IR 05000327/2007008
Download: ML072530521
Text
September 7, 2007
Tennessee Valley AuthorityATTN:Mr. William R. CampbellChief Nuclear Officer and Senior Vice President6A Lookout Place1101 Market StreetChattanooga, TN 37402-2801
SUBJECT: SEQUOYAH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION ANDRESOLUTION (PI&R) INSPECTION REPORT 05000327/2007008 AND05000328/2007008
Dear Mr. Campbell:
On August 10, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspectionat your Sequoyah Nuclear Plant, Units 1 and 2. The enclosed inspection report documents theinspection findings, which were discussed on August 10, 2007, with Mr. R. Douet and othermembers of your staff.The inspection was an examination of activities conducted under your license as they relate tothe identification and resolution of problems, and compliance with the Commission's rules andregulations and with the conditions of your operating license. Within these areas, the inspectioninvolved examination of selected procedures and representative records, observations ofactivities, and interviews with personnel.On the basis of the sample selected for review, overall the team concluded that problems werebeing properly identified, documented, evaluated, and corrected. However the team identifiedseveral isolated examples where corrective actions did not appear appropriate, were notaccurately documented, or were not completely carried out. The team observed that the qualityof Problem Evaluation Report documentation has improved since the last NRC biennial PI&Rinspection. The team did observe that there continues to be some lingering issues regardingextension of corrective actions due to resource limitations.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC Public TVA2Document Room or from the Publicly Available Records (PARS) component of NRC's documentsystem (ADAMS). ADAMS is accessible from the NRC Web site athttp://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Tilda Y. Liu, Acting ChiefReactor Projects Branch 6Division of Reactor ProjectsDocket No.:50-327, 50-328License No.:DPR-77, DPR-79
Enclosure:
Inspection Report 05000327/2007008 and 05000328/2007008
w/Attachment:
Supplemental Informationcc w/encl: (See page 3)
TVA2Document Room or from the Publicly Available Records (PARS) component of NRC's documentsystem (ADAMS). ADAMS is accessible from the NRC Web site athttp://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Tilda Y. Liu, Acting ChiefReactor Projects Branch 6Division of Reactor ProjectsDocket No.:50-327, 50-328License No.:DPR-77, DPR-79
Enclosure:
Inspection Report 05000327/2007008 and 05000328/2007008
w/Attachment:
Supplemental Informationcc w/encl: (See page 3)X PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLEG SENSITIVE X NON-SENSITIVEADAMS: X YesACCESSION NUMBER:_________________________OFFICERII:DRpRII:DRPRII:DRPRII:DRSRII:DRSSIGNATURE/RA//RA By E-Mail/RA By E-Mail//RA By E-Mail//RA/NAMEJBaptistSFreemanTLiuWFowlerARichardsonDATE3/ /20083/ /20083/ /20083/ /20083/ /20083/ /20083/ /2008 E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNO OFFICIAL RECORD COPY DOCUMENT NAME: C:\FileNet\ML072530521.wpd TVA3cc w/encl:Ashok S. BhatnagarSenior Vice PresidentNuclear Generation Development and ConstructionTennessee Valley AuthorityElectronic Mail DistributionRandy DouetSenior Vice PresidentNuclear SupportTennessee Valley AuthorityElectronic Mail DistributionWalter M. Justice, IIInterim Vice PresidentNuclear Engineering & Technical ServicesTennessee Valley AuthorityElectronic Mail DistributionTim ClearySite Vice PresidentSequoyah Nuclear PlantElectronic Mail DistributionGeneral CounselTennessee Valley AuthorityElectronic Mail DistributionJohn C. Fornicola, General ManagerNuclear Assurance Tennessee