IR 05000327/2021011

Biennial Problem Identification and Resolution Inspection Report 05000327/2021011 and 05000328/2021011

ML21200A001
Person / Time
Site:	Sequoyah
Issue date:	07/19/2021
From:	Tom Stephen Reactor Projects Region 2 Branch 6
To:	Jim Barstow Tennessee Valley Authority
References
IR 2021011
Download: ML21200A001 (20)

Text

July 16, 2021

SUBJECT:

SEQUOYAH NUCLEAR PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000327/2021011 AND 05000328/2021011

Dear Mr. Barstow:

On June 24, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Sequoyah Nuclear Plant and discussed the results of this inspection with Mr. Chris Reneau, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.

Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection. 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 Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

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:

As stated

Inspection Report

Docket Numbers:

05000327 and 05000328

License Numbers:

DPR-77 and DPR-79

Report Numbers:

05000327/2021011 and 05000328/2021011

Licensee:

Tennessee Valley Authority

Facility:

Sequoyah Nuclear Plant

Location:

Soddy Daisy, TN 37379

Inspection Dates:

June 07, 2021 to June 24, 2021

Inspectors:

N. Childs, Resident Inspector

M. Kirk, Resident Inspector

S. Ninh, Senior Project Engineer

J. Seat, Project Engineer

Approved By:

Thomas A. Stephen, Chief

Reactor Projects Branch #5

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Sequoyah Nuclear Plant, 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

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.

• Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems.

• Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.

• Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Based on the samples reviewed, the team determined that the licensee's corrective action program (CAP) complied with regulatory requirements and self-imposed standards. The licensee's implementation of the CAP adequately supported nuclear safety.

1. Corrective Action Program Effectiveness

Problem Identification: The team determined that the licensee was generally effective in identifying problems and entering them into the CAP at the appropriate threshold. This conclusion was based upon the inspectors review of the requirements for initiating condition reports (CR) as prescribed by licensee procedure, NPG-SPP-22.300, "Corrective Action Program," and site management's expectation that employees are encouraged to initiate CRs. The inspection team observed licensee staff at the Plant Screening Committee (PSC)and Management Review Committee (MRC) meetings actively questioning and challenging CRs to ensure issues were adequately documented and entered into the CAP. Based on samples reviewed, the inspectors determined that licensee staff adequately trend equipment and programmatic issues at an appropriate level. The inspectors performed walkdowns, reviewed CRs, and system health and trend reports for the Component Cooling System (CCS), Emergency Diesel Generators, and Essential Raw Cooling Water (ERCW)

System. Based on reviews and system walkdowns, the inspectors determined that deficiencies were being identified and entered into the CAP. Overall, the team determined that issues were being identified and documented at the appropriate threshold.

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 prioritized and evaluated in accordance with the CAP requirements prescribed in procedure NPG-SPP-22.300. Based on reviews and observations, the inspectors determined that adequate consideration was given to system or component operability and associated plant risk. The inspectors reviewed causal analyses to ensure licensee staff appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. The inspectors determined that plant personnel had generally conducted cause evaluations in compliance with the CAP procedures and performed adequate levels of analysis based on the significance of the issue being evaluated. Overall, the licensee's process for evaluating and prioritizing issues supported nuclear safety.

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 corrective actions were effective, timely, and commensurate with the safety significance of the issues. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence. The inspectors reviewed CRs and effectiveness reviews, as applicable, to verify that the significant conditions adverse to quality had not recurred. Effectiveness reviews for corrective actions to preclude repetition (CAPR) were sufficient to ensure corrective actions were properly implemented and were effective. The inspectors reviewed corrective action documents for NRC findings issued since the last problem, identification, and resolution (PI&R) biennial inspection. The team determined that corrective actions completed or planned, including expected completion dates, were adequate to address the NRC findings.

2. Use of Operating Experience (OE)

Based on a review of selected documentation related to OE issues, the team determined that the licensee was effective in screening operating experience for applicability to the plant. Industry OE was evaluated at either the corporate or plant level depending on the source and type of document. Relevant information was forwarded to the applicable department for further action or informational purposes. Operating experience issues requiring action were entered into the CAP for tracking and closure. The team determined that the licensee's use of industry and NRC OE was effective, and the program adequately supported nuclear safety.

3. Self-Assessments and Audits

The team determined that the scopes of assessments and audits were adequate. Self-assessments were generally detailed and critical. The team verified that CRs were created to document areas for improvement and findings resulting from self-assessments, and that actions had been completed consistent with the staff recommendations. Audits of the quality assurance program appropriately assessed performance and identified areas for improvement. Generally, the licensee performed evaluations that were technically accurate.

4. Safety Conscious Work Environments (SCWE)

Based on interviews with plant staff and reviews of the employee concerns program (ECP),

CRs, and the latest safety culture assessment results, the inspectors found no evidence of challenges to the safety conscious work environment. Employees interviewed appeared willing to raise nuclear safety concerns through at least one of several means available.

