CNL-15-152, Watts Bar Nuclear Plant (WBN) Unit 2 - Reply to Notice of Violation (EA-15-075)
| ML15208A078 | |
| Person / Time | |
|---|---|
| Site: |  |
| Issue date: | 07/24/2015 |
| From: | Shea J W Tennessee Valley Authority |
| To: | Document Control Desk, NRC/RGN-II |
| References | |
| CNL-15-152, EA-15-075 | |
| Download: ML15208A078 (6) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-15-152 July 24, 2015 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.20555-0001 Watts Bar Nuclear Plant,Unit2 Construction Permit No.CPPR-2 NRC Docket No.50-391 10 CFR 2.201
SUBJECT:
WATTS BAR NUCLEAR PLANT(WBN)UNIT2-REPLY TO NOTICE OF VIOLATION (EA-15-075)
Reference:
NRC letter dated June 29, 2015,"Watts Bar Nuclear Plant Unit 2 Construction-NRC Integrated Inspection Report 05000391/2015604 and Notice of Violation" PursuanttoTitle 10, Code of Federal Regulations (10 CFR)2.201, Tennessee Valley Authority's (TVA)response to NoticeofViolation EA-15-075 is enclosed.TVA accepts the violation and has developed and implemented corrective actions to ensure the identified discrepancies have been corrected and will not recur.The enclosure providesTVA'sreplyto theviolation,includinga detailed description of the corrective steps taken and the results achieved.TVA achieved full complianceinMarch 2015 when Engineering completed the assessmentof87 hangers for rebar damage.There arenonew regulatory commitments madeinthisletter.
Should you have questions regarding this response, please contact Gordon Arent at (423)365-2004.J.W.Shea Vice President, Nuclear Licensing Enclosure cc: See Page 2 U.S.Nuclear Regulatory Commission CNL-16-152 Page 2 July 24, 2015
Enclosure:
ReplytoNoticeof Violation cc (Enclosure);
NRC Regional Administrator-Region II NRC Director, Office of Enforcement NRC Senior Resident Inspector-WattsBar NuclearPlant,Unit2NRCProject Manager-WattsBarNuclearPlant,Unit2 WATTS BAR NUCLEAR PLANT,UNIT2 ENCLOSURE REPLY TO NOTICE OF VIOLATION Description of the Violation10CFR50,AppendixB, Criterion V, Instructions, Procedures, and Drawings, requires thatactivitiesaffectingquality shall be prescribed by documented instmctions, procedures, ordrawings,ofatypeappropriatetothecircumstances andshallbe accomplished in accordance with these instructions, procedures, or drawings.Instmctions, procedures, ordrawingsshallincludeappropriate quantitative or qualitative acceptance criteria fordeterminingthatImportantactivitieshavebeen satisfactorily accomplished.
TVA Procedure MAI-5.1B, Wedge Bolt (WB)Anchor Installation, Revision21,isthe implementing/controlling process for anchorboltinstallation, and includes the requirements for drillingtheholeto be used for anchorboltinstallation.MAIS.1B, Revision 21, Section 6.2.5.A.3, states that unless specifically pennitted, reinforcing steel shall not be cut ordrilledtoinstall anchors.Site Engineering approval is requiredtodrill through the reinforcing bar.Contrary to the above, on or about December 1, 2011, contract employees assignedtodrill holes for anchor bolt installation willfullydrilledinto the reinforcing steel of the steam generatorhousing,a safety-relatedstructure,without notifyingSiteEngineering,orobtaining their approval as required by TVA ProcedureMAIS.1B.Specifically,the contract employees damaged reinforcing steel in at least five locations associated with hdes drilled under work Older 111335067 and worii order 111335073.Thisisa Severity Level IV cited violation identified as VIO 05000391/2015604-02, Failure to Follow Anchor Bolt Installation Procedure.
TVA Response TennesseeValleyAuthorityTVA) does not dispute the facts as described by the Nuclear Regulatory Commission(NRC)and accepts theviolation.As noted in theNoticeof Violation, the damage to the structure was evaluated and determinednotto require repair.Reason for the Violation:
Watts Bar Nuclear Plant(WBN)Unit2 contract employees knowingly performed work, outside of the scope of the work order, contrarytoTVA procedure MAI-5.1 B,"Wedge Bolt (WB)AnchorInstallation."TVA's extentofconditionreview determined that the inappropriate work was isolatedtoworkactivitiesinWork Orders (WO)111335067 and 111335073.
Corrective Steps That Have Been Taken And The Results Achieved: Upon notification of the events and circumstances sun^ounding this violation, TVA Employee Concerns Program (ECP)personnel initiated case ECP-2013-WC-429-RR, and Problem Evaluation Report (PER)838631 was generated to enter the concern into the Corrective Action Program.The names of the individuals involved were turned over to the Office of Inspector General (OIG)for their investigation and determination of any legal recourse.Walkdown packages were initiated to inspect theworkperfomried under WO 111335067 and W0111335073.
CNL-15-152 E-1
- Work Order 111335067 installed resen/oir and interconnectingtubingfor snubbers on Steam Generators 2 and 3.*Work Order 111335073 installed reservoir and interconnecting tubing for snubbers on Steam Generators 1 and 4.An apparent cause evaluation and extentofconditionreviewincluded the following.
- Interviews with involved personnel.*A search of work orders performed by involved individuals.
