IR 05000327/2011009
| ML112690467 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/26/2011 |
| From: | Hopper G Reactor Projects Branch 7 |
| To: | Krich R Tennessee Valley Authority |
| References | |
| IR-11-009 | |
| Download: ML112690467 (19) | |
Text
UNITED STATES mber 26, 2011
SUBJECT:
SEQUOYAH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000327/2011009 AND 05000328/2011009
Dear Mr. Krich:
On August 18, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Sequoyah Nuclear Power Plant Units 1 and 2. The enclosed report documents the inspection results, which were discussed on August 18, 2011, with you and other members of your staff.
The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with station personnel.
On the basis of the samples selected for review, there were no findings identified during this inspection. The inspectors concluded that problems were properly identified, evaluated, and resolved within the corrective action program (CAP). However, the team identified two minor issues associated with the licensees prioritization of issues, screening of issues, and quality of effectiveness reviews.
TVA 2 In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). Adams is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos. 50-327, 50-328 License Nos. DPR-77, DPR-79
Enclosure:
Inspection Report 05000327/2011009 and 05000328/2011009 w/Attachment: Supplemental Information
REGION II==
Docket Nos: 50-327, 50-328 License Nos: DPR-77, DPR-79 Report No: 05000327/2011009 and 05000328/2011009 Licensee: Tennessee Valley Authority (TVA)
Facility: Sequoyah Nuclear Plant, Units 1 and 2 Location: Sequoyah Access Road Soddy-Daisy, TN 37379 Dates: August 1 - 5, 2011 August 15 - 18, 2011 Inspectors: R. Taylor, Senior Project Inspector, Team Leader M. Checkle, Allegations Coordinator W. Deschaine, Resident Inspector, Sequoyah C. Fletcher, Senior Reactor Inspector Approved by: George T. Hopper, Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000327/2011009, 05000328/2011009; 08/01/2011 - 08/18/2011; Sequoyah Nuclear Plant,
Units 1 and 2; biennial inspection of the identification and resolution of problems.
The inspection was conducted by one senior project inspectors, a senior reactor inspector, an allegations coordinator, and a resident inspector. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Identification and Resolution of Problems The inspection team concluded that, in general, problems were adequately identified, prioritized, and evaluated; and effective corrective actions were implemented. Site management was actively involved in the corrective action program (CAP) and focused appropriate attention on significant plant issues. The team found that employees were encouraged by management to initiate problem evaluation reports (PERs) as appropriate to address plant issues.
The licensee was effective at identifying problems and entering them into the CAP for resolution, as evidenced by the relatively few deficiencies identified by the NRC that had not been previously identified by the licensee during the review period. The threshold for initiating PERs was appropriately low, as evidenced by the type of problems identified and large number of PERs entered annually into the CAP. In addition, PERs normally provided complete and accurate characterization of the problem.
Generally, prioritization and evaluation of issues were adequate and consistent with the licensees CAP guidance. Formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems did address the cause of the problems.
The age and extensions for completing evaluations were closely monitored by plant management, both for high priority PERs, as well as for adverse conditions of less significant priority. Also, the technical adequacy and depth of evaluations (e.g., root cause investigations)were typically adequate. However, the team identified two minor issues associated with the licensees prioritization of issues, screening of issues, and quality of effectiveness reviews.
Corrective actions were generally effective, timely, and commensurate with the safety significance of the issues.
The operating experience program was effective in screening operating experience for applicability to the plant, entering items determined to be applicable into the CAP, and taking adequate corrective actions to address the issues. External and internal operating experience was adequately utilized and considered as part of formal root cause evaluations for supporting the development of lessons learned and corrective actions for CAP issues.
The licensees audits and self-assessments were critical and effective in identifying issues and entering them into the corrective action program. These audits and assessments identified issues similar to those identified by the NRC with respect to the effectiveness of the CAP.
