IR 05000327/2019002

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Integrated Inspection Report 05000327/2019002 and 05000328/2019002
ML19204A173
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 07/23/2019
From: Lopez O
NRC/RGN-II/DRP/RPB5
To: James Shea
Tennessee Valley Authority
Omar Lopez-Santiago
References
IR 2019002
Download: ML19204A173 (17)
v • d • e


Text

{{#Wiki_filter:uly 23, 2019

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - INTEGRATED INSPECTION REPORT 05000327/2019002 AND 05000328/2019002

Dear Mr. Shea:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Sequoyah, Units 1 and 2. On July 17, 2019, the NRC inspectors discussed the results of this inspection with Mr. Matt Rasmussen and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Sequoyah.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Sequoyah. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, /RA/ Omar R. Lopez-Santiago, Chief Reactor Projects Branch 5 Docket Nos.: 05000327 and 05000328 License Nos.: DPR-77 and DPR-79 Inspection Report 05000327/2019002 and 05000328/2019002 cc w/ encl: Distribution via LISTSERV

ML19204A173 OFFICE RII: DRP RII: DRP RII: DRS RII: DRS NAME N Childs D Hardage S Ninh O Lopez-Santiago DATE 7/19/2019 7/18/2019 7/19/2019 7/23/2019

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Numbers: 05000327 and 05000328 License Numbers: DPR-77 and DPR-79 Report Numbers: 05000327/2019002 and 05000328/2019002 Enterprise Identifier: I-2019-002-0023 Licensee: Tennessee Valley Authority Facility: Sequoyah Nuclear Plant, Units 1 and 2 Location: Soddy Daisy, TN 37379 Inspection Dates: April 01, 2019 to June 30, 2019 Inspectors: N. Childs, Resident Inspector D. Hardage, Senior Resident Inspector Approved By: Omar R. Lopez-Santiago, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a integrated inspection at Sequoyah, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations Obstruction in Steam Generator Pressure Channel sense line results in engineered safeguard feature actuation system (ESFAS) channel inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.15 Systems NCV 05000327/2019002-01 Management Open/Closed The inspectors identified a green, non-cited violation of 10 CFR 50 Appendix B criterion XVI when the licensee failed to ensure the pressure instrumentation sense line for a steam generator pressure protection channel transmitter was not obstructed. Specifically, identified blockages in the sense line were not cleared and resulted in an inoperable ESFAS channel.

Additional Tracking Items None.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power (RTP). On April, 14, 2019, the reactor tripped on number 3 steam generator low level following a loss of the 'A' main feedwater pump. The unit was returned to RTP on April 17, 2019 and remained at or near RTP for the remainder of the inspection period.

Unit 2 began the inspection period at rated thermal power and remained at or near RTP for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01 - Adverse Weather Protection Summer Readiness Sample (IP Section 03.01)

Main article: IP 71111.01

The inspectors evaluated summer readiness of offsite and alternate current (AC) power systems on May 31, 2019.

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

Main article: IP 71111.04

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Unit 2 A component cooling system (CCS) header following the restoration of 2A2 CCS heat exchanger on April 5, 2019
(2) Unit 1 offsite power while 1A start bus was out of service for inspection and planned maintenance on April 28, 2019
(3) Common 1-IV and 0-IV vital inverters, III and 2-S vital chargers while 2-IV vital inverter was out of service for inspection and planned maintenance on April 30, 2019

71111.04S - Equipment Alignment Complete Walkdown Sample (IP Section 03.02)

Main article: IP 71111.04S

The inspectors evaluated system configurations during a complete walkdown of the High Pressure Fire Protection System on June 26, 2019.

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

Main article: IP 71111.05Q

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Unit 1 and Unit 2 auxiliary building, elevation 759 on April 9, 2019
(2) Emergency Raw Cooling Water Building on May 6, 2019
(3) Diesel Generator Building, elevation 740.5 on May 22, 2019
(4) Diesel Generator Building, elevation 722 on June 17, 2019
(5) Unit 1 and Unit 2, Auxiliary Building - El. 734 (Vital Battery Board Rooms 1-4) on June 24, 2019

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

Main article: IP 71111.11Q

The inspectors observed and evaluated licensed operator performance in the main control room following a reactor trip on April 14, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample) The inspectors observed and evaluated a simulator training scenario on May 29, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

Main article: IP 71111.12

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Review of licensee activities in response to Part 21 2019-53993 regarding transformers installed in AMETEK vital inverters at SQN on April 15, 2019
(2) Maintenance rule functional failure of the 1A1 main feed pump oil pump motor (CDE 3062) on May 3, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

Main article: IP 71111.13

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unit 1 and Unit 2, week of April 14 - April 20, 2019, including protected equipment status reviews for scheduled maintenance on OB2 component cooling system heat exchanger and Unit 1 reactor startup
(2) Unit 1 and Unit 2, week of April 21 - April 28, 2019, including protected equipment status reviews for scheduled maintenance on the 1A start bus and C control air compressor
(3) Unit 1 and Unit 2, week of May 5 - May 11, including protected equipment status reviews for scheduled maintenance on 1-I vital invertor, 1A start bus and emergent maintenance on protection rack 1-R-3
(4) Unit 2, week of May 26 - June 1, including protected equipment status reviews for scheduled maintenance on 2B containment spray pump and 2A1 480V shutdown board transformer replacement

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Unit 2 PORV 340A isolated due to excessive leakby (CR 1513968) on May 7, 2019
(2) 1-PT-1-23 appears to lag other Loop 3 Steam Generator Pressure Instruments (CR

===1507948) on May 9, 2019

(3) Unit 2 annunciator M-6B window A-1 LS-3-39D Steam Gen Loop 1 Low FW Flow/Low Water Level alarmed (CR 1518725) on May 22, 2019
(4) Emergency Gas Treatment System (EGTS) Decay Cooldown Valve 0-FCV-0028A has a damaged seat (CR 1524125) on June 13, 2019
(5) ERCW operability impacted by aligning cooling to station compressors during the summer (CR 1521279) on June 21,2019
(6) Gas/water flow noted from 1-VLV-63-832 and 1-VLV-63-837 during cold leg injection piping vent (CR 1519228) on May 23, 2019

==71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples) The inspectors evaluated the following temporary or permanent modifications:

(1) Temporary Modification SQN-1-2018-062-001, Install Tuned Vibration Damper on the 1A-A Charging Pump
(2) Temporary Modification SQN-2-2019-063-001, Safety Injection System Continuous Pressure Relief Line

