IR 05000327/2013008
| ML13218B085 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/06/2013 |
| From: | Manuel Crespo Reactor Projects Branch 7 |
| To: | James Shea Tennessee Valley Authority |
| References | |
| IR-13-008 | |
| Download: ML13218B085 (16) | |
Text
August 6, 2013
SUBJECT:
SEQUOYAH NUCLEAR PLANT - NRC PROBLEM IDENTIFICATION AND
RESOLUTION INSPECTION REPORT 05000327/2013008, 05000328/2013008
Dear Mr. Shea:
On June 27, 2013, the U. S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Sequoyah Nuclear Power Plant, Units 1 and 2.
The enclosed inspection report documents the inspection results, which were discussed on June 27, 2013, with Mr. J.T. Carlin and other members of your staff.
The inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.
Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Sequoyah Nuclear Power Plant Units 1 and 2 was adequate. Licensee identified problems were entered into the corrective action program at a low threshold.
Problems were generally prioritized and evaluated commensurate with the safety significance of the problems. Corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of problems.
Lessons learned from the industry operating experience were generally reviewed and applied when appropriate. Audits and self-assessments were effectively used to identify problems and appropriate actions.
No findings were identified during this inspection. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Manuel Crespo, Acting Chief Reactor Projects Branch 7 Division of Reactor Projects
Docket Nos.
50-327, 50-328 License Nos. DPR-77, DPR-79
Enclosure:
Inspection Report 05000327/2013008, 05000328/2013008
w/Attachment: Supplemental Information
REGION II==
Docket Nos.:
50-327, 50-328
License Nos.:
Report Nos.:
05000327/2013008, 05000328/2013008
Licensee:
Tennessee Valley Authority (TVA)
Facility:
Sequoyah Nuclear Plant, Units 1 and 2
Location:
Sequoyah Access Road
Soddy-Daisy, TN 37379
Dates:
June 10 - 14, 2013 June 24 - 27, 2013
Inspectors:
N. Staples, Senior Project Inspector, Team Leader R. Taylor, Senior Project Inspector M. Coursey, Reactor Inspector J. Dymek, Reactor Inspector
Approved by:
M. Crespo, Acting Chief Reactor Projects Branch 7 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000327/2013008, 05000328/2013008; 06/10/2013 - 06/27/2013; Sequoyah Nuclear Plant,
Units 1 and 2; biennial inspection of the identification and resolution of problems.
The inspection was conducted by two senior project inspectors and two reactor inspectors. No findings were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Rev. 4.
Identification and Resolution of Problems
The inspectors concluded that, in general, problems were properly identified, evaluated, prioritized, and corrected. The licensee was effective at identifying problems and entering them into the corrective action program (CAP) for resolution, as evidenced by the relatively few number of deficiencies identified by external organizations (including the NRC) that had not been previously identified by the licensee, during the review period. Generally, prioritization and evaluation of issues were adequate, formal root cause evaluations for significant problems were adequate, and corrective actions specified for problems were acceptable. Overall, corrective actions developed and implemented for issues were generally effective and implemented in a timely manner.
The inspectors determined that overall, audits and self-assessments were adequate in identifying deficiencies and areas for improvement in the CAP, and appropriate corrective actions were developed to address the issues identified. Operating experience usage was found to be generally acceptable and integrated into the licensees processes for performing and managing work, and plant operations.
Based on discussions and interviews conducted with plant employees from various departments, the inspectors determined that personnel at the site felt free to raise safety concerns to management and use the CAP to resolve those concerns.
REPORT DETAILS
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a.
Assessment of the Corrective Action Program
- (1) Inspection Scope
The inspectors reviewed the licensees corrective action program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of problem evaluation reports (PERs). To verify that problems were properly identified, appropriately characterized and entered into the CAP, the inspectors reviewed PERs that were issued between August 2011 and May 2013, including a detailed review of selected PERs associated with the following risk-significant systems:
Reactor Coolant, Auxiliary Feedwater and Component Cooling. Where possible, the inspectors independently verified that the corrective actions were implemented. The inspectors also reviewed selected common causes and generic concerns associated with root cause evaluations to determine if they had been appropriately addressed. To help ensure that samples were reviewed across all cornerstones of safety identified in the NRCs Reactor Oversight Process, the inspectors selected a representative number of PERs that were identified and assigned to the major plant departments, including operations, maintenance, engineering, health physics, chemistry, and security. The inspectors reviewed selected PERs, verified corrective actions were implemented, and attended meetings where PERs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
The inspectors conducted plant walkdowns of equipment to assess the material condition and to identify any deficiencies that had not been previously entered into the CAP. The inspectors reviewed PERs, maintenance history, completed work orders for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.
Control room reviews were also performed to assess the Main Control Room deficiency list and to ascertain if deficiencies were entered into the CAP. The inspectors reviewed Operator Workarounds and Operator Burden screenings and verified compensatory measures were implemented for deficient equipment.
The inspectors conducted a detailed review of selected PERs to assess the adequacy of the root-cause and apparent-cause evaluations of the problems identified. The inspectors reviewed these evaluations against the descriptions of the problem described in the PERs and the guidance in licensee procedures NPG-SPP-03.1, Corrective Action Program, NPG-SPP-03.1.5, Apparent Cause Evaluations, and NPG-SPP-03.1.6, Root Cause
Analysis.
