IR 05000390/2005005

IR 05000390-05-005, 05000391-05-005, 10/01/2005 - 12/31/2005, Watts Bar, Units 1 & 2. Identification and Resolution of Problems

ML060320459
Person / Time
Site:	Watts Bar
Issue date:	01/27/2006
From:	Cahill S Reactor Projects Region 2 Branch 6
To:	Singer K Tennessee Valley Authority
References
IR-05-005
Download: ML060320459 (27)

Text

January 27, 2006Tennessee Valley AuthorityATTN:Mr. K. W. SingerChief Nuclear Officer and Executive Vice President6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801SUBJECT:WATTS BAR NRC INTEGRATED INSPECTION REPORT 05000390/2005005AND 05000391/2005005

Dear Mr. Singer:

On December 31, 2005, the US Nuclear Regulatory Commission (NRC) completed aninspection at your Watts Bar Nuclear Plant, Units 1 and 2. The enclosed integrated inspection report documents the inspection results which were discussed on January 4, 2006, with Mr. M. Skaggs and other members of your staff. This report documents one NRC-identified finding of very low safety significance (Green). Theissue was determined to involve a violation of NRC requirements. However, because of thevery low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A of theNRC Enforcement Policy. If you contest the NCV in the enclosed report, you should provide aresponse within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRCResident Inspector at the Watts Bar facility.

TVA2In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public Document Roomor from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (thePublic Electronic Reading Room).

Sincerely,

/RA by Joseph W. Shea Acting for/Stephen J. Cahill, Chief Reactor Projects Branch 6 Division of Reactor ProjectsDocket Nos. 50-390, 50-391License No. NPF-90 and Construction Permit No. CPPR-92

Enclosure:

NRC Inspection Report 05000390/2005005, 05000391/2005005 w/Attachment: Supplemental Information

REGION IIDocket Nos:50-390, 50-391License Nos:NPF-90 and Construction Permit CPPR-92Report Nos:05000390/2005005, 05000391/2005005 Licensee:Tennessee Valley Authority (TVA)

Facility:Watts Bar Nuclear Plant, Units 1 and 2Location:1260 Nuclear Plant RoadSpring City, TN 37381Dates:October 1, 2005 - December 31, 2005 Inspectors:J. Bartley, Senior Resident InspectorM. Pribish, Resident Inspector J. Kreh, Emergency Preparedness Inspector (Sections 1EP4, 4OA1)

M. Maymi, Reactor Inspector (Section 1R12.2)

J. Polickoski, Project Engineer (Section 1R01, 1R17)

M. Scott, Senior Reactor Inspector (Section 1R12.2)Approved by:Stephen J. Cahill, Chief Reactor Projects Branch 6 Division of Reactor Projects EnclosureSUMMARY OF FINDINGSIR 05000390/2005005, 05000391/2005005, 10/01/2005 - 12/31/2005, Watts Bar, Units 1 & 2. Identification and Resolution of Problems.The report covered a three-month period of routine inspection by resident inspectors andannounced inspections by an emergency preparedness specialist and regional reactor inspectors. One finding of significance was identified. The significance of an issue is indicated by its color (Green, White, Yellow, Red) using the Significance Determination Process in Inspection Manual Chapter 0609, Significance Determination Process (SDP). The NRC'sprogram for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.A.NRC-Identified Findings and Self-Revealing FindingsCornerstone: Mitigating Systems*Green. The inspectors identified a non-cited violation (NCV) for the failure tocomply with 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, in that turbine-driven auxiliary feedwater (TDAFW) turbine casing jet plug leaksidentified on June 3, 2004, were not corrected which resulted in the TDAFW pump being declared inoperable on May 17, 2005, while performing steam leak repairs. This finding affected the Problem Identification and Resolution Cross-Cutting Area.This finding was considered more than minor because it is associated with theequipment performance attribute of the Mitigating Systems Cornerstone to ensure the availability of systems that respond to initiating events to preventundesirable consequences (i.e., core damage). The failure to repair turbine jet plug steam leaks during the refueling outage resulted in unnecessary unavailability of the TDAFW pump during power operations. The finding wasdetermined to be of very low safety significance because the motor-driven auxiliary feedwater (MDAFW) pumps were available and the TDAFW pump wasout of service for less than its Technical Specification allowed outage time.

(Section 4OA2.3)B.Licensee-Identified ViolationsNone.

EnclosureReport DetailsSummary of Plant StatusUnit 1 operated at or near 100 percent power for the entire inspection period. Unit 2 remainedin a suspended construction status.1.REACTOR SAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01Adverse Weather Protection a.Inspection ScopeThe inspectors reviewed licensee actions taken in preparation for low temperatureweather conditions to limit the risk of freeze-related initiating events and to adequately protect mitigating systems from its effects. The inspectors reviewed the licenseeprocedure 1-PI-OPS-1-FP, Freeze Protection, and walked down selected components associated with the four areas listed below to evaluate implementation of plant freezeprotection. In addition, the material condition of insulation, heat trace elements, and temporary heated enclosures on selected freeze-protected components were inspected for damage and viability. Corrective actions for items identified in relevant problemevaluation reports (PERs) and work orders (WOs) were assessed for effectiveness and timeliness. Specific documents reviewed are listed in the attachment.*Intake pumping station*Emergency diesel generators (DGs)