71111.19 - Post-Maintenance Testing Post Maintenance Test Sample (IP Section 03.01)

Main article: [[=

=IP 71111.18|count=5}}

The inspectors evaluated the following post maintenance tests:

(1) WO 119758872, 2A2 CCS heat exchanger cleaning and inspection, on April 8, 2019
(2) WO 120454374, Replace LCP card and NVRAM in 1-R-3 on May 9, 2019
(3) WO 118341145, 2-MOVP-067-0126A, Perform EQ inspection and maintenance on May 21, 2019
(4) WO 120286121, 2B Containment Spray Pump, replace coupling due to high vibrations on May 29, 2019
(5) WO 119584204, Main Control Room A/C Chiller oil cooler cleaning and internal inspection on June 16, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IP Section 03.01)

Main article: IP 71111.22

1-SI-SXP-070-201.A, Component Cooling Pump 1A-A Performance Test on April 12, 2019 Surveillance Tests (other) (IP Section 03.01) ===

Main article: IP 15079
(1) 1-SI-OPS-082-007.A, Electrical Power System Diesel Generator 1A-A on April 29, 2019
(2) 2-PI-SFT-070-001.0, Performance Testing of Component Cooling Heat Exchangers 2A1, 2A2 on May 21, 2019
(3) 0-SI-SFT-065-001.B, Emergency Gas Treatment System Filter Train B on June 13, 2019

==71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample) Emergency preparedness drill conducted on May 15,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)==

Main article: IP 71114.06
(1) Unit 1 unplanned scrams per 7000 critical power hours (April 2018 - March 2019)
(2) Unit 2 unplanned scrams per 7000 critical power hours (April 2018 - March 2019)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)

(1) Unit 1 unplanned power changes per 7000 critical hours (April 2018 - March 2019)
(2) Unit 2 unplanned power changes per 7000 critical hours (April 2018 - March 2019)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 1 unplanned scrams with complications (April 2018 - March 2019)
(2) Unit 2 unplanned scrams with complications (April 2018 - March 2019)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Chemistry Department Safety Culture Concerns (CR 1484992).
(2) Corrective actions to address Part 21 2019-02 from Weschler Instruments (CR 1506204)
(3) Operating experience review of cryofit coupling failure at Brunswick Nuclear Station (CR 1506831)

Semiannual Trend Review (IP Section 02.02) ===

Main article: IP 71151

The inspectors reviewed the licensees corrective action program for potential adverse trends in non-functional radiation monitors that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Obstruction in Steam Generator Pressure Channel sense line results in engineered safeguard feature actuation system (ESFAS) channel inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.15 Systems NCV 05000327/2019002-01 Management Open/Closed The inspectors identified a green, non-cited violation of 10 CFR 50 Appendix B criterion XVI when the licensee failed to ensure the pressure instrumentation sense line for a steam generator pressure protection channel transmitter was not obstructed. Specifically, identified blockages in the sense line were not cleared and resulted in an inoperable ESFAS channel.

Description:

On April 14, 2019, Unit 1 reactor tripped on low steam generator level following the loss of a main feedwater pump. During the post trip review of this transient, the licensee noted that, following rapid pressure changes, one of the loop 3 steam generator pressure indicators, 1-PT-1-23, was lagging the indication of other steam generator pressure transmitters.

Specifically, the licensee noted pressure indication on the steam generators (except for 1-PT-1-23) increased from approximately 880 psig to 920 psig (40 psig) in less than a second and then remained steady for over a second while 1-PT-1-23 slowly increased by 16 psig over the same time period. Similarly, when steam generator pressures later increased approximately 60 psig in less than a second, 1-PT-1-23 slowly increased by 7 psig in the same time period.

The required response times for the steam pressure channel is 0.028 seconds. 1-PT-1-23 is used to monitor loop 3 steam line pressure and is one of three transmitters that are used with their instrument loops to provide the two-out-of-three (per steam line) logic required by Technical Specifications for Safety Injection and Steam Line Isolation. Due to this observed delayed response, operators declared 1-PT-1-23 inoperable.

It should be noted that, until the time of the trip on April 15, 2019, the licensee considered 1-PT-1-23 operable based on acceptable channel checks and calibrations. Prompted by questions raised by the inspectors, the licensee reviewed past operating experience which identified similar behavior of 1-PT-1-23 in 2015; this behavior was not recognized at that time and no corrective actions were taken. Plugging of steam generator pressure transmitter sense lines had been previously identified at Sequoyah. Condition Report (CR) 915880 was written in July 2014 documenting that steam generator instrument sense lines had been found plugged or partially plugged and erratic measurements had been attributed to partial sense line plugging. Actions were generated in the licensee's corrective action program to clear 1-PT-1-23 sense line to remove corrosion products during the upcoming refueling outage (1R20) and setup repetitive work orders for performance of this action. These actions were not performed.

Corrective Actions: 1-PT-1-23 was removed from service and the sense line was rodded out to remove accumulated material. 1-PT-1-23 was returned to operable status on April 16, 2019.

Corrective Action References: CR 1507948, CR 915880, WO 120407126, WO 116483457, PER 915889-003

Performance Assessment:

Performance Deficiency: The licensees failure to ensure identified blockages in the instrumentation sense line for a steam generator pressure protection channel transmitter were removed was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone. Specifically, identified blockages in 1-PT-1-23 sense line were not cleared and resulted in an inoperable engineered safeguard feature actuation system (ESFAS) channel.

Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The finding screened to green because all four questions in Exhibit 2, "Mitigating Systems Screening Questions" were answered "no".

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. The licensee created corrective action work orders several years prior to the event to clear the steam generator pressure transmitter sense lines. However, the work management process did not prioritize the execution of this work and these work orders were never performed.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criteria XVI, Corrective Actions, requires, in part, that measures be established to assure conditions adverse to quality are promptly identified and corrected. Contrary to the above, from November 23, 2015 until April 14, 2019, the measures established by the licensee failed to correct an identified condition adverse to quality. Specifically, the licensee identified a condition adverse to quality, obstruction of a steam generator pressure transmitter sense line, but did not take action to correct the condition.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On July 17, 2019, the inspectors presented the integrated inspection results to Mr. Matt Rasmussen and other members of the licensee staff.

