ML16344A048

Watts Bar Nuclear Plant, Units 1 and 2 - Reply to Notice of Violation (EA-16-117)

ML16344A048
Person / Time
Site:	Watts Bar
Issue date:	12/09/2016
From:	Simmons P Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-16-117
Download: ML16344A048 (5)

Text

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381December 9, 201610 cFR 2.201ATTN: Document Control DeskU.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Units 1 and 2Facility Operating License NPF-90 and NPF-96NRC Docket Nos. 50-390 and 50-391

SUBJECT:

Watts Bar Nuclear Plant Units 1 and 2 - Reply to Notice of Violation

Reference:

(EA-l6-117)

NRC letter dated November 10,2016, "Watts Bar Nuclear Plant- NRCI ntegrated I nspection Report 05000390/2016, 05000391

/201 6003 and Noticeof Violation and Ol Report Number 0l-2-2015-039' Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 2.201, Tennessee ValleyAuthority's (TVA) response to Notice of Violation EA-16-1 17 is enclosed.

The enclosure provides TVA's reply to the violation (Reference),

including a detaileddescription of the corrective steps taken and the results achieved.

TVA achieved fullcompliance for this issue on August 27,2015.There are no new regulatory commitments made in this letter. Should you have questions regarding this response, please contact Gordon Arent at (423) 365-2004.

Respectfully,

/@Paul SimmonsSite Vice President

Enclosure:

Reply to Notice of Violation cc: see Pag e 2 U.S. Nuclear Regulatory Commission Page 2December 9, 2016cc (Enclosure):

U.S. Nuclear Regulatory Commission Region llMarquis One Tower245 Peachtree CenterAve.,

NE Suite 1200Atlanta, Georgia 30303 -1257NRC Resident lnspector Watts Bar Nuclear Plant1260 Nuclear Plant RoadSpring City, Tennessee 37381Fred Brown, Deputy Regional Administrator for Construction U.S. Nuclear Regulatory Commission Region llMarquis One Tower245 Peachtree Center Ave., NE Suite 120AAtlanta, Georgia 30303 -1257Director, Office of Enforcement U.S. Nuclear Regulatory Commission 4p.1 5AOne White Flint North1 1555 Rockville PikeRockville, Maryland 2A852-2738 WATTS BAR NUCLEAR PLANT, UNITS 1 and 2ENCLOSURE REPLY TO NOTICE OF VIOLATION EA.l6-117 Description of the Wolation10 CFR 50.9(a) sfafes, in paft, that information required by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete andaccurate in all material respecfs.

Watts Bar Nuclear Plant Units 1 and 2 Technical Specification 5.7.1.1.d

requires, in part,that written procedures be esfab/rshed, implemented, and maintained coveing the activities involved with Fire Protection Program implementation.

The Watts Bar Fire Protection Report lists compensatory actions that must be implemented when there are impaired fire protection

sysfems, including, under some circumstances, acontinuous fire watch.TVA Corporate Procedure NPG-SPP-18.4.6, Control of Fire Protection lmpairmenfs, Rev.0006, is the implementing/controlling process for all Fire Protection impairments, andesfab/tshes the process for implementing compensatory actions for fire impairments asdirected by the Fire Protection Report.NPG-SPP-18.4.6, Section 3.2.6.A, sfafes that "Fire watches are utilized forthe surueillance of areas where fire protection sysfems are impaired.

The compensatory fire watch processr.s descnbed in Attachment 7" of NPG-SPP-I8.4.6.

NPG-SPP-18.4.6, Aftachment 7, Section 3.1, specifie,s compensatory fire watchresponsibilities, and requires that compensatory fire watches .log on Form NPG-SPP-18.4.6-3, Continuous Compensatory Fire Watch Tumover Fom, each time coverage isassumed or tran sfe rred.'NPG-SPP-1 8. 4. 6, Secfrbn 4.2. C, requires th at Fonn NPG-SPP-1 8. 4. G3 be retained for g0days.Fire Protection lmpairment Permit C10-0639, dated August 6, 2010, established acontinuous fire watch for multiple areas on the 713' elevation of the auxiliary building as acompensatory measure for fire protection equipment disabled to support Unit 2 construction activities.

Contrary to the above, on April 28, 2015, the licensee failed to maintain continuous compensatory fire watch information that was complete and accurate in all mateialrespecfs.

Specifically, a Continuous Compensatory Fire Watch Tumover Form, NPG-SPP-18.4.6-3, stated that continuous fire watch patrols for Fire Protection lmpairment PermitC10-0639 were completed, when in fact such fire watches had not been pertonned.

Thecontinuous fire watch patrol data is material to the NRC in that it provides evidence ofcompliance with regulatory requirements.

I/,,s,s a Severity Level lV violation (Enforcement Policy Secfion 2.2. 1.d).E-1 TVA ResponseTVA does not dispute the facts as described by the Nuclear Regulatory Commission (NRC)and accepts the violation.

As noted in the Notice of Violation, the violation was of low safetysignificance and was self-identified.

Reason for the Violation The willful falsification of Fire Watch (FW) records and coercion by FW foreman to solicitindividuals to falsify records was identified a result of a referral from TVA EmployeeConcerns to TVA's Office of the lnspector General (OlG). This document falsification wasperformed in an effort to hide an inadequately performed fire watch.On April 27 , 2015 trom 0747 to 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, a continuous fire watch was not properlyperformed for multiple areas of the Watts Bar Nuclear Plant WBN) Auxiliary Building 713'elevation.

Specifically, a continuous fire watch for Fire Protection lmpairment Permit C10-0639 was not briefed as being within the scope of fire watch duties for the fire watchstanders involved with this event. When fire watch foremen recognized a discrepancy in thefire watch documentation on April 28, 2015, the fire watch foremen prepared, and convinced several craft individuals to sign, false fire watch turnover paperwork.

When not allindividuals involved would sign the falsified documents, the documents were destroyed.

Condition Report (CR) 1019953 was subsequently generated on April 29, 2015 by anoperations senior reactor operator and addressed the missing fire watch records.On May 1,2015, a concerned individual contacted the Senior Vice President (SVP) at WattsBar and informed him of this document falsification event. The WBN SVP informed the VPWatts Bar Unit 2 Project who informed the Employee Concerns Program (ECP). ECPpersonnel then made contact with the concerned individual on May 4,2015. Because theissue involved document falsification, the ECP investigator requested that OIG investigate the document falsification concern.

After the ECP investigator met with a Special Agent ofthe OlG, OIG accepted the case on May 5, 2015.Corrective Steps That Have Been Taken And The Results AchievedUpon learning that records may have been falsified on May 1 ,2015, the VP Watts Bar Unit 2Project contacted TVA's Employee Concerns Program (ECP) on behalf of the WBN SeniorVice President.

Because the issue involved potentialwillful misconduct, ECP site personnel requested an investigation to be performed by the Office of the lnspector General (OlG).This investigation, completed on August 27,2015, concluded that a number of individuals had attempted to falsify fire watch records.One of the foreman involved in this event was a WA employee.

Upon determining hisinvolvement with this event, the individual was suspended on June 3,2015 in accordance with TVA disciplinary procedures.

The contract foreman and laborers were removed fromfire watch duties in May 2015 when their employer became aware they were involved in anon-going investigation.

Upon completion of the investigation by OlG, TVA denied siteaccess to the individuals involved with this incident on August 27,2015.TVA considers this violation to be an isolated action of employees

, and the violation wasnot caused by lack of management oversight.

lt is likely that prior 10 CFR 50.9 trainingprovided to site personnel led an individual to identify this issue to TVA management and tothe NRC.E-2 As part of a previous confirmatory order, TVA had taken actions to stress the importance ofcomplete and accurate reporting in accordance with 10 CFR 50.9. This included thefollowing corrective actions:The Chief Nuclear Officer and the Senior Vice President of Nuclear Construction issued a joint communication to all Nuclear Power Group and Nuclear Construction employees regarding expectations for assuring work activities are performed anddocumented in a complete and accurate manner.The executive management expectations (above) were reinforced through the use offleet wide posters and communications.

These communications specifically discussed 10 CFR 50.9, Completeness and Accuracy of !nformation, willfulviolations, and the consequences of non-compliance.

TVA provided initial 10 CFR 50.9 training in 2012 (manager, supervisor and craftlevel) to employees at all Nuclear Construction sites and refresher training in 2014.TVA enhanced existing 10 CFR 50.9 related general employee training (GET) fornew employees joining Nuclear Power Group and Nuclear Construction, andupdated the associated annual requalification training.

Priorto issuance of the NRC Notice of Violation on November 10, 2016, WBN took action toinvestigate this issue and implemented personnel actions for those involved.

Corrective Steos That Will Be TakenNo additional corrective actions are required.

Date When Full Compliance Was AchievedTVA achieved full compliance on August 27,2015.Additional ActionsTVA will communicate this event by December 31, 2016 to Wafts Bar personnel, stressing the importance of accuracy of records and the need to maintain personal integrity whensigning record documents.

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