The inspectors assessed if the licensee had adequately determined the causes of identified problems, and had adequately addressed operability, reportability, common cause, generic concerns, extent-of-condition, and extent-of-cause. The review also assessed if the licensee had appropriately identified and prioritized corrective actions to prevent recurrence for significant conditions adverse to quality.
The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included PER screening meetings and Corrective Action Review Board.
Documents reviewed are listed in the Attachment.
- (2) Assessment
Identification of Issues
The inspectors determined that the licensee was generally effective in identifying problems and entering them into the CAP and there was a low threshold for entering issues into the CAP. Site management was actively involved in the CAP and focused appropriate attention on significant plant issues.
In the area of trending, the inspection team made several observations. The inspection team noted that fleet procedure NPG-SPP-02.7, PER Trending, did not give specific thresholds for the identification of negative trends. In addition, CAP trend codes were not applied and utilized at the equipment level. The team also noted that out of approximately 500+ trending codes, only a small fraction of codes were utilized, with codes being utilized differently amongst departments. The licensee issued PER 747130 to address these observations.
Prioritization and Evaluation of Issues
Based on the review of PERs sampled by the inspection team during the onsite period, the inspectors concluded that problems were generally prioritized and evaluated in accordance with the licensees CAP procedures. Each PER was assigned a significance level by certified members during the PER Screening Committee meeting.
The inspectors determined that station personnel had conducted root cause and apparent cause analyses in compliance with the licensees CAP procedures. The assigned cause determinations were appropriate and considered the significance of the issues being evaluated. A variety of formal causal-analysis techniques were used depending on the type and complexity of the issue consistent with NPG-SPP-03.1, Corrective Action Program.
Effectiveness of Corrective Actions
The inspectors determined that, overall, corrective actions were timely, commensurate with the safety significance of the issues, and effective in that conditions adverse to quality were corrected and non-recurring. For significant conditions adverse to quality, the corrective actions directly addressed the cause and effectively prevented recurrence.
Effectiveness reviews for corrective actions to prevent recurrence were sufficient to ensure corrective actions were properly implemented and were effective.
- (3) Findings
No findings were identified.
b.
Assessment of the Use of Operating Experience (OE)
- (1) Inspection Scope
The inspectors examined licensee program for reviewing industry OE, reviewed licensee procedure NPG-SPP-02.3, Operating Experience Program, and reviewed the licensees OE database to assess the effectiveness of how external and internal OE data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal OE items, etc.) issued since August 2011, to verify if the licensee had appropriately evaluated each notification for applicability and if issues identified through these reviews were entered into the CAP.
Documents reviewed are listed in the Attachment.
- (2) Assessment
The inspectors determined that the licensee was generally effective in screening operating experience for applicability to the plant. Industry OE was evaluated by plant OE Coordinators and relevant information was then forwarded to the applicable department for further action or informational purposes. OE issues requiring action were entered into the CAP for tracking and closure. In addition, OE was included in all root cause evaluations in accordance with licensee procedures.
- (3) Findings
No findings were identified.
c.
Assessment of Self-Assessments and Audits
- (1) Inspection Scope
The inspectors reviewed audit reports and self-assessment reports, including those which focused on problem identification and resolution, to assess the thoroughness and self-criticism of the licensee's audits and self assessments, and to verify that problems identified through those activities were appropriately prioritized and entered into the CAP for resolution in accordance with licensee procedure NPG-SPP-02.1, NPG Self-Assessment and Benchmarking Program.
- (2) Assessment
The inspectors determined that the scopes of assessments and audits were adequate.
Self-assessments were generally detailed and critical. The inspectors verified that PERs were created to document all areas for improvement and findings resulting from the self-assessments, and verified that actions had been completed consistent with those recommendations. Generally, the licensee performed evaluations that were technically accurate.
- (3) Findings
No findings were identified.
c.
Assessment of Safety-Conscious Work Environment
- (1) Inspection Scope
The inspectors randomly interviewed several on-site workers regarding their knowledge of the CAP and their willingness to write PERs or raise safety concerns. During technical discussions with members of the plant staff, the inspectors also conducted interviews to develop a general perspective of the safety-conscious work environment.
The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees Employee Concerns Program (ECP) and interviewed the ECP manager.
Additionally, the inspectors reviewed a sample of ECP issues to verify that concerns were properly reviewed and identified deficiencies were resolved and entered into the CAP when appropriate.
- (2) Assessment
The inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees. The inspectors determined that employees felt free to raise issues, and that management encouraged employees to place issues into the CAP for resolution.
The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.
- (3) Findings
No findings were identified.
4OA6 Meetings, Including Exit
On June 27, 2013, the inspectors presented the inspection results to Mr. Carlin and other members of the site staff. The inspectors confirmed that all proprietary information examined during the inspection had been returned to the licensee.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- G. Franceschi, Performance Improvement Manager
- J. McCamy, Quality Assurance Manager
- J. Cross, Chemistry Manager
- G. Yelliot, Employee Concerns Manager
- M. Baker-Lindsay, QA Sr. Program Manager
- S. Tuthill, QA Program Manager
- M. McBrearty, Licensing Manager
- M. Tipton, Performance Improvement
- M. Woods, Performance Improvement
NRC personnel
- S. Shaeffer Chief, Branch 6, Division of Reactor Projects
LIST OF ITEMS
OPEN, CLOSED AND DISCUSSED
Open
None
Closed
None
Discussed
None