines in the work environment, but rather different perceptions of the work

environment held by different shifts in Operations.

• The Employee Concerns Program Conduct of Operations Manual, Rev. 1, states

that when analyzing responses to questions in the SCWE, Management, and

Precursor categories, it is ideal for responses to be greater than 90% Always.

At a minimum the aggregate of Always and Often should be greater than

90%. However, these standards for evaluating survey results were not

consistently adhered to, as the 2015 pulsing surveys results did not meet the

minimum threshold of 90% favorable for six out of seven survey questions in the

aforementioned categories. Interviews also suggested that, at times, when the

senior management team reviewed responses to the pulsing surveys, the

sometimes response was included as a favorable response, which also

suggested a relaxation of standards for evaluating safety culture data.

• Presentation materials from the nuclear safety culture and employee

engagement survey conducted in 2015 suggested an improving culture at WBN,

primarily based on one survey question that indicated 75% of the respondents

believed the safety culture at WBN had improved in the past year. However, this

limited assessment of the results did not highlight ongoing challenges to the

WBN safety culture or department-specific challenges, which were apparent in a

15

detailed review of department-specific survey results and comments. In addition,

a single positive statement from the 2015 survey was used as the basis for

determining the safety culture was improving as part of the Chilled Work

Environment RCA. Although WBN recognized the performance deficiency to

track and evaluate results from nuclear safety culture surveys, as required by

NPG-SPP-01.7.3 (CR 1186612), a detailed review of the 2015 survey results

was never performed as part of the RCA. A single indication of an improving

culture was inappropriately used as evidence of a healthy or acceptable culture.

• In September 2016, the Site Leadership Team (SLT) convened for its semi-

annual nuclear safety culture meeting. This meeting consisted of a review of the

last 6 months of information from the Nuclear Safety Culture Monitoring Panel

(NSCMP), which met monthly rather than quarterly as one of the interim

corrective actions the site took due to the issuance of the CEL in March 2016.

Although the NSCMP never rated the environment for raising concerns as a

strength during the previous 6 month period, the SLT chose to rate this safety

culture trait as a strength (the NSCMP rated the trait as an improvement

opportunity on three occasions, and acceptable on two occasions from April-

August). The SLT meeting minutes noted that the environment for raising

concerns was rated as a strength because all employees feel comfortable raising

concerns and no examples could be provided where individuals did not raise

concerns. There was no mention of ECP pulsing surveys, which continued to

indicate challenges to the SCWE in Operations, extent of condition reviews that

identified SCWE challenges in other departments, or ongoing actions to respond

to the Chilling Effect Letter issued by the NRC.

• Also during the September 2016 meeting the SLT rated the problem identification

and resolution trait as acceptable, even though the NSCMP consistently rated

problem identification and resolution as an improvement opportunity from April-

August. The basis for the acceptable rating was noted to be because the site

does well at identifying issues and trending of issues had improved. However,

this rating did not reflect longstanding concerns employees had voiced with

regard to the effective resolution of issues. Overall, the SLT rated six traits as

acceptable, three as improvement opportunities, and one trait as a strength.

• The October 2016 meeting of the NSCMP resulted in lower ratings for many of

the nuclear safety culture traits as compared to previous meetings. However, the

decline in the ratings was not believed to reflect a decline in the site-wide safety

culture, but rather a more accurate indication of the current status of the safety

culture. The basis for the change in the index was attributed to the inclusion of

more craft (non-supervisory) employees at the NSCMP meeting. Six traits were

rated as improvement opportunities, and four traits were rated as acceptable. As

a result, previous NSCMP ratings of safety culture were speculated to be overly

positive.

• The overall effectiveness measure for CAPR closure in the Chilled Work

Environment RCA (CR 1155393) had multiple weaknesses that could challenge

the integrity of the effectiveness review.

16

o Some success criteria were vague and open to interpretation. For

instance, one of the success criteria was favorable results from

employee engagement surveys, yet it was not clear what constituted

favorable results. The 2015 employee engagement survey was

evaluated as favorable, yet further review revealed substantial negative

write-in comments and selected departments with lower scores on key

safety culture measures. In addition, it was not clear what constituted a

satisfactory interim effectiveness review.

o Some success criteria only required evidence that a corrective action had

been completed, not whether the action achieved its intended result. For

example, completion of training and non-training actions from the RCA.

o Some success criteria included vague qualifiers, such as applicable or

selected.

o The effectiveness measure did not stipulate whether all, or only some, of

the success criteria must be met.