• Refueling water storage tank

• Main feedwater sense lines enclosure b.FindingsNo findings of significance were identified.1R04Equipment Alignment.1Quarterly Partial Walkdowns a.Inspection ScopeThe inspectors conducted three equipment alignment partial walkdowns to evaluate theoperability of selected redundant trains or backup systems, listed below, with the othertrain or system inoperable or out of service. The inspectors reviewed the functionalsystem descriptions, Updated Final Safety Analysis Report (UFSAR), system operatingprocedures, and Technical Specifications (TSs) to determine correct system lineups forthe current plant conditions. The inspectors performed walkdowns of the systems to 2Enclosureverify that critical components were properly aligned and to identify any discrepancieswhich could affect operability of the redundant train or backup system.*A-train auxiliary building gas treatment system (ABGTS) during B-train ABGTScomponent outage*A-train safety injection (SI) pump and centrifugal charging pump (CCP) during B-train SI pump component outage*B-train residual heat removal (RHR) and containment spray (CS) during A-trainRHR pump com ponent outage b.FindingsNo findings of significance were identified..2Semiannual Complete Walkdown a.Inspection ScopeThe inspectors conducted a detailed walkdown/review of the alignment and condition ofthe vital 480-VAC systems including the 480-VAC shutdown power system, reactormotor-operated valve (MOV) power system, and the control and auxiliary ventilationpower system to verify proper equipment alignment and identify any discrepancies thatcould impact the function of the system and increase risk. The inspectors utilizedlicensee procedures, as well as licensing and design documents, when verifying that the system alignment was correct. During the walkdown, the inspectors also verified, as appropriate, that: (1) electrical power was available as required; (2) major portions of

the system and components were correctly labeled, cooled, ventilated, etc.; (3) essentialsupport systems were operational; (4) ancillary equipment or debris did not interfere withsystem performance; and (5) tagging clearances were appropriate. Pending design andequipment issues were reviewed to determine if the identified deficiencies significantly impacted the system's functions. Items included in this review were the operatorworkaround list, the temporary modification list, system health reports, and outstandingmaintenance work requests/work orders. In addition, the inspectors reviewed the licensee's corrective action program to ensure that the licensee was identifying equipment alignment problems and that they were properly addressed for resolution.

Specific documents reviewed are listed in the attachment. b.FindingsNo findings of significance were identified.

3Enclosure1R05Fire Protection a.Inspection ScopeThe inspectors conducted tours of 10 areas important to reactor safety, listed below, toverify the licensee's implementation of fire protection requirements as described in the Fire Protection Program, Standard Programs and Processes (SPP)-10.0, Control of Fire Protection Impairments, SPP-10.10, Control of Transient Combustibles, SPP-10.11, Control of Ignition Sources (Hot Work). The inspectors evaluated, as appropriate, conditions related to (1) licensee control of transient combustibles and ignition sources; (2) the material condition, operational status, and operational lineup of fire protection systems, equipment, and features; and (3) the fire barriers used to prevent fire damageor fire propagation. Specific documents reviewed are listed in the attachment.*Cable spreading room*480-V reactor (RX) motor-operated valve (MOV) Board Rooms 1A and 1B

• 480-V RX MOV Board Rooms 2A and 2B

• Vital Battery Rooms I, II, III, IV, and V b.FindingsNo findings of significance were identified.1R06Flood Protection Measures a.Inspection ScopeThe inspectors reviewed internal flood protection barriers associated with an essentialraw cooling water (ERCW) strainer room pipe break to verify that the flood protection barriers and equipment were being maintained consistent with the UFSAR. Specifically, the inspectors reviewed selected risk-important plant design features and procedures intended to protect the plant and its safety-related equipment from internal flooding events. The inspectors also reviewed room sump pump calculations, internal flooding water barrier requirements and room sump pump capacities to verify compliance with the licensee's design requirements. The inspectors conducted walkdowns of the areas and considered the following attributes: (1) sealing of equipment below the flood line, such as electrical conduits; (2) holes or unsealed penetrations in floors and walls between flood areas; (3) adequacy of watertight doors between flood areas; (4) common drain system and sumps, including floor drain piping and check valves; (5) operablesump pumps, level alarm and control circuits including maintenance and calibrations of flood protection equipment; and (6) sources of potential internal flooding that are not analyzed or not adequately maintained, such as failure of high pressure fire protection piping. In addition, the inspectors reviewed the licensee's corrective action program to ensure that the licensee was identifying flood-related problems and that they wereproperly addressed for resolution. Specific documents reviewed are listed in the attachment.

4Enclosure b.FindingsNo findings of significance were identified.1R11Licensed Operator Requalification a.Inspection ScopeOn October 21, 2005, the inspectors observed operators in the plant's simulator duringlicensed operator annual requalification examinations to verify that operatorperformance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with procedures TRN-1, Administering Training, and TRN-11.4, Continuing Training for Licensed Personnel. The inspectors observed a shift crew's response to Lesson Plan 3-OT-SRE0032B, Loss of Coolant Accident from 75% Power. In addition, the inspectors verified that the training program included risk-significant operator actions, emergency plan implementation, and lessons learned from previous plant experiences. b.FindingsNo findings of significance were identified.1R12Maintenance Effectiveness.1 Routine Reviews a.Inspection ScopeThe inspectors reviewed a performance-based problem regarding low voltage in DGbattery cells (PER 92140). In addition, the inspectors reviewed the licensee's Maintenance Rule (MR) (a)(1) action plan to correct performance problems on the auxiliary air system. The focus of the reviews was to assess the effectiveness ofmaintenance efforts that apply to scoped structures, systems, or components (SSCs)and to verify that the licensee was following the requirements of licensee procedure TI-119, Maintenance Rule Performance Indicator Monitoring, Trending, and Reporting 10 CFR 50.65, and SPP-6.6, Maintenance Rule Performance Indicator Monitoring, Trending, and Reporting 10 CFR 50.65. Reviews focused, as appropriate, on (1)

appropriate work practices; (2) identification and resolution of common cause failures; (3) scoping in accordance with 10 CFR 50.65; (4) characterization of reliability issues;(5) charging unavailability time; (6) trending key parameters; (7) 10 CFR 50.65(a)(1) or(a)(2) classification and re-classification; and (8) the appropriateness of performance criteria for SSCs classified as (a)(2) or goals and corrective actions for SSCs classified as (a)(1). Specific documents reviewed are listed in the attachment. b.FindingsNo findings of significance were identified.

5Enclosure.2Periodic Evaluation (Biennial) a.Inspection ScopeThe inspectors reviewed the licensee's MR periodic assessment, Fifth PeriodicAssessment Report, Revision 0 (data storage number T25 050 125 988, dated 2/1/05). This report was issued to satisfy paragraph (a)(3) of 10 CFR 50.65, and covered the 18-month period ending September 30, 2004. The inspection was to determine the effectiveness of the assessment and that it was issued in accordance with the time requirement of the MR and included evaluation of balancing reliability and unavailability,(a)(1) activities, (a)(2) activities, and use of industry operating experience. To verify compliance with 10 CFR 50.65, the inspectors reviewed selected MR activities covered by the assessment period for the following MR component and attendant systems; RHR,radiation monitor, auxiliary control air, ERCW, and ventilation (electrical board room andmain control room) systems. Specific procedures and documents reviewed are listed inthe attachment to this report.The inspectors also reviewed selected plant WO data, assessment, modifications, thesite guidance implementing procedures; discussed and reviewed relevant corrective action issues (i.e., PERs), reviewed generic operations event data, attendant MR-related meeting minutes, probabilistic risk reports; and discussed issues with system engineers. Operational event information was evaluated by the inspectors in its use in MR functions. The inspectors selected WOs and other corrective action documents on systems recently removed from 10 CFR 50.56a(1) status and those in a(2) status for theassessment period to investigate the justification for their status. The inspectors selected MR valves found in the plant's EOPs to verify functional testing. The inspectors toured and inspected repaired components. The documents were compared to the site's MR program criteria, and the MR a(1) evaluations and rule-related data bases. b.FindingsNo findings of significance were identified.1R13Maintenance Risk Assessments and Emergent Work Evaluation a.Inspection ScopeThe inspectors evaluated, as appropriate for the five work activities listed below: (1) theeffectiveness of the risk assessments performed before maintenance activities were conducted; (2) the management of any resultant risk increases; (3) that, upon identification of an unforseen situation, necessary steps were taken to plan and control the resulting emergent work activities; and (4) that maintenance risk assessments and emergent work problems were adequately identified and resolved. The inspectors verified that the licensee was complying with the requirements of 10 CFR 50.65 (a)(4);and licensee procedures SPP-7.0, Work Control and Outage Management; SPP-7.1, Work Control Process; and TI-124, Equipment to Plant Risk Matrix.

6Enclosure*Emergent work on 1B-B MDAFW pump suction pressure gage during A-trainshutdown board room chiller outage*Concurrent maintenance on B-train ABGTS, 2B-B CCS pump and containmentair return fan*A-A auxiliary air compressor outage affecting multiple systems including auxiliaryfeedwater (AFW) level control valves and steam generator atmospheric dumps*Emergent work on A-train Eagle 21 during B-train work week

• B-B auxiliary air compressor outage affecting multiple systems concurrent 480-Vboard room chiller com ponent outage b.FindingsNo findings of significance were identified.1R14Personnel Performance During Non-routine Plant Evolutions a.Inspection ScopeThe inspectors reviewed personnel performance during a loss of B-train auxiliary airwhich occurred on December 5, 2005. The loss of B-train auxiliary air was due to theinadvertent bumping of a switch during maintenance activities. The inspectors observed the licensee's response, both in the main control room and at the B-train auxiliary aircompressor skid, to verify that appropriate actions were taken in accordance with Abnormal Operating Instruction (AOI) 10, Loss of Control Air. The inspectors verified that the correct Technical Specification (TS) limiting conditions for operations (LCOs)

were entered and that system responses were as expected for a loss of B-train auxiliaryair. b.FindingsNo findings of significance were identified.1R15Operability Evaluations a.Inspection ScopeThe inspectors reviewed the five operability evaluations which are listed below andaffected risk-significant mitigating systems, listed below, to assess, as appropriate: (1)the technical adequacy of the evaluations; (2) whether continued system operability waswarranted; (3) whether other existing degraded conditions were considered as compensatory measures; (4) whether the compensatory measures, if involved, were in place, would work as intended, and were appropriately controlled; (5) where continued operability was considered unjustified, the impact on TS LCOs and the risk significancein accordance with the SDP. The inspectors verified that the operability evaluationswere performed in accordance with SPP-3.1, Corrective Action Program.*PER 90643, Incorrect bolts (wrong material) installed on DG battery racks 7Enclosure*PER 5313, Emergency gas treatment system (EGTS) pressure control valvelogic with annulus vacuum*PER 91670, EGTS logic issues

• PER 93750, Temporary spray shield installed on TDAFW pump outboardbearing*PER 89590, 1B-B CS pump suction relief valve external leak through set screw b.FindingsNo findings of significance were identified.1R16Operator Workarounds a.Inspection ScopeThe inspectors reviewed the cumulative effects of operator workarounds to assess: (1)the effect on the reliability, availability, and potential for mis-operation of a system; (2)the potential for increasing an initiating event frequency or affecting multiple mitigating systems; and (3) the cumulative effects on the ability of the operators to respond in acorrect and timely manner to plant transients and accidents. The inspectors reviewed the current operator workarounds as defined by Operations Department Procedure (OPDP)-1, Conduct of Operations, and interviewed operators to determine if there were other conditions which would require actions to compensate for equipment problems or deficiencies. There were no risk-significant operator workarounds during this quarter and no Priority 1 or 2 operator workarounds during the time of the inspection in December 2005. b.FindingsNo findings of significance were identified.1R17Permanent Plant Modifications a.Inspection Scope The inspectors reviewed one permanent plant modification accomplished by WO 05-814940-003, Implementation of DCN 51872-A, Place a hard line jumper on steamgenerator PORV controllers to prevent the local/remote switch from inadvertently opening the PORV. The inspectors verified that pre-job coordination and communication and design change installation controls were adequate; that affected operational procedures were identified and revised accordingly; and that post-maintenance testing and equipment return to service was adequate.

b.Findings No findings of significance were identified.

8Enclosure1R19Post-Maintenance Testing a.Inspection ScopeThe inspectors reviewed six post-maintenance test (PMT) procedures and/or testactivities, as appropriate, for selected risk-significant mitigating systems to assesswhether: (1) the effect of testing on the plant had been adequately addressed by controlroom and/or engineering personnel; (2) testing was adequate for the maintenance performed; (3) acceptance criteria were clear and adequately demonstrated operational readiness consistent with design and licensing basis documents; (4) test instrumentation had current calibrations, range, and accuracy consistent with the application; (5) testswere performed as written with applicable prerequisites satisfied; (6) jumpers installed or leads lifted were properly controlled; (7) test equipment was removed following testing; and (8) equipment was returned to the status required to perform its safety function.

The inspectors verified that these activities were performed in accordance with SPP-8.0, Testing Programs; SPP-6.3, Pre-/Post-Maintenance Testing; and SPP-7.1, Work Control Process. Specific documents reviewed are listed in the attachment.*WO 04-819795-000, Replace pressure regulator and actuator diaphragm onABGTS exhaust fan 2B-B discharge damper*WO 05-811405-000, A-A auxiliary air compressor not shutting downautomatically*WO 04-820414-000, B-train main control room chiller maintenance*WO 04-818773-000, B-train electric board room chiller maintenance*WO 05-823565-000, Replace containment isolation valve 1-FCV-30-135-A

• WO 05-825673-000, Replace 50/51 relay modules on the 1A-A SI pump breaker b.FindingsNo findings of significance were identified.1R22Surveillance Testing a.Inspection ScopeThe inspectors witnessed six surveillance tests and/or reviewed test data of selectedrisk-significant SSCs, listed below, to assess, as appropriate, whether the SSCs met the requirements of the TS; the UFSAR; SPP-8.0, Testing Programs; SPP-8.2, SurveillanceTest Program; and SPP-9.1, ASME Section XI. The inspectors also determined whether the testing effectively demonstrated that the SSCs were operationally ready andcapable of performing their intended safety functions. Specific documents reviewed are listed in the attachment.*WO 05-816402-000, 1-SI-211-5-B, Channel Calibration Test on DegradedVoltage Relays for 6.9-kV Shutdown Board 1B-B*WO 05-816566-000, 1-SI-63-901-B, Safety Injection Pump 1B-B QuarterlyPerformance Test*

9Enclosure*WO 05-817034-000, 0-SI-82-17-A, 184-day Fast Start and Load Test DG 1A-A*WO 05-818152-000, 1-SI-72-901-A, Containment Spray Pump 1A-A QuarterlyPerformance Test**WO 05-814498-000, 0-SI-236-33, 125-VDC Battery III Annual Inspection*WO 05-8164996-000, 1-SI-3-902 Turbine-Driven AFW Pump 1A-S QuarterlyPerformance Test**This procedure included inservice testing requirements. b.FindingsNo findings of significance were identified.1R23Temporary Plant Modifications a.Inspection ScopeThe inspectors reviewed the following two temporary plant modifications against therequirements of SPP-9.5, Temporary Alterations, and SPP-9.4, 10 CFR 50.59 Evaluation of Changes, Test, and Experiments, and verified that the modifications did not affect system operability or availability as described by the TS and UFSAR. Inaddition, the inspectors verified that the installation of the temporary modification was in accordance with the work package, that adequate configuration control was in place,procedures and drawings were updated, and post-installation tests verified operability ofthe affected systems. Specific documents reviewed are listed in the attachment.*TACF 0-05-0004-032, Install temporary service air compressor during D stationair compressor maintenance*Temporary spray shield installed over TDAFW pump outboard packing underWO 05-817480-000 for adjusting packing b.FindingsNo findings of significance were identified.Cornerstone: Emergency Preparedness 1EP4Emergency Action Level (EAL) and Emergency Plan Changes a.Inspection ScopeThe inspectors reviewed the Radiological Emergency Plan (REP) changes in Revision77 (Appendix C: Watts Bar only). Minor EAL modifications were made in the subject revision. The revision of the REP in effect at the time of the inspection was Revision 79.The inspection was conducted in accordance with NRC Inspection Procedure 71114,Attachment 4, Emergency Action Level and Emergency Plan Changes. The applicable 10Enclosureplanning standard 10 CFR 50.47(b)(4) and related requirements contained in AppendixE to 10 CFR Part 50 were used as reference criteria. This inspection activity represents one sample on an annual cycle. Specific documents reviewed are listed in theattachment. b.FindingsNo findings of significance were identified.1EP6Drill Evaluation a.Inspection ScopeThe inspectors observed a licensee-evaluated requalification scenario on October 21,2005, which included a formal evaluation of the event classification. The inspectors observed the drill to verify that the emergency response organization was properlyclassifying the event in accordance with Emergency Plan Implementing Procedure (EPIP)-1, Emergency Plan Classification Flowchart, and making accurate and timely notifications and protective action recommendations in accordance with EPIP-2, Notification of Unusual Event; EPIP-3, Alert; EPIP-4, Site Area Emergency; EPIP-5, General Emergency; and the Radiological Emergency Plan. In addition, the inspectors verified that licensee evaluators were identifying deficiencies and properly dispositioning performance against the performance indicator criteria in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline.4.OTHER ACTIVITIES 4OA1Performance Indicator Verifications a.Inspection ScopeThe inspectors reviewed the licensee's procedure for developing the data for theemergency preparedness (EP) performance indicators (PIs), which are: (1) drill andexercise performance (DEP); (2) emergency response organization (ERO) drill participation; and (3) alert and notification system (ANS) reliability. The inspectorsexamined data reported to the NRC for the period July 2004 - September 2005. Procedural guidance for reporting PI information and records used by the licensee to identify potential PI occurrences was also reviewed. The inspectors verified the accuracy of the PI for ERO DEP through review of a sample of dr ill and event records. The inspectors reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO. Theinspectors verified the accuracy of the PI for ANS reliability through review of a sampleof the licensee's records of periodic system tests.The inspection was conducted in accordance with NRC Inspection Procedure 71151,Performance Indicator Verification. The applicable planning standard 10 CFR 50.9 and NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 3, were 11Enclosureused as reference criteria. This inspection activity represents three samples on anannual cycle. Specific documents reviewed are listed in the attachment. b.FindingsNo findings of significance were identified.4OA2Identification & Resolution of Problems.1Review of Items Entered into the Corrective Action ProgramAs required by Inspection Procedure 71152, Identification and Resolution of Problems,and in order to help identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program (CAP). This review was accomplished by reviewing daily PER summary reports and attending daily PER review meetings..2Semi-Annual Review to Identify Trends a.Inspection ScopeAs required by Inspection Procedure 71152, Identification and Resolution of Problems,the inspectors performed a review of the licensee's CAP and associated documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors' review was focused on human performance trends, licensee trending efforts, and repetitive equipment and corrective maintenance issues. The inspectors also considered the results of the daily inspector CAP item screening discussed in Section 4OA2.1. The inspectors' review nominally considered the six-month period of June through December 2005, although some examples expanded beyond those dates when the scope of the trend warranted. The inspectors compared and contrasted their results with the results contained in the licensee's latest integrated quarterly assessment reportand trend PERs in the CAP. The inspectors also performed an independent trend evaluation based on PERs that were NRC identified between January and December2005 and compared this to the licensee's trend reports. b.Assessment and Observations No findings of significance were identified. The licensee's trending methodology, scope, and implementation were, in general, broad-based and thorough. The licensee site support organization monitored for trends on a monthly and semi-annual basis using PER reports sorted on standardized caus e codes, systems, organizations, and keywords. The licensee site support organization also reviewed each PER generated during the six-month period to identify potential trends that may not be identified usingthe reports. Potentially negative trends were brought to the attention of the responsibleorganization and site management. The engineering organization trended repetitive equipment issues under the MR program. Equipment issue trends were monitored by trending component/system failures and unavailability time. The inspectors compared 12Enclosurethe licensee process results with the results of the inspectors' daily screening and didnot identify any discrepancies or potential trends in the CAP data that the licensee hadfailed to identify. The most recent Site Integrated Review for January through June 2005 identified problems in the areas of work control, operations precisely controllingplant evolutions, plant status control, and refueling outage planning/preparation. Theseidentified issues are consistent with the inspectors' observations. The inspectors noted, as part of the review of NRC-identified PERs, that there is an increasing trend in statusand configuration control issues being identified by the inspectors. During July through September the inspectors identified five conditions in this area, while 10 conditions were identified during October through December. These were all determined to be minor in the NRC SDP. The licensee initiated PER 94842 to address the overall configurationcontrol issue. In addition, the licensee identified an equipment trend associated with anincreased rate in pinhole leaks in high pressure fire protection piping. The licensee initiated a trend PER to evaluate the condition and has WOs planned to replace affected piping during the next refueling outage.The inspectors performed a review of human performance trends for calendar year2005. The number of PERs generated for human performance issues has been slightly decreasing over the past six months. This slight decrease in the number of human performance PERs occurred during a period when the overall PER generation rate increased from 210 per month to approximately 260 per month indicating an improving trend in human performance. The inspectors confirmed this trend by doing an independent trend review based on NRC identified PERs during the last year..3Annual Sample: Decision to Defer TDAFW Pump Steam Leak Repairs Out of RF06

a. Inspection ScopeThe inspectors reviewed the licensee's evaluation of the decision to defer planned work on the Unit 1 TDAFW pump. The work was planned due to increasing moisture and particulate levels into the TDAFW turbine and governor oil lubricating system. Theinspectors evaluated whether the licensee promptly identified and corrected conditions adverse to quality in accordance with 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. Documents reviewed are listed in the attachment to this report.Background: On February 18, 2005, three days before the start of the Spring 2005refueling outage, the licensee made the decision to remove TDAFW work to repair low energy casing leaks, identified in WO 04-814482-000 (March 2004), from the Spring 2005 refueling outage and defer the work to the Fall 2006 refueling outage. The basis for the decision was documented in PER 76734. The PER justification concluded that the moisture intrusion was due to a known low energy exhaust steam leak that was not expected to worsen, on the joint between the turbine casing and the gland seal housingof the turbine. The justification also took into consideration that the highest moisturelevels over the last operating cycl e had not exceeded the August 2004 value of 0.12%. On May 17, 2005, oil sample results were received from the May 6, 2005, quarterly surveillance run of the TDAFW pump. The turbine oil sample particulate levels exceeded the licensee's administrative warning limit defined in licensee procedure 13EnclosureTI-78, Lubrication Program. The turbine oil sample moisture level was 0.41%, whichwas approaching the TI-78 warning limit of 0.50%, so the TDAFW pump was declared inoperable. On May 19, 2005, the licensee determined that additional turbine casingsteam leaks at the turbine jet plugs were the cause of the moisture intrusion into the turbine oil system. Turbine insulation removal was necessary to determine the location of the jet plug leaks.On May 18, 2005, the licensee initiated PER 82869 to evaluate the adequacy of thedecision to defer the TDAFW pump work to the Fall 2006 outage. The PER was presented to the licensee's management review committee (MRC) on May 23, 2005, as a B level (second highest PER classification) PER requiring a root cause evaluation. In August 2005, the PER cause evaluation was changed to an apparent cause. On November 28, 2005, the PER was downgraded to a C level PER requiring an apparent cause and the corrective action plan was approved by the MRC. On November 28, 2005, PER 82869 was approved by the MRC with the conclusion that: (1) there was a rigorous evaluation of the details for the justification to defer the work;(2) the problem identified by the oil sample of May 6, 2005, was due to emergent leaks that occurred during the performance of the surveillance test of May 6, 2005, and; (3)the licensee's apparent cause investigation did not identify a cause and that the decisionto defer the work to the 2006 outage was adequate. b. Assessment and ObservationsThe inspectors determined that the licensee's evaluation conducted under PER 82869failed to identify that the deferral justification was inadequate. In addition, the inspectorsidentified a minor non-compliance of the licensee's corrective action program for approval of extensions for completing corrective action plans.The inspectors performed an independent investigation after the MRC approved PER82869 as complete on November 28, 2005. Contrary to the licensee's conclusion, the inspectors determined that the deferral justification was not rigorous and that theproblem identified by the oil sample of May 6, 2005 was not due to an emergent leak that occurred during the surveillance test. The inspectors found that there was known jet plug leakage and indications of a steam leak other than the low energy exhaust steam leak on the turbine casing joint which was the basis for the deferral justification.

The licensee's PER 82869 investigation failed to identify these and two other lower level deficiencies associated with the deferral justification.*The deferral justification did not include jet plug leakage identified during a June2004 uninsulated run. The inspectors reviewed WO 04-814482-000 after concluding the oil moisture content problems were indicative of a condition beyond the casing joint leak. The WO contained a picture with an arrow pointing to the jet plug and a handwritten comment indicating that the jet plug appeared to be leaking. No additional WOs or corrective action documents were generated to address the apparent jet plug leakage and the engineer performing the deferral evaluation was not aware of the condition. Leakage from the jet 14Enclosureplugs is high energy steam and is expected to get worse with time. Thecompliance aspects of this observation are addressed in Section 4AO2.3.c.*The deferral justification assumed that the only steam leak was the low energyleak at the turbine casing joint. The deferral justification and the PER 82869 investigation did not question why very similar steam leaks (location, type and magnitude) had occurred during previous cycles at Watts Bar and at other plantswithout affecting moisture content of the lube oil. After the May 2005 jet plug steam leak repairs, oil moisture levels returned to normal with the low energy exhaust steam leak identified in March 2004 still existing.*The deferral justification stated that oil moisture content never exceeded 0.12%during the cycle. The deferral justification did not consider that the oil waschanged prior to the next routine surveillance run. Post-run oil sample moisturelevels were low, as expected, after the oil change. *The deferral justification did not address high oil particulate levels and the effecton the turbine's governor system.The inspectors also identified that the licensee did not comply with administrativetimeliness requirements for developing corrective action plans. The corrective action plan development for PER 82869 exceeded the time period allowed by SPP-3.1 on several occasions without MRC-approved extension requests. The licensee initiated PER 94841 to identify that extensions were not implemented as expected. This findingis considered minor because it did not adversely affect safety and has been entered into the licensee's CAP. c.FindingsIntroduction: The inspectors identified a Green NCV for the failure to comply with10 CFR 50 Appendix B, Criterion XVI, Corrective Action, in that TDAFW turbine casing jet plug leaks were not promptly corrected which resulted in the TDAFW pump being declared inoperable and was unavailable while performing steam leak repairs.Description: On June 4, 2004, licensee maintenance personnel identified a leakingturbine jet plug during an uninsulated run of the TDAFW pump. A photograph was taken and annotated to indicate the leaking jet plug. The photograph was inserted into WO 04-814482-000 which was for repairing low energy exhaust steam leaks on the turbine casing and gland seal housing joint. However, during the followup inspection for PER 82869, the inspectors identified that no WO or PER was generated to document the set plug deficiency. On May 17, 2005, routine oil sample results were received from the May 6, 2005, quarterly surveillance run of the TDAFW pump.

15EnclosureThe turbine oil sample particulate levels exceeded the licensee's administrative warninglimit in accordance with licensee procedure TI-78, Lubrication Program. The turbine oil sample moisture level was 0.41%, which was approaching the TI-78 warning limit of 0.50%. The licensee declared the TDAFW pump inoperable, entered LCO 3.7.5, andcommenced troubleshooting to identify the source of the problem. On May 19, 2005, the licensee determined that turbine casing steam leaks at the turbine jet plugs were the cause of the moisture intrusion into the turbine oil system. The jet plugs were seal welded which stopped the high energy steam leaks and corrected the oil moisture level and particulate problems. The TDAFW pump was returned to service on May 20, 2005.Analysis: This finding was considered more than minor because it was associated withthe equipment performance attribute of the Mitigating Systems Cornerstone to ensure the availability of systems that respond to initiating events to prevent undesirableconsequences (i.e., core damage). The failure to promptly repair turbine jet plug steam leaks during the refueling outage resulted in unnecessary unavailability of the TDAFWpump during power operations. Using Appendix A of MC 0609, the finding was determined to be of very low safety significance (Green) because the MDAFW pumps were available and the TDAFW pump was out of service for less than its technical specification allowed outage time. The cause of this finding affects the Problem Identification and Resolution (PI&R) cross-cutting area.Enforcement: 10 CFR 50, Appendix B, Criterion XVI, requires that measures beestablished to assure that conditions adverse to quality are promptly identified and corrected. Contrary to this, jet plug steam leaks on the TDAFW pump turbine identified on June 3, 2004, a condition adverse to quality, were not promptly corrected and resulted in unnecessary unavailability during power operations. Because this violationwas of very low safety significance and has been entered into the corrective action program as PER 95189, this violation is being treated as a non-cited violation consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000390/2005005-01,Failure to Take Adequate Corrective Action to Correct TDAFW Jet Plug Leaks..4Annual Sample: PMT Requirements When Instrument Tubing/Fittings are Replaced a.Inspection ScopeThe inspectors reviewed the licensee's actions for PER 63799 which was initiated toresolve an NRC question concerning whether the PMT program should require afunctional/operational test of associated instruments when tubing/fittings are replaced. Specific documents reviewed are listed in the attachment. b.Assessment and ObservationsNo findings of significance were identified. The licensee performed a review of PMTrequirements at other TVA nuclear units, other nuclear utilities, and other nuclearmaintenance organizations to determine if the Watts Bar requirements were adequate.

The licensee's review found that the Watts Bar PMT requirements as specified in licensee procedure TI-126, Post-Maintenance Testing Matrices, were consistent with 16Enclosurethose of the organizations reviewed. As a PER corrective action, an item was added tothe piping/tubing replacement matrix of TI-126 to "check that the instrument is readingcorrectly for plant operation when plant conditions allow." The instrument check was considered an enhancement action and would only be implemented in WOs planned after the TI-126 revision date.The inspectors reviewed the corrective actions of PER 63799 and determined that thecorrective actions were adequate and timely to address the initial concern. The inspectors reviewed seven completed WOs, which were planned after the TI-126 revision date, and determined that the TI-126 requirement to check instrument readingsduring PMTs was not implemented in five of the WOs. The licensee initiated PER 93877 concerning the improper implementation of TI-126 requirements and initiated an immediate action to remind all planners and maintenance supervisors of the TI-126 specific requirements for tubing/fitting replacement. The inspectors determined that the TI-126 procedural compliance finding was minor because no instruments were rendered unavailable due to the omission of the TI-126 instrument check requirement..5Annual Sample: Failure to Perform an Adequate PMT for RHR Pump Seal (NCV05000390/2005002-03) a.Inspection ScopeThe inspectors reviewed the implementation of corrective actions for NCV05000390/2005002-03, Failure to Perform an Adequate PMT for RHR Pump Seal, whichwas documented in Level B PER 78875. b.Assessment and ObservationsNo findings of significance were identified. The inspectors reviewed the licensee'sapparent cause determination and corrective actions. The licensee's apparent cause was performed using a "why staircase" methodology and determined that there were three causes: the PMT coordinator overlooked that there were specific pressure requirements; the foreman/performer made the assumption that the specified PMTconditions were met; and there was no barrier (signoff) in place to ensure that pressure requirements were met (inadequate work order preparation). The inspectors concluded that the apparent causes were appropriately identified. The inspectors reviewed the planned corrective actions and determined that the actionsappeared to be adequate to correct the deficiency. Five corrective actions were implemented to address the three identified causes. The inspectors reviewed the corrective actions as implemented and confirmed that four of the five were completed as specified in the CAP. The inspectors were not able to review documentation that confirmed that corrective action 78775-002, "distribute a PER lessons learned to maintenance, operations, and modifications personnel", was completed. The PER lessons learned was drafted and e-mailed to a single representative of each of the organizations. The corrective action was documented as being complete based on this e-mail. The inspectors checked with the personnel who received this e-mail and verified 17Enclosurethe PER lessons learned was distributed to the organizations. However, there was nodocumentation showing that the PER lessons learned was actually distributed to thecraft level. The organizations described the process they would have followed on receipt of the e-mail, such as covering the material at shift turnover briefs or shop talks.

Typically, there is no documentation for these actions. The inspectors interviewed a sampling of maintenance and operations personnel who were aware of the issue which indicated that the corrective action appeared to have been carried out.4OA6Meetings.1Exit Meeting SummaryThe inspectors presented the inspection results to Mr. M. Skaggs, Site Vice President ofthe Watts Bar Nuclear Plant, and other members of licensee management at the conclusion of the inspection on January 4, 2006. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

One proprietary document was identified..2Regulatory Performance MeetingA meeting was held on November 22, 2005 at the Watts Bar site between the licensee'sMr. M. Skaggs and Mr. Stephen Cahill, Chief, Reactor Projects Branch 6 of the NRCRegion II office. The purpose of the meeting was to discuss a White Finding regarding the failure to promptly identify and correct silt clogging of an Essential Raw Cooling Water backup cooling line to the 1A Charging Pump in November 2004 and the results of the associated NRC Supplemental Inspection that was done July 13-15, 2005 at theWatts Bar site (see NRC Supplemental Inspection Report No. 05000390/2005011). Thecorrective action implementation plan for the issue and the licensee's perception of thecorrective action program lessons learned from the finding were discussed. The meeting constituted the Regulatory Performance Meeting for the finding. Both theSupplemental Inspection and the Regulatory Performance Meeting are required per the NRC Action Matrix (contained in NRC Manual Chapter 305, Operating ReactorAssessment Program) for a licensee in the Regulatory Response Column. As discussed in the NRC Annual Assessment Follow-up Letter dated May 31, 2005, WattsBar Unit 1 was in the Regulatory Response Column due to the White Finding. At the conclusion of the meeting, all of the Action Matrix requirements for the White Finding were completed.ATTACHMENT: SUPPLEMENTAL INFORMATION AttachmentSUPPLEMENTAL INFORMATIONPARTIAL LIST OF PERSONS CONTACTEDLicenseeB. Briody, Maintenance ManagerM. DeRoche, Site Nuclear Assurance Manager D. Feldman, Training Manager J. Frisco, Site Engineering Manager A. Hinson, Maintenance and Modifications Manager J. Hinman, Manager of Projects G. Laughlin, Plant Manager P. Pace, Licensing and Industry Affairs Manager P. Sawyer, Radiation Protection Manager M. Skaggs, Site Vice President S. Smith, Operations Superintendent D. White, Operations Manager ITEMS OPENED, CLOSED, AND DISCUSSEDOpened and Closed50-390/2005005-01NCVFailure to Take Adequate Corrective Action to CorrectTDAFW Jet Plug Leaks (Section 4OA2.3)

A-2AttachmentLIST OF DOCUMENTS REVIEWEDSection 1R01Problem Evaluation Report - PERs*PER 92837, Freeze protection discrepancies for the MFW feed flow venturis, RWSTlevel transmitter, and intake pumping structure*PER 93038, Insulation not restored on ERCW pump motors E-B and H-B oil cooler lines Work Orders - WOs

• WO 03-019203-002, replace DG 2B-B room heater 2A thermostat

• WO 04-824705-000, condensate storage tank B heat trace circuits failed on low currentflow*WO 05-821341-000, DG 2A-A room heater 2B does not work

• WO 05-821342-000, DG 1B-B room heater 1A does not work

• WO 05-821343-000, DG 2B-B room heater 2B does not workSection 1R04*SOI-212.01/02/03/04, 480V Shutdown Board 1A1-A/1A2-A/1B1-B/1B2-B*SOI-213.01/02/03/04, 480V Reactor MOV Board 1A1-A/1A2-A/1B1-B/1B2-B*SOI-214.01/02, 480V C&A Bldg Vent Board 1A1-A/1A2-A

• SOI-215.01/02/03/04,480V Diesel Auxiliary Board 1A1-A/1A2-A/1B1-B/1B2-B*0-PI-OPS-17.1, 18 Month Locked Breaker VerificationSection 1R05*PER 91195, Fire damper 0-ISD-31-2777 has single fusible link instead of two asrequiredSection 1R06*TI-50.023, Intake Pumping Station Strainer Room B Sump Pump A Performance Test*TI-50.024, Intake Pumping Station Strainer Room B Sump Pump B Performance Test

• WO 04-822793-000, TI-50.023

• WO 04-822795-000, TI-50.024Section 1R12PERs*PER 91597, RG 1.55 is not referenced in Topical Report

• PER 89025, HVAC - ABGTS damper found failed (TYPICAL)

• PER 12718, Raw water problems

• PER 75063, Auxiliary air micro switches*PER 81176, Auxiliary air modification*PER 02593, Residual heat removal inadequate work review

• PER 72620, ERCW cooling to CCP 1A

• PER 83266, EDG 1B exhaust fan failure

• PER 64947, RHR bearing oil contaminationMaintenance Rule Expert Panel - Meeting Minutes*September 12, 2002

• December 15, 2004 A-3Attachment*January 7, 2005*August 19, 2005

• July 8, 2005Site Working Procedures*TI-119, Maintenance Rule Performance Indicator Monitoring, Trending, and Reporting -10 CFR 50.65, Revisions 17 - 23 Work Orders*05-810852, replace auxiliary air micro switches (TYPICAL)*04-820526, radiation monitor filter movement modificationMiscellaneous*Watts Bar System Health Report Card, 2 nd period FYo4*Watts Bar System Health Report Card, 3 rd period FY04*Watts Bar System Health Report Card, 1 st period FY05*Fourth Periodic Assessment Report, dated 9/13/2003Audits and Self Assessments*WBN-04-007, Engineering Self Assessment - Maintenance Rule and EPIX ReportPrograms*Audit Report SSA0405, Maintenance ProgramSection 1R19*PER 90958, PMT requirements not specified in PMT section of WO 04-819796-000*PER 91676, PMT specified did not verify corrective maintenance on A train auxiliary aircompressor was successfulSection 1R22*PER 91844, Personnel did not verify 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> wait time was met for continuing vitalbattery III surveillance test*PER 92381, 1-SI-0-4, Monthly Surveillance incorrectly allowed the AFW flow channeloperability check to be N/A'd if AFW not in serviceSection 1R23*PER91944, Test equipment installed under a WO exceeded the 90 day limit and atemporary alteration evaluation was not performed*PER 93750, Temporary plastic shield placed on the TDAFW pump outboard packingwithout a TACFSection 1EP4*Radiological Emergency Plan, Revisions 77 and 79*EPIL-1, Attachment 5, Plan Effectiveness Determination for Revision 77 to REP, Appendix C A-4AttachmentSection 4OA1*EPIL-15, Emergency Preparedness Performance Indicators, Revision 9*Documentation package (scenario/time line/event notification forms/critique report) forERO drills on 08/17/

2004, 06/02/2005*Documentation of DEP opportunities: Licensed operator simulator evaluations on 08/06/2004, 08/11/2004, 09/14/2004, 11/17/2004, 11/19/2004, 11/24/20004*Documentation of ANS tests, 07/01/2004 - 09/30/2005

• Records of drill and exercise participation by selected key ERO personnel, 2004-2005Section 4OA2*Watts Bar Nuclear Plant Corrective Action Program Report dated December 19, 2005*Watts Bar Nuclear Plant Integrated Trend Review - Site Report January through June 2005*SMMMD-22, Planners GuideWork Orders *05-812325-000, replace test tee for RHR flow indicator 1-FT-74-24*05-812477-000, replace test tee for SI flow transmitter 1-FT-63-173A

• 04-822271-000, replace test tee and tubing for CCP pressure indicator 1-PI-62-110

• 05-813941-000, replace tubing and fittings for main feed pump turbine low pressurestop valve drain 1-FCV-46-14A*05-810909-000, replace tubing for containment spray pressure indicator 1-PI-72-15

• 05-813960-000, replace tubing and fittings for condensate booster pump pressureindicator 1-PI-2-109*05-817882-000, replace tubing and fittings for main turbine extraction drain air operatedvalve 1-FCV-7-6