Based on general discussions with licensee employees during the inspection, targeted interviews with plant personnel, and reviews of selected employee concerns records, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP as well as the employee concerns program to resolve those concerns.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Assessment of the Corrective Action Program
- (1) Inspection Scope The inspectors reviewed the licensees CAP procedures which described the administrative process for initiating and resolving problems primarily through the use of problem evaluation reports (PERs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed PERs that had been issued between August 2009 and August 2011, including a detailed review of selected PERs associated with four risk-significant systems:
Essential Raw Cooling Water (ERCW), Component cooling Water (CCW), Diesel Generators (DGs), and Low Voltage AC/DC. Where possible, the inspectors independently verified that the corrective actions were implemented as intended. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP), the team selected a representative number of PERs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, emergency preparedness, health physics, chemistry, and security. These PERs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The inspectors reviewed selected PERs, verified corrective actions were implemented, and attended meetings where PERs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
The inspectors conducted plant walkdowns of equipment associated with selected systems and other plant areas to assess the material condition and to look for any deficiencies that had not been previously entered into the CAP. The inspectors reviewed PERs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a 24-month period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.
Control Room walkdowns were also performed to assess the main control room (MCR)deficiency list and to ascertain if deficiencies were entered into the CAP. Operator Workarounds and Operator Burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment were being implemented in the field.
The team conducted a detailed review of selected PERs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the PERs and the guidance in licensee procedures PIDP-5, Apparent Cause Evaluations, and PIDP-6, Root Cause
Analysis.
The inspectors assessed if the licensee had adequately determined the cause(s) of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence.
The team reviewed selected industry operating experience items, including NRC generic communications, to verify that they had been appropriately evaluated for applicability and that issues identified through these reviews had been entered into the CAP.
The team reviewed site trend reports, to determine if the licensee effectively trended identified issues and initiated appropriate corrective actions when adverse trends were identified.
The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included PER Screening Committee (PSC) meetings and Corrective Action Review Board (CARB) meetings.
Documents reviewed are listed in the Attachment.
- (2) Assessment Identification of Issues The team determined that the licensee was generally effective in identifying problems and entering them into the CAP and that there was a low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating PERs as described in licensee procedure PIDP-1, PER Initiation, managements expectation that employees were encouraged to initiate PERs for any reason, and a review of system health reports. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.
Prioritization and Evaluation of Issues Based on the review of audits conducted by the licensee and the assessment conducted by the inspection team during the onsite period, the team concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in the PER significance determination guidance in PIDP-4, Corrective Action Program Screening and Oversight. Each PER written was assigned a priority level by the PSC. Management reviews of applicable PERs conducted by the CARB were thorough, and adequate consideration was given to system or component operability and associated plant risk.
The team determined that the station had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures, and assigned cause determinations were appropriate considering the significance of the issues being evaluated. A variety of causal-analysis techniques were used depending on the type and complexity of the issue consistent with licensee procedures PIDP-4, Apparent Cause Evaluations, and PIDP-5, Root Cause
Analysis.
The team determined that generally, the licensee had performed evaluations that were technically accurate and of sufficient depth. The team further determined that operability, reportability, and degraded or non-conforming condition determinations had been completed consistent with the guidance contained in PIDP-2, PER Supervisory Review, and PIDP-3, Operability and Reportability Reviews of PERs.
The inspectors identified an issue associated with the licensees prioritization and screening of issues. This issue was screened in accordance with Manual Chapter 0612, Issue Screening, and determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- During a review of the licensees prioritization of ERCW valve position and temperature recorder issues the inspectors noted inconsistencies in the screening of D and C level PERs. The team determined that the licensee was screening PERs as D level PERs when they met the criteria of C level PERs.
Although the PERs where not screened in accordance with licensee procedures, the team determined that appropriate causal factors were identified and operability considerations were taken. The licensee initiated PERS 419335 and 418112 to address this issue.
Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the team determined that overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective, in that conditions adverse to quality were corrected and non-recurring.