EXIT MEETINGS AND DEBRIEFS

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

• On June 24, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Mr. Chris Reneau, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71152B

Corrective Action

Documents

1096744

1191019

246672

1364613

1376156

1383541

1393611

1396860

1404119

1404171

24070

1436447

1438327

1459288

1466649

1467085

1469779

1478023

1485220

1491999

1497144

1497873

1498586

1507644

1507948

1508834

1513074

1515689

1516260

20621

20726

22545

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

24521

26168

26428

27311

28237

28243

29074

1530154

1530159

1532058

1533146

1534118

1535543

1536556

1536791

1537213

1537226

1539112

1539126

1544222

1544227

1544846

1548593

1546981

1547878

1550548

1550552

1551560

1553230

1554178

1556233

1558970

1559230

1559287

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

1560185

1560409

1561136

1561202

1563833

1565699

1566459

1572651

1573093

1573472

1573726

1578600

1578708

1579205

1580587

1580779

1586184

1587965

1587974

1590030

1590551

1596820

1599699

1600942

1600953

1601743

1602795

1607309

1607353

1611217

1611705

1615005

1616525

1616533

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

1618274

20231

25313

25372

25456

26031

27192

27194

27752

28045

28188

29477

1634550

1636605

1639059

1641685

1641712

1641725

1641731

1646424

1646839

1647725

1649323

1649710

1651597

1651613

1652910

1656464

1656894

1659301

1670044

1673465

1679682

1679684

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

1679685

1680819

1683540

1687263

1689360

1690542

1691677

1699840

1516474

1516581

1516583

1517306

1518410

1554059

1554316

1557934

1565732

1580909

22043

1676122

1555831

1563326

1563420

1605671

1605726

1559894

1559882

1573190

22540

29694

1544976

1543380

1544977

1549710

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

1554245

1554234

1548304

1548308

1548377

1548502

1548619

1586834

1586823

1659406

1636692

1616076

1647730

1658103

1672639

1619939

1353663

Corrective Action

Documents

Resulting from

Inspection

1698257,

1698617,

1700017,

1700043,

1700055,

1700060,

1700061,

1700062,

1700063,

1700064,

1700235,

1700289,

1700303,

1703096,

1703331

Drawings

1, 2-37W206-8

Mechanical Pumping Station Piping & Equipment

Revision 4

1, 2-47W845-1

Mechanical Flow Diagram - Essential Raw Cooling Water

Revision 54

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

System

1, 2-47W845-2

Mechanical Flow Diagram - Essential Raw Cooling Water

System

Revision 116

1, 2-47W845-5

Mechanical Flow Diagram - Essential Raw Cooling Water

System

Revision 63

Engineering

Changes

DCN T12553-A

Authorize use of Rains Flo packing on the ERCW pumps and

CCS pumps

Revision A

Engineering

Evaluations

SQN-20-1852

Qualify 47A056-1006 Supports Installed in the EDGB

2/10/2020

Miscellaneous

Level 2 Evaluation Report - Operations Department

Performance Gap

Revision 0

SQN Plant Screening Committee Package

06/10/2021

SQN Management Review Committee Meeting Agenda

06/10/2021

Level 2 Evaluation Report - Elevated Condensate Pressure

resulted in #3 HDT Runback and Rx Trip

01/13/2020

Level 2 Evaluation for CR 1559894

Operations Department Performance Assessment

2/28/2021

Operations Department Performance Assessment

06/30/2020

Control Room Deficiencies

04/09/2021

DC-V-13.9.9

Design Criteria - Component Cooling Water System (70)

Revision 29

SQN-DC-V-11.8

Diesel Generator and Auxiliary System Design Criteria

Document

Revision 15

SQN-DC-V-12.1

Flood Protection Provisions

Revision 21

System #67 -

Essential Raw

Cooling Water

Health Report Summary - P1

FY20 (Oct -

Mar)

System #67 -

Essential Raw

Cooling Water

Health Report Summary - P2

FY19 (Apr -

Sep)

