ML23220A158
| ML23220A158 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 08/09/2023 |
| From: | Louis Mckown Division Reactor Projects II |
| To: | Jim Barstow Tennessee Valley Authority |
| References | |
| IR 2023002 | |
| Download: ML23220A158 (1) | |
See also: IR 05000390/2023002
Text
Vice President Nuclear Regulatory
Affairs & Support Services
Tennessee Valley Authority
Chattanooga, TN 37402-2801
SUBJECT: WATTS BAR NUCLEAR PLANT - INTEGRATED INSPECTION REPORT
05000390/2023002 AND 05000391/2023002
Dear James Barstow:
On June 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
Watts Bar Nuclear Plant. On August 3, 2023, the NRC inspectors discussed the results of this
inspection with Mr. Anthony Williams, Site VP and other members of your staff. The results of
this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Two of these
findings involved violations of NRC requirements. We are treating these violations as non-cited
violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this
inspection report, 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
Watts Bar Nuclear Plant.
If you disagree with a cross-cutting aspect assignment 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 Watts Bar Nuclear Plant.
This letter, its enclosure, and your response (if any) will be made available for public inspection
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public
Inspections, Exemptions, Requests for Withholding.August 9, 2023
J. Barstow 2
Sincerely,
Louis J. McKown, II, Chief
Reactor Projects Branch #5
Division of Reactor Projects
Docket Nos. 05000390 and 05000391
License Nos. NPF-90 and NPF-96
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Signed by McKown, Louis
on 08/09/23
X SUNSI Review X Non-Sensitive X Publicly Available
Sensitive Non-Publicly Available
OFFICE RII/DRP RII/DRP RII/DRP
NAME W. Deschaine N. Smalley L. McKown
DATE 08/9/2023 08/9 /2023 08/9 /2023
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers: 05000390 and 05000391
License Numbers: NPF-90 and NPF-96
Report Numbers: 05000390/2023002 and 05000391/2023002
Enterprise Identifier: I-2023-002-0023
Licensee: Tennessee Valley Authority
Facility: Watts Bar Nuclear Plant
Location: Spring City, TN 37381
Inspection Dates: April 1, 2023, to June 30, 2023
Inspectors: J. Bell, Senior Health Physicist
W. Deschaine, Senior Resident Inspector
K. Henry, Resident Inspector
M. Keefe-Forsyth, Safety Culture Program Manager
M. Magyar, Reactor Inspector
A. Nielsen, Senior Health Physicist
J. Rivera, Health Physicist
D. Simpkins, Sr. Tech Training Program Specialist
J. Weaver, Allegations & Enforcement Specialist
R. Wehrmann, Resident Inspector
D. Willis, Team Leader
Approved By: Louis J. McKown, II, Chief
Reactor Projects Branch #5
Division of Reactor Projects
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Watts Bar 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.
List of Findings and Violations
Failure to demonstrate effective control of performance of a maintenance rule (a)(2) system
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.3] - Change 71111.12
Systems NCV 05000390,05000391/2023002-01 Management
Open/Closed
The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR
50.65(a)(2) for failure to demonstrate the effective control of performance of a maintenance
rule scoped system through appropriate preventive maintenance. Specifically, the licensee
failed to adequately monitor performance of the shutdown board room (SDBR) heating
ventilation and air conditioning system (HVAC), a maintenance rule scoped system, in
accordance with their preventive maintenance program and did not implement (a)(1) goals
and corrective actions.
Failure to adequately implement ERCW Surveillance Test Procedure
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.14] - 71111.24
Systems NCV 05000390,05000391/2023002-02 Conservative
Open/Closed Bias
The inspectors identified a Green finding and associated NCV of Technical Specification (TS)
5.7.1.1 a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2,
Appendix A, February 1978. Specifically, failure to implement Section 6.4 of 0-SI-67-917-A
Revision 021, Essential Raw Cooling Water Pumps A-A and B-A Comprehensive Pump Test,
and 0-SI-67-918-A, Revision 022, Essential Raw Cooling Water Pumps C-A and D-A
Comprehensive Pump Test, and Appendix F of these procedures were not performed.
Specifically, failure to perform these sections did not ensure that the system was restored to
its normal alignment.
Additional Tracking Items
None
2
PLANT STATUS
Unit 1 began the inspection period at rated thermal power (RTP). On April 14, 2023, the unit
was shutdown for a planned refueling outage (U1R18). The unit was returned to 100 percent
RTP on May 15, 2023. On May 16, 2023, the unit was down powered to 39% due to a Low-
Pressure Feedwater Heater string isolation and dropped rod (M4). The unit was returned to 100
percent RTP on May 20, and remained there for the remainder of the inspection period.
Unit 2 operated at or near rated thermal power for the entire inspection period.
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 performed activities described in IMC 2515,
Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of
IPs. 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) Unit 1 Residual Heat Removal system (both trains) on April 20th, 2023.