The team also identified weaknesses in the training provided to employees who are

responsible for providing inputs to the nuclear safety culture monitoring process, and

employees who are analyzing and making assessments based on these inputs, such as

the participants on the NSCMP. The team noted that all managers and staff receive

computer-based training (CBT) on safety culture and SCWE as part of their initial

training upon hire. In addition, employees were required to take refresher CBT in 2016

as part of the chilled work environment corrective actions. The CBT primarily focused on

defining safety culture terms and emphasizing employees rights and responsibilities to

raise nuclear safety concerns. However, there was no additional training for NSCMP

members to assist them in preparing inputs to the panel meetings or evaluating the

inputs provided at the panel meetings. The lack of training to develop a common

understanding of what to look for in the work environment that could indicate a declining

safety culture may continue to challenge the effectiveness of safety culture self-

assessments.

One of the changes made to the NSCMP meeting format as part of the chilled work

environment improvement plan was to include craft and other non-supervisory

employees in the NSCMP meetings. Interviews indicated that this change was viewed

by management and employees as an improvement to the culture monitoring process.

The safety culture ratings from the October 2016 meeting also appeared to be more self-

critical. However, the NSCMP ratings of the sites safety culture were still susceptible to

large fluctuations in ratings (e.g., over-weighting recent activities rather than taking a

holistic view of the overall state of the safety culture). The sustainability of positive

changes to the sites safety culture may continue to be challenged without independent

checks to ensure that self-assessments are appropriately self-critical.

Employee Concerns Program

The team determined that the documentation in ECP files was sufficiently detailed to

demonstrate appropriate processing of concerns by ECP staff. However, within the ECP

files, it was difficult to track what corrective actions the site had taken as a result of ECP

recommendations. In some cases when CRs were developed to address ECP

recommendations, some of the corrective actions were later changed or cancelled. The

lack of documentation and follow-through to ensure that actions are taken as a result of

ECP substantiated concerns may continue to challenge the perceived effectiveness of

17

ECP, particularly in cases where employees who raise concerns are not getting

feedback regarding how their concerns were addressed.

c. Findings

No findings were identified.

4OA5 Other

1. Review of TVA Response to the Chilled Work Environment For Raising And Addressing

Safety Concerns At The Watts Bar Nuclear Plant

a. Inspection Scope

On March 23, 2016, the NRC issued CHILLED WORK ENVIRONMENT FOR RAISING

AND ADDRESSING SAFETY CONCERNS AT THE WATTS BAR NUCLEAR PLANT

letter (ML16083A479). The NRC requested, in part, that the licensee provide their plan

of action for addressing the chilled work environment to the NRC within 30 days of the

date of the letter. Included in the plan the NRC requested TVA evaluate effectiveness of

the implementation of Confirmatory Order (EA-09-009, EA-09-203) requirements relative

to the current conditions. The Confirmatory Order (CO) Item #1 required the licensee to

implement a process to review proposed adverse employment actions before actions are

taken to determine whether the proposed action comports with employee protection

regulations, and whether the proposed actions could negatively impact the SCWE.

The inspectors reviewed TVAs April 22, 2016, response, entitled RESPONSE TO NRC

LETTER CONCERNING A CHILLED WORK ENVIRONMENT FOR RAISING AND

ADDRESSING SAFETY CONCERNS AT THE WATTS BAR NUCLEAR PLANT

(ML16113A228).

b. Findings:

Introduction: The inspector identified a Severity Level IV NCV of 10 CFR 50.9 (a),

Completeness and accuracy of information, for the licensees failure to provide

accurate information associated with TVAs response to the CHILLED WORK

ENVIRONMENT FOR RAISING AND ADDRESSING SAFETY CONCERNS AT THE

WATTS BAR NUCLEAR PLANT letter dated March 23, 2016. Specifically, on April 22,

2016, the licensee provided information to the Commission that inaccurately indicated

that the licensee completed an evaluation of the effectiveness of the implementation of

CO (EA-09-009, EA-09-203) requirements relative to the current conditions at Watts Bar.

The licensee entered this issue into the corrective action program as CR 1263417.

Description: On March 23, 2016 the NRC issued CHILLED WORK ENVIRONMENT

FOR RAISING AND ADDRESSING SAFETY CONCERNS AT THE WATTS BAR

NUCLEAR PLANT (ML16083A479) after determining that a chilled work environment

existed in the Operations Department at Watts Bar Nuclear Plant. The NRC requested a

response to the letter which included, in part, that the licensee provide their plan of

action for addressing the chilled work environment to the NRC within 30 days of the date

of the letter. Included in the plan we requested TVA evaluate effectiveness of the

implementation of Confirmatory Order (EA-09-009, EA-09-203) requirements relative to

the current conditions.

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On April 22, 2016, the licensee provided, RESPONSE TO NRC LETTER CONCERNING

A CHILLED WORK ENVIRONMENT FOR RAISING AND ADDRESSING SAFETY

CONCERNS AT THE WATTS BAR NUCLEAR PLANT (ML16113A228). In response to

the NRCs request the licensee provided the following response:

Requested Attribute 3: Evaluate effectiveness of the implementation of

Confirmatory Order (EA-09-009, EA-09 203) requirements relative to the current

conditions. A review was conducted to determine the effectiveness of the actions

required by Confirmatory Order EA-09-009/203. The review found that there are

two potential gaps and two additional corrective actions that need follow-up

review. Furthermore, in Table 3 this action was reported as complete.

The inspector reviewed the actions taken by the licensee which were identified as the

basis for making these assertions to the NRC. The inspector reviewed the evaluation

performed associated with CO Item #1. The action the licensee had taken credit for as

an effectiveness review indicated an audit of the adverse action program was in

progress and would be completed in April 2016. It detailed that afterwards, the licensee

would review the audit to determine the effectiveness of this item and in the interim TVA

drafted changes to the adverse action process to ensure safety conscious work

environment issues were thoroughly reviewed prior to taking action. The licensee further

documented completion of an effectiveness review of the CO in CR 1162755 Action 17.

The inspector determined the licensee based their April 22, 2016, response to the NRC

on a report of the completion of these actions. Although these actions were intended to

evaluate the effectiveness of the CO item #1, the licensee failed to recognize that this

activity was not completed prior to their April 22, 2016, letter. Subsequent to the

April 22, 2016, letter the licensee had not completed these actions and closed the action

in the CAP.

Analysis: The NRC determined this constituted a more than minor traditional

enforcement violation associated with failure to provide accurate information. A cross-

cutting aspect was not assigned because traditional enforcement violations are not

assessed for cross-cutting aspects. The ROPs significance determination process does

not specifically consider the regulatory process impact in its assessment of licensee

performance. Therefore, it is necessary to address violations which impede the NRCs

ability to regulate, using traditional enforcement. The inspector determined that the

licensees failure to provide accurate information to the NRC was a violation of the

requirements of 10 CFR 50.9, which had the potential to impede or impact the regulatory

process, and therefore subject to traditional enforcement as described in the NRC

Enforcement Policy, dated November 1, 2016. This violation is characterized as a

Severity Level IV violation because it was similar to Example Section 6.9.d.1 of the NRC

Enforcement Policy and was appropriate for the circumstances.

Enforcement: 10 CFR 50.9, Completeness and Accuracy of Information states, in part,

that information provided to the Commission by a licensee shall be accurate in all

material respects.

Contrary to the above, on April 22, 2016, TVA provided a letter to the Commission that

was not accurate in all material respects. Specifically, TVAs letter was inaccurate in

that it stated that (1) A review was conducted to determine the effectiveness of the

actions required by Confirmatory Order EA-09-009/203; and (2) in Table 3: Focus

19

Area: Willingness to Raise Concerns, Assessment Activity, Effectiveness review of CO

EA-09-203, TVA will conduct an effectiveness review of the applicable corrective

actions completed in accordance with CO-EA-09-009/203 to; Determine whether those

corrective actions were effective in preventing or minimizing recurrence of the issue.

This Table 3 item was annotated as Complete.

These statements were not accurate, in that the licensee failed to complete a review to

determine the effectiveness of action #1 required by Confirmatory Order EA-09-009/203.

This information was material because the NRC relied on this information to determine if

TVA was in compliance with Confirmatory Order EA-09-009/203 requirements, and was

relied on to determine the need, extent, and scheduling of additional regulatory

oversight. This issue has been entered into the licensees CAP as CR 1263417 and is

being treated as an NCV consistent with Section 2.3.2.a of the Enforcement Policy, NCV

0500390,05000391/2016013-02, Failure to Provide Accurate Information.

.2 Implementation of the Confirmatory Order EA-09-009/203 at Watts Bar Nuclear Plant

a. Inspection Scope:

The inspectors reviewed the licensees implementation of Confirmatory Order EA-09-

009/203 and NPG-SPP-11.10 R4, Adverse Employment Action procedure. The

inspector reviewed the licensees documentation of issues associated with the Adverse

Employment Action procedure implementation in CR 1162755.

Background

The inspector reviewed TVA documentation of issues associated with the Adverse

Employment Action procedure implementation in CR 1162755 Action 27.

• Although process requirements were met referencing NPG-SPP-11.10 R4, it

was recognized that the Site VP did not perform reviews of the HR reviews for

disciplinary actions taken, as compared to VPs at SQN and BFN performing the

reviews, considering SCWE. Per WBN HR, these reviews were not required if

SCWE elements were not identified. As a result, industry procedures were

reviewed for comparison of methods used.