THIRD PARTY REVIEWS Inspectors reviewed Institute of Nuclear Power Operations report that was issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.01 Procedures AOP-P.01 Loss of Offsite Power Revision 39 AOP-P.07 Degraded Grid or Abnormal Voltage Conditions Revision 15 NPG-SPP-07.16 On Line Work Control Power Systems Alerts/Offsite Revision 6 Power 71111.04 Miscellaneous SQN U1 Protected Equipment List 04/30/2019 0-PE-2019 Protected equipment clearance for 2-IV vital inverter 04/29/2019 and No. IV vital charger maintenance Procedures 0-SI-OPS-082-007.W AC Electrical Power Source Operability Verification Revision 45 2-SO-70-1 Component Cooling Water System "A" Train Revision 49 71111.04S Corrective Action CR 1332919 Fire Protection System Pressure Decline 08/28/2017 Documents CR 1445092 Poor Overall System Health on HPFP (026) Yard Ring 09/05/2018 Header Valves Miscellaneous SQN-DC-V-43.0 Sequoyah Nuclear Plant - High Pressure Fire Revision 9 Protection Water Supply System System Health Report System 26 - Fire Protection 1st Quarter Scorecard 2019 Work Orders 115815343; 119405060; 119405058; 1194045538 71111.05Q Fire Plans AUX-0-669-00 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 4 669 AUX-0-734-00 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 4 734 AUX-0-734-01 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 10 734 Unit 1 Side AUX-0-734-02 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 9 734 Unit 2 Side AUX-0-759-01 Auxiliary Building Elevation 759 Unit 1 Side Revision 6 AUX-0-759-02 Auxiliary Building Elevation 759 Unit 2 Side Revision 6 DGB-0-722-00 Fire Protection Pre-Fire Plans Diesel Generator Revision 7 Building El. - 722 DGB-0-740.5-00 Fire Protection Pre-Fire Plans Diesel Generator Revision 5 Building - El. 740.5 Inspection Type Designation Description or Title Revision or Procedure Date ERCW-0-688-00 Fire Protection Pre-Fire Plans ERCW Building - El. Revision 2 688 ERCW-0-704-00 Fire Protection Pre-Fire Plans ERCW Building - El. Revision 2 704 ERCW-0-720-00 Fire Protection Pre-Fire Plans ERCW Building - El. Revision 3 20 Procedures NPG-SPP-18.4.7 Control of Transient Combustibles Revision 13 71111.11Q Miscellaneous SEG OPL273S1908 RCS Leak, LOCA, ES-1.2, Loss of Sump Recirc 01/10/2019 Procedures 0-GO-6 Power Reduction From 30% Reactor Power to Hot Revision 64 Standby 0-SI-NUC-000-038.0 Shutdown Margin Revision 105 71111.12 Corrective Action CR 1508008 OE - Part 21 Ametek Solidstate Controls Inverters 04/15/2019 Documents CR 1508784 SQN Supply Chain Request a Part 21 Evaluation 04/17/2019 CR 1508834 Loss of 1A1 Main Feed Pump Lube Oil Pump Results 04/15/2019 in Trip of 1A Main Feed Pump Turbine CR 1513554 Maintenance Rule Functional Failure of 1A1 Main 05/03/2019 Feed Pump Main Oil Pump Motor Miscellaneous CDE 3062 1A Main Feedwater Pump Trip and Balance of Plant 04/14/2019 Runback Procedures NPG-SPP-03.4 Maintenance Rule Performance Indicator Monitoring, Revision 3 Trending, and Reporting - 10CFR50.65 TI-4 Maintenance Rule Performance Indicator Monitoring, Revision 32 Trending, and Reporting - 10CFR50.65 71111.13 0-GO-16 System Operability Checklists Revision 24 NPG-SPP-07.3.4 Protected Equipment Revision 5 71111.15 Corrective Action CR 1310102 1 minute and 4 seconds of gas observed during 06/22/2017 Documents performance of 1A-A SI pump discharge piping vent CR 1514732 ACMP SO-19-14 U2 PORV Tailpipe Temperature 05/07/2019 Change Drawings 2-47W610-3-1 Mechanical Control Diagram Main & Aux Feedwater Revision 21 Sys 2-47W610-3-5 Mechanical Control Diagram Main & Aux Feedwater Revision 5 Sys Inspection Type Designation Description or Title Revision or Procedure Date 2-47W611-99-6 Mechanical Logic Diagram Reactor Protection System Revision 3 Operability Past Operability Evaluation for CR 07/06/2017 Evaluations 1310089/1310095/1310102 Procedures 0-SO-68-3 Pressurizer Pressure Control Revision 37 71111.18 Calculations 47A43502008 Calculation for pipe support 47A435-2-8 Revision 1 MDQ0020632019000316 Flow Characteristics of SQN-2-2019-063-001, Safety Revision 0 Injection Continuous Pressure Relief Line to Centrifugal Charging Pump Suction SCG-4M-00212 Qualification of CCP and Absorber per TMOD SQN-1- Revision 13 D 2018-062-001 Engineering SQN-1-2018-062-001 Install Tuned Vibration Damper on the 1A-A Charging Revision 0 Changes Pump SQN-2-2019-063-001 Temporary Modification - Safety Injection System Revision 1 Continuous Pressure Relief Line Procedures NPG-SPP-09.3 Plant Modifications and Engineering Change Control Revision 30 NPG-SPP-09.3 IP-ENG- Standard Design Process Revision 0 001 NPG-SPP-09.5 Temporary Modifications - Temporary Configuration Revision 15 Changes Work Orders 119853291; 119890013; 20196052; 120222735; 20408521, 120408522, 20408523 71111.19 Procedures 0-MI-EMV-317-146.0 Inspection and Preventive Maintenance of Limitorque Revision 51 Motor Operators Maintenance Instruction 1-PI-ICC-001-03A.1 Calibration of Steam Generator Loop 1 Steam Revision 21 Flow/Feed Flow Mismatch Channel I Rack 3 Loops 1- F-1-3A (F-512) and 1-F-3-35A (F-510) 1-SI-ICC-001-02A.1 Channel Calibration of Steam Generator Loop 1 Revision 22 Steam Pressure Channel I Rack 3 Loop 1-P-1-2A (P- 514) 1-SI-ICC-001-09A.1 Channel Calibration of Steam Generator Loop 2 Revision 20 Steam Pressure Channel I Rack 3 Loop 1-P-1-9A (P- 24) Inspection Type Designation Description or Title Revision or Procedure Date 1-SI-ICC-030-045.1 Channel Calibration of Containment Pressure Channel Revision 20 I Rack 3 Loop 1-P-30-45 (P-937) 2-SI-SXP-072-201.B Containment Spray Pump 2B-B Performance Test Revision 18 MMTP-144 Motor Operated Valve Diagnostic Testing Revision 2 Work Orders 119970546 Machine rough head castings into finished condenser 06/15/2019 heads 71111.22 Procedures 0-GO-16 System Operability Checklist Revision 70 0-SO-82-1 Diesel Generator 1A-A Revision 60 0PI-EDG-082-DAQ.0 Installation and Removal of the DG Data Acquisition Revision 11 System 1-SI-SXP-070-201.A Component Cooling Pump 1A-A Performance Test Revision 14 Work Orders 119534391 Emergency Gas Treatment System Filter Train B 06/13/2019 WO 119619175 CCS Heat Exchanger Performance Test - 2A1 and 05/08/2019 2A2 71114.06 Miscellaneous 2019 SQN May SAMG Emergency Preparedness Drill 05/15/2019 Procedures EPIP-1 Emergency Plan Classification Matrix Revision 54 SAG-1 Main Control Room Severe Accident Guideline Initial Revision 8 Response SAG-2 Main Control Room Severe Accident Guideline TSC Revision 5 Recommending Strategies 71152 Corrective Action CR 1397569 1,2-RM-90-400 Non-Functional Greater than 90 Days 03/13/2018 Documents CR 1461088 0-RM-90-133/140 Out of Service Greater than Thirty 10/29/2018 Days CR 1472608 Adverse Trend in Non-Functional Radiation Monitors 12/06/2018 CR 1484992 Anonymous condition report identified performance 01/24/2019 gaps in chemistry department management CR 1485018 OE - Part 21 - EN 53833 - Potential Defect in 01/24/2019 Weschler Instruments CR 1500304 Part 21 Issue for Engineering Review 03/19/2019 CR 1506204 Part 21 Material to be Returned to Westinghouse 04/09/2019 CR 1506831 Review Unusual Event at Brunswick which Required a 04/10/2019 Shutdown on 03/28/2019 71153 Procedures AOP-S.01 Main Feedwater Malfunctions Revision 28 Inspection Type Designation Description or Title Revision or Procedure Date EPM-4 User's Guide Revision 32 14|= =IP 71111.18|count=5}}

