IR 05000327/2020006
| ML21062A127 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/03/2021 |
| From: | Tom Stephen Division Reactor Projects II |
| To: | Jim Barstow Tennessee Valley Authority |
| References | |
| IR 2020006 | |
| Download: ML21062A127 (7) | |
Text
March 3, 2021
SUBJECT:
ANNUAL ASSESSMENT LETTER FOR SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - REPORT 05000327/2020006 AND 05000328/2020006
Dear Mr. Barstow:
The NRC has completed its end-of-cycle performance assessment of Sequoyah Nuclear Plant, Units 1and 2, reviewing performance indicators (PIs), inspection results, and enforcement actions from January 1, 2020 through December 31, 2020. This letter informs you of the NRCs assessment of your facility during this period and its plans for future inspections at your facility.
The NRC concluded that overall performance at your facility was consistent with ensuring public health and safety. The baseline inspection program was completed at your facility as defined in Inspection Manual Chapter 2515, Light-Water Reactor Inspection Program - Operations Phase.
The NRC determined the performance at Sequoyah Ferry Nuclear Plant, Units 1 and 2, during the most recent quarter was within the Licensee Response Column, the highest performance category of the NRCs Reactor Oversight Process (ROP) Action Matrix, because all inspection findings had very low safety significance (i.e., Green), and all PIs were within the expected range (i.e., Green). Therefore, the NRC plans to conduct ROP baseline inspections at your facility.
The enclosed inspection plan lists the inspections scheduled through December 31, 2022.
The NRC is providing the inspection plan to allow for the resolution of any scheduling conflicts and personnel availability issues. Routine inspections performed by resident inspectors are not included in the inspection plan. The inspections listed during the last twelve months of the inspection plan are tentative and may be revised. The NRC will contact you as soon as possible to discuss changes to the inspection plan should circumstances warrant any changes. In response to the COVID-19 public health emergency (PHE), the NRC is adjusting inspection plans and schedules in order to safeguard the health and safety of both NRC and your staffs while still effectively implementing the ROP. Each planned inspection is being carefully reviewed in order to determine if any portions of the inspection can be performed remotely, how best to perform on-site portions to minimize personnel health risks and adjust inspection schedules if needed. This is done in accordance with guidance contained in the February 1, 2021 memo, Calendar Year 2021 Inspection Guidance During COVID-19 Telework Restrictions (ADAMS Accession No. ML21027A274). For inspections requiring extensive coordination with offsite organizations, such as evaluated emergency preparedness exercises, NRC guidance and frequently asked questions for security and emergency preparedness can be found here: https://www.nrc.gov/about-nrc/covid-19/security-ep/. Similarly, the NRC has developed guidance if force-on-force inspections cannot be completed as scheduled due to an emergency, such as the COVID-19 PHE. These changes help ensure the health and safety of both NRC and licensee staff while maintaining the NRCs important safety and security mission during the COVID-19 PHE. The attached inspection plan is accurate on the date of issuance but remains subject to change based on approval of potential exemption requests or other changes needed due to changing conditions during the COVID-19 PHE. NRC staff will contact your appropriate regulatory affairs staff in order to coordinate inspection planning and scheduling.
In addition to the ROP baseline inspections, we also plan to conduct an Initial License Examination in 2021.
Based on investigations completed in late 2019 and early 2020 involving two allegations of discrimination, the NRC issued TVA a Notice of Violation (NOV) on August 24, 2020. The NOV citied three Severity Level (SL) II and one SL I violation, and proposed imposition of a $606,942 Civil Penalty (CP) (ADAMS Accession Number ML20218A483). TVA responded to the NOV in a letter dated September 23, 2020 and denied all four violations (ADAMS Accession Number ML20274A014). Subsequently, the NRC issued an order imposing the CP to TVA on October 29, 2020 (ADAMS Accession Number ML20297A525).
On November 30, 2020, TVA requested a hearing on the substantiated cases of discrimination; that hearing will occur later in calendar year 2021. Therefore, the NRC will defer scheduling inspection procedure 92722, Follow up Inspection for Any Severity Level I or II Traditional Enforcement Violation or for Two or More Severity Level III Traditional Enforcement Violations in a 12 Month Period, until the matter is settled.
During end-of-cycle assessment meetings that follow issuance of escalated enforcement discrimination violations, the NRC is required to evaluate whether a theme exists in the safety conscious work environment (SCWE) cross-cutting area that could necessitate corrective actions by the licensee and greater oversight by the NRC. Inspection Manual Chapter 0305, Operating Reactor Assessment Program, states that a cross-cutting theme in the area of SCWE exists if the licensee has received correspondence from the NRC that transmitted (1) a SL I, II, or III enforcement action that involved discrimination or (2) a confirmatory order that involved discrimination. Although the NRCs process suggests that a SCWE theme exists due to the enforcement actions issued on August 24, 2020, we note that the incidents leading to the proposed enforcement actions are not indicative of current performance at Sequoyah in this area.
The NRC has conducted multiple safety culture inspections at each TVA site since 2018 and has determined that TVA has made sufficient progress in addressing SCWE concerns and has demonstrated an improving safety culture since 2018. 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, and Requests for Withholding.
Please contact me at (404) 997-4703 with any questions you may have regarding this letter.
Sincerely,
/RA/
Thomas A. Stephen, Chief Reactor Projects Branch 5 Division of Reactor Projects
Docket Nos.: 05000327 and 05000328 License Nos.: DPR-77 and DPR-79
Enclosure:
Sequoyah Inspection/Activity Plan (01/01/2021-12/31/2022)
cc Distribution via ListServ
ML21062A127 OFFICE RII/DRP RII/DRP RII/DRP
NAME S. Ninh D. Hardage T. Stephen
DATE 3/01/2021 3/01/2021 3/03/2021
Sequoyah 03/01/2021 - 12/31/2022 Unit Start End Activity CAC Title Staff Count EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS
1, 2 03/08/2021 03/12/2021 IP 71111.17T 000709 Evaluations of Changes, Tests, and Experiments SECURITY BASELINE INSPECTION
1, 2 03/22/2021 03/26/2021 IP 71130.02 000734 Access Control 1, 2 03/22/2021 03/26/2021 IP 71130.04 000736 Equipment Performance, Testing, and Maintenance 1, 2 03/22/2021 03/26/2021 IP 71130.07 000739 Security Training 1, 2 03/22/2021 03/26/2021 IP 71130.09 001656 Security Plan Changes 1, 2 03/22/2021 03/26/2021 IP 71151 001338 Performance Indicator Verification UNIT 1 IN-SERVICE INSPECTION
1 05/10/2021 05/14/2021 IP 71111.08P 000702 Inservice Inspection Activities (PWR)
PROBLEM IDENTIFICATION & RESOLUTION
1, 2 06/07/2021 06/11/2021 IP 71152B 000747 Problem Identification and Resolution 1, 2 06/21/2021 06/25/2021 IP 71152B 000747 Problem Identification and Resolution RP PUBLIC RAD SAFETY AND TRANSPORTATION INSPECTION
1, 2 07/12/2021 07/16/2021 IP 71124.06 000730 Radioactive Gaseous and Liquid Effluent Treatment 1, 2 07/12/2021 07/16/2021 IP 71124.07 000731 Radiological Environmental Monitoring Program 1, 2 07/12/2021 07/16/2021 IP 71124.08 000732 Radioactive Solid Waste Processing & Radioactive Material Handling, Storage, &
Transportation 1, 2 07/12/2021 07/16/2021 IP 71151 000746 Performance Indicator Verification TRIENNIAL HEAT SINK PERFORMANCE
1, 2 08/02/2021 08/06/2021 IP 71111.07T 000700 Heat Sink Performance EMERGENCY PREPAREDNESS EXERCISE INSPECTION
1, 2 09/06/2021 09/10/2021 IP 71114.01 000716 Exercise Evaluation 1, 2 09/06/2021 09/10/2021 IP 71114.04 000719 Emergency Action Level and Emergency Plan Changes 1, 2 09/06/2021 09/10/2021 IP 71114.08 000723 Exercise Evaluation Scenario Review 1, 2 09/06/2021 09/10/2021 IP 71151 001397 Performance Indicator Verification UNIT 2 IN-SERVICE INSPECTION
2 10/04/2021 10/08/2021 IP 71111.08P 000702 Inservice Inspection Activities (PWR)
Page 1 of 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
IP 22 Inspection Activity Plan Report
Sequoyah 03/01/2021 - 12/31/2022 Unit Start End Activity CAC Title Staff Count RP OCCUPATIONAL RAD SAFETY BASELINE INSPECTION
1, 2 10/04/2021 10/08/2021 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1, 2 10/04/2021 10/08/2021 IP 71124.02 000726 Occupational ALARA Planning and Controls 1, 2 10/04/2021 10/08/2021 IP 71151 000746 Performance Indicator Verification SECURITY BASELINE INSPECTION
1, 2 01/24/2022 01/28/2022 IP 71130.02 000734 Access Control 1, 2 01/24/2022 01/28/2022 IP 71130.09 001656 Security Plan Changes 1, 2 01/24/2022 01/28/2022 IP 71151 001338 Performance Indicator Verification DESIGN BASES ASSURANCE INSPECTION (TEAMS)
1, 2 02/28/2022 03/04/2022 IP 71111.21M 000713 Design Bases Assurance Inspection (Teams)
1, 2 03/14/2022 03/18/2022 IP 71111.21M 000713 Design Bases Assurance Inspection (Teams)
SEQUOYAH INITIAL LICENSE EXAM
1, 2 03/28/2022 04/01/2022 OV 000956 VALIDATION OF INITIAL LICENSE EXAMINATION (OV)
1, 2 05/02/2022 05/13/2022 EXAD 000500 LICENSE EXAM ADMINISTRATION (EXAD)
EMERGENCY PREPAREDNESS EXERCISE INSPECTION
1, 2 09/12/2022 09/16/2022 IP 71114.01 000716 Exercise Evaluation 1, 2 09/12/2022 09/16/2022 IP 71114.04 000719 Emergency Action Level and Emergency Plan Changes 1, 2 09/12/2022 09/16/2022 IP 71151 001397 Performance Indicator Verification MATERIAL CONTROL AND ACCOUNTABILITY
1, 2 10/01/2022 12/31/2022 IP 71130.11 000742 Material Control and Accounting (MC&A)
SEQUOYAH REQUAL INSPECTION
1, 2 10/03/2022 10/07/2022 IP 71111.11B 000704 Licensed Operator Requalification Program and Licensed Operator Performance UNIT 1 IN-SERVICE INSPECTION +SG
1 10/24/2022 10/28/2022 IP 71111.08P 000702 Inservice Inspection Activities (PWR)
RP OCCUPATIONAL RAD SAFETY BASELINE INSPECTION
1, 2 10/31/2022 11/04/2022 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1, 2 10/31/2022 11/04/2022 IP 71124.03 000727 In-Plant Airborne Radioactivity Control and Mitigation 1, 2 10/31/2022 11/04/2022 IP 71124.04 000728 Occupational Dose Assessment 1, 2 10/31/2022 11/04/2022 IP 71124.05 000729 Radiation Monitoring Instrumentation Page 2 of 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
IP 22 Inspection Activity Plan Report
Sequoyah 03/01/2021 - 12/31/2022 Unit Start End Activity CAC Title Staff Count RP OCCUPATIONAL RAD SAFETY BASELINE INSPECTION
1, 2 10/31/2022 11/04/2022 IP 71151 000746 Performance Indicator Verification 1, 2 11/14/2022 11/18/2022 IP 71124.01 000725 Radiological Hazard Assessment and Exposure Controls 1, 2 11/14/2022 11/18/2022 IP 71124.03 000727 In-Plant Airborne Radioactivity Control and Mitigation 1, 2 11/14/2022 11/18/2022 IP 71124.04 000728 Occupational Dose Assessment 1, 2 11/14/2022 11/18/2022 IP 71124.05 000729 Radiation Monitoring Instrumentation 1, 2 11/14/2022 11/18/2022 IP 71151 000746 Performance Indicator Verification Page 3 of 3 This report does not include INPO and OUTAGE activities.
This report shows only on-site and announced inspection procedures.
IP 22 Inspection Activity Plan Report