(2) Units 1 & 2 Spent Fuel Pool Cooling system on April 26th, 2023.
(3) Unit 1 Auxiliary Feedwater System on June 28, 2023.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1) Intake Pumping Station (Elevations 711', 722' and 741') on May 24, 2023.
(2) Cable Spreading Room (Control Building Elevation 729' and 741') on June 5, 2023.
(3) Unit 1 Control Rod Drive Equipment Room, Pressurizer Heater Transformer Room,
and Miscellaneous Equipment Room (Auxiliary Building Elevations 782' and 786') on
June 26, 2023.
(4) Auxiliary Building Corridor (Elevation 676') on June 27, 2023.
3
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated the onsite fire brigade training and performance during an
announced fire drill on May 31, 2023.
71111.06 - Flood Protection Measures
Flooding Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated internal flooding mitigation protections in the Unit 1 and 2
turbine driven auxiliary feedwater pump rooms on June 29, 2023.
71111.08P - Inservice Inspection Activities (PWR)
The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-
significant piping system boundaries, and containment boundary are appropriately monitored for
degradation and that repairs and replacements were appropriately fabricated, examined and
accepted by reviewing the following activities from April 24, 2023, to April 27, 2023:
PWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01) (1 Sample)
The inspectors verified that the following nondestructive examination and welding activities
were performed appropriately:
(1) Ultrasonic Examination (UT)
MRP-146-CL-1, Pipe to Nozzle, Augmented (reviewed)
MRP-146-CL-2, Pipe to Nozzle, Augmented (reviewed)
Visual Examination (VT)
Bare metal visual of the Reactor Vessel Closure Head, N-729-6 (reviewed)
PWR Inservice Inspection Activities Sample - Vessel Upper Head Penetration Inspection
Activities (IP Section 03.02) (1 Sample)
The inspectors verified that the license conducted the following vessel upper head
penetration inspections and addressed any identified defects appropriately:
(1) Bare metal visual of the Reactor Vessel Closure Head, N-729-6 (reviewed)
PWR Inservice Inspection Activities Sample - Boric Acid Corrosion Control Inspection Activities
(IP Section 03.03) (1 Sample)
The inspectors verified the licensee is managing the boric acid corrosion control program
through a review of the following evaluations:
(1) Boric Acid Walkdown - April 17, 2023
CR 1739795
CR 1850475
4
CR 1850485
CR 1850488
CR 1850494
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(2 Samples)
(1) The inspectors observed and evaluated licensed operator performance in the control
room for the following activities:
Unit 1 Startup on May 11, 2023
Dropped Rod recovery on May 18, 2023
(2) The inspectors observed and evaluated licensed operator performance in the control
room during the following activities:
Unit 1 shutdown activities on April 14, 2023
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1) The inspectors observed and evaluated the following licensed operator requalification
(LOR) simulator scenarios (LOR training cycle 2302), which included a reactor
coolant system (RCS) loop 2 T cold failing high, a small break loss-of coolant
accident (LOCA), and a large break LOCA.
Crew 5A on June 1, 2023
Crew 5B on June 1, 2023
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1) System 31 - Shutdown Board Room HVAC and timeliness of placing the system in
(a)1 status, CR 1848149 documented this condition on April 4, 2023, and inspectors
reviewed the CR and Maintenance Rule (a)1 evaluation during May 2023.
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to
ensure the following SSC remains capable of performing its intended function:
(1) Electrical cable termination on safety related cables in the RCS on April 25, 2023.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 Samples)
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The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1) Unit 1 shutdown activities for refueling outage April 14 - 15, 2023.
(2) Unit 1 Blackout testing & Mode 5 & 6 activities during the week of April 16, 2023.
(3) Risk assessment for (week of) April 23, 2023, with testing on the A train shutdown
board and the Unit 1 core having been off-loaded.
(4) RWST level switch troubleshooting and repair on May 17, 2023, under
WO 123741821 and CR 1856924.
(5) Dropped rod troubleshooting and recovery under CR 1856992 and WO 123741325
on May 17, 2023.
(6) Unit 1 elevated risk due to A train essential raw cooling water (ERCW) pump
troubleshooting and comprehensive testing on May 23, 2023, under WO 123109038.
(7) Unit 1 elevated risk due to Delta T/TAVG channel tuning being extended to a second
workday under WO 122773491 on May 24, 2023, and May 25, 2023.
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (1 Sample)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1) Operability evaluation of A train ERCW pumps documented in CR 1858712 and
Immediate Determination of Operability documented in EWR 123753097 on May 25,
2023.
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1) WBN-2021-031-002, Temporary chiller to support replacement of B train shutdown
board room chiller on June 30, 2023.
(2) WO TM - 122006136, Installation of an electrical jumper (which supports auto-start
logic for SDBR A chiller package) while the SDBR B chiller package is out-of-service
for maintenance on June 30, 2023.