The inspectors evaluated the following post maintenance tests:

(1) WO 119758872, 2A2 CCS heat exchanger cleaning and inspection, on April 8, 2019
(2) WO 120454374, Replace LCP card and NVRAM in 1-R-3 on May 9, 2019
(3) WO 118341145, 2-MOVP-067-0126A, Perform EQ inspection and maintenance on May 21, 2019
(4) WO 120286121, 2B Containment Spray Pump, replace coupling due to high vibrations on May 29, 2019
(5) WO 119584204, Main Control Room A/C Chiller oil cooler cleaning and internal inspection on June 16, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IP Section 03.01)

Main article: IP 71111.22

1-SI-SXP-070-201.A, Component Cooling Pump 1A-A Performance Test on April 12, 2019 Surveillance Tests (other) (IP Section 03.01) ===

Main article: IP 15079
(1) 1-SI-OPS-082-007.A, Electrical Power System Diesel Generator 1A-A on April 29, 2019
(2) 2-PI-SFT-070-001.0, Performance Testing of Component Cooling Heat Exchangers 2A1, 2A2 on May 21, 2019
(3) 0-SI-SFT-065-001.B, Emergency Gas Treatment System Filter Train B on June 13, 2019

==71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample) Emergency preparedness drill conducted on May 15,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)==

Main article: IP 71114.06
(1) Unit 1 unplanned scrams per 7000 critical power hours (April 2018 - March 2019)
(2) Unit 2 unplanned scrams per 7000 critical power hours (April 2018 - March 2019)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)

(1) Unit 1 unplanned power changes per 7000 critical hours (April 2018 - March 2019)
(2) Unit 2 unplanned power changes per 7000 critical hours (April 2018 - March 2019)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 1 unplanned scrams with complications (April 2018 - March 2019)
(2) Unit 2 unplanned scrams with complications (April 2018 - March 2019)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Chemistry Department Safety Culture Concerns (CR 1484992).
(2) Corrective actions to address Part 21 2019-02 from Weschler Instruments (CR 1506204)
(3) Operating experience review of cryofit coupling failure at Brunswick Nuclear Station (CR 1506831)

Semiannual Trend Review (IP Section 02.02) ===

Main article: IP 71151

The inspectors reviewed the licensees corrective action program for potential adverse trends in non-functional radiation monitors that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Obstruction in Steam Generator Pressure Channel sense line results in engineered safeguard feature actuation system (ESFAS) channel inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.15 Systems NCV 05000327/2019002-01 Management Open/Closed The inspectors identified a green, non-cited violation of 10 CFR 50 Appendix B criterion XVI when the licensee failed to ensure the pressure instrumentation sense line for a steam generator pressure protection channel transmitter was not obstructed. Specifically, identified blockages in the sense line were not cleared and resulted in an inoperable ESFAS channel.

Description:

On April 14, 2019, Unit 1 reactor tripped on low steam generator level following the loss of a main feedwater pump. During the post trip review of this transient, the licensee noted that, following rapid pressure changes, one of the loop 3 steam generator pressure indicators, 1-PT-1-23, was lagging the indication of other steam generator pressure transmitters.

Specifically, the licensee noted pressure indication on the steam generators (except for 1-PT-1-23) increased from approximately 880 psig to 920 psig (40 psig) in less than a second and then remained steady for over a second while 1-PT-1-23 slowly increased by 16 psig over the same time period. Similarly, when steam generator pressures later increased approximately 60 psig in less than a second, 1-PT-1-23 slowly increased by 7 psig in the same time period.

The required response times for the steam pressure channel is 0.028 seconds. 1-PT-1-23 is used to monitor loop 3 steam line pressure and is one of three transmitters that are used with their instrument loops to provide the two-out-of-three (per steam line) logic required by Technical Specifications for Safety Injection and Steam Line Isolation. Due to this observed delayed response, operators declared 1-PT-1-23 inoperable.

It should be noted that, until the time of the trip on April 15, 2019, the licensee considered 1-PT-1-23 operable based on acceptable channel checks and calibrations. Prompted by questions raised by the inspectors, the licensee reviewed past operating experience which identified similar behavior of 1-PT-1-23 in 2015; this behavior was not recognized at that time and no corrective actions were taken. Plugging of steam generator pressure transmitter sense lines had been previously identified at Sequoyah. Condition Report (CR) 915880 was written in July 2014 documenting that steam generator instrument sense lines had been found plugged or partially plugged and erratic measurements had been attributed to partial sense line plugging. Actions were generated in the licensee's corrective action program to clear 1-PT-1-23 sense line to remove corrosion products during the upcoming refueling outage (1R20) and setup repetitive work orders for performance of this action. These actions were not performed.