System #70 -

Component

Cooling System

Health Report Scorecards - P2

FY18 - FY20

Procedures

NEDP-22

Operability Determinations and Functional Evaluations

Revision 21

NEDP-27

Past Operability Evaluations

Revision 5

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

NPG-SPP-01.16

Condition Report Initiation

Revision 4

NPG-SPP-

09.0.1.1

System Monitoring and Trending

Revision 3

NPG-SPP-09.16

Plant Health Committee and Plant Health Sub-Committee

Revision 15

NPG-SPP-09.7

Corrosion Control Program

Revision 8

NPG-SPP-09.7.4

Boric Acid Corrosion Control Program

Revision 7

NPG-SPP-

2.000

Performance Improvement Program

Revision 10

NPG-SPP-

2.102

NPG Self-Assessment and Benchmarking Programs

Revision 10

NPG-SPP-

2.300

Corrective Action Program

Revision 21

NPG-SPP-

2.500

Operating Experience Program

Revision 14

NPG-SPP-

2.600

Issue Resolution

Revision 10

0-PI-CEM-015-

001.0

Steam Generator Hideout Return Sampling and Analysis

Revision 4

0-SI-OPS-067-

2.M

ERCW Flow Balance Valve Position Verification

Revision 35

0-SO-67-1

Essential Raw Cooling Water

Revision 114

0-SO-67-3

ERCW Strainers and Traveling Screens

Revision 33

0-TI-CEM-000-

001.1

Secondary Chemistry Specifications

Revision 63

0-TI-CEM-000-

001.3

Primary Chemistry Specifications

Revision 92

0-TI-CEM-000-

001.4

Auxiliary System and Common System Chemistry

Specifications

Revision 49

0-TI-DXX-000-

097.1

Boric Acid Control Program

Revision 15

0-TI-DXX-000-

915.0

Underground Piping and Tanks Integrity Program

Revision 7

0-TI-OPS-000-

2.64

Locked Valve List

Revision 33

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

NPG-SPP-01.7.1

Employee Concerns Program

Revision 5

NPG-SPP-03.4

Maintenance Rule Performance Indicator Monitoring,

Trending and Reporting - 10CFR50.65

2/05/2014

NPG-SPP-

09.0.1.1

System Walkdown Checklist

Revision 7

NPG-SPP-09.15

Underground Piping and Tanks Integrity Program

Revision 9

NPG-SPP-

09.18.13

Equipment Failure Trending

Revision 2

TI-4

Maintenance Rule Performance Indicator Monitoring,

Trending, and Reporting - 10CFR50.65

Revision 35

Self-Assessments

Biennial Self-Assessment - Nuclear Safety Culture

11/15/2019 -

2/15/2019

SSA1907

Audit Report, Radiation Protection and Radwaste Sequoyah

Nuclear Plant (SQN)

07/15/2019 -

07/26/2019

CR 1553713

Shift Manager Effectiveness in Driving Crew Performance

Improvements

10/09/2019

CR 1582138

Bi-Monthly CAP Assessment

01/29/2020

CR 1598305

Pre-NIEP Self Assessment

05/15/2020

CR 1629512

Bi-Monthly CAP Assessment

08/13/2020

CR 1642281

NRC Graded Exercise/Baseline Inspection - Improvement

Opportunities

Revision 0

CR 1642686

Bi-Monthly CAP Assessment

10/15/2020

CR 1653113

Assess Operations implementation of the Clearance process

Revision 0

CR 1653137

Evaluate current status of operations department leadership

and team effectiveness and identify improvement

opportunities

Revision 0

CR 1659297

Bi-Monthly CAP Assessment

2/16/2020

CR 1659297

Bi-Monthly CAP Assessment

2/16/2020

CR 1673828

Bi-Monthly CAP Assessment

2/23/2021

CR 1675152

21 SQN Pre-Problem Identification and Resolution (PI&R)

Self-Assessment

03/01/2021 -

03/18/2021

CRP-QA-SA-20-

001 (CR

QA Assessment Program

11/06/2019

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

1553757)

CRP-QA-SA-20-

2 (CR

1555201)

QA Post DNP Assessment Program

2/20/2019

QA-SQ-19-011

Sequoyah Nuclear Plant - Quality Assurance June Site

Report

07/09/2019

QA-SQ-19-018,

Revision 1

Sequoyah Nuclear Plant - Quality Assurance September Site

Report

10/17/2019

QA-SQ-20-001

Sequoyah Nuclear Plant - Quality Assurance December Site

Report

01/08/2020

QA-SQ-20-008

Sequoyah Nuclear Plant - Quality Assurance March Site

Report

04/08/2020

QA-SQ-20-015

Sequoyah Nuclear Plant - Quality Assurance June Site

Report

07/09/2020

QA-SQ-20-022

Sequoyah Nuclear Plant - Quality Assurance September Site

Report

10/08/2020

QA-SQ-21-001

Sequoyah Nuclear Plant - Quality Assurance December Site

Report

01/12/2021

SQN-CEM-SA-

19-004

Secondary Chemistry Control

2/07/2019

SQN-CEM-SA-

19-006

Chemical Traffic Control Self-Assessment

01/07/2019

SQN-CEM-SA-

20-001

Chemistry QA/QC Self-Assessment

09/08/2020

SSA1906

Audit Report, Chemistry, Effluent, and Environmental

Monitoring Sequoyah (SQN)

06/03/2019 -

06/14/2019

SSA2002

Audit Report, Security and Safeguards Information (SGI),

Sequoyah Nuclear Plant

01/06/2020 -

01/16/2020

SSA2004

Audit Report, Maintenance, Sequoyah Nuclear Plant

03/16/2020 -

03/30/2020

SSA2107

Audit Report, Corrective Action Program

01/19/2021 -

01/28/2021

Work Orders

119534627

119593079

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

20011394

20323404

20405727

20556874

20561705

20609457

20609581

20715080

20799515

20845914

20915544

21128321

21274740

21276488

21283139

21352981

21353681

21367674

21583869

21702254

21722819

21749911

21923081

2090528