- Walkdown packagestoperform rebar scans near potentially affected supports.The Extent of Condition(EOC)review confirmed the condition waslimitedto personnel responsible for completing WOs 111335067 and 111335073.Ofatotal populationof87 hangers involving the personnel of interestforthe drilling andinstallationof anchorbolts,57hadno rebar damage based on scans and engineering evaluations.
For the remaining 30 hangers.TVA accepted damage at 25 locations as a conservative measure, even though there was no evidence that damage occurred.Five damaged rebar were discovered asaresultoftheinvestigation.Each was evaluated by Engineering and determinedtonot require repair due to safety margin designed into thewallsbeing adequate to accept the damage.Field Change Requests and Drawing Request Authorizations were issued to document both the assumed and confinned rebar damage.Disciplinary actions were taken against the responsible individuals where violations of procedures and/or processestookplace,and were refen^ed to OIGfortheir investigation.
During 2012, TVA was perfonning 10 CFR 50.7 and 50.9 Safety Conscience Wori<Environment(SCWE)trainingfor everyone on theproject.Thistrainingis relevanttothis event because it reinforces a cultureinwhich safety issues can be raised without fear of reprisal, discusses the'chillingeffect',and reiterates the importance of procedure adherence.
Related Corrective Actions: In January 2013, due to other similar events, managementdirectedawork stoppage of anchorboltinstallation.Craft personnelworkon drilling and installing anchor bolts was stopped, and anchor bolt installation retraining was conducted with emphasis on strict procedure use and adherence.Thisretrainingalso focusedoncriteriafor contacting Engineering andobtainingEngineeringauthorizationbefore drilling into rebar or other emt)edded features, emphasized that bendingofboltsisnot procedurally allowed and that scanning for rebar must occurpriortoboring holes in concrete for anchorboltinstallation.Additionally,adirective was issued and disseminated to applicable craft personnel to provide requirements for personneltoperfonn rebar scanningpriortoboring holes for anchor bolts.CNL-15-152 E-2 Asaresultofaprevious TVA willful violation (EA-12-021) and subsequent alternate disputeresolutionresultingina ConfirmatoryOrderbythe NRC, TVA hastakenasignificantnumberofactions addressing expectationsforassuringwork activitiesareperformedand documentedina complete and accurate manner.Specifically, the following actions were taken.*The Chief Nuclear Officer and the Senior Vice President of Nuclear ConstructionissuedajointcommunicationtoallNuclearPowerGroupandNuclearConstmction employees regarding expectationsforassuringworkactivities areperformedand documentedina complete and accurate manner.*The executive management expectations(above)werereinforcedthrough the use offleetwide posters and communications.
These communications specifically discussed 10 CFR 50.9, Completeness and AccuracyofInformation, willful violations, and the consequences of non-compliance.*TVA revised the existing Nuclear PowerGroup(NPG) procedure, NPG-SPP-01.2,"Administration of Site Technical Procedures," to reinforce the requirements of 10 CFR 50.9 and the need to ensure complete and accurate documentation of work completion steps.*TVAprovided initial 10 CFR 50.9trainingin 2012 (manager, supervisor and craft-level) to employeesatall Nuclear Construction sites.*TVAprovided refresher 10CFR50.9trainingin 2014 (manager, supervisor andcraft-level)toWBNUnit2 employees, which will continue every two years through 2016, or until construction is complete.*TVA enhanced existing 10 CFR 50.9 related general employeetraining(GET)for new employees joining Nuclear Power Group and Nuclear Construction, and updated the associated annual requalification training.*Withinsix months of issuance of the Confirmatory Order andpriorto July 1, 2013, TVA performed checks of theWBNUnit2 construction contractors and subcontractors via the Employee Concems Program(ECP),toidentify scheduling pressure issues.Surveys were taken in December 2012 and May 2013.Issues identified were and continue to be addressed commensurate with safety and in accordancewithTVA's Corrective Action Program.In 2013, TVA performed effectiveness reviews of actions taken and actions planned, including those taken in response to the ECP checks described above.Based on the results of the effectiveness review, TVA implemented appropriate corrective actions.CNL-15-152 E-3 Project Oversight:
Broader project oversight activities are alsocontinuallybeing performed to assess WBNUnit2 performance.
Theseactivitiesincludethe following:
- Independent Project Assurance organization established and began performing assessments in Summer 2012.*Work environment (cultural risk)assessment wasinitiatedin conjunction with OIG in January 2013.The purposeofthis assessmentistoimprovedialogue,buildtrust and a better work environment, identify potential risks to the project, and help ensure theprojectis completed in accordancewithregulatory requirements.
- Nuclear Construction Review Board was establishedinApril 2012.The board performs independentreviewI assessments in selected focus areas including nuclear safety culture work environment and safety concerns.*The OIG staff is located on site.Senior project management routinely interfaces with OIG staff as issues are identified and requests assistance with investigations as needed.*IndependentProjectReview Team was established.
The team providesinsightto the TVA Nuclear Oversight Committee from independent nuclear experts and provides an independent perspective of nuclear safety culture.Corrective Steps That Will Be Taken: TVA will continuetoprovide refresher 10CFR50.9training (manager, supervisor andcraft-level)toWBNUnit2 employees every two years through 2016,oruntil constmction is complete.Date When Full Compliance Will Be Achieved: TVA achieved full complianceinMarch 2015 when Engineering completed the assessment of 87 hangers for rebar damage.CNL-15-152 E-4