Corrective Actions: 1-PT-1-23 was removed from service and the sense line was rodded out to remove accumulated material. 1-PT-1-23 was returned to operable status on April 16, 2019.

Corrective Action References: CR 1507948, CR 915880, WO 120407126, WO 116483457, PER 915889-003

Performance Assessment:

Performance Deficiency: The licensees failure to ensure identified blockages in the instrumentation sense line for a steam generator pressure protection channel transmitter were removed was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone. Specifically, identified blockages in 1-PT-1-23 sense line were not cleared and resulted in an inoperable engineered safeguard feature actuation system (ESFAS) channel.

Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The finding screened to green because all four questions in Exhibit 2, "Mitigating Systems Screening Questions" were answered "no".

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. The licensee created corrective action work orders several years prior to the event to clear the steam generator pressure transmitter sense lines. However, the work management process did not prioritize the execution of this work and these work orders were never performed.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criteria XVI, Corrective Actions, requires, in part, that measures be established to assure conditions adverse to quality are promptly identified and corrected. Contrary to the above, from November 23, 2015 until April 14, 2019, the measures established by the licensee failed to correct an identified condition adverse to quality. Specifically, the licensee identified a condition adverse to quality, obstruction of a steam generator pressure transmitter sense line, but did not take action to correct the condition.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On July 17, 2019, the inspectors presented the integrated inspection results to Mr. Matt Rasmussen and other members of the licensee staff.

THIRD PARTY REVIEWS Inspectors reviewed Institute of Nuclear Power Operations report that was issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.01 Procedures AOP-P.01 Loss of Offsite Power Revision 39 AOP-P.07 Degraded Grid or Abnormal Voltage Conditions Revision 15 NPG-SPP-07.16 On Line Work Control Power Systems Alerts/Offsite Revision 6 Power 71111.04 Miscellaneous SQN U1 Protected Equipment List 04/30/2019 0-PE-2019 Protected equipment clearance for 2-IV vital inverter 04/29/2019 and No. IV vital charger maintenance Procedures 0-SI-OPS-082-007.W AC Electrical Power Source Operability Verification Revision 45 2-SO-70-1 Component Cooling Water System "A" Train Revision 49 71111.04S Corrective Action CR 1332919 Fire Protection System Pressure Decline 08/28/2017 Documents CR 1445092 Poor Overall System Health on HPFP (026) Yard Ring 09/05/2018 Header Valves Miscellaneous SQN-DC-V-43.0 Sequoyah Nuclear Plant - High Pressure Fire Revision 9 Protection Water Supply System System Health Report System 26 - Fire Protection 1st Quarter Scorecard 2019 Work Orders 115815343; 119405060; 119405058; 1194045538 71111.05Q Fire Plans AUX-0-669-00 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 4 669 AUX-0-734-00 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 4 734 AUX-0-734-01 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 10 734 Unit 1 Side AUX-0-734-02 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 9 734 Unit 2 Side AUX-0-759-01 Auxiliary Building Elevation 759 Unit 1 Side Revision 6 AUX-0-759-02 Auxiliary Building Elevation 759 Unit 2 Side Revision 6 DGB-0-722-00 Fire Protection Pre-Fire Plans Diesel Generator Revision 7 Building El. - 722 DGB-0-740.5-00 Fire Protection Pre-Fire Plans Diesel Generator Revision 5 Building - El. 740.5 Inspection Type Designation Description or Title Revision or Procedure Date ERCW-0-688-00 Fire Protection Pre-Fire Plans ERCW Building - El. Revision 2 688 ERCW-0-704-00 Fire Protection Pre-Fire Plans ERCW Building - El. Revision 2 704 ERCW-0-720-00 Fire Protection Pre-Fire Plans ERCW Building - El. Revision 3 20 Procedures NPG-SPP-18.4.7 Control of Transient Combustibles Revision 13 71111.11Q Miscellaneous SEG OPL273S1908 RCS Leak, LOCA, ES-1.2, Loss of Sump Recirc 01/10/2019 Procedures 0-GO-6 Power Reduction From 30% Reactor Power to Hot Revision 64 Standby 0-SI-NUC-000-038.0 Shutdown Margin Revision 105 71111.12 Corrective Action CR 1508008 OE - Part 21 Ametek Solidstate Controls Inverters 04/15/2019 Documents CR 1508784 SQN Supply Chain Request a Part 21 Evaluation 04/17/2019 CR 1508834 Loss of 1A1 Main Feed Pump Lube Oil Pump Results 04/15/2019 in Trip of 1A Main Feed Pump Turbine CR 1513554 Maintenance Rule Functional Failure of 1A1 Main 05/03/2019 Feed Pump Main Oil Pump Motor Miscellaneous CDE 3062 1A Main Feedwater Pump Trip and Balance of Plant 04/14/2019 Runback Procedures NPG-SPP-03.4 Maintenance Rule Performance Indicator Monitoring, Revision 3 Trending, and Reporting - 10CFR50.65 TI-4 Maintenance Rule Performance Indicator Monitoring, Revision 32 Trending, and Reporting - 10CFR50.65 71111.13 0-GO-16 System Operability Checklists Revision 24 NPG-SPP-07.3.4 Protected Equipment Revision 5 71111.15 Corrective Action CR 1310102 1 minute and 4 seconds of gas observed during 06/22/2017 Documents performance of 1A-A SI pump discharge piping vent CR 1514732 ACMP SO-19-14 U2 PORV Tailpipe Temperature 05/07/2019 Change Drawings 2-47W610-3-1 Mechanical Control Diagram Main & Aux Feedwater Revision 21 Sys 2-47W610-3-5 Mechanical Control Diagram Main & Aux Feedwater Revision 5 Sys Inspection Type Designation Description or Title Revision or Procedure Date 2-47W611-99-6 Mechanical Logic Diagram Reactor Protection System Revision 3 Operability Past Operability Evaluation for CR 07/06/2017 Evaluations 1310089/1310095/1310102 Procedures 0-SO-68-3 Pressurizer Pressure Control Revision 37 71111.18 Calculations 47A43502008 Calculation for pipe support 47A435-2-8 Revision 1 MDQ0020632019000316 Flow Characteristics of SQN-2-2019-063-001, Safety Revision 0 Injection Continuous Pressure Relief Line to Centrifugal Charging Pump Suction SCG-4M-00212 Qualification of CCP and Absorber per TMOD SQN-1- Revision 13 D 2018-062-001 Engineering SQN-1-2018-062-001 Install Tuned Vibration Damper on the 1A-A Charging Revision 0 Changes Pump SQN-2-2019-063-001 Temporary Modification - Safety Injection System Revision 1 Continuous Pressure Relief Line Procedures NPG-SPP-09.3 Plant Modifications and Engineering Change Control Revision 30 NPG-SPP-09.3 IP-ENG- Standard Design Process Revision 0 001 NPG-SPP-09.5 Temporary Modifications - Temporary Configuration Revision 15 Changes Work Orders 119853291; 119890013; 20196052; 120222735; 20408521, 120408522, 20408523 71111.19 Procedures 0-MI-EMV-317-146.0 Inspection and Preventive Maintenance of Limitorque Revision 51 Motor Operators Maintenance Instruction 1-PI-ICC-001-03A.1 Calibration of Steam Generator Loop 1 Steam Revision 21 Flow/Feed Flow Mismatch Channel I Rack 3 Loops 1- F-1-3A (F-512) and 1-F-3-35A (F-510) 1-SI-ICC-001-02A.1 Channel Calibration of Steam Generator Loop 1 Revision 22 Steam Pressure Channel I Rack 3 Loop 1-P-1-2A (P- 514) 1-SI-ICC-001-09A.1 Channel Calibration of Steam Generator Loop 2 Revision 20 Steam Pressure Channel I Rack 3 Loop 1-P-1-9A (P- 24) Inspection Type Designation Description or Title Revision or Procedure Date 1-SI-ICC-030-045.1 Channel Calibration of Containment Pressure Channel Revision 20 I Rack 3 Loop 1-P-30-45 (P-937) 2-SI-SXP-072-201.B Containment Spray Pump 2B-B Performance Test Revision 18 MMTP-144 Motor Operated Valve Diagnostic Testing Revision 2 Work Orders 119970546 Machine rough head castings into finished condenser 06/15/2019 heads 71111.22 Procedures 0-GO-16 System Operability Checklist Revision 70 0-SO-82-1 Diesel Generator 1A-A Revision 60 0PI-EDG-082-DAQ.0 Installation and Removal of the DG Data Acquisition Revision 11 System 1-SI-SXP-070-201.A Component Cooling Pump 1A-A Performance Test Revision 14 Work Orders 119534391 Emergency Gas Treatment System Filter Train B 06/13/2019 WO 119619175 CCS Heat Exchanger Performance Test - 2A1 and 05/08/2019 2A2 71114.06 Miscellaneous 2019 SQN May SAMG Emergency Preparedness Drill 05/15/2019 Procedures EPIP-1 Emergency Plan Classification Matrix Revision 54 SAG-1 Main Control Room Severe Accident Guideline Initial Revision 8 Response SAG-2 Main Control Room Severe Accident Guideline TSC Revision 5 Recommending Strategies 71152 Corrective Action CR 1397569 1,2-RM-90-400 Non-Functional Greater than 90 Days 03/13/2018 Documents CR 1461088 0-RM-90-133/140 Out of Service Greater than Thirty 10/29/2018 Days CR 1472608 Adverse Trend in Non-Functional Radiation Monitors 12/06/2018 CR 1484992 Anonymous condition report identified performance 01/24/2019 gaps in chemistry department management CR 1485018 OE - Part 21 - EN 53833 - Potential Defect in 01/24/2019 Weschler Instruments CR 1500304 Part 21 Issue for Engineering Review 03/19/2019 CR 1506204 Part 21 Material to be Returned to Westinghouse 04/09/2019 CR 1506831 Review Unusual Event at Brunswick which Required a 04/10/2019 Shutdown on 03/28/2019 71153 Procedures AOP-S.01 Main Feedwater Malfunctions Revision 28 Inspection Type Designation Description or Title Revision or Procedure Date EPM-4 User's Guide Revision 32