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated refueling outage 1R18 activities from April 14, 2023, to
May 12, 2023.
71111.24 - Testing and Maintenance of Equipment Important to Risk
6
The inspectors evaluated the following testing and maintenance activities to verify system
operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)
(1) Surveillance Instruction 1-SI-32-901-A, Valve Full Stroke Exercising during Cold
Shutdown Control Air (Train A), following maintenance of 1-FCV-32-80 and 1-FCV-
32-110, on April 27, 2023 (WO 122771552).
(2) Surveillance Instruction 1-SI-74-905-A, Residual Heat Removal Pump 1A-A
Comprehensive Test during refueling outages, following pump rebuild, on April 28,
2023 (WO 122772523).
(3) Surveillance Instruction 1-SI-72-906-A, Containment Spray Valve Position Indication
Verification / Full Stroke Exercising (Train A), following maintenance of 1-FCV-72-2,
on April 30, 2023 (WO 122772211).
(4) Surveillance Instruction 1-SI-72-908-A, Containment Spray Pump 1A-A
Comprehensive Pump Test, following a motor replacement, on April 30, 2023 (WO 123456131).
(5) Surveillance Instruction 1-SI-3-920, Valve Position Indication Verification AFW
System Turbine Driven AFW Train, following Level Control Valve maintenance on the
Unit 1 TDAFW, on May 3, 2023 (WO 122772376).
(6) Surveillance Instruction 1-SI-3-901-A, Motor Driven Auxiliary Feedwater Pump 1A-A
Quarterly Performance Test, following maintenance of 1-CKV-3-815, on May 3, 2023
(WO 123590770).
Surveillance Testing (IP Section 03.01) (3 Samples)
(1) Surveillance Instruction 0-SI-82-3, Loss of Offsite Power with Safety Injection - DG
1A-A, on April 16-17, 2023 (WO 122771788).
(2) Surveillance Instruction 0-SI-82-19-A, 184 Day Fast Start and Load Test DG 2A-A, on
May 16, 2023 (WO 123108830).
(3) Surveillance Instructions 0-SI-67-917-A and 0-SI-67-918-A, A train Essential Raw
Cooling Water (ERCW) Comprehensive Tests, on May 30, 2023 (WOs 123765351
and 123765355).
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
(1) Surveillance Instruction 1-SI-63-907, Residual Heat Removal Hot Leg and Cold Leg
Injection Check Valve Testing During Refueling Outages, on April 18, 2023 (WO 122771649).
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
(1) Surveillance Instruction 1-SI-43-701-A, Containment Isolation Valve Local Leak Rate
Test Post Accident Sampling (X-86A), on April 24, 2023 (WO 122772805).
Ice Condenser Testing (IP Section 03.01) (1 Sample)
(1) Surveillance Instruction 1-SI-61-2, Unit 1 Ice Weighing, from April 30, 2023, to
May 7, 2023, (WO 122771773).
71114.06 - Drill Evaluation
7
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
(1 Sample)
(1) The inspectors observed the sites response to an emergency preparedness drill on
April 5, 2023. This drill involved a reactor coolant system leak that started small and
progressed into a larger break. As the refueling water storage tank drained due to
injection into the core, a transfer to cold leg recirculation was required but both
containment sump recirculation valves failed to open so the emergency core cooling
system pumps and containment spray pumps had to be turned off which led to
inadequate core cooling and a general emergency declaration.
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated how the licensee identifies the magnitude and extent of
radiation levels and the concentrations and quantities of radioactive materials and
how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated how the licensee instructs workers on plant-related
radiological hazards and the radiation protection requirements intended to protect
workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and
controlling contamination and radioactive material:
(1) Material stored in spent fuel pool
(2) Licensee surveys of potentially contaminated material leaving the Radiologically
Controlled Area.
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following
radiological work:
(1) Unit 1 reactor vessel head lift
(2) Refuel floor activities
(3) Unit 1 reactor vessel defueling
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very
8
(1) Unit 1 entry to under-vessel area
(2) Tritiated drain collector tank
(3) Waste packaging area
(4) Unit 2 pipe chase
(5) Unit 1 regenerative heat exchanger
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section
03.06) (1 Sample)
(1) The inspectors evaluated radiation worker and radiation protection technician
performance as it pertains to radiation protection requirements.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation
systems:
(1) Main Control Room Emergency Ventilation System
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
(1) High Efficiency Particulate Air unit in use for Unit 1 seal table work
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
(1) The inspectors evaluated the licensees use and maintenance of self-contained
breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
(1) The inspectors evaluated licensee performance as it pertains to radioactive source
term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
(1) The inspectors evaluated how the licensee processes, stores, and uses external
dosimetry.
