IR 05000327/2015009
ML15211A452 | |
Person / Time | |
---|---|
Site: | Sequoyah ![]() |
Issue date: | 07/29/2015 |
From: | Masters A Reactor Projects Branch 7 |
To: | James Shea Tennessee Valley Authority |
References | |
IR2015009 | |
Download: ML15211A452 (15) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION uly 29, 2015
SUBJECT:
SEQUOYAH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000327/2015009, 05000328/2015009
Dear Mr. Shea:
On June 25, 2015, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Sequoyah Nuclear Plant Units 1 and 2. The enclosed report documents the inspection findings, which were discussed on June 25, 2015, with Mr. Preston Pratt and other members of your staff. A re-exit was conducted with Mrs. Erin Henderson via telephone on July 24, 2015, to discuss the final results of the inspection.
Based on the inspection samples, the inspectors determined that your staffs implementation of the corrective action program supported nuclear safety. In reviewing your corrective action program, the inspectors assessed how well your staff identified problems at a low threshold, your staffs implementation of the stations process for prioritizing and evaluating these problems, and the effectiveness of corrective actions taken by the station to resolve these problems. In each of these areas, the inspectors determined that your staffs performance was adequate to support nuclear safety.
The inspectors also evaluated other processes your staff used to identify issues for resolution.
These included your use of audits and self-assessments to identify latent problems and your incorporation of lessons learned from industry operating experience into station programs, processes, and procedures. The inspectors determined that your stations performance in each of these areas supported nuclear safety.
Finally, the inspectors determined that your stations management maintains a safety-conscious work environment adequate to support nuclear safety. Based on the inspectors observations, your employees are willing to raise concerns related to nuclear safety through at least one of the several means available. The NRC inspectors did not identify any findings or violations of more than minor significance.
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/
Anthony D. Masters, Chief Reactor Projects Branch 7 Division of Reactor Projects Docket Nos. 50-327, 50-328 License Nos. DPR-77, DPR-79 Enclosure: IR 05000327/2015009 and 05000328/2015009 w/Attachment:
Supplemental Information
ML15211A452 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRP RII:DRP RII:DRS RII:DRP RII:DRP RII:DRP SIGNATURE REW1 RCT1 Via Email/RA/BCC2 Via Email/RA/WXD1 ADM2 Via Email/RA/AJB3 NAME R. Williams R. Taylor B. Collins W. Deschaine A. Masters A. Blamey DATE 7/27/2015 7/29/2015 7/27/2015 7/27/2015 7/27/2015 7/24/2015 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.: 05000327, 05000328 License Nos.: DPR-77, DRP-79 Report Nos.: 05000327/2015009 and 05000328/2015009 Licensee: Tennessee Valley Authority (TVA)
Facility: Sequoyah Nuclear Plant, Units 1 and 2 Location: Sequoyah Access Road Soddy-Daisy, TN 37379 Dates: June 8 - 12, 2015 June 22 - 25, 2015 Inspectors: R. Williams, Senior Reactor Inspector, Team Leader R. Taylor, Senior Project Inspector B. Collins, Reactor Inspector W. Deschaine, Resident Inspector Approved by: Anthony D. Masters, Chief Reactor Projects Branch 7 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000327/2015009 and 05000328/2015009; June 8 - 25, 2015; Sequoyah Nuclear Plant,
Units 1 and 2; Biennial Inspection of the Problem Identification and Resolution Program.
The inspection was conducted by a senior reactor inspector, a senior project inspector, a reactor inspector, and a resident inspector. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Identification and Resolution of Problems The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.
The inspectors determined that overall, audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.
Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.
The NRC inspectors did not identify any findings or violations of more than minor significance.
REPORT DETAILS
4OA2 Problem Identification and Resolution
1. Corrective Action Program Effectiveness
a. Inspection Scope
The team reviewed the licensees Corrective Action Program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of condition reports (CRs). To verify that problems were being properly identified, appropriately characterized, and entered into the CAP, the inspectors reviewed CRs that had been issued between July 2013 and May 2015, including a detailed review of selected CRs associated with the following risk-significant systems:
Control Air, Heating Ventilation and Air Conditioning (HVAC), and Essential Raw Cooling Water (ERCW) systems. Where possible, the team independently verified that the corrective actions were implemented as intended. The team also reviewed selected common causes and generic concerns associated with root cause evaluations (RCE) to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the Reactor Oversight Process (ROP), the team selected a representative number of CRs that were identified and assigned to the major plant departments, including quality assurance, health physics, chemistry, emergency preparedness and security. These CRs were reviewed to assess each departments threshold for identifying and documenting plant problems, thoroughness of evaluations, and adequacy of corrective actions. The team reviewed selected CRs, verified corrective actions were implemented, and attended meetings where CRs were evaluated for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
Plant walkdowns of equipment within the selected systems listed above and other plant areas were conducted by inspectors to assess the material condition and to identify deficiencies that had not been previously entered into the CAP. The inspectors reviewed CRs, maintenance history, corrective actions (CAs), 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 two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-related issues.
The main control room (MCR) deficiency list was assessed to ascertain if deficiencies were entered into the CAP and tracked to resolution. Operator workarounds (OWA) and operator burden screenings were reviewed, and the inspectors verified compensatory measures for deficient equipment which were being implemented in the field. The inspectors conducted a detailed review of selected CRs 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 CRs and the guidance in licensee procedure NPG-SPP-22.306, Level 1 Evaluation and NPG-SPP-22.305, Level 2 Evaluation. 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 inspectors reviewed selected industry operating experience (OE) 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 inspectors 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 reviewed licensee audits and self-assessments, including those which focused on problem identification and resolution programs and processes, to verify that findings were entered into the CAP and to verify that these audits and assessments were consistent with the NRCs assessment of the licensees CAP. The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included the PER Screening Committee (PSC) and Management Review Committee (MRC) meetings.
Documents reviewed are listed in the Attachment.
b. Assessment Problem Identification The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was an appropriately low threshold for entering issues into the CAP. This conclusion was based on a review of the requirements for initiating CRs as described in licensee procedure NPG-SPP-22.300, Corrective Action Program, and managements expectation that employees were encouraged to initiate CRs for any reason. Trending was generally effective in monitoring equipment performance. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues. Based on reviews and walkdowns of accessible portions of the selected systems, the inspectors determined that system deficiencies were being identified and placed in the CAP.
However, the inspectors identified one minor violation of 10 CFR 50 Appendix B, Criterion V for the sites failure to establish appropriate quantitative or qualitative acceptance criteria for ERCW pump leakage. During the walkdown of the ERCW system and through subsequent interviews with the system engineer, it was noted that no procedure or instruction was identified that governed the acceptable leakage for the ERCW pumps.
10 CFR 50 Appendix B, Criterion V requires, in part, that, Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to this, the licensee noted that no quantitative acceptance criteria existed for the ERCW pump packing gland leak-off, and that it was up to the observer performing walkdowns and plant expectations of what was acceptable. The inspectors determined that this acceptability line and a consistent level of plant expectations was not adequately demonstrated by the licensee. The inspectors evaluated this issue in accordance with NRC Inspection Manual Chapter (IMC) 0612 and found the issue to be of minor significance due to current pump performance and equipment condition, and that there was no current evidence that the operability of the system had been challenged due to ERCW pump packing gland leakage. This issue was entered in into the licensees CAP as CR 1042782.
Problem Prioritization and Evaluation Based on the review of CRs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures as described in NPG-SPP-22.302, Corrective Action Program Screening. Each CR was assigned a priority level at the CR screening meeting, and adequate consideration was given to system or component operability and associated plant risk.
The inspectors determined that station personnel 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 formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with licensee procedures NPG-SPP-22.306, Level 1 Evaluation and NPG-SPP-22.305, Level 2 Evaluation.
Effectiveness of Corrective Actions Based on a review of corrective action documents, interviews with licensee staff, and verification of completed corrective actions, the inspectors 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, CRs, and effectiveness reviews demonstrated that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to prevent recurrence (CAPRs) were sufficient to ensure corrective actions were properly implemented and were effective.
However, the inspectors identified one minor violation of 10 CFR 50 Appendix B, Criterion V for the sites failure to follow procedures for performing Effectiveness Reviews to ensure that corrective actions taken to prevent recurrence of a significant condition adverse to quality were actually effective to preclude repetition. Procedure NPG-SPP-22.300, Corrective Action Program, Rev. 2, requires that corrective actions designed to preclude repetition of significant conditions adverse to quality be evaluated for effectiveness in accordance with procedure NPG-SPP-22.001, Effectiveness Reviews and NPGSPP-22.308, CAP Health.
10 CFR 50 Appendix B, Criterion V requires, in part, that, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to this, for root cause evaluation 861748, QA Level 2 Escalation of Procedure Use and Adherence Issues, an effectiveness review of the corrective actions taken had been scheduled but had failed to be performed, and at the time of discovery was two months overdue. The inspectors evaluated this issue in accordance with IMC 0612 and found the issue to be of minor significance as this issue was determined to be an administrative oversight and the licensees subsequent evaluation of the CAPRs for RCE 861748 determined that they were effective in preventing recurrence. The issue was entered into the licensees CAP as CR 1043414.
c. Findings
No findings of significance were identified.
2. Use of Operating Experience
a. Inspection Scope
The team examined the licensees use of industry OE to assess the effectiveness of how external and internal operating experience information was used to prevent similar or recurring problems 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 July 2013, to verify whether the licensee had appropriately evaluated each notification for applicability to the Sequoyah Nuclear Plant, and whether issues identified through these reviews were entered into the CAP.
b. Assessment Based on a review of selected documentation related to operating experience issues, the inspectors 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 the 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 procedure NPG-SPP-22.500, Operating Experience Program.
c. Findings
No findings of significance were identified.
3. Self-Assessments and Audits
a. 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. Additionally, the team verified that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure NPG-SPP-22.102, NPG Self-Assessment and Benchmarking Program.
b. 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 inspectors independent reviews. The team verified that CRs were created to document areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations.
Generally, the licensee performed evaluations that were technically accurate.
c. Findings
No findings of significance were identified.
4. Safety-Conscious Work Environment
a. Inspection Scope
During the course of the inspection, the team assessed the stations safety-conscious work environment (SCWE) through review of the stations Employee Concerns Program (ECP) and interviews with various departmental personnel. The team reviewed a sample of ECP issues to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP when appropriate.
b. Assessment Based on the interviews conducted and the CRs reviewed, the inspectors 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 ECP. 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.
c. Findings
No findings of significance were identified.
4OA6 Exit
Exit Meeting Summary
On June 25, 2015, the inspectors presented the inspection results to Mr. Preston Pratt and other members of the site staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection. A re-exit was conducted with Mrs. Erin Henderson via telephone on July 24, 2015, to discuss the final results of the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- D. Babylon, Performance Improvement Manager (acting)
- B. Basham, Performance Improvement
- D. Fults, Employee Concerns Manager (acting)
- E. Henderson, Licensing Manager
- M. Randolph, Performance Improvement
- R. Smartt, Engineering Support Technician
- R. Travis, Licensing Engineer
NRC personnel
- G. Smith, Senior Resident Inspector
LIST OF REPORT ITEMS
Opened, Closed, and Discussed
None