14]]

[[IP sample::=

=IP 71111.18|count=5}}

The inspectors evaluated the following post maintenance tests:

(1) WO 119758872, 2A2 CCS heat exchanger cleaning and inspection, on April 8, 2019
(2) WO 120454374, Replace LCP card and NVRAM in 1-R-3 on May 9, 2019
(3) WO 118341145, 2-MOVP-067-0126A, Perform EQ inspection and maintenance on May 21, 2019
(4) WO 120286121, 2B Containment Spray Pump, replace coupling due to high vibrations on May 29, 2019
(5) WO 119584204, Main Control Room A/C Chiller oil cooler cleaning and internal inspection on June 16, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IP Section 03.01)

Main article: IP 71111.22

1-SI-SXP-070-201.A, Component Cooling Pump 1A-A Performance Test on April 12, 2019 Surveillance Tests (other) (IP Section 03.01) ===

Main article: IP 15079
(1) 1-SI-OPS-082-007.A, Electrical Power System Diesel Generator 1A-A on April 29, 2019
(2) 2-PI-SFT-070-001.0, Performance Testing of Component Cooling Heat Exchangers 2A1, 2A2 on May 21, 2019
(3) 0-SI-SFT-065-001.B, Emergency Gas Treatment System Filter Train B on June 13, 2019

==71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample) Emergency preparedness drill conducted on May 15,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below: IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)==

Main article: IP 71114.06
(1) Unit 1 unplanned scrams per 7000 critical power hours (April 2018 - March 2019)
(2) Unit 2 unplanned scrams per 7000 critical power hours (April 2018 - March 2019)

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2 Samples)

(1) Unit 1 unplanned power changes per 7000 critical hours (April 2018 - March 2019)
(2) Unit 2 unplanned power changes per 7000 critical hours (April 2018 - March 2019)

IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)

(1) Unit 1 unplanned scrams with complications (April 2018 - March 2019)
(2) Unit 2 unplanned scrams with complications (April 2018 - March 2019)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) Chemistry Department Safety Culture Concerns (CR 1484992).
(2) Corrective actions to address Part 21 2019-02 from Weschler Instruments (CR 1506204)
(3) Operating experience review of cryofit coupling failure at Brunswick Nuclear Station (CR 1506831)

Semiannual Trend Review (IP Section 02.02) ===

Main article: IP 71151

The inspectors reviewed the licensees corrective action program for potential adverse trends in non-functional radiation monitors that might be indicative of a more significant safety issue.