Internal Dosimetry (IP Section 03.03) (1 Sample)
The inspectors evaluated the following internal dose assessments:
9
(1) Reviewed three positive whole body count records from 06/01/2021 to 05/17/2023
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
(1) Reviewed three declared pregnant worker records from 06/01/2021 to 05/17/2023
(2) Reviewed three multi-badging records from 06/01/2021 to 05/17/2023
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (10 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant
walkdowns:
(1) Area Radiation Monitors (ARMs) in the auxiliary building
(2) ARMs in the turbine building
(3) ARMs on the refueling floor
(4) Small Article Monitors (SAMs) at the exit to the radiologically controlled area (RCA)
(5) Portal Monitors (PMs) at the exit to the RCA
(6) Personnel Contamination Monitors (PCMs) at the exit to the RCA
(7) Portable ion chamber survey meter ready for use in the instrumentation lab
(8) Telepole radiation survey meter ready for use in the instrumentation lab
(9) REM Ball neutron survey meter ready for use in the instrumentation lab
(10) AMP-100 GM ratemeter ready for use in the instrumentation lab
Calibration and Testing Program (IP Section 03.02) (14 Samples)
The inspectors evaluated the calibration and testing of the following radiation detection
instruments:
(1) Waste Packaging Area Radiation Monitor, 0-RE-90-3
(2) Unit 2 Upper Containment High Range Radiation Monitor, 2-RE-90-271
(3) Unit 2 Lower Containment High Range Radiation Monitor, 2-RE-90-273
(4) SAM-12s, TVA no. 848507
(5) GEM-5s (PM), TVA no. 848514
(6) ARGOS-5ABs (PCM), TVA no. 848606
(7) Ludlum 9-3 ion chamber survey meter, TVA no. 952051
(8) Telepole II survey meter, TVA no. 952194
(9) RadEye-G survey meter, TVA no. 951239
(10) Ludlum 12-4 / REM Ball neutron survey meter, TVA no. 951093
(11) AMS-4 continuous air monitor, TVA no. 860405
(12) Steadfast II whole body counter
(13) Ludlum Model-177 benchtop counter, TVA no. 07212
(14) DMC 3000 self-reading dosimeter, serial no. A1DCE9
Effluent Monitoring Calibration and Testing Program Sample (IP Section 03.03) (2 Samples)
10
The inspectors evaluated the calibration and maintenance of the following radioactive
effluent monitoring and measurement instrumentation:
(1) Unit 2 Shield Building Vent Radiation Monitor, 2-RE-90-400
(2) Waste Disposal System Liquid Effluent Monitor, 0-RE-90-122
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
(1) April 4, 2022, through May 17, 2023
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) Qualified Safety Culture Assessors performed a follow-up corrective action inspection
the week of May 1, 2023. The scope of this inspection included review of corrective
actions taken following identification of safety conscious work environment (SCWE)
concerns in the Watts Bar Chemistry Department as observed in NRC Inspection
Report 05000390, 391/2022003 and ML 23128A275. The May 2023, team
conducted interviews and focus groups of impacted licensee staff and leadership.
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
(1) The inspectors reviewed the licensees corrective action program for potential
adverse trends in the area of procedure use and adherence in the operations
department that might be indicative of a more significant safety issue.
71153 - Follow Up of Events and Notices of Enforcement Discretion
Personnel Performance (IP section 03.03) (2 Samples)
(1) The inspectors evaluated the B train low pressure feedwater heater isolation and
subsequent dropped control bank rod and licensees performance on May 16, 2023.
(2) The inspectors evaluated operator performance during an unanticipated Unit 2 trip
from an intermittent failure of the Current Transformer (CT) 252 on June 29, 2023.
Reporting (IP section 03.05) (1 Sample)
(1) Inspectors evaluated the licensee submittal of Event Notification 55441 eight-hour
notification under 10 CFR 50.72(b)(3)(ii)(B) for unanalyzed condition of 2A EDG.
11
INSPECTION RESULTS
Failure to demonstrate effective control of performance of a maintenance rule (a)(2) system
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.3] - Change 71111.12
Systems NCV 05000390,05000391/2023002-01 Management
Open/Closed
The inspectors identified a Green finding and associated non-cited violation (NCV) of 10 CFR
50.65(a)(2) for failure to demonstrate the effective control of performance of a maintenance
rule scoped system through appropriate preventive maintenance. Specifically, the licensee
failed to adequately monitor performance of the shutdown board room (SDBR) heating
ventilation and air conditioning system (HVAC), a maintenance rule scoped system, in
accordance with their preventive maintenance program and did not implement (a)(1) goals
and corrective actions.
Description: While reviewing reliability and availability data for the SDBR HVAC system
(system 031, function 030-K) from December 1, 2020, to, January 30, 2023, the inspectors
identified that the licensee had changed the plant configuration of the system from the
described configuration in the UFSAR.
UFSAR section 9.4.3.2.4 Shutdown Board Room Air-Conditioning System states in part that
The electrical boards for either unit can provide the service necessary for the safe shutdown
of both plant units following an accident in either unit. Environmental control (for the shutdown
boards) is provided by four fan-coil air-handling units supplied with chilled water from two
100% redundant water chillers. One of the two redundant chillers is normally operating, and
the other is in standby.
As of February 10, 2022, the licensee modified the plant configuration under TMOD WBN-0-
2021-031-002, to install a temporary non-safety related chiller for the B train SDBR chiller.
This non-safety related chiller has been in service providing environmental control for the
SDBRs since this date and the A train SDBR room chiller was placed in standby and has not
been started or run since. Without performance data required to support (a)(2) status start or
run demands the reliability of the A train of SDBR could not be assessed.
The licensees procedure NPG-SPP-03.4, Maintenance Rule, Performance Indicator
Monitoring, Trending and Reporting - 10CFR50.65, Section 3.2.6 A. directs licensee staff to
change monitoring status from (a)(2) to (a)(1) when performance data required to support
(a)(2) status is no longer collected or available.
Hence, NPG-SPP-03.4 required the licensee to change the status of this system from (a)(2)
to (a)(1) which they failed to do until the NRC brought this to the sites attention on January
30, 2023.
Corrective Actions: Following the meeting with the NRC on January 30, 2023, the site moved
the SDBR HVAC system (system 031, function 030-K) from (a)(2) to (a)(1) and created an
(a)(1) evaluation in accordance with their procedure NPG-SPP-03.4. The (a)(1) evaluation
was presented to the maintenance rule expert panel on February 16, 2023, and the (a)(1)
plan was approved by the maintenance rule expert panel on March 22, 2023. The site also
entered this condition into their corrective action plan as CR 1848149.
12
Corrective Action References: CR 1848149
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to adequately
implement the requirements of NPG-SPP-03.4, Maintenance Rule, Performance Indicator
Monitoring, Trending and Reporting - 10CFR50.65, Revision 5 was a performance
deficiency reasonably within the licensees ability to foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Equipment Performance attribute of the Mitigating
Systems cornerstone and adversely affected the cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. Specifically, due to a lack of any performance or condition
monitoring of the A Train of the SDBR HVAC system the licensee failed to demonstrate that
the performance of the system is being effectively controlled through maintenance. This
condition is similar to the Inspection Manual Chapter 0612 Appendix E more than minor
Example 8.g.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The
inspectors assessed the significance of the finding using Inspection Manual Chapter 0609,
attachment 04, Initial Characterization of Findings, and determined that the finding was
associated with the Mitigating Systems cornerstone. Using Inspection Manual Chapter 0609,
appendix A, The Significance Determination Process For Findings At-Power, exhibit 2,
Mitigating Systems Screening Questions, section A, the screening questions, were all
answered a NO; therefore, the inspectors determined the finding was of very low safety
significance (Green).
Cross-Cutting Aspect: H.3 - Change Management: Leaders use a systematic process for
evaluating and implementing change so that nuclear safety remains the overriding priority.
The inspectors determined that the finding has a cross-cutting aspect of Change
Management - H.3 in the Human Performance area because the licensee failed to use a
systematic process for evaluating and implementing change so that nuclear safety remains
the overriding priority. Specifically, when the plant was modified by TMOD WBN-0-2021-031-
002 no maintenance rule evaluation was conducted the SDBR HVAC system.
Enforcement:
Violation: 10 CFR 50.65(a)(1), requires, in part, each holder of an operating license for a
nuclear power plant under this part shall monitor the performance or condition of structures,
systems, or components, against licensee-established goals, in a manner sufficient to provide
reasonable assurance that these structures, systems, and components, as defined by 10 CFR 50.65(b), are capable of fulfilling their intended functions.
10 CFR 50.65(a)(2), requires, in part, that monitoring as specified in 10 CFR 50.65(a)(1) is
not required where it has been demonstrated that the performance or condition of a structure,
system, or component is being effectively controlled through the performance of appropriate
preventive maintenance, such that the structure, system, or component remains capable of
performing its intended function.
Contrary to the above, from January 15, 2022, until March 22, 2023, the licensee failed to
13
demonstrate that the performance or condition of a structure, system, or component was
being effectively controlled through the performance of appropriate preventive maintenance,
such that the structure, system, or component remained capable of performing its intended
function. Specifically, the licensee failed to demonstrate that the performance of the A SDBR
HVAC system was being effectively controlled such that the system remained capable of
performing its intended function.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to adequately implement ERCW Surveillance Test Procedure
Cornerstone Significance Cross-Cutting Report
Aspect Section
Mitigating Green [H.14] - 71111.24
Systems NCV 05000390,05000391/2023002-02 Conservative
Open/Closed Bias
The inspectors identified a Green finding and associated NCV of Technical Specification (TS) 5.7.1.1 a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2,
Appendix A, February 1978. Specifically, failure to implement Section 6.4 of 0-SI-67-917-A
Revision 021, Essential Raw Cooling Water Pumps A-A and B-A Comprehensive Pump Test,
and 0-SI-67-918-A, Revision 022, Essential Raw Cooling Water Pumps C-A and D-A
Comprehensive Pump Test, and Appendix F of these procedures were not performed.