Valley AuthorityElectronic Mail DistributionBeth A. Wetzel, ManagerCorporate Nuclear Licensing and Industry AffairsTennessee Valley Authority4X Blue Ridge1101 Market StreetChattanooga, TN 37402-2801Glenn W. Morris, ManagerLicensing and Industry AffairsSequoyah Nuclear PlantTennessee Valley AuthorityElectronic Mail DistributionRobert H. Bryan, Jr., General ManagerLicensing and Industry AffairsSequoyah Nuclear PlantTennessee Valley Authority4X Blue Ridge1101 Market StreetChattanooga, TN 37402-2801Chris R. Church, Plant ManagerSequoyah Nuclear PlantTennessee Valley AuthorityElectronic Mail DistributionLawrence E. Nanney, DirectorTN Dept. of Environment & ConservationDivision of Radiological HealthElectronic Mail DistributionCounty MayorHamilton County CourthouseChattanooga, TN 37402-2801Ann Harris341 Swing LoopRockwood, TN 37854James H. Bassham, DirectorTennessee Emergency ManagementAgencyElectronic Mail Distribution TVA4Distribution w/encl:Bob Pascarelli, NRRB. Moroney, NRRC. Evans (Part 72 Only)L. Slack, RII EICSOE Mail (email address if applicable)RIDSNRRDIRSPUBLIC EnclosureU. S. NUCLEAR REGULATORY COMMISSIONREGION IIDocket Nos:50-327, 50-328License Nos:DPR-77, DPR-79Report No:05000327/2007008 and 05000328/2007008Licensee:Tennessee Valley Authority (TVA)Facility:Sequoyah Nuclear PlantLocation:Sequoyah Access RoadSoddy-Daisy, TN 37379Dates:July 23, 2007 - August 10, 2007Inspectors:J. Baptist, Team LeaderS. Freeman, Senior Resident InspectorW. Fowler, Reactor InspectorA. Richardson, Physical Security InspectorApproved by:T. Liu, Acting Chief Reactor Projects Branch 6Division of Reactor Projects
SUMMARY OF FINDINGS
IR 05000327/2007008, IR 05000328/2007008; 07/23/2007 - 08/10/2007; Sequoyah Nuclear Plant, Units 1 & 2; Problem Identification and Resolution.The inspection was conducted by one Region II senior project engineer, a senior residentinspector, one Region II reactor inspector, and a Region II physical security inspector. Nofindings were identified during this inspection.Identification and Resolution of ProblemsThe team determined that the licensee was identifying plant deficiencies at an appropriately lowlevel and effectively entering them into their corrective action program. The team alsodetermined that the licensee was prioritizing and evaluating issues properly. The teamidentified several isolated examples where corrective actions did not appear appropriate, werenot accurately documented, or were not completely carried out. Overall, the team found theeffectiveness of corrective actions to be acceptable. The team observed that the quality ofProblem Evaluation Report (PER) documentation has improved since the last NRC biennialPI&R inspection, but further improvements could be made. There continue to be multipleextensions for corrective actions with resources identified as the most significant contributingcause. The team concluded, however, that the licensee was generally providing an effectivecorrective action program.The inspection team identified that the last NRC Sequoyah PI&R inspection report 50-327,328/2005009, issued 09/09/05 identified lingering technical problems with the ElectronicCorrective Action Program (eCAP) electronic document management program. A review of thetechnical interface between personnel and the eCAP program identified that personnel werecomfortable with the software and it's functionality in creating and processing PERs.On the basis of interviews conducted during this inspection, the inspectors determined thatworkers at the site felt free to put safety concerns into the corrective action program. Theinspectors concluded that the Employee Concerns Resolution program was functioningacceptably but the inspectors observed that there was a work backlog.