INSPECTION RESULTS

Obstruction in Steam Generator Pressure Channel sense line results in engineered safeguard feature actuation system (ESFAS) channel inoperability Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.5] - Work 71111.15 Systems NCV 05000327/2019002-01 Management Open/Closed The inspectors identified a green, non-cited violation of 10 CFR 50 Appendix B criterion XVI when the licensee failed to ensure the pressure instrumentation sense line for a steam generator pressure protection channel transmitter was not obstructed. Specifically, identified blockages in the sense line were not cleared and resulted in an inoperable ESFAS channel.

Description:

On April 14, 2019, Unit 1 reactor tripped on low steam generator level following the loss of a main feedwater pump. During the post trip review of this transient, the licensee noted that, following rapid pressure changes, one of the loop 3 steam generator pressure indicators, 1-PT-1-23, was lagging the indication of other steam generator pressure transmitters.

Specifically, the licensee noted pressure indication on the steam generators (except for 1-PT-1-23) increased from approximately 880 psig to 920 psig (40 psig) in less than a second and then remained steady for over a second while 1-PT-1-23 slowly increased by 16 psig over the same time period. Similarly, when steam generator pressures later increased approximately 60 psig in less than a second, 1-PT-1-23 slowly increased by 7 psig in the same time period.

The required response times for the steam pressure channel is 0.028 seconds. 1-PT-1-23 is used to monitor loop 3 steam line pressure and is one of three transmitters that are used with their instrument loops to provide the two-out-of-three (per steam line) logic required by Technical Specifications for Safety Injection and Steam Line Isolation. Due to this observed delayed response, operators declared 1-PT-1-23 inoperable.

It should be noted that, until the time of the trip on April 15, 2019, the licensee considered 1-PT-1-23 operable based on acceptable channel checks and calibrations. Prompted by questions raised by the inspectors, the licensee reviewed past operating experience which identified similar behavior of 1-PT-1-23 in 2015; this behavior was not recognized at that time and no corrective actions were taken. Plugging of steam generator pressure transmitter sense lines had been previously identified at Sequoyah. Condition Report (CR) 915880 was written in July 2014 documenting that steam generator instrument sense lines had been found plugged or partially plugged and erratic measurements had been attributed to partial sense line plugging. Actions were generated in the licensee's corrective action program to clear 1-PT-1-23 sense line to remove corrosion products during the upcoming refueling outage (1R20) and setup repetitive work orders for performance of this action. These actions were not performed.

Corrective Actions: 1-PT-1-23 was removed from service and the sense line was rodded out to remove accumulated material. 1-PT-1-23 was returned to operable status on April 16, 2019.

Corrective Action References: CR 1507948, CR 915880, WO 120407126, WO 116483457, PER 915889-003

Performance Assessment:

Performance Deficiency: The licensees failure to ensure identified blockages in the instrumentation sense line for a steam generator pressure protection channel transmitter were removed was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone. Specifically, identified blockages in 1-PT-1-23 sense line were not cleared and resulted in an inoperable engineered safeguard feature actuation system (ESFAS) channel.

Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. The finding screened to green because all four questions in Exhibit 2, "Mitigating Systems Screening Questions" were answered "no".

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. The licensee created corrective action work orders several years prior to the event to clear the steam generator pressure transmitter sense lines. However, the work management process did not prioritize the execution of this work and these work orders were never performed.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criteria XVI, Corrective Actions, requires, in part, that measures be established to assure conditions adverse to quality are promptly identified and corrected. Contrary to the above, from November 23, 2015 until April 14, 2019, the measures established by the licensee failed to correct an identified condition adverse to quality. Specifically, the licensee identified a condition adverse to quality, obstruction of a steam generator pressure transmitter sense line, but did not take action to correct the condition.

Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On July 17, 2019, the inspectors presented the integrated inspection results to Mr. Matt Rasmussen and other members of the licensee staff.