Specifically, failure to perform these sections did not ensure that the system was restored to
its normal alignment.
Description: On May 30, 2023, the NRC inspectors reviewed the completed surveillance
tests packages of Essential Raw Cooling Water (ERCW) Train A Comprehensive Pump
Testing Surveillances 0-SI-67-917-A Rev 021 (Essential Raw Cooling Water Pumps A-A and
B-A Comprehensive Pump Test) and 0-SI-67-918-A Rev 022 (Essential Raw Cooling Water
Pumps C-A and D-A Comprehensive Pump Test). ERCW Comprehensive Pump tests were
performed on 30 May 2023.
During their review, the inspectors observed that the licensee had not performed Appendix F
in either procedure. Appendix F in either procedure has a Note that states, in part, that the
next steps ensure ERCW flow to the CS and SI Pump Room coolers. Specifically, from May
30, 2023, to June 1, 2023, the licensee failed to implement all portions of these Surveillance
procedures. 0-SI-67-917/918-A, Section 6.4 Return to Normal Alignment, steps 12 and 9,
respectively, state: Perform Appendix F to check ERCW flow to RHR Pump Room Cooler
1A-A. This step was marked NA due to the installed flow meter being out of service.
The NRC inspectors brought the condition to the attention of the operations department
leadership (CR 1859940). Comprehensive pump test alignment has the potential to cause
shifts in debris due to opening the cross connection between A and B Trains of ERCW, which
has resulted in blockage of some safety related coolers. Licensee staff performed WO 123771615 conditional performance of 1-TI-67.001 Rev 007 (Component Flow Blockage
Testing Essential Raw Cooling Water (Train A)) Attachment 4 (Flow Blockage Testing - SI,
CS, and RHR Pump Room Cooler 1A), which validated that there was adequate flow to the
ECCS components. The test was completed satisfactory on June 01, 2023, at 03:54.
14
Corrective Actions: Condition was documented in a condition report, additional testing under
WO 123771615 was performed to provide objective evidence that the A Train ERCW system
was restored to proper alignment post ERCW pump testing.
Corrective Action References: CR 1859940
Performance Assessment:
Performance Deficiency: The inspectors determined that the licensees failure to adequately
implement Section 6.4 Step [12] of 0-SI-67-917-A Rev 021 and Section 6.4 Step [9] of 0-SI-
67-918-A Rev 022 was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Configuration Control attribute of the Mitigating Systems
cornerstone and adversely affected the cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, the licensee failed to implement procedure steps to ensure
ERCW flow to safety related room coolers that are required to function after an accident to
ensure continued operation of the supported pumps.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The
inspectors assessed the significance of the finding using IMC 0609 Appendix A, The
Significance Determination Process (SDP) for Findings At-Power. The inspectors assessed
the significance of the finding using IMC 0609 Appendix A, The Significance Determination
Process (SDP) for Findings At-Power. The inspectors performed a review of this finding
using the guidance provided in IMC 0609, Appendix A, Exhibit 2, Mitigating Systems
Screening Questions, and determined this finding is of very low safety significance (Green)
because the answer to all 6 questions was NO. For Question 6 if NO screen as Green.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices
that emphasize prudent choices over those that are simply allowable. A proposed action is
determined to be safe in order to proceed, rather than unsafe in order to stop. The inspectors
determined that the finding has a cross-cutting aspect of H.14 - Conservative Bias because
the licensee lacked the appropriate risk sensitivity to restoration of the ERCW system after
performance of the comprehensive pump testing and failed to exercise procedure adherence
during system restoration.
Enforcement:
Violation: Unit 1 and Unit 2 Technical Specifications 5.7.1.1 a., requires, in part, that written
procedures shall be established, implemented and maintained for the applicable procedures
recommended in Regulatory Guide 1.33 Revision 2, Appendix A February 1978. Regulatory
Guide 1.33 Revision 2 Appendix A 8.b.(1)(f) requires, in part, that; specific procedures for
surveillance tests are required for each surveillance test listed in technical specifications such
as Service Water System Functional Tests.