REPORT DETAILS
4.OTHER ACTIVITIES (OA)4OA2Problem Identification and Resolution a.Assessment of the Corrective Action Program (1)Inspection ScopeThe inspectors reviewed items selected across the seven NRC cornerstones of safety todetermine if problems were being properly identified, characterized, and entered into thecorrective action program (CAP) for timely and complete evaluation and resolution. Theinspectors reviewed in detail the licensee's CAP procedure, SPP-3.1, "Corrective ActionProgram," Revision (Rev.) 12, which described the process for documenting andresolving issues via problem evaluation reports (PERs). The licensee's CAP proceduredefined four priority action categories for significance screening of their PERs. Thesecategories include Level A for significant adverse conditions, Level B for adverseconditions of substantial severity potentially warranting corrective action, Level C forconditions adverse to quality where documentation of corrective actions is required, andLevel D for conditions that are not adverse to quality and do not warrant correcting, butrather, can be enhanced, improved, or made more efficient. The team reviewed itemsselected across the span of plant activities to determine if problems were being properlyidentified, characterized, and entered into the corrective action program for evaluationand resolution. Specifically, the inspectors selected and reviewed approximately 340PERs initiated by the licensee from July 2005, to July 2007. When necessary, theinspectors' reviews included PERs older than July 2005 that were referenced by theoriginal PER sample set. The team examined PERs and work orders (WOs) associatedwith the Auxiliary Feedwater System, Emergency Raw Cooling Water System, and theComponent Cooling Water System. The team reviewed PERs associated withOperations, Maintenance, Engineering, Radiological Protection, Chemistry, Security andEmergency Preparedness events, problems, and deficiencies. The team reviewedoperating experience resolution documents, and Employee Concerns Resolutionactivities. The team also reviewed licensee corrective action trend reports, PEReffectiveness reviews, as well as Nuclear Assurance department audits andsurveillances from the review period. The team evaluated these items to determine thelicensee's threshold for identifying problems.The inspectors conducted walkdowns of components associated with the AuxiliaryFeedwater System, Emergency Raw Cooling Water System, and the ComponentCooling Water System to verify that problems had been properly identified andcharacterized in the CAP. System performance was reviewed by discussion with systemengineers and by review of work requests (WRs) and completed maintenance workorders (WOs), maintenance rule data, and system health reports to verify that equipmentdeficiencies were being appropriately entered into the CAP. Control room operator logswere reviewed to verify that PERs were initiated for deficiencies described in the logswhen appropriate. In addition, the inspectors attended plant morning status meetingsand CAP initial review meetings to observe management oversight in the correctiveaction process. The inspectors reviewed licensee audits and self-assessments(focusing primarily on problem identification and resolution) to verify that findings were 4entered into the CAP and to verify that these findings were consistent with the NRC'sassessment of the licensee's CAP.Documents reviewed are listed in the Attachment.
(2) Assessment Identification of Issues. The team determined that the licensee was effective at identifying problems at anappropriately low threshold and entering them into the corrective action program. Onlyin review of PER 94993, written January 7, 2006 to document repetitive High PressureSteam Supply controller component failure, was there evidence that a PER was neverinitiated to examine the cause of the repeat event. At the time of the close of theinspection, the licensee had already addressed this issue and entered the issue into thecorrective action program as PER 128545.The inspectors observed that the licensee had implemented a process for initiating ananonymous PER. Paper copies of PERs are available throughout the plant and havevarious drop-boxes for depositing the concerns. This is referenced in the last NRCSequoyah PI&R inspection report 50-327,328/2005009, issued 09/09/05 and wasverified to be functional through inspection of the anonymous PER database andinterviews with site personnel. Prioritization and Evaluation of Issues. The team determined that PER level classifications were consistent with establishedprocedures and that licensee audits and self-assessments generally confirmed thatconclusion. The team further determined that operability, reportability, degraded or non-conforming condition determinations and cause evaluations were also consistent withSPP-3.1. However, the team did identify one evaluation and two classificationdeficiencies that were entered into the corrective action program by the licensee at theclose of the inspection.*On November 27, 2004, operations identified elevated RHR discharge pressuresduring an RCS leak search. Subsequently, PER 72764 was then generated toaddress the cause and affects on operability. The Functional Evaluation (FE) todetermine RHR operability did not address potential affects on elevated RHRsystem suction side pressures in the event the RHR pumps are started andmaintained on min-flow. After operating on min-flow the RHR discharge pipingpressures will then equalize with pressures in the suction piping. Equalizingpressure in the suction piping could then impact the ability of the containmentsump valves to open in order to enter recirculation. During the inspection furtherevaluations were performed and verified the suction piping would have equalizedat 275 psi, which is below the 305 psid maximum opening pressure that thedouble-disk containment sump gate valves can operate under. At the time of thecompletion of this inspection, the licensee had entered the issue into thecorrective action program as PER 128560.