The NRC inspector reviewed NPG-SPP-11.10 R4. The CR 1162755 documentation

incorrectly indicated that process requirements used to implement the CO were met.

Specifically, this procedure required a review of HR disciplinary actions for SCWE

implications, even if SCWE elements were not identified. The inspectors reviewed the

following procedural sections of NPG-SPP-11.10, Revision 0004, that provide the site

VP review requirements.

3.1.5 Roles and Responsibilities - TVA Vice President (VP)

A. At nuclear sites, the Site Vice President (or designee) will review certain

proposed actions as described in this SPP to determine if those actions

may be viewed as harassment, intimidation, retaliation or discrimination

(HIRD) or will likely create a chilling effect in the affected organization, or in

other organizations.

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3.2.2 Review Process - Personnel Actions Impacting TVA Employees

D. The Vice President (or designee) will complete section 3, Vice President

Record of Action of form 41175.

E. If the Vice President (or designee) determines that the proposed personnel

action may be viewed as HIRD or will likely create a chilling effect in the

affected organization, or in other organizations, the Vice President (or

designee) will direct the Line Manager to prepare a Chilling Effect Mitigation

Plan (section 4 of form 41175) for Vice President (or designee) review and

approval before taking any proposed personnel action.

F. For NPG employees, if documentation indicates protected activity, the Line

Manager proposing a personnel action under review may not take such action

through the discipline review process unless the Vice President (or designee)

has rendered a determination of "no objection."

G. For employees outside of NPG, no proposed action may be initiated until the

Vice President (or designee) has rendered a determination of "no objection."

3.2.3 Review Process - Personnel Actions Impacting Contractors

C. The TVA HR Representative ensures that the Vice President (or designee)

reviews the package before action is taken and that Vice President Record of

Action is completed. The Vice President (or designee) must review all

proposed actions affecting Staff Augmented or Task Managed Contractors

unless those actions are covered by an exclusion.

D. For proposed actions brought for review to the Vice President (or designee),

the Vice President will complete section 3: Vice President Record of Action.

The Vice President (or designee) will consider all relevant information including

any extenuating or mitigating information.

The inspector also performed an independent review of the implementation of NPG-

SPP-11.10, Adverse Employment Action procedure, because of the inconsistencies in

CR 1162755. The inspector reviewed the implementing procedure and 9 samples

(containing 15 actions) of the application of the Adverse Action Program from the past

24 months at Watts Bar. All of the samples that were reviewed were inadequate to meet

the intent of the Confirmatory Order requirements.

An integrated review and grouping of the deficiencies from the review of the CR and

interviews with site staff responsible for implementation indicated the existence of a

more significant programmatic breakdown as compared to a collection of random

individual implementer errors. These deficiencies were exhibited by the three

fundamental groups primarily responsible for successful implementation of NPG-SPP-

11.10, Attachment 2, TVA 41175 Adverse Employment Action Review process:

Managers; Human Resources; and ECP staff. The deficiency grouping is listed below.

1. The inspector identified deficiencies in the ability of the licensee to determine if

the subject employee had engaged in protected activity. NPG-SPP-11.10,

21

Section 3.2.2 Review Process - Personnel Actions Impacting TVA Employees,

step B includes the following:

As part of completing the Human Resources Review, the HR Representative will

do an independent verification of the employee's activity regarding Employee

Concerns and Problem Evaluation Reports (PERs). The HR Representative shall

contact the Employee Concerns Program regarding Employee Concern issues to

verify if ECP contact has been made within the last twelve months. The

applicable HR Representative shall contact the Performance Improvement group,

or validate through Maximo, to identify if PERs have been generated within the

last twelve months.

During review of the HR activities associated with independent verification of the

employee's activity regarding Employee Concerns and PERs, the inspector

identified multiple examples, of the following activities, which were inconsistent

with the procedure requirements and each resulted in incorrect determinations if

the subject employee had engaged in protected activity:

a. HR was adding a qualifying criteria that PERs generated by the subject

employee be safety related for them to be considered in the evaluation

of potential protected activity. This distinction inappropriately excluded

activities that should have been accounted for as participation in

protected activity. This demonstrates a potential fundamental

misunderstanding of applicability and purpose of the process.

b. In addition to identifying if PERs had been generated by the subject

employee, HR was making determinations if the PERs constituted a

protected activity through review of a simple list of CRs and not a review

of their content.

c. ECP was adding a qualifying criteria that ECP concerns raised by the

subject employee needed to be associated with the adverse action being

proposed for them to be considered in the evaluation of protected activity.

It was also not recognized that ECP contact does not need to be the

subject of the adverse action for it to have a potential adverse effect on

the SCWE.

2. There was a lack of rigor in implementing the process based on the quality of

processing that was observed.

3. Supervisors & HR representatives did not demonstrate an understanding of what

was acceptable for the various required evaluations.

4. Internal review of the program did not identify the widespread issues with

implementation.

5. After receiving feedback about the program implementation from internal

reviews, issues were not identified and entered into the corrective action

program. For example, the inspector identified that in the past 24 months no

chilling effect mitigation plans were developed at Watts Bar. This condition was

not viewed as significant or investigated more deeply as part of the investigation

22

into the Chilled Work Environment at WBN even though adverse actions and the

perceptions they propagated were part of the identified causes. Additionally, a

corporate TVA-wide audit in April 2016 highlighted a concern that none of the

adverse actions sampled during that review had SCWE mitigation plans

developed.

b. Findings

Introduction: The inspector identified an Apparent Violation of Confirmatory Order, (EA-

09-009,203) Dated December 22, 2009 (ML093510993) for the licensees failure to

implement the requirements of the Order. Specifically, the licensee failed to; (1)

implement a process to review proposed licensee adverse employment actions at Watts

Bar Nuclear plant before actions were taken to determine whether the proposed action

comports with employee protection regulations, and whether the proposed actions could

negatively impact the SCWE; and (2) implement a process to review proposed

significant adverse employment actions by contractors performing services at TVAs

nuclear plant sites before the actions were taken to determine whether the proposed

action comports with employee protection regulations, and whether the proposed action

could negatively impact the SCWE. The NRC has not made an enforcement decision on

this matter.

Description: Based on questions concerning the licensees evaluation of the

effectiveness of the implementation of Confirmatory Order (EA-09-009, EA-09-203)

requirements relative to the current conditions, the inspector performed an independent

review of the implementation of NPG-SPP-11.10, Adverse Employment Action

procedure. The inspector reviewed the implementing procedure and 9 samples

(containing 15 action evaluations, sample #2 contained 2 action evaluations and sample

1. 3 contained 6 action evaluations) of the application of the Adverse Action Program

from the past 24 months at Watts Bar. (Due to the sensitive nature of the information

reviewed, the inspector reviewed the results of the inspection activities with the HR

manager and will only reference the records inspected as samples 1-9.)

The review of these records identified the following deficiencies:

• All samples were found to be inadequate and not meeting the intent of the Order.

• All were missing required documentation / evaluations. NPG-SPP-11.10 Sections

3.2.2, subsections A, B, C, E, F, G

• 6 samples did not have any VP/ERB review documented (Samples 1, 2, 3, 4, 8,

9) NPG-SPP-11.10 Sections 3.2.2, subsections C, E, F, G

• 8 samples indicated incorrect determinations of engagement in protected activity

(Samples 1, 2, 3, 4, 5, 6, 7, 9) NPG-SPP-11.10 Sections 3.2.2, subsections A

and B.

• Most did not have adequate, if any, assessment of potential effect on SCWE.

(Samples 3, 4, 6, 7, 8, 9) NPG-SPP-11.10 Sections 3.2.2, subsections A and B

The inspector determined this constituted a failure to comply with requirement 1

contained in Confirmatory Order EA-09-009; 203. The licensee failed to implement a

process to review proposed adverse employment actions before actions were taken to

determine whether the proposed action comports with employee protection regulations,

and whether the proposed actions could negatively impact the SCWE. The inspector

23

based this determination on every example reviewed included deficiencies that

represented either an inadequacy or failure to make determinations of whether the

proposed action comports with employee protection regulations and/or make

determinations of whether proposed actions could negatively impact the SCWE.

Additionally, the inspector identified issues during the inspection which indicated the

existence of a more significant programmatic breakdown as compared to a collection of

individual implementer errors. These deficiencies were exhibited by the three

fundamental groups primarily responsible for successful implementation of the Adverse

Employment Action Review process (NPG-SPP-11.10, Attachment 2, TVA 41175):

Managers; Human Resources; and ECP staff.

Analysis: The NRC determined this violation constituted a more than minor traditional

enforcement violation associated with failure to implement actions required by

Confirmatory Order Modifying License, (EA-09-009,203). A cross-cutting aspect was not

assigned because traditional enforcement violations are not assessed for cross-cutting

aspects. The ROPs significance determination process does not specifically consider

the regulatory process impact in its assessment of licensee performance. Therefore, it is

necessary to address violations which impede the NRCs ability to regulate, using

traditional enforcement. The inspector determined that the licensees failure to

implement actions as required by Confirmatory Order Modifying License, (EA-09-

009,203) dated December 22, 2009 (ML093510993), was an apparent violation. This

violation had the potential to impede or impact the regulatory process, and therefore is

subject to traditional enforcement as described in the NRC Enforcement Policy, dated

November 1, 2016. The NRC has not made an enforcement decision on this matter.

Enforcement: Confirmatory Order Modifying License, (EA-09-009,203) dated

December 22, 2009, (ML093510993) states, in part, that by no later than ninety (90)

calendar days after the issuance of this Confirmatory Order, TVA shall implement a

process to review proposed licensee adverse employment actions at TVAs nuclear plant

sites before actions are taken to determine whether the proposed action comports with

employee protection regulations, and whether the proposed actions could negatively

impact the Safety Conscious Work Environment (SCWE). Such a process should

consider actions to mitigate a potential chilling effect if the employment action, despite its

legitimacy, could be perceived as retaliatory by the workforce.

Additionally, by no later than one hundred twenty (120) calendar days after the issuance

of the confirmatory order, TVA shall implement a process to review proposed significant

adverse employment actions by contractors performing services at TVAs nuclear plant

sites before the actions are taken to determine whether the proposed action comports

with employee protection regulations, and whether the proposed action could negatively

impact the SCWE. Such a process will likewise consider actions to mitigate a potential

chilling effect if the employment action, despite its legitimacy, could be perceived as

retaliatory by the workforce.

TVA implements the above process through procedure NPG-SPP-11.10, Adverse

Employment Action. NPG-SPP-11.10, Section 3.2.2, entitled Review Process -

Personnel Actions Impacting TVA Employees, paragraph D, states that the Vice

President (or designee) will complete section 3, Vice President Record of Action of form

41175 (attachment 2 to NPG-SPP-11.10). Form 41175, entitled TVA 41175 Adverse

Employment Action Review, states that the purpose of the review is to ensure that

24

proposed actions (1) are warranted; (2) do not occur because an individual has engaged

in a protected activity; and (3) do not create the perception that persons were retaliated

against because they engaged in a protected activity.

Additional actions are delineated in NPG-SPP-11.10 Sections 3.2.2, subsections A, B,

C, E, F, G, related to the positions of the Vice President, Line Manager and the Human

Resource Representative, and in Section 3.2.3, entitled Review Process - Personnel

Actions Impacting Contractors.

Contrary to the above, from November 2014 to August 2016, the licensee failed to

comply with Confirmatory Order (EA-09-009,203), in that the site; (1) failed to implement

a process to review proposed licensee adverse employment actions at Watts Bar

Nuclear plant before actions were taken to determine whether the proposed action

comports with employee protection regulations, and whether the proposed actions could

negatively impact the SCWE; and (2) failed to implement a process to review proposed

significant adverse employment actions by contractors performing services at TVAs

nuclear plant sites before the actions were taken to determine whether the proposed

action comports with employee protection regulations, and whether the proposed action

could negatively impact the SCWE. Watts Bar failed to comply with the CO because the

site failed to implement procedure NPG-SPP-11.10, Adverse Employment

Action. Specifically, the Vice President (or designee) failed to complete Form 41175,

entitled TVA 41175 Adverse Employment Action Review as required by Section

3.2.3.D, for multiple adverse employment actions taken against TVA and contractor

personnel during this time period. Additionally, the Vice President, Line Management,

and HR Representatives did not perform procedural steps that were required by

procedure NPG-SPP-11.10, subsection 3.2.2.A, B, C, E, F, and G, and in Section

3.2.3. AV 0500390,05000391/2016013-03, Failure to Implement Confirmatory Order

Requirements for Adverse Employment Action

4OA6 Exit Meeting Summary

On November 17, 2016, December 1, 2016, January 11, 2017, and February 21, 2017,

the inspectors presented the inspection results to Mr. Simmons and other members of

the site staff.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by the

licensee and are violations of NRC requirements which meet the criteria of the NRC

Enforcement Policy, for being dispositioned as a Non-Cited Violation.

Technical Specification 3.5.2 Emergency Core Cooling Systems (ECCS) - Operating

Condition A required, in part, that while in Mode 1 that if one train becomes inoperable

that it be restored to an operable status in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Condition B required action to

place the unit in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if that train is not restored in

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Contrary to the above, the Unit 1 1B-B CCP was inoperable from July 24,

2016, until August 5, 2016, in excess of the allowed outage time of Condition A without

the unit being placed in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as required by

Condition B. This issue was documented in the licensees corrective action program as

CR 1199024. The finding was screened using IMC 0609 Appendix A, Exhibit 2,

Mitigating Systems Screening Questions, dated June 19, 2012. The finding required a

25

detailed risk evaluation because a single train of CCP was inoperable for greater than its

allowed outage time. The regional Senior Reactor Analyst reviewed the inspector

provided detailed risk evaluation that was performed using the Saphire SDP

module. The finding was determined to be Green.

ATTACHMENT: SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel:

S. Connors, Watts Bar Plant Manager

P. Summers, Browns Ferry Director of Safety and Licensing

B. Dungan, TVA Operations CFAM

J. Callie, TVA Corporate Developmental Manager

R. Seipel, Senior Manager, Corporate QA

D. Tesar, Watts Bar Performance Improvement

G. Arent, Watts Bar Licensing Manager

B. J. Allen, Watts Bar Shift Manager

M. Miller, Watts Bar Shift Manager

S. Delk, Watts Bar Performance Improvement

K. McCormick, Watts Bar Human Resources Manager

I. Hagins-Dyer, TVA Employee Concerns Program Manager

LIST OF REPORT ITEMS

Opened

05000390,391/2016013-01 FIN Failure to Implement the Program

Requirement to Enter Issues into the CAP

(4OA2.1.c)

05000390,391/2016013-02 NCV Failure to Provide Accurate Information

(4OA5.1.b)

05000390,391/2016013-03 AV Failure to Implement Confirmatory Order

Requirement for Adverse Employment

Action (4OA5.2.b)

Attachment

LIST OF DOCUMENTS REVIEWED

Procedures

NPG-SPP-01.7, Nuclear Safety Culture Rev. 3

NPG-SPP-01.7.1, Employee Concerns Program Rev. 2

NPG-SPP-01.7.2, Nuclear Safety Culture Monitoring, Rev. 6

NPG-SPP-01.7.3, Conduct of Nuclear Safety Culture Assessments and Organizational

Effectiveness Surveys, Rev. 2

NPG-SPP-03.19, Conduct of Quality Assurance Internal Audits Rev. 0003

NPG-SPP-07.2.5, Outage Control Center, Rev. 12

NPG-SPP-07.2.11, Shutdown Risk Management, Rev. 10

NPG-SPP 07.3 Work Management Process, Rev. 19

NPG-SPP-11.10, Adverse Employment Action, Rev. 4 and 5

NPG-SPP-22.300, Corrective Action Program, Rev. 5 and 6

NPG-SPP-22.301, Service Request Initiation, Rev. 5

NPG-SPP-22.302, Corrective Action Program Screening, Rev. 10

NPG-SPP-22.303, CR Actions, Closures, and Approvals, Rev. 9

NPG-SPP-22.305, Level 2 Evaluation, Rev. 5

NPG-SPP-22.306, Level 1 Evaluation, Rev. 5

NPG-SPP-22.500, Operating Experience Program, Rev 3

0-MI-0.16, Maintenance Guidelines for Belt Driven Equipment, Rev. 14

NIEP-GUID-002 Nuclear Industry Evaluation Program Guidelines Rev 7

Condition Reports

CR 1006456 CR 1111791 CR 1138400 CR 1159529

CR 1022739 CR 1114410 CR 1138406 CR 1159531

CR 1022869 CR 1114975 CR 1138407 CR 1159570

CR 1037157 CR 1116741 CR 1138408 CR 1159574

CR 1038059 CR 1116743 CR 1138411 CR 1159576

CR 1051686 CR 1117683 CR 1138414 CR 1159577

CR 1058300 CR 1117704 CR 1141520 CR 1159579

CR 1064721 CR 1118195 CR 1143483 CR 1159583

CR 1068912 CR 1118632 CR 1144186 CR 1160796

CR 1077284 CR 1120553 CR 1145320 CR 1160910

CR 1078464 CR 1121520 CR 1145455 CR 1162210

CR 1080513 CR 1123625 CR 1148640 CR 1162422

CR 1082102 CR 1125040 CR 1148722 CR 1163150

CR 1082469 CR 1125256 CR 1150853 CR 1163431

CR 1086438 CR 1126079 CR 1151910 CR 1166564

CR 1089482 CR 1127691 CR 1151954 CR 1167102

CR 1090220 CR 1127786 CR 1152029 CR 1167216

CR 1092415 CR 1129322 CR 1152033 CR 1168120

CR 1096405 CR 1131256 CR 1152376 CR 1168996

CR 1096590 CR 1131257 CR 1153507 CR 1168997

CR 1098240 CR 1131261 CR 1155393 CR 1172114

CR 1099011 CR 1133776 CR 1155665 CR 1173130

CR 1105960 CR 1134949 CR 1156304 CR 1173643

CR 1110852 CR 1136395 CR 1159526 CR 1174000

Attachment

3

CR 1174328 CR 1192192 CR 1205689 CR 1225006

CR 1174648 CR 1193846 CR 1205697 CR 1225007

CR 1174766 CR 1193848 CR 1205700 CR 1225008

CR 1175968 CR 1196925 CR 1205701 CR 440533

CR 1178230 CR 1198401 CR 1205702 CR 586986

CR 1178855 CR 1198406 CR 1205704 CR 597045

CR 1179264 CR 1198407 CR 1206000 CR 688380

CR 1180094 CR 1199001 CR 1206140 CR 858640

CR 1180388 CR 1199024 CR 1206191 CR 925734

CR 1183115 CR 1201623 CR1209096 CR 962894

CR 1183877 CR 1201749 CR 1214844 CR 967927

CR 1184858 CR 1202562 CR 1215887 CR 967929

CR 1186612 CR 1203785 CR 1216892 CR 970267

CR 1186886 CR 1205684 CR 1225001 CR 984600

CR 1191927 CR 1205685 CR 1225004

Condition Reports Generated

CR 1228949

Work Order 116843198

116843219

117375376

Self-Assessments & Trends

Contractor review of the RCA for CR 1155393

1028286, WBN-RP-SSA-15-009 snapshot self assessment of PER effectiveness, 05/20/2015

1028291, WBN-RP-SSA-15-009 snapshot self assessment finding, 05/20/2015

1138943, Potential Trend for Training in "Zero Effectiveness" for SA/BMs in trimester,

02/18/2016

1174000, Cognitive Adverse Trend - Station LCO Entries, 5/23/2016

1175070, Trend of reactivity management related issues, 5/25/2016

1175805, Cognitive Adverse Trend - eSOMS violations, 5/27/2016

1139470, Monitoring Trend - PSC Performance, 02/19/2016

1132777, Trend in Engineering CRs being Closed to WOs without a PA focus being applied

to the WO, 6/22/2016

1131109, Modification Impact Reviews Performance Improvement Plan, 6/22/2016

1154532, QA ID, Negative trend associated with TI-65 breaches, 03/28/2016

1101733, Adverse Trend for Timeliness of Engineering Operating Experience (OE) Reviews,

11/06/2015

1199378, QA identified - Adverse Trend in OCC Logkeeping, 08/04/2016

QA-WB-16-004, Corrective Action program (Self-Assessment/ Benchmarking, Trending, and

OE) Watts Bar Nuclear (WBN) 3/28/16 thru 5/16/16

4

Other Documents

Apparent Cause Evaluation for CR 1121520, Rev. 0 Inappropriate Management of an Emergent

Issue Results in a Challenge to Plant Operation

Root Cause Analysis for CR 1127691, Rev. 0 and Rev. 1 Inappropriate Management of an

Emergent Issue Results in a Challenge to Plant Operation

Root Cause Analysis for CR 1155393, Rev. 0 Chilling Effect Letter Causal Analysis

Root Cause Analysis for CR 1206140, Rev. 0 Inappropriate closure of a compensatory measure

Root Cause Analysis for CR 1199024, Rev. 0 1BB CCP Room Cooler Shaft and Bearing

Degradation

Past Operability Evaluation for CR 1199024, Rev. 0

CAP Training Manual section on Correcting Behaviors and Behavior Observation Plans

Control room and OCC staffing watch bill from November 9, 2015 until November 12, 2015

Watts Bar Unit 1 Technical Specifications, Amendment 107

Watts Bar Chilling Effect Letter Review Meeting Minutes from July 18, 2016, August 23, 2016,

and October 4, 2016

Watts Bar Senior Manager mentorship of Shift Managers Program Guidance, Rev. 1

Effectiveness Review results from corrective action 1155393-024

Employee Concerns Program Conduct of Operations, Rev. 1

Gelfond Employee Engagement Survey, dated Summer 2015

Gelfond Nuclear Supplement to Employee Engagement Survey, dated Summer 2015

Nuclear Safety Culture Monitoring Panel Meeting Minutes, 10/13/2016

Nuclear Safety Culture Site Leadership Team Meeting Minutes, 09/07/2016

WBN Safety Conscious Work Environment/CEL Refresher Training, Rev. 0

Shift Order 16-05, 2/19/16

Shift Order 16-15, 8/27/16

Shift Order 16-39, 12/27/16

QA Records

NC-WB-14-016 Assessment Report

1209096 CR Summary Report

1080513 CR Summary Report

QA-WB-16-004 CAP Assessment Report

QA-WB-15-015 Quality Assurance - Oversight Report

QA-WB-14-016 Pre PI and R Assessment Report

SSA 1502 CAP Audit Report - WBN

SSA 1502 CAP Audit Fleet Comparative Report

SSA 1302 WBN CAP Audit Report.

SSA 1302 CAP Fleet Comparative Report

SSA 1411 NIEP