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| {{Adams
| | #REDIRECT [[IR 05000327/2025012]] |
| | number = ML25230A230
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| | issue date = 09/12/2025
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| | title = Nuclear Plant NRC Radiation Safety Inspection Report 05000327/2025012 and Investigation Report 2-2024-011 and Notice of Violation
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| | author name = Suggs L
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| | author affiliation = NRC/RGN-II/DFRSS
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| | addressee name = Erb D
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| | addressee affiliation = Tennessee Valley Authority
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| | docket = 05000327
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| | license number = DPR-077
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| | contact person =
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| | case reference number = EAF-RII-2025-0138, OI 2-2024-011
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| | document report number = IR 2025012
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| | document type = Enforcement Action, Inspection Report, Letter type:OI, Notice of Violation
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| | page count = 1
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| }}
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| =Text=
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| {{#Wiki_filter:EAF-RII-2025-0138 Delson Erb Vice President, OPS Support Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801
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| ==SUBJECT:==
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| SEQUOYAH NUCLEAR PLANT - NRC RADIATION SAFETY INSPECTION REPORT 05000327/2025012 AND INVESTIGATION REPORT 2-2024-011 AND NOTICE OF VIOLATION
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| ==Dear Delson Erb:==
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| This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection and investigation completed on April 23, 2025, at Sequoyah Nuclear Plant, Unit 1 (Investigation Report 2-2024-011). The enclosed Inspection Report (Enclosure 1) presents the results of this inspection and investigation, which were discussed with Kevin Michael, Site Vice President, and members of your staff on August 18, 2025.
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| Based on the results of this investigation, the NRC has determined that one Severity Level IV violation of NRC requirements occurred.
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| The violation was evaluated in accordance with the NRC Enforcement Policy which is available on the NRC's Web site at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in the enclosed Notice of Violation (Notice) (Enclosure 2) and the circumstances surrounding it are described in detail in the subject inspection report. Consistent with Section 2.3.2.a.4 of the NRC Enforcement Policy, the violation is dispositioned as a cited violation because it involved willfulness by contract staff performing work at your facility, the violation was not licensee-identified, and because the NRC determined that a lack of management oversight or supervision of contracted employees was a contributing cause to the violation.
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| The violation is associated with a radiological contamination event that occurred in April 2024 during demobilization of contaminated equipment from the Unit 1 steam generator platforms. On April 23, 2025, the NRCs Office of Investigations (OI) Region II, Atlanta, GA, completed an investigation of this event to determine whether employees willfully violated licensee procedures during the equipment demobilization. Based on the investigation results, the NRC determined that the actions of some contracted employees involved willfulness and directly contributed to the violation being cited. Specifically, some non-supervisory contracted employees demonstrated a careless disregard for radiological boundaries and their radiation work permit.
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| As a result, multiple individuals were contaminated, and contamination was tracked outside the high contamination area and throughout lower containment. The personnel contamination levels in all cases were very low and the resulting dose did not exceed NRC regulatory limits, the individuals were successfully decontaminated as needed, and multiple recounts confirmed there was no residual contamination.
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| September 12, 2025
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| D. Erb 2
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| You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
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| In accordance with NRC Inspection Manual Chapter 0305, Operating Reactor Assessment Program, Section 13.02.b, the NRC may conduct a follow-up inspection of this violation during routine inspection activities or using Inspection Procedure 92702, Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders.
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| In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter, its enclosures, and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the Public without redaction.
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| Sincerely, LaDonna Suggs, Director Division of Fuels, Radiological Safety, and Security Docket No. 50-327 License No. DPR-77
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| ==Enclosures:==
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| 1.
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| Inspection Report 2.
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| Notice of Violation Signed by Suggs, LaDonna on 09/12/25
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| ML25230A230
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| SUNSI Review
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| Non-Sensitive
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| Sensitive
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| Publicly Available
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| Non-Publicly Available OFFICE RII: DFRSS RII: DFRSS RII: ACES RII: RC OGC OE NAME A. Nielsen J. Diaz M. Kowal S. Price R. Carpenter or P. Lom J. Peralta or D. Bradley DATE 08/21/2025 08/21/2025 08/22/2025 08/22/2025 09/09/2025 09/05/2025 OFFICE RII: DFRSS NAME L. Suggs DATE 09/12/2025 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
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| 05000327 License Number:
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| DPR-77 Report Number:
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| 05000327/2025012 Enterprise Identifier:
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| I-2025-012-0014 Licensee:
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| Tennessee Valley Authority Facility:
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| Sequoyah Nuclear Plant Location:
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| Soddy-Daisy, Tennessee Inspection Dates:
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| April 15, 2024, to April 23, 2025 Inspectors:
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| Adam Nielsen, Senior Health Physicist Approved By:
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| LaDonna B. Suggs, Director Division of Fuels, Radiological Safety, and Security
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| 2
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| ==SUMMARY==
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| The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a radiation protection inspection at Sequoyah Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
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| List of Findings and Violations Failure to Implement Radiological Controls During Removal of Contaminated Items from the Unit 1 Steam Generator Platforms Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NOV 05000327/2025012-01 Open EAF-RII-2025-0138 Not Applicable 71124.01 A self-revealing, Severity Level IV violation of Technical Specification 5.4.1 was identified when the licensee failed to implement radiation work permit and procedural requirements during maintenance activities on the Unit 1 steam generator platforms. Specifically, workers tasked with steam generator manway cover installation removed highly contaminated equipment from the primary platforms without radiation protection staff present and without utilizing protective clothing appropriately.