0-SI-67-917-A Rev 021 (Essential Raw Cooling Water Pumps A-A and B-A Comprehensive
Pump Test) and 0-SI-67-918-A Rev 022 (Essential Raw Cooling Water Pumps C-A and D-A
Comprehensive Pump Test) are Surveillance procedures that perform Inservice Testing for
the ERCW pumps. The licensee established 0-SI-67-917-A Rev 021 and 0-SI-67-918-A Rev
022 to verify the operational readiness of the ERCW pumps and provide for a partial
determination that the Train A ERCW check valves stroke open or closed. Specifically,
15
Section 6.4 Return to Normal Alignment Step [12] in 0-SI-67-917-A and Step [9] in 0-SI-918-A
directed the licensee to PERFORM Appendix F to check ERCW Flow to RHR Pump Room
Cooler 1A-A.
Contrary to the above, on May 30, 2023, the licensee failed to implement Section 6.4 Step
[12] of 0-SI-67-917-A and Section 6.4 Step [9] of 0-SI-67-918-A. Specifically, failure to
perform Appendix F of 0-SI-67-917-A and 0-SI-67-918-A resulted in failure to ensure that
adequate flow was established to the safety related coolers on the A Train ERCW.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Assessment 71152A
Qualified Safety Culture Assessors performed a follow-up corrective action inspection the
week of May 1, 2023. The scope of this inspection included review of corrective actions taken
following identification of SCWE concerns in the Watts Bar Chemistry Department as
observed in Reissue Watts Bar Nuclear Plant - Integrated Inspection Report 05000390/2022003 and 05000391/2022003 (ML23128A275). The May 2023 team conducted
interviews and focus groups of impacted licensee staff and leadership.
The team found that the corrective actions put into place to correct previously identified work
environment issues in this department appear to have been effective. TVA staff engaged by
the inspection team reported willingness to raise safety concerns through multiple avenues
out of fear of retaliation including willingness to use employee concerns and corrective action
programs. The agency will continue to monitor SCWE concerns at Watts Bar via the Resident
Inspectors and baseline inspection under reactor oversight program.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On August 3, 2023, the inspectors presented the integrated inspection results to Mr.
Anthony Williams, Site VP, and other members of the licensee staff.
On April 27, 2023, the inspectors presented the ISI inspection results to Mr. Anthony
Williams, Site VP, and other members of the licensee staff.
On May 18, 2023, the inspectors presented the Radiation Protection inspection results to
Mr. Anthony Williams, Site VP, and other members of the licensee staff.
On July 27, 2023, the inspectors presented the initial integrated inspection results to
Mrs. Beth Jenkins, Watts Bar Plant Manager, and other members of the licensee staff.
THIRD PARTY REVIEWS
Inspectors reviewed World Association of Nuclear Operators (WANO) report that was issued
during October 2022. No safety significance issues were identified.
16
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Drawings 0-47W855-1-ISI Mechanical - Flow Diagram Fuel Pool Cooling And Cleaning Revision 0
System
1-47W810-1-ISI Unit 1 Flow Diagram Residual Heat Removal System Revision 0
WBN-47W803-1 Flow Diagram Feedwater Revision 39
WBN-47W803- Stress Analysis Problem Boundary Drawing Feedwater Revision 2
101
Procedures 0-SOI-78.01 Spent Fuel Pool Cooling and Cleaning System Revision
0042
0-SOI-78.01 ATT Spent Fuel Pool Cooling and Cleaning System Valve Revision 10
1V Checklist
1-SOI-3.02 System Operating Instruction, Auxiliary Feedwater System Revision 30
1-SOI-74.01 Residual Heat Removal System Revision
0022
71111.05 Calculations EPMDOM- Combustible Loading Data 0148
012990
Fire Plans CON-0-729-01 Control Building Elevations 729 & 741 002
CON-0-729-01 Control Building Elevations 729 & 741 003
MAP
WBN-PFP-AUX- Pre-Fire Plan for the Auxiliary Building Corridor Elevation 676Revision 3
0-676-01
WBN-PFP-AUX- Pre-Fire Plan for the Auxiliary Building Elevation 772 Revision 5
0-772-05, Rev. 5
WBN-PFP-AUX- Pre-Fire Plan for the Auxiliary Building Elevation 786 Revision 2
0-786-01
Miscellaneous TVA 41419 Fire Drill Evaluation Report May 31,
2023
Procedures WBN-NPG-SPP- Transient Combustibles Revision 18
18.4.7
71111.06 Procedures MDN-000-999- WBN Probabilistic Risk Assessment - Internal Flooding Revision 4
2008-0146 Analysis Notebook
WB-DC-40-31.51 Evaluating the Effects of Flooding due to Moderate Energy Revision 5
Pipe Failures Inside and Outside Containment
17
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.12 Miscellaneous Inspection Report QC Inspection Report Number 4/25/2023
Number: 868414
W47 230412 500 QC certifications for Darrick L. Handy 9/19/2022
71111.18 Procedures 0-SOI-30.07 Shutdown Board Rooms HVAC EL 757 & 772 0026
0-TI-31.004 Installation and Operation of Temporary Chiller for B SDBR 000
Chiller
NPG-SPP-09.4 10 CFR 50.59 Evaluations of Changes, Tests, and 0018
Experiments
71111.20 Corrective Action CR 1855245 NRC Identified Containment Debris following Mode 4 05/9/2023
Documents containment closeout
Resulting from
Inspection
71111.24 Corrective Action CR 1856847 (NRC Identified) Update DG test procedures to include 05/16/2023
Documents alternate method of cylinder measurement.
Resulting from
Inspection
Procedures 0-MI-61.06 Servicing Ice Condenser Revision 13
0-SI-67-917-A Essential Raw Cooling Water (ERCW) Pump A-A and Pump Revision 21
B-A Comprehensive Tests
0-SI-67-918-A Essential Raw Cooling Water (ERCW) Pump C-A and Pump Revision 22
D-A Comprehensive Tests
0-SI-82-19-A 184 Day Fast Start and Load Test DG 2A-A Revision 37
0-SI-82-3 Loss of Offsite Power With Safety Injection - DG 1A-A Revision 80
1-SI-3-901-A Motor Driven Auxiliary Feedwater Pump 1A-A Quarterly Revision 40
Performance Test
1-SI-32-901-A Valve Full Stroke Exercising during Cold Shutdown Control Revision 22
Air (Train A)
1-SI-43-701-A Containment Isolation Valve Local Leak Rate Test Post Revision 13
Accident Sampling
1-SI-61-2 Unit 1 Ice Weighing Revision 25
1-SI-63-907 Residual Heat Removal Hot Leg and Cold Leg Injection Revision 36
Check Valve Testing During Refueling Outages
1-SI-72-906-A Containment Spray Valve Position Indication Verification / Revision 18
Full Stroke Exercising (Train A)
18
Inspection Type Designation Description or Title Revision or
Procedure Date
1-SI-72-908-A Containment Spray Pump 1A-A Comprehensive Pump Test Revision 6
1-SI-74-905-A Residual Heat Removal Pump 1A-A Comprehensive Test Revision 8
during refueling outages
1-TI-61.003 Containment Debris Log Revision 2
1-TI-61.005 Manipulation and Use of ICEMAN Data Revision 0
TI-100.001 Inservice Testing of Pumps Revision 19
TI-100.002 Inservice Testing of Valves Revision 17
71114.06 Miscellaneous 2023 WBN April Training Drill (Team B) Package 4/5/2023
71124.01 Corrective Action CR 1850900
Documents CR 1857250
Resulting from CR 1857499
Inspection CR 1857503
Miscellaneous NuclearIQ Database, tritium concentrations in the spent fuel 03/18/23 -
pool 04/19/23
Procedures NISP-RP-002 Radiation and Contamination Surveys Rev. 1
NISP-RP-004 Radiological Posting and Labeling Rev 1
NISP-RP-007 Control of Radioactive Material Rev 1
RCI-137 Radiation Protection Tritium Control Program Rev 9
Radiation 140423105 1R18 Upper Containment Upper Containment Air Sample 04/14/2023
Surveys WBN-M- U1 A CCP Room 04/15/23
20230415-1
WBN-M- 772' Plenum Room Posting Update 05/16/23
20230516-7
Radiation Work 23160012 U1R18 Outage - Upper Containment High Radiation Area Rev 0
Permits (RWPs)
71124.03 Procedures RCI-107 Respiratory Protection Equipment Inspection, Maintenance, Rev 33
Issuance and Accountability
71124.04 Corrective Action CR 1851507
Documents
Resulting from
Inspection
Miscellaneous TVA RP Prospective Determination for Occupational Rev. 2
Exposure (2011-2018)
19
Inspection Type Designation Description or Title Revision or
Procedure Date
71124.05 Miscellaneous SSD-0-LPR-90-3 Scaling and Setpoint Document for Waste Package Area Rev. 11
Monitor
SSD-2-LPR-90- Scaling and Setpoint Document for Unit 2 Shield Building Rev. 22
400 Radiation Monitor
Procedures 2-SI-90-1 18 Month Channel Calibration Containment Upper Rev. 0005
Compartment High Range Post Accident Area Radiation
Monitor Loop 2-LPR-90-271-A
2-SI-90-3 18 Month Channel Calibration Containment Lower Rev. 0005
Compartment High Range Post Accident Area Radiation
Monitor Loop 2-LPR-90-273-A
71152A Corrective Action CR 1805670
Documents CR 1805670
71152S Corrective Action 1856930 Several Operations SIs do not have the correct Start and
Documents Stop times in Maximo
1856935 The surveillance task sheets (STS) for 13 vaulted
surveillances were not fully completed
1856945 Incomplete QA records in ECM
1858681 QA identified a deficiency associated with T-Mods not being
correctly closed
71153 Procedures WBN-2-GO-5 Unit Shutdown From 30% Reactor Power to Hot Standby Revision 9
WBN-ES-0.1 Reactor Trip Response Revision 26
20