For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence in that a review of performance indicators, PERs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CATPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
The inspectors identified two issues associated with the licensees effectiveness reviews. These issues were screened in accordance with Manual Chapter 0612, Issue Screening, and determined to be of minor significance and not subject to enforcement action in accordance with the NRCs Enforcement Policy.
- The effectiveness review procedure is not related to the effectiveness review grading sheet contained in the Corrective Action Review Board (CARB) over site procedure. Per was418091 written to address this issue.
- The effectiveness review grading sheet contained in the CARB oversight procedure does not provide specific attributes for each potential score listed. In addition the grading sheet is a combined root cause, apparent cause and effectiveness review grading sheet with each having different scoring criteria.
Per 418091 was written to address this issue.
- (3) Findings No findings of significance were identified.
b. Assessment of the Use of Operating Experience (OE)
- (1) Inspection Scope The team examined licensee programs for reviewing industry operating experience, reviewed licensee procedure SPP-3.9, Operating Experience Program, reviewed the licensees operating experience database, and interviewed the OE Coordinator, to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the team selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), which had been issued since August 10, 2007, to verify whether the licensee had appropriately evaluated each notification for applicability to the Sequoyah plant, and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the
.
- (2) Assessment Based on interviews with the OE Coordinator and a review of documentation related to the review of operating experience issues, the team determined that the licensee was generally effective in screening operating experience for applicability to the plant.
Industry OE was evaluated at either the corporate or plant level depending on the source and type of document. Relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, operating experience was included in all apparent cause and root cause evaluations in accordance with licensee procedures PIDP-5, Apparent Cause Evaluations, and PIDP-6, Root Cause
Analysis.
- (3) Findings No findings of significance were identified.
c. Assessment of Self-Assessments and Audits
- (1) Inspection Scope The team reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure SPP-1.6, NPG Self-assessment and Benchmarking Program.
- (2) Assessment The team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical, as evidenced by findings consistent with the teams independent review. PERs were created to document the results and associated recommendations from the final reports. The team verified that all recommendations from self-assessments reviewed had been entered into the CAP, and verified that actions had been completed consistent with those recommendations. The team also determined that the licensee had adequately prioritized issues entered into the CAP. Generally, the licensee performed evaluations that were technically accurate. Site trend reports were thorough and a low threshold was established for evaluation of potential trends. The team concluded that the self-assessments and audits were an effective tool to identify adverse trends.
- (3) Findings No findings of significance were identified.
d. Assessment of Safety-Conscious Work Environment
- (1) Inspection Scope The team randomly interviewed 15 on-site workers regarding their knowledge of the corrective action program at Sequoyah and their willingness to write PERs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors conducted discussions to develop a general perspective of the safety-conscious work environment at the site. The discussions were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Concerns Resolution Program (CRP) and interviewed the CRP manager. Additionally, the inspectors reviewed a sample of completed CRP reports to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.
- (2) Assessment Based on the interviews conducted and the PERs reviewed, the team determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and CRP. These methods were readily accessible to all employees.
Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.
- (3) Findings No findings of significance were identified.
4OA6 Meetings, Including Exit
On August 18, 2011, the inspectors presented the inspection results to Mr. J. Carlin and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.
ATTACHMENT: SUPPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- N. Thomas, Licensing Engineer
- D. Sutton, Licensing Engineer
- A. Bergeron, Operations Training
- P. Johnson, Quality Assurance
- P. Simmons, Work Control Manager
- G. Yelliott, ECP Coordinator
- W. Price, Assistant Engineering Director
- J. Miller, Performance Improvement
- G. Franceschi, Performance Improvement
- A. Justice, Performance Improvement
- R. Baumer, Operating Experience
- C. Hoffman, Operations
- R. Burkett, Operations
- M. Kerwin, Maintenance
NRC
- G. Hopper, Branch Chief, Reactor Projects Branch 7
- C. Young, Senior Resident Inspector, Sequoyah Nuclear Plant
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
Discussed
None