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| Additional Tracking Items None.
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| 3 INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
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| RADIATION SAFETY 71124.01 - Radiological Hazard Assessment and Exposure Controls Radiological Hazards Control and Work Coverage (IP Section 03.04) (1 Sample)
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| The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
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| (1)
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| Steam generator manway cover installation during the U1R26 refueling outage.
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| INSPECTION RESULTS Failure to Implement Radiological Controls During Removal of Contaminated Items from the Unit 1 Steam Generator Platforms Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NOV 05000327/2025012-01 Open EAF-RII-2025-0138 Not Applicable 71124.01 A self-revealing, Severity Level IV (SL IV) violation of Technical Specification (TS) 5.4.1 was identified when the licensee failed to implement radiation work permit (RWP) and procedural requirements during maintenance activities on the Unit 1 steam generator (SG) platforms. Specifically, workers tasked with SG manway installation removed highly contaminated equipment from the primary platforms without radiation protection (RP) staff present and without utilizing protective clothing appropriately.
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| ==
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| Description:==
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| On April 15, 2024, 23 contracted employees entered Unit 1 lower containment to perform manway cover installation on the SG platforms, which were posted as High Contamination Areas (HCAs) at the laydown area step-off pad. After completing manway cover installation, the work crew began demobilization of both primary platforms. This included removal of several highly contaminated and unbagged items (e.g. shield doors with contamination levels up to 250,000 disintegrations per minute per 100 cm2) from the platforms, down into the laydown areas, then out into the raceway. The workers removed the objects from the laydown area HCAs and into the raceway without regard to a step-off pad, walking across the boundary multiple times without stopping to remove outer gloves and shoe covers. In addition, RP technicians were not notified of the demobilization effort and were not present to oversee handling and bagging of the objects and perform surveys of the material
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| 4 prior to leaving the HCA. As a result of these actions, multiple individuals were contaminated, and contamination was tracked outside the HCA and throughout lower containment. The personnel contamination levels in all cases were very low and the resulting dose did not exceed NRC regulatory limits, the individuals were successfully decontaminated as needed, and multiple recounts confirmed there was no residual contamination.
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| During the pre-job briefings prior to entering containment, the work crew had been told to limit their activities to manway cover installation and to notify RP if the job scope changed, as required by licensee procedure NPG-SPP-05.18, Revision 10. The inspectors noted that RWP 24130013 required RP to be present to perform surveys and oversee the bagging of the objects prior to removal from the HCA. The RWP also required workers to wear two sets of gloves and two sets of shoe covers, to facilitate travel across the HCA boundary by use of the step-off pad.
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| On April 23, 2025, the NRCs Office of Investigations (OI) Region II, Atlanta, GA, completed an investigation of this contamination event to determine whether contracted licensee employees willfully violated licensee procedures during demobilization of contaminated equipment from the Unit 1 SG platforms. Based on the investigation results, the NRC determined that the actions of some contracted employees involved willfulness and directly contributed to the violation of NRC requirements.
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| Corrective Actions: The licensee took immediate corrective actions including backtrack surveys to evaluate the extent of the contamination spread and decontamination of areas as needed. The licensee also held meetings with the work crew and their supervisors, and restricted access to the Radiological Controlled Area (RCA) for all workers until remedial radworker training was completed.
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| Corrective Action References: CR 1924598 and CR 1924796 Performance Assessment: None Enforcement: The Reactor Oversight Processs (ROPs) significance determination process does not specifically consider willfulness in its assessment of licensee performance.
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| Therefore, it is necessary to address this violation, which involves willfulness, using traditional enforcement to adequately deter non-compliance.
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| Severity: In accordance with the NRC's Enforcement Policy, the significance of this issue most closely aligns with Severity Level IV example 6.7.d.4: "A licensee fails to conduct required leakage or contamination tests or to use properly calibrated equipment, although the failure does not contribute to an event." Specifically, RP was not present to perform appropriate contamination surveys, but that failure did not contribute to an overexposure or significant event.
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| Violation: During an NRC investigation completed on April 23, 2025, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
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| Sequoyahs TS 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Regulatory Guide 1.33, Appendix A, Section 7, covers RP procedures for access control to radiation areas including a RWP system.
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| Procedure NPG-SPP-05.18, Radiation Work Permits, Revision 10, Section 3.1.4, required
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| 5 individual workers to notify RP staff of any change in job scope.
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| Procedure NPG-SPP-05.1, Radiological Controls, Revision 16, Section 3.2.12, stated that each worker shall be responsible for awareness and compliance with the radiation protection requirements of an RWP and for meeting the prerequisites for RWP entry.
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| RWP 24130013, Revision 0, stated, in part, that any equipment moved from primary SG platforms to laydown areas must be surveyed and bagged/wrapped as determined by RP staff and that RP must survey all equipment prior to removal from laydown areas. RWP 24130013 also required workers to wear two sets of gloves and two sets of shoe covers.
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| Contrary to the above, on April 15, 2024, the licensee failed to implement existing RP procedures associated with access control to radiation areas that included an RWP system, as evidenced by the examples listed below. The failure to follow RP procedures resulted in the contamination of multiple individuals with low levels of radioactive material.
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| : 1. Licensee contractors did not notify RP staff of a change in job scope as required by NPG-SPP-05.18. Specifically, the contractors were directed to install SG manway covers on Unit 1 but proceeded to expand the job scope to remove highly contaminated equipment from the SG primary platforms and laydown areas without notifying RP staff.
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| : 2. Licensee contractors did not comply with the requirements in RWP 24130013 as required by procedure NPG-SPP-05.1. Specifically, the contractors removed several highly contaminated objects from the Unit 1 SG primary platforms and laydown areas without RP staff present to perform the required surveys and oversee bagging of the objects, and failed to appropriately utilize protective clothing when crossing the HCA step-off pad.
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| Enforcement Action: This violation is being cited because it did not meet the non-cited violation criteria in Section 2.3.2.a.4 of the NRC Enforcement Policy, in that the violation involved willfulness by a group of contracted employees, the violation was not licensee-identified, and a lack of management oversight or supervision of contracted employees was a contributing cause to the violation.
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| EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
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| On August 18, 2025, the inspectors presented the results to Kevin Michael, Site Vice President, and other members of the licensee staff.
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| NOTICE OF VIOLATION Tennessee Valley Authority (TVA)
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| Docket No.: 05000327 Sequoyah Nuclear Plant, Unit 1 License No.: DPR-77 EAF-RII-2025-0138 During a U.S. Nuclear Regulatory Commission (NRC) investigation completed on April 23, 2025, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the following violation identified in Inspection Report 05000327/2025012 is being cited:
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| Sequoyah Technical Specification (TS) 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Regulatory Guide 1.33, Appendix A, Section 7, covers radiation protection (RP) procedures for access control to radiation areas including a radiation work permit (RWP) system.
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| Procedure NPG-SPP-05.18, Radiation Work Permits, Revision 10, Section 3.1.4, required individual workers to notify RP staff of any change in job scope.
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| Procedure NPG-SPP-05.1, Radiological Controls, Revision 16, Section 3.2.12, stated that each worker shall be responsible for awareness and compliance with the radiation protection requirements of an RWP and for meeting the prerequisites for RWP entry.
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| RWP 24130013, Revision 0, stated, in part, that any equipment moved from primary steam generator (SG) platforms to laydown areas must be surveyed and bagged/wrapped as determined by RP staff and that RP must survey all equipment prior to removal from laydown areas. RWP 24130013 also required workers to wear two sets of gloves and two sets of shoe covers.
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| Contrary to the above, on April 15, 2024, the licensee failed to implement existing RP procedures associated with access control to radiation areas that included an RWP system, as evidenced by the examples listed below. The failure to follow RP procedures resulted in the contamination of multiple individuals with low levels of radioactive material.
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| 1.
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| Licensee contractors did not notify RP staff of a change in job scope as required by NPG-SPP-05.18. Specifically, the contractors were directed to install SG manways on Unit 1 but proceeded to expand the job scope to remove highly contaminated equipment from the SG primary platforms and laydown areas without notifying RP staff.
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| 2.
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| Licensee contractors did not comply with the requirements in RWP 24130013 as required by procedure NPG-SPP-05.1. Specifically, the contractors removed several highly contaminated objects from the Unit 1 SG primary platforms and laydown areas without RP staff present to perform the required surveys and oversee bagging of the objects, and failed to appropriately utilize protective clothing when crossing the HCA step-off pad.
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| This is a Severity Level IV violation (NRC Enforcement Policy Sections 2.2.1.d and 6.7.d).
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| 2 Pursuant to the provisions of 10 CFR 2.201, TVA is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at Sequoyah Nuclear Plant, within 30 days of the date of the issuance of this Notice of Violation. Please mark your reply "Reply to a Notice of Violation; EAF-RII-2025-0138" and include the following for each violation:
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| (1) The reason for the violation, or, if contested, the basis for disputing the violation or severity level (2) The corrective steps that have been taken and the results achieved (3) The corrective steps that will be taken (4) The date when full compliance will be achieved Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
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| If you contest this enforcement action, please provide an additional copy of your response, with your basis for denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
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| Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
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| Consistent with 10 CFR 19.11, you may be required to post this Notice of Violation within two working days of receipt.
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| Dated this September 12, 2025}}
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