5*PERs 88634, "Fitting Omitted from Design Documentation for EDG PressureControl Valve Modification" and 88773, "Expert Panel not Properly Notified When480V Auxiliary Board Room A/C Train B Exceeded Maintenance Rule FunctionalFailure Criteria" were identified to have been improperly classified as "D" levelPERs when they met the licensee's criteria for issue classification of "C" levelPERs. At the time of the completion of this inspection, the licensee had enteredthe issue into the corrective action program as PER 128216. The inspectors observed that there had been many time extensions granted on PERactions in the past. The licensee has recently recognized this data, as well, and plans torevise procedures to require an escalating level of approval for successive correctiveaction extensions.Effectiveness of Corrective Actions. Based on a review of numerous corrective action plans and their implementation, theteam found, for the most part, that the licensee's corrective actions were effective. Effectiveness reviews and audits were generally of good depth and correctly identifiedissues similar to those raised during previous NRC inspections. However, the team dididentify several corrective action deficiencies.*During a review of a May 2007 security event identified in PER 124559, theinspectors noted that an issue related to Safeguards Information, was noteffectively dispositioned. The license identified Safeguards Information in a non-Safeguards document and performed actions to remove the SafeguardsInformation but did not ensure all actions were taken to expunge the informationfrom other potential sources. Based on a subsequent review of this issue by thelicensee, PER 128744 was issued to document the issue and corrective actionswere taken. This ineffective review is considered a weakness in the area ofproblem resolution, however, additional inspection is needed. Pendingcompletion of additional inspection, this issue will be identified as URI 05000327,328/2007008-01, Safeguards Information.*On July 13, 2006, PER 104944 was created to address testing of eight GL 89-10MOVs prior to the 120 day deadline requirement for issuance of the trend reportafter the U1C13 outage. Subsequently, not all MOVs were tested prior to the120 day deadline. However, procedural guidance has been revised by requiringtesting of all valves prior to issuance of the trend report rather than being anexpectation.*On April 26, 2007, the Main Control Room (MCR) weather radio did not performits function of informing the MCR staff of a tornado watch in the local area. Thisfailure prevented the MCR staff from initiating actions to mitigate the potentialdamage should a tornado strike the site. This issue was previously identified inPER 99140 on March, 14, 2006 which was closed to Work Order (WO) 06-773314 without any further actions taken. At the time of the completion of thisinspection, the licensee had purchased a new MCR radio and entered the issueinto the corrective action program as PER 128060.
6*On April 23, 2006, PER 101573 was written identifying the 1B-B EmergencyDiesel Generator (EDG) 1B2 engine Woodward governor speed droop settingfound out of position. The governor speed droop setting stayed in such aconfiguration for approximately three months without correction. A functionalevaluation was performed verifying that the 1B-B EDG remained operable butnumerous monthly maintenance test procedures were performed with the settingin a position contrary to that identified in the surveillance procedure. The teamdetermined that actions to immediately disposition the PER were not adequateaddressed in a timely manner.*On July 17, 2006, PER 106937 was written to evaluate measures that wouldprevent the potential for releasing Tritium from the Reactor Water Storage Tank(RWST) moat in times of heavy rainfall. Actions were taken, however, on July11, 2007 and July 28, 2007 the RWST moat was allowed to overflow. The teamconcluded that the corrective actions to prevent such occurrences wereinadequate even though radiological limits were not exceeded. At the time of thecompletion of this inspection, the licensee had devised a new process to attemptto prevent such occurrences.*On February 23, 2006 PER 97828 was written to identify Abnormal OperatingProblems in Radiological Emergency Preparedness Drill. The problemdescription section of the PER asked for a training needs evaluation afterchanges were made to the procedure, however, there were no actions specifiedin the PER to accomplish this activity. The team concluded that the licensee didnot comply with prescribed closeout provisions of licensee procedure SPP-3.1,Corrective Action Program. At the time of the completion of this inspection, thelicensee had entered the issue into the corrective action program as PER 127938with plans to complete the training needs analysis as previously mentioned.*On August 25, 2005, PER 88252 was written to document the storage of items infront of an Emergency Operating Instruction (EOI)/ Abnormal OperatingProcedure (AOP) gang box. The items maintained in the gang box provide ameans to mitigate a loss of the safety related service water to the plants coolantcharging pumps. This was a repeat occurrence from July 9, 2005 when PER85589 was written for a similar occurrence. The actions taken to disposition PER88252 were adequate in preventing future occurrences of the same event,however a PER was never written questioning why the adequacy of PER 85589was not successful in preventing recurrence. At the time of the completion of thisinspection, the licensee had entered the issue into the corrective action programas PER 128058.The inspectors did not identify any more than minor equipment performance issues fromthe above described deficiencies.