THIRD PARTY REVIEWS Inspectors reviewed Institute of Nuclear Power Operations report that was issued during the inspection period.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 71111.01 Procedures AOP-P.01 Loss of Offsite Power Revision 39 AOP-P.07 Degraded Grid or Abnormal Voltage Conditions Revision 15 NPG-SPP-07.16 On Line Work Control Power Systems Alerts/Offsite Revision 6 Power 71111.04 Miscellaneous SQN U1 Protected Equipment List 04/30/2019 0-PE-2019 Protected equipment clearance for 2-IV vital inverter 04/29/2019 and No. IV vital charger maintenance Procedures 0-SI-OPS-082-007.W AC Electrical Power Source Operability Verification Revision 45 2-SO-70-1 Component Cooling Water System "A" Train Revision 49 71111.04S Corrective Action CR 1332919 Fire Protection System Pressure Decline 08/28/2017 Documents CR 1445092 Poor Overall System Health on HPFP (026) Yard Ring 09/05/2018 Header Valves Miscellaneous SQN-DC-V-43.0 Sequoyah Nuclear Plant - High Pressure Fire Revision 9 Protection Water Supply System System Health Report System 26 - Fire Protection 1st Quarter Scorecard 2019 Work Orders 115815343; 119405060; 119405058; 1194045538 71111.05Q Fire Plans AUX-0-669-00 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 4 669 AUX-0-734-00 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 4 734 AUX-0-734-01 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 10 734 Unit 1 Side AUX-0-734-02 Fire Protection Pre-Fire Plans Auxiliary Building - El. Revision 9 734 Unit 2 Side AUX-0-759-01 Auxiliary Building Elevation 759 Unit 1 Side Revision 6 AUX-0-759-02 Auxiliary Building Elevation 759 Unit 2 Side Revision 6 DGB-0-722-00 Fire Protection Pre-Fire Plans Diesel Generator Revision 7 Building El. - 722 DGB-0-740.5-00 Fire Protection Pre-Fire Plans Diesel Generator Revision 5 Building - El. 740.5 Inspection Type Designation Description or Title Revision or Procedure Date ERCW-0-688-00 Fire Protection Pre-Fire Plans ERCW Building - El. Revision 2 688 ERCW-0-704-00 Fire Protection Pre-Fire Plans ERCW Building - El. Revision 2 704 ERCW-0-720-00 Fire Protection Pre-Fire Plans ERCW Building - El. Revision 3 20 Procedures NPG-SPP-18.4.7 Control of Transient Combustibles Revision 13 71111.11Q Miscellaneous SEG OPL273S1908 RCS Leak, LOCA, ES-1.2, Loss of Sump Recirc 01/10/2019 Procedures 0-GO-6 Power Reduction From 30% Reactor Power to Hot Revision 64 Standby 0-SI-NUC-000-038.0 Shutdown Margin Revision 105 71111.12 Corrective Action CR 1508008 OE - Part 21 Ametek Solidstate Controls Inverters 04/15/2019 Documents CR 1508784 SQN Supply Chain Request a Part 21 Evaluation 04/17/2019 CR 1508834 Loss of 1A1 Main Feed Pump Lube Oil Pump Results 04/15/2019 in Trip of 1A Main Feed Pump Turbine CR 1513554 Maintenance Rule Functional Failure of 1A1 Main 05/03/2019 Feed Pump Main Oil Pump Motor Miscellaneous CDE 3062 1A Main Feedwater Pump Trip and Balance of Plant 04/14/2019 Runback Procedures NPG-SPP-03.4 Maintenance Rule Performance Indicator Monitoring, Revision 3 Trending, and Reporting - 10CFR50.65 TI-4 Maintenance Rule Performance Indicator Monitoring, Revision 32 Trending, and Reporting - 10CFR50.65 71111.13 0-GO-16 System Operability Checklists Revision 24 NPG-SPP-07.3.4 Protected Equipment Revision 5 71111.15 Corrective Action CR 1310102 1 minute and 4 seconds of gas observed during 06/22/2017 Documents performance of 1A-A SI pump discharge piping vent CR 1514732 ACMP SO-19-14 U2 PORV Tailpipe Temperature 05/07/2019 Change Drawings 2-47W610-3-1 Mechanical Control Diagram Main & Aux Feedwater Revision 21 Sys 2-47W610-3-5 Mechanical Control Diagram Main & Aux Feedwater Revision 5 Sys Inspection Type Designation Description or Title Revision or Procedure Date 2-47W611-99-6 Mechanical Logic Diagram Reactor Protection System Revision 3 Operability Past Operability Evaluation for CR 07/06/2017 Evaluations 1310089/1310095/1310102 Procedures 0-SO-68-3 Pressurizer Pressure Control Revision 37 71111.18 Calculations 47A43502008 Calculation for pipe support 47A435-2-8 Revision 1 MDQ0020632019000316 Flow Characteristics of SQN-2-2019-063-001, Safety Revision 0 Injection Continuous Pressure Relief Line to Centrifugal Charging Pump Suction SCG-4M-00212 Qualification of CCP and Absorber per TMOD SQN-1- Revision 13 D 2018-062-001 Engineering SQN-1-2018-062-001 Install Tuned Vibration Damper on the 1A-A Charging Revision 0 Changes Pump SQN-2-2019-063-001 Temporary Modification - Safety Injection System Revision 1 Continuous Pressure Relief Line Procedures NPG-SPP-09.3 Plant Modifications and Engineering Change Control Revision 30 NPG-SPP-09.3 IP-ENG- Standard Design Process Revision 0 001 NPG-SPP-09.5 Temporary Modifications - Temporary Configuration Revision 15 Changes Work Orders 119853291; 119890013; 20196052; 120222735; 20408521, 120408522, 20408523 71111.19 Procedures 0-MI-EMV-317-146.0 Inspection and Preventive Maintenance of Limitorque Revision 51 Motor Operators Maintenance Instruction 1-PI-ICC-001-03A.1 Calibration of Steam Generator Loop 1 Steam Revision 21 Flow/Feed Flow Mismatch Channel I Rack 3 Loops 1- F-1-3A (F-512) and 1-F-3-35A (F-510) 1-SI-ICC-001-02A.1 Channel Calibration of Steam Generator Loop 1 Revision 22 Steam Pressure Channel I Rack 3 Loop 1-P-1-2A (P- 514) 1-SI-ICC-001-09A.1 Channel Calibration of Steam Generator Loop 2 Revision 20 Steam Pressure Channel I Rack 3 Loop 1-P-1-9A (P- 24) Inspection Type Designation Description or Title Revision or Procedure Date 1-SI-ICC-030-045.1 Channel Calibration of Containment Pressure Channel Revision 20 I Rack 3 Loop 1-P-30-45 (P-937) 2-SI-SXP-072-201.B Containment Spray Pump 2B-B Performance Test Revision 18 MMTP-144 Motor Operated Valve Diagnostic Testing Revision 2 Work Orders 119970546 Machine rough head castings into finished condenser 06/15/2019 heads 71111.22 Procedures 0-GO-16 System Operability Checklist Revision 70 0-SO-82-1 Diesel Generator 1A-A Revision 60 0PI-EDG-082-DAQ.0 Installation and Removal of the DG Data Acquisition Revision 11 System 1-SI-SXP-070-201.A Component Cooling Pump 1A-A Performance Test Revision 14 Work Orders 119534391 Emergency Gas Treatment System Filter Train B 06/13/2019 WO 119619175 CCS Heat Exchanger Performance Test - 2A1 and 05/08/2019 2A2 71114.06 Miscellaneous 2019 SQN May SAMG Emergency Preparedness Drill 05/15/2019 Procedures EPIP-1 Emergency Plan Classification Matrix Revision 54 SAG-1 Main Control Room Severe Accident Guideline Initial Revision 8 Response SAG-2 Main Control Room Severe Accident Guideline TSC Revision 5 Recommending Strategies 71152 Corrective Action CR 1397569 1,2-RM-90-400 Non-Functional Greater than 90 Days 03/13/2018 Documents CR 1461088 0-RM-90-133/140 Out of Service Greater than Thirty 10/29/2018 Days CR 1472608 Adverse Trend in Non-Functional Radiation Monitors 12/06/2018 CR 1484992 Anonymous condition report identified performance 01/24/2019 gaps in chemistry department management CR 1485018 OE - Part 21 - EN 53833 - Potential Defect in 01/24/2019 Weschler Instruments CR 1500304 Part 21 Issue for Engineering Review 03/19/2019 CR 1506204 Part 21 Material to be Returned to Westinghouse 04/09/2019 CR 1506831 Review Unusual Event at Brunswick which Required a 04/10/2019 Shutdown on 03/28/2019 71153 Procedures AOP-S.01 Main Feedwater Malfunctions Revision 28 Inspection Type Designation Description or Title Revision or Procedure Date EPM-4 User's Guide Revision 32 14| ]]

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