b.Assessment of the Use of Operating Experience (1)Inspection ScopeThe inspectors examined licensee programs for reviewing industry operatingexperience, reviewed the licensee's operating experience database, and interviewedpersonnel, to assess the effectiveness of how external and internal operating experiencedata was handled at the plant. In addition, the inspectors selected thirteen operatingexperience notification documents (NRC generic communications, 10 CFR Part 21reports, licensee event reports, vendor notifications, and TVA plant internal operatingexperience items, etc.), which had been issued since April 2005, to verify whether thelicensee had appropriately evaluated each notification for applicability to the Sequoyahplant. Documents reviewed are listed in the Attachment.
(2)AssessmentThe team determined that the licensee was effective in screening operating experiencefor applicability to the plant. The inspectors verified that the licensee had entered thoseitems determined to be applicable into the CAP and taken adequate corrective actions toaddress the issues. External and Internal operating experience was adequately utilizedand considered as part of formal root cause evaluations for supporting the developmentof lessons learned and corrective actions for CAP issues. c.Assessment of Self-Assessments and Audits (1)Inspection ScopeThe inspectors reviewed CAP trend reports, CAP backlogs, PER trend reports,department self-assessments, and Nuclear Assessment Section audits to verify that thelicensee appropriately prioritized and evaluated problems with the CAP in accordancewith their risk significance. The inspectors compared the NRC's CAP assessmentresults against the licensee's assessment of the CAP effectiveness.
(2)AssessmentThe team determined that the scope of self-assessments and audits were adequate.Department self-assessments and Nuclear Assessment Section audits were generallyself-critical and effective in identifying issues that were entered in the CAP for resolution.Corrective actions developed as a result of these assessments and audits weregenerally effective. The team noted that these audits and assessments identified issuessimilar to those identified by the NRC. d.Assessment of Safety-Conscious Work Environment (1)Inspection ScopeThe team reviewed numerous audits, assessments, PERs, WOs, and other correctiveaction documents and held discussions with numerous personnel at various levels in theorganization to assess if a work environment existed that was conducive to the 8identification of nuclear safety issues. Inspectors also examined the licensee'semployee Concerns Resolution Program records and discussed the program with theimplementer to determine if issues affecting nuclear safety were being appropriatelyaddressed.
(2)AssessmentThe team determined that workers at the site felt free to raise safety concerns. Personnel stated that they do not hesitate to raise nuclear safety issues to theirmanagement without fear of retaliation by their management. The wide spectrum ofPER documented issues supported this conclusion. The team had no indication duringthis inspection of individuals being inhibited from identifying problems using thecorrective action process.Inspectors concluded that the Concerns Resolution Program was functioningacceptably, but that there was a backlog of work to be done in the program. There wereno technical safety issues identified that were lingering without attention in the program.The inspectors reviewed the last three Nuclear Assurance (NA) assessments of the CAPprogram performance. The management organization is appropriately responding to NAby initiating PERs and taking corrective actions.4OA6MeetingsExit Meeting SummaryOn August 10, 2007, the inspectors presented the inspection results to Mr. R. Douet andother members of his staff, who acknowledged the findings. The inspectors asked thelicensee whether any of the material examined during the inspection should beconsidered proprietary. No proprietary information was identified